ML12272A055

Inservice Testing Program, Third Ten-Year Interval, Third Interval Start - February 17, 2010

ML12272A055
Person / Time
Site:	Fermi
Issue date:	05/18/2012
From:	DTE Energy
To:	Office of Nuclear Reactor Regulation
Billerbeck J
References
Download: ML12272A055 (474)

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I, DIE Energy -Fermi 2 Inservice Testing Program Third Ten-Year Interval Fermi 2 Nuclear Operations Center 6400 N. Dixie Highway Newport, Michigan 48166 Date of Commercial Operation 23-1988 Third Interval Start - February 17, 2010 APPROVALS:

Prepared By: Date: /0/1 0 ?AI IST Pr i-am ager Reviewed By: c.-A ______Date: 32.2 ISI be od Engineer0 Reviewed By: OLDate: I? / C)/(

Supervisor Performance Engi ing Approved By: ______________Date: ~ /

M agerPerformance Engineering Concurrence By: L-'- i----- Date: /)2/2Q-ANII - HSB Global Standards INFORMATION AND PROCEDURES DSN: IST PmZcran7 Description Rev: 0 Date: I ' )..

DTC: TM PLAN File: 1715.04 Reci ient:_____

Date Approved: ~J1 5D~,-Release authorized by: - z IST PROGRAM PLAN PART I Page 1 C

IST Program Plan Description IST PROGRAM PLAN MASTER INDEX Part I 1ST Program Description (DSN: IST Program Description)

Part 2 IST Pump Testing Program (DSN: IST Pump Testing Program)

Part 3 IST Pump Scope Table (DSN: IST Pump Scope Table)

Part 4 IST Valve Testing Program (DSN: IST Valve Testing Program)

Part 5 IST Valve Scope Table (DSN: IST Valve Scope Table)

Part 6 IST Check Valve Condition Monitoring Plans (DSN: IST CVCM Plans)

Part 7 IST Program Relief Requests (DSN: IST Program Relief Requests)

Part 8 IST Program Cold Shutdown Justifications (DSN: IST Program CSJ)

Part 9 IST Program Refueling Outage Justifications (DSN: IST Program ROJ)

Part 10 IST Program Technical Positions (DSN: IST Program Tech Positions)

PROGRAM PLAN TABLE OF CONTENTS PART 1 IST Program Description 1.1 Purpose 1.2 Scope 1.3 Requirements 1.4 Plant Systems PART 2 IST Pump Testing Program 2.1 Pump Inservice Testing Plan Description 2.2 Pump Plan Table Description 2.3 Measurement of Test Quantities 2.4 Allowable Ranges of Test Quantities 2.5 Instrument Accuracy 2.6 Reference Value Accuracy PART 3 IST Pump Scope Table PART 4 IST Valve Testing Program 4.1 Valve Inservice Testing Plan Description 4.2 Valve Plan Table Description 4.3 Measurement of Test Quantities 4.4 Allowable Ranges of Test QuantitiesR 4.5 Instrument Accuracy 4.6 Reference Value Accuracy PART 5. Valve Scope Table PART 6 IST Check Valve Condition Monitoring Plans CMP No. Description CMP-0 RHR Service Water, Return Checks CMP-02 Standby Liquid Control CIV Checks CMP-03 RHR M Flow Checks CMP04 Core Spray Pump Discharge Checks CMP-05 Core Spray Pump Mi Flow Checks 1ST PROGRAM PLAN PART 1 Page 2

