1. ISTOG MOV TESTING TRANSITION Prepared by: E. Cavey DTE-Fermi 2 Page 1 The GOAL of this effort was to develop implementation guidance for ASME Code Case OMN-1 / ASME 2006/2007 mandatory Appendix III. The PROCESS was to: Thoroughly review Appendix III guidance against the industry-wide standards for MOV Programs Identify any areas of change impact for plants transitioning from GL 96-05 compliance to ASME App. III compliance Clarify language and intent for any significant change impact issues Provide effective guidance for individual plants to utilize in adopting App. III STATUS: Guidance document prepared, being reviewed by ISTOG Steering Committee

2. ISTOG MOV TESTING TRANSITION Prepared by: E. Cavey DTE-Fermi 2 Page 2 Generic Letter 89-10 identified significant weaknesses in MOV design basis capability. Commonly used factors in required torque/thrust calculations were found to be non- conservative Plants had insufficient knowledge of the configurations of installed MOVs MOV settings were inadequately controlled and general conditions were poor due to weak maintenance regimes. Plants had to invest significant effort and expense to accurately quantify design basis requirements, to refurbish and upgrade their MOVs and to validate, through a major testing effort, each MOVs design basis capability. Generic Letter 96-05 later replaced GL 89-10 as a means to ensure appropriate periodic testing to maintain MOV design basis capability throughout plant life.

3. ISTOG MOV TESTING TRANSITION Prepared by: E. Cavey DTE-Fermi 2 Page 3 As stated before, at the time of GL 89-10, many critical MOVs were found to be inadequately sized, setup and maintained such that they may not have functioned as needed in certain accident scenarios. The significance of this common-mode issue is that it crossed all system and divisional boundaries, effectively diminishing confidence in accident mitigation readiness and redundancy. It was distressing that all of the problems identified through GL 89-10 occurred even though nearly all of the affected MOVs were being routinely tested per Technical Specifications and ASME Code requirements. This testing had not identified these problems. In app. 1993 ASME and the NRC acknowledged the inadequacy of standard Code testing of MOVs but also recognized the value of routine diagnostic testing as was being performed in support of GL 89-10. The concept of Code Case OMN-1 was created.

4. ISTOG MOV TESTING TRANSITION Prepared by: E. Cavey DTE-Fermi 2 Page 4 While OMN-1 was slowly being transformed from concept to written form, concerns about the ineffectiveness of the present Code and TS testing were allayed by the fact that plants were continuing to perform diagnostic testing per GL 89-10. Also, the test methods, equipment and analysis were being constantly enhanced through industry and vendor efforts. The JOG Program was one such effort. The JOG Program was created to accomplish two major goals: Provide for a standardized programmatic process to comply with the intent of GL 96-05. The most significant aspect of this was the methodology for determining the required frequency of periodic verification testing, i.e., the JOG Matrix. Identify whether a key design assumption, valve factor, remains constant over time. This was accomplished through a structured process to compile and analyze a large amount of dynamic test data over several years. The JOG Program should be looked back upon as a success and as an example of what the nuclear industry can accomplish when it is dedicated to working closely together on an issue, with strong contributions from nearly every plant. The NRC issued it’s SE on the finalized JOG Program on 9/25/2006.

5. ISTOG MOV TESTING TRANSITION Prepared by: E. Cavey DTE-Fermi 2 Page 5 Today, MOV design basis capability is better assured than nearly any other component type in our industry. MOV failures rates are lower and most failures are less consequential. MOV Periodic Verification (PV) testing is an embedded aspect of plant operations and maintenance. Post maintenance testing requirements consider PV testing with the same importance as LLRT. The JOG Program has wrapped up and plants have assimilated the results into their PV testing regime. Regulatory effort to eliminate ineffective standard Code testing and to establish Code controls of PV testing is the right thing to do. This will provide for continuity and quality of PV testing and will ensure MOV capability is maintained. The desire is to accomplish this transition without significant bureaucratic burden and while maintaining the proven integrity of MOV PV testing programs at every plant. The Motor Operated Valve ASME Code Case OMN-1 / 2007 OM Appendix III Adoption Guideline is intended to aid in this transition effort.

6. ISTOG MOV TESTING TRANSITION Prepared by: E. Cavey DTE-Fermi 2 Page 6 Motor Operated Valve ASME Code Case OMN-1 / 2007 OM Appendix III Adoption Guideline Revision 0 Table of ContentsPage Foreword2 Introduction3 Background3 OMN-1 Overview6 Risk-Informed Guidance7 Implementation8 Potential Savings11 Potential Costs11 Appendix III12 - 23

7. ISTOG MOV TESTING TRANSITION Prepared by: E. Cavey DTE-Fermi 2 Page 7 Motor Operated Valve ASME Code Case OMN-1 / 2007 OM Appendix III Adoption Guideline Revision 0 Foreword This document has been prepared for The Inservice Testing Owners’ Group (ISTOG). The purpose of this document is to provide a guideline that describes an acceptable means to implement the requirements of ASME OM Mandatory Appendix III. This document represents technical positions regarding implementation of this ASME Code as prepared and agreed upon by both ISTOG and the MOV Users Group (MUG). This document was created with contributions from Shawn Comstock, Kurt Helmers, Tom Ickes, Ron Lippy, and John Perkins. The principle author of this document is Ed Cavey. Suggestions for improvement and additional examples of implementation are invited. See the forum at www.istog.net for additional information on this topic, including procedures, evaluations, best practices and lessons learned from member experiences in implementing this ASME OM Code.www.istog.net

8. ISTOG MOV TESTING TRANSITION Prepared by: E. Cavey DTE-Fermi 2 Page 8 MANDATORY APPENDIX III Preservice and Inservice Testing of Active Electric Motor Operated Valve Assemblies in Light-Water Reactor Power Plants ( This Appendix is mandatory and contains requirements to augment the rules of Subsection ISTC, Inservice Testing of Valves in Light-Water Reactor Nuclear Power Plants. ) III-1000 INTRODUCTION III-1100 APPLICABILITY This Appendix establishes the requirements for preservice and inservice testing to assess the operational readiness of active motor- operated valves (MOVs) in light water reactor (LWR) power plants

9. ISTOG MOV TESTING TRANSITION Prepared by: E. Cavey DTE-Fermi 2 Page 9 QUESTIONS ???