1. Current Air-Operated Valve Regulatory Activities Steven Unikewicz US Nuclear Regulatory Commission Office of Nuclear Reactor Regulation January 2006

2. 2 Topics Current Regulations / Guidance NRC Reg Guide 1.192 Risk Informed IST 10 CFR 50.69 Recent Events/Current Topics Other AOV related Regulatory Activities

3. 3 Current Regulations / Guidance ASME OM Code of record: 10 CFR 50.55a(b)(2) –2001 Edition through the 2003 Addenda –2004 Edition endorsement expected Jan/Feb 2006 –Scope defined in ISTA 1100 Use of ASME Code defined in 10 CFR 50.55a(f) –ASME Code Class components or equivalent NUREG 1482 Guidelines for Inservice Testing –Revision 1 incorporates guidance to date and ASME 2000A Edition –Revision 0 still valid for 1995 and earlier Editions

4. 4 NRC Reg Guide 1.192 ASME OM Code Case Acceptability issued March 2003 Conditions placed on certain Code Cases Licensees may use approved OM Code Cases provided all conditions listed in Code Case and Reg Guide are met Risk Informed IST Code Cases - Code Case OMN-3 - Code Case OMN-12

5. 5 OMN 3 Requirements for Safety Significance Categorization of Components using Risk Insights for Inservice Testing RI component Code Cases use OMN 3 to catagorize HSS and LSS components Four (4) conditions proposed on use of OMN 3 –Condition 1: Program must include non-ASME components categorized as HSSC that may not be in current IST program –Condition 2: Decision Criteria must be consistent with Reg Guide 1.174

6. 6 OMN 3 - Condition 3: Defense in Depth and Safety Margin evaluations must be consistent with Reg Guide 1.175 - Condition 4: Implementation of Inservice Testing Program and Performance Monitoring must be consistent with Reg Guide 1.175 and OMNs 1, 4, 7 and 12

7. 7 OMN 12 Alternative Requirements for IST using Risk Insights for Pneumatically and Hydraulically Operated Valves New AOV/HOV test strategy coupled with risk-informed categorization Used in conjunction with Code Case OMN-3 NRC conditions ensure technical philosophy consistent with Code Case OMN-1 (MOV Code Case)

8. 8 OMN 12 Alternative Requirements for IST using Risk Insights for Pneumatically and Hydraulically Operated Valves Eight (8) NRC Conditions on use of OMN-12 –(1) Include a mix of static and dynamic testing which may be altered when justified by evaluation of test data –(2) Evaluate adequacy of diagnostic test interval which shall not exceed 5 years or 3 RO –(3) Evaluate potential increase in CDF and risk of interval extension to ensure small and consistent with NRC Regulatory Guide 1.174 and 1.175 criteria –(4) Degradation rate and capability margin evaluated to ensure AOV/HOV capable of performing design basis functions until next test

9. 9 OMN 12 Alternative Requirements for IST using Risk Insights for Pneumatically and Hydraulically Operated Valves - (5) Capable of performing design basis function until next test - (6) Setpoints based on direct dynamic test information, test based methodology, or grouping with dynamically tested valves - (7) Initial and periodic diagnostic testing to verify setpoints - (8) Evaluate operability of AOV/HOV if valve does not satisfy acceptance criteria

10. 10 Reg Guide 1.175 Risk Informed IST Same as current IST Program Scope except: Must include Non- ASME Code AOVs / HOVs categorized as high safety significant (HSS ) AOVs / HOVs that are not within the scope of the Code but AOV / HOV program identified - Non ASME Code low safety significant (LSS) AOVs / HOVs - Non-ASME Code LSS Dampers Consider comprehensive activities for related Non-ASME Code HSS Components (eg. Dampers) - March 27, 2000 SONGS SE (Adams ML003695622)

11. 11 10 CFR 50.69 NRC prepared 10 CFR 50.69 to risk-inform regulations for treatment of structures, systems, and components (SSCs), including MOVs. 10 CFR 50.69 categorizes SSCs based on safety significance, and specifies treatment that is intended to provide appropriate confidence in design capability. To provide reasonable confidence that low-risk safety ‑ related SSCs can perform their design ‑ basis functions, proposed 10 CFR 50.69 replaces special treatment requirements with high-level requirements for (1)design control; (2)procurement; (3)maintenance, inspection, testing, and surveillance; and (4)corrective action.

12. 12 Recent Events/Current Topics It is expected that Sites have fully implemented their AOV JOG Programs - RIS 2000-003 Performance of Safety-Related POV’s Under Design Basis Conditions Recent Inspections have identified lack of Design Basis information at various sites - Air Accumulator Sizing - Underestimation of Thrust

13. 13 Recent Events/Current Topics Failures of valve plugs and loosening of valve parts due to vibration Extended Power Uprates –Replacement of manual valves with AOVs –Follow JOG or QME or prototype testing –Stating manufacture’s experience is not enough Testing – mix of Static / Dynamic techniques

14. 14 Other AOV related Regulatory Activities Continued participation with ASME OM 19, Sub-group on Air Operated Valves – next meeting July 19, 2006 after the ASME/NRC Pump and Valve Symposium Continued participation with ASME OM Code, Sub- section ISTE, Risk Informed Inservice Testing Ninth ASME/NRC Pump and Valve Symposium, July 17 thru 19, 2006, at L’Enfant Plaza Hotel in Washington, DC see www.asmeconferences.org/nrcasme9 for more detailswww.asmeconferences.org/nrcasme9