IST Program Plan Description CMP-06 HPCI Booster Pump Suction Checks CMP-07 EECW Return Checks CMP-08 EECW Pump Discharge Checks CMP-09 HPCI Turbine Check Valves CMP-10 HPCI Turbine Exhaust Check Valve PART 7 IST Program Relief Requests 7.1 Relief Request Index (See ARMS DSN NRC-09-0064 for full text of Relief Requests) 7.2 Summary of Relief Requests including applicable components 7.2 NRC Safety Evaluation Reports Index 7.2.1 Dated July 6, 2010 - SER for Relief Requests PRR-002, PRR-003 and PRR-006 7.2.2 Dated July 6, 2010 - SER for Relief Requests PRR-004, PRR-005, PRR-007 and PRR-010 7.2.3 Dated October 5, 2010 - SER for Relief Request PRR-009 7.2.4 Dated September 28, 2010 - SER for Relief Requests VRR-011, VRR-012 and VRR-013 PART 8 IST Program Cold Shutdown Justifications 8.1 CSJ Index 8.2 Cold Shutdown Justifications PART 9 IST Program Refueling Outage Justifications 9.1 ROJ Index 9.2 Refueling Outage Justifications PART 10 IST Program Technical Positions 10.1 Technical Positions Index 10.2 Fermi 2 IST Program Technical Positions IST PROGRAM PLAN PART 1 Page 3

IST Program Plan Description 1.1 Purpose To provide requirements for the performance and administration of assessing the operational readiness of those pumps and valves whose specific functions are required to either:

- Shutdown the reactor to the safe shutdown condition, and/or

- Maintain the safe shutdown condition, and/or

- To mitigate the consequences of an accident.

Fermi 2 was designed and licensed to operate with the Hot Shutdown condition defined as the "safe" shutdown condition. Since Safe Shutdown is defined in the Fermi 2 licensing basis as the hot shutdown condition, inservice testing of components which are required to achieve cold shutdown is unwarranted. However, decay heat removal is an important safety function that must be accomplished or core damage could result.

Although the RHR shutdown cooling subsystem does not meet a specific criterion of 10 CFR 50.36(c)(2)(ii), it is identified as a significant contributor to risk reduction. For the purposes of IST scoping the term "Safe Shutdown" will be conservatively defined as a Cold Shutdown condition. Any and all components necessary to aghieve and maintain a Cold Shutdown condition will be included within the IST scope.

The Fenni 2 Inservice Testing Program (IST) is required by 10CFR50.55a(f). Fenni 2 used the following guidance documents in developing the IST Program:

• Regulatory Guide 1.26, Revision 3, February 1976, "Quality Group Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants"

" ANSI/ANS-52.1-1983, American National Standard, "Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants" e Standard Review Plan 3.9.6, "Inservice Testing of Pumps and Valves"

- Updated Final Safety Analysis Report, Fermi 2,

• Technical Specifications, Fenni 2,

• Generic Letter 89-04, "Guidance On Developing Acceptable Inservice Testing Programs,

• Generic Letter 89-04, Supplement 1: "Guidance On Developing Acceptable Inservice Testing Programs", dated April 4, 1995,

• NUREG-1482 Revision 1, Guidelines for Inservice Testing at Nuclear Power Plants".

The Fermi 2 third 120-month interval Pump and Valve Inservice Testing Plan will be in effect as follows:

Begin: 02/15/2010 End:. 02/16/2020 IST PROGRAM PLAN PART.1 Page 4

The key features of this Plan are: the Pump and Valve table listings, Relief Requests, Refueling Outage Justifications, Cold Shutdown Justifications, Check Valve Condition Monitoring Plans and Technical Positions. The Fermi 2 Inservice Testing Basis Document (maintained within the ISTM Program Management software) includes the justification for inclusion of components in the scope of IST and also the justifications for exclusion from the program. Administrative procedures, surveillance testing procedures, and other records required to define and execute the Inservice Testing Program are all retained as QA records and available at Fermi 2.

The Fenni 2 IST Program is committed to the testing interval and missed surveillance requirements stated in Fenni Technical Specifications Surveillance Requirements SR 3.0.2 and SR 3.0.3. Per these requirements, the allowed grace period for IST exams is 25% of the test interval up to intervals of 2 years. For test intervals.greater than 2 years the maximum allowable grace period will be 6 months.

1.2 Scope The IST program plan has been prepared to meet the requirements of the American Society of Mechanical Engineers (ASME) OM Code 2004 Edition. Mandatory Appendix II of the ASME OM Code 2004 Edition (as modified by 10CFR50.55a(b)(iv)(A), (B) and (C)) will be used for check valve condition monitoring activities.

