APPLYING THE OM CODE

Steve Hutton (An Applier and Sometimes Implementor of the Code)

Users of Code and Standards

We are all users of Code and Standards. You could qualify as an applier, interpreter, enforcer, or implementor.
Applier is an all-inclusive term meaning anyone who picks up the Code book and uses it. Interpreter is specific to ASME Committee members. Enforcer is specific to the Regulatory or Enforcement Agencies. Implementor is an individual who must comply with the Code and Standard or face enforcement powers.

10CFR50.55a Codes and Standard - Mandatory Codes

The two Code groups are ASME B&PV Code and ASME OM Code
The ASME B&PV Code [10CFR50.55a(g)], Inservice Inspection Requirements The ASME OM Code [10CFR50.55a(f)], Inservice Testing Requirements

Groups Have Their Own Unique Talents

O&M group is the Operations and Maintenance organization, with expertise in plant operations and the maintenance of components. B&PV group is the Boiler and Pressure Vessel organization, with expertise in the inspection and testing of components.

Transfer of Power
The B&PV group transferred the testing of pumps, valves, and snubbers over to O&M group in the 1990s. The transfer is well documented in the individual Codes. The testing of pumps and valves went from ASME B&PV Code, Section XI, to the ASME OM Code, Section IST.

The ASME B&PV Code Section XI Inservice Inspection Requirements

Section XI currently describes how the inspection of ASME components (vessels, pumps, valves, piping systems, and their supports) must be implemented. The inspections are examinations performed using one of three methods: visual, surface, or volumetric.

Inspection Method Techniques

Visual Methods include VT-1, VT-2, and VT-3. Surface Methods include Liquid Penetration and Magnetic Particle. Volumetric Methods include radiography and ultrasonic plus eddy current.

VT-2 Examination Technique

The VT-2 examination is performed during a pressure test of the component.

ASME OM Code Section IST, Inservice Testing Requirements

Inservice Testing Requirements
Pump Testing Valve Testing Snubber Testing

Testing is the exercising of the component while monitoring pertinent parameters.

Development of a Code
The OM Code has been newly developed (late 1990s). The unique thing about a Code vs. a Standard is that the requirements of a Code can be enforced. To allow for proper implementation of a Code, structure and guidance must be provided.

Organization of a Code
The source of the OM Code was the B&PV Code. The B&PV Code has an organization as front matter along with the policy, preface, etc. The organization provides the Code structure (Sections, subsections, articles, subarticles, sub-subarticles, paragraphs, subparagraphs, etc.)

B&PV Code Organization

The organization also provides references used within a Section. References fall into one of six categories:
References to other portions of the same Section References to different Sections References to Specifications and Standards other than those published in Code Sections References to Government Regulations References to Appendices References to Technical Reports

References to Other Portions of the Same Section

When a reference is made to another Article, Subarticle, or paragraph number in the same Section, all numbers subsidiary to that reference shall be included. Therefore, each article, subarticle, paragraph, and subparagraph stands as an item independent of others of the same level.

Example of Separation
Article ISTB-5000, Specific Testing Requirements, consists of three subarticles:
ISTB-5100 Centrifugal Pumps (Except Vertical Line Shaft Centrifugal Pumps) ISTB-5200 Vertical Line Shaft Centrifugal Pumps ISTB-5300 Positive Displacement Pumps

None of these subarticles refers to the others, but only to a common table; this way of handling internal reference is called separation.

Example of Non-Separation
ISTC-3522 Category C, Check Valves, subparagraph (a), refers to subparagraph ISTC-5221. Because ISTC-5221 is referred to in the minor subparagraph ISTC-3522(a) (and only there), all the requirements of ISTC-5221 apply to ISTC-3522(a) (but not to any other portion of ISTC-3522); this way of handling internal reference is called non-separation.

References to Appendices
Appendices are identified as Mandatory or Nonmandatory Mandatory Appendices
Contain requirements that must be followed Designated by a Roman numeral followed by Arabic numerals

Nonmandatory Appendices
Contain information or guidance Designated by a capital letter followed by Arabic numerals

Preparation of Technical Inquiries

The OM Code front matter provides:
Introduction Inquiry format Code Revisions and Additions Code Cases Code Interpretations Submittals

Inquiry Purposes
Submittals to the Committee shall include: (a) Purpose, (b) Background, and (c) Presentations. Purpose
revision to current Code requirement(s) new or additional Code requirement(s) Code Case Code interpretation

Code Revisions and Additions

For revisions, identify the requirements of the Code that require revision and submit a copy of the existing Code requirements marked up with the needed revisions. For additions, provide the recommended wording along with references to the existing Code requirements. Addenda include additions and revisions to individual Sections of the Code.

Code Cases
Requests for Code Cases shall include a Statement of Need and Background Information. The Code Committee meets regularly to formulate Cases in order to clarify the intent of existing requirements or to provide, when the need is urgent, rules for materials or constructions not covered by existing Code rules.

Code Interpretations
For inquiries requesting an interpretation of technical aspects of the Code: Provide a condensed and precise question, omitting superfluous background information, composed in such a way that a yes or a no reply, possibly with brief provisos, is acceptable. ASME issues written replies to such inquiries. These interpretations are not part of the Code or the Addenda.

Code Interpretations
If an interpretation provides more information than a yes or no response, it should not be found to be new or altering. This is because, as stated before, Code interpretations are not part of the Code. As a user, when you pick up the Book and use it, interpretations are not normally supplied and should not be needed.

Policy on Interpretation
The NRC incorporates the ASME Code by reference into 10CFR50.55a. Upon adoption, the Code provisions become a part of NRC regulations as modified by other provisions in the regulations. The NRC recognizes that the ASME is the official interpreter of the Code. However, only the NRC can determine whether the ASME Interpretation is acceptable such that it constitutes compliance with NRC's regulations and does not adversely affect safety.

Policy on Interpretation (cont.)

The NRC cannot a priori approve Code Interpretations. While it is true that the ASME is the official interpreter of the Code, if the ASME interprets the Code in a manner which the NRC finds unacceptable (e.g., results in non-compliance with NRC regulatory requirements, a license condition, or technical specifications), the NRC can take exception to the Interpretation and is not bound by the ASME Interpretation. To put it another way, only the ASME can provide an Interpretation of the Code, but the NRC may make the determination whether that Interpretation constitutes compliance with NRC regulations.

Interpretation No.: 04-08

Subject: Appendix I, I-1350(a) (ASME OM Code-2001 through OMb-2003 Addenda) Question: In accordance with the OM Code 2001 edition with 2003 Addenda, is it a requirement of Appendix I, I1350(a), that the maximum test interval for a class 2 or 3 valve group that contains only one valve be 10 years? Reply: No, in accordance with Appendix I, I-1350(a), a minimum of 20% of the valves from a group shall be tested within any 48-month interval. In the case of a valve group of one, this one shall be tested within any 48-month interval. Presenters Response: Stating that a valve group can consist of a single valve is counterintuitive.

Interpretation No.: 01-18

Subject: ASME OM Code-1995 with ASME OMa Code1996 Addenda, Appendix I Question (1): Are replacement valves for an operating nuclear power plant, required by para. I6 to be tested in accordance with para. I7.2, required to be tested 6 months prior to fuel cycle initial criticality? Reply: No. Paragraph I7.2 does not apply after initial electric power generation. However, the valve must have been tested within 5 years or 10 years as required by I1.3. Presenters Response: As worded, the proviso is misleading (see Question 2) and does not follow Code etiquette.

Interpretation No.: 01-18

Subject: ASME OM Code-1995 with ASME OMa Code1996 Addenda, Appendix I. Question (2): In ASME OM Code-1995 with ASME OMa Code-1996 Addenda, para. I 1.3.3(a), the statement is made that the test interval for any individual valve shall not exceed 5 years. Is this Code referring to installed life rather than test interval? Reply (2): No. Presenters Response: This shows that the proviso in Question (1) misleads the user about replacement-valve testing having to follow I 1.3.3(a); I 1.3.3(a) requires maintenance testing at intervals, but Question (1) is about testing related to a valves installed life.

Interpretation No.: 01-18

Subject: ASME OM Code-1995 with ASME OMa Code-1996 Addenda, Appendix I. Question (2): When ending the first 10-year OM-1 test interval and starting the new 10-year OM-1 test interval, does the 48-month requirement of ANSI/ASME OM-1 1981, Part 1, para. 1.3.4.1.2; ASME/ANSI OM-1987 (Part 1), para. 1.3.4.1(b); ASME OM Code-1990, Appendix I, para. I1.3.5(b); ASME OMc Code-1994, Appendix I, para. I1.3.5(a); and ASME OM Code-1995, para. I1.3.5(a) start over at the beginning of the new test interval for Class 2 and 3 relief valves, excluding PWR Main Steam Safety Valves? Reply (2): No, the test interval applies to any 48-month period. Presenters Response: Stating that the 48-month requirement applies to subsequent 5-year or 10-year test intervals is not merely issuing an interpretation; it is adding to the Code.

Conclusions
A organization section would be appropriate for the OM Code, Section IST. Users apply the Code hierarchically. A Code interpretation cannot be used as an revision or addition to the Code. Sites (implementors) should develop individual programs defining terms and detailing processes involving Code compliance.

Conclusion
Site-approved programs could include:
Inservice Pump and Valve Testing Program Safety and Relief Testing Program Snubber Inspection and Testing Program Check Valve Condition Monitoring Program Motor Operated Valve Testing Program Inservice Inspection Program Inservice Pressure Testing Program Etc.

Questions
The floor is open for discussion.