The IST Program Plan provides a complete listing of those pumps and valves included in the program per the requirements of the following:

- ASME OM Code 2004, Subsection ISTA, "General Requirements "

ISTA contains the requirements directly applicable to inservice testing including the Owner's Responsibility and Records Requirements.

- ASME OM Code 2004, Subsection ISTB, "Inservice Testing of Pumps in Light-Water Reactor Nuclear Power Plants" ISTB establishes the requirements for inservice testing of pumps in light-water reactor nuclear power plants. The pumps covered are those provided with an emergency power source, which are required in the shutting down the reactor to the safe shutdown condition, in maintaining the safe shutdown condition, and/or in mitigation of the consequences of an -accident.

- ASME OM Code 2004, Subsection ISTC, "Inservice Testing of Valves in Light-Water Reactor Nuclear Power Plants" ISTC establishes the requirements for inservice testing of valves in light-water reactor nuclear power plants. The valves covered include those which provide overpressure protection and those which are required to perform a specific function, either actively through the changing of valve obturator position or passively by maintaining required obturator position in shutting down a reactor to the safe-shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

IST PROGRAM PLAN PART 1 Page 5

- ASME OM Code 2004, Subsection ISTD, "Preservice.andInservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants" ISTD establishes the requirements for inservice testing of snubbers in light-water reactor nuclear powef plants including the Owner's Responsibility and Records Requirements. Specific information about the Fermi Snubber Test Program is still contained within the ISI Program document.

- ASME OM Code 2004, Mandatory Appendix I, "Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants" Provides the requirements for performance testing and monitoring of nuclear plant pressure relief devices. Methods, intervals, and record requirements for monitoring and testing are established, as well as guidelines for the evaluation of results. The Appendix applies to safety valves, safety relief valves, pilot-operated pressure relief valves, power-actuated pressure relief valves, nonreclosing pressure relief devices and vacuum relief devices, including all accessories and appurtenances.

- ASME OM Code 2004, Mandatory Appendix II, "Check Valve Condition Monitoring Program" Provides an alternative to the testing or examination requirements of ISTC-3510 through ISTC-5221. The purpose of this program is both to improve valve performance and to optimize testing, examination, and preventive maintenance activities in order to maintain the continued acceptable perfonnance of a select group of check valves.

The IST classification of each pump and valve matches the classification in the CECO Data Base (Central Component Data Base). Items identified as not being ASME Section III, Class 1, 2, or 3, are listed as Non-Code, NC. This classification indicates that the component was not designe< and procured as an ASME Section III component; however, commensurate with its safety function, it is being included in the IST Program.

The GL 89-10 Motor Operated Valves (MOVs) included in the'post GL 89-10 Basis Verification Program (GL 96-05) have been identified as a part of the IST Program.

They are subjected to a continuing periodic verification test program (GL 96-05) to assure that MOVs continue to meet their design required performance specifications.

Fermi has not yet implemented ASME Code Case OMN-1, which credits the GL'96-05 periodic testing in lieu of ISTC stroke time testing. The latest revision of non-mandatory Code Case OMN-1 has not yet been accepted by the NRC through issuance of Reg Guide 1.192.

1.3 Requirements IST PROGRAM PLAN PART 1 Page 6

1.3.1 The IST Plan is implemented through the performance of implementing procedures to satisfy testing requirements identified for each component in the program.

1.3.2 The acceptability of component performance is determined by comparison to the identified acceptance criteria contained in the implementing procedure.

That acceptance criteria is derived from Technical Specifications and ASME Code requirements.

1.3.3 Periodic review of selected performance data associated with pumps and valves is performed for trending purposes.

1.3.4 Maintenance activities are reviewed to determine the impact on the performance of the IST Program pumps and valves.

1.3.5 The content of the IST Plan is revised as necessary during the interval due to Code edition upgrade, design changes or program enhancements.

1.3.6 Applicable changes to implementing test procedures are reviewed to ensure IST Plan compliance.

1.3.7 Component performance anomalies are analyzed and input provided for program resolution.

1.4 Plant Systems Plant systems are identified by a single alphabetic character followed by two numeric characters. These alpha numeric codes are the primary system identifiers used at Fermi. These same system identifiers are then used to identify Process and Instrumentation Drawings (P&IDs) and Functional Operating Sketches (FOSs). The ISI Boundary Drawings referenced in Section C are based on the FOS Drawings and are also numbered with the three character identifier. System component numbers are then based on the three character alpha-numeric system codes. These component numbers begin with the three character system code.

The list below identifies the three character system identifiers and system names included in the Inservice Testing Program for Pumps and Valves.

Plant Identification System (PIS) Codes for Plant Systems B21 - PIS Number for the Nuclear Boiler System B31 - PIS Number for the Reactor Recirculation System C11 - PIS Number for the Control Rod Drive System C41 - PIS Number for the Standby Liquid Control System C51 - PIS Number for the Neutron'Monitoring System El 1 - PIS Number for the Residual Heat Removal System E21 - PIS Number for the Core Spray System IST PROGRAM PLAN PART 1 Page 7

E41 - PIS Number for.the High Pressure Coolant Injection System E51 - PIS Number for the Reactor Core Isolation Cooling System GI1 - PIS Number for the Radwaste System G33 - PIS Number for the Reactor Water Cleanup System G41 - PIS Number for the Fuel Pool Cooling and Cleanup System G51 - PIS Number for the Torus Water Management System N11 - PIS Number for the Main Steam Supply System N21 - PIS Number for the Feedwater System P11 - PIS Number for the Condensate Storage and Transfer System P34 - 'PIS Number for the Post Accident Sampling System P42 - PIS Number for the Reactor Building Closed Cooling Water. System P44 - PIS Number for the Emergency Equipment Cooling Water System P45 - PIS Number for the Emergency Equipment Service Water System P50 - PIS Number for the Station and Control Air System R30 - . PIS Number for the Diesel Generator System T23 - PIS Number for the Primary Containment System T41 - PIS Number for the Control Center HVAC System T46 - PIS Number for the Standby. Gas Treatment System T48 - PIS Number for the Containment Atmosphere Control System T49 - PIS Number for the Primary Containment Pneumatic System T50 - PIS Number for the Primary Containment Atmosphere Monitoring System IST PROGRAM PLAN PART 1 Page 8

f FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES FERMI 2 THIRD 10 YEAR INTERVAL - START DATE 02/15/2010 PART 2: IST PUMP TESTING PROGRAM REVISION 0 Revision Summary:

1. Complete rewrite for start of 3rd ten year interval OUAL Prepared: Date: (n Z9a 2AOt PE-03 Li IS ogram nacre Reviewed: JK d Date: PE-03 I' ISI/PEP En hi er Reviewed: ~?-QAI'Date: > N/A Supervisor, Perforniance gineering Approved: PWzA 3.. s y- A p. ry s- f,_ ,., Date: _________ N/A Manager, Performance Engineering INFORMATION AND PROCEDURES DSN: IST Pump Testing Program Rev: 0 Date: (

DTC: TM PLAN File: 1715.04 Recipient:_______

Date Approyed: nlf,4- &,1~fli2- Release authorized by:___________________

1ST PROGRAM PLAN PART 2 Page 1 o

1.0 INSERVICE TESTING PLAN FOR PUMPS 1.1 Pump Inservice Testing Plan Description This testing program for pumps meets the requirements of the ASME OM Code 2004 Edition, Section ISTB "Inservice Testing of Pumps in Light-Water Reactor Nuclear Power Plants". Where these requirements have been determined to be impractical, specific requests for relief were written. NRC approvals of these relief requests are documented in IST Program Plan Part 7. NRC Generic Letter 89-04 and NUREG 1482, Revision 1 have also been used as guidance in the development of the IST Program Plan for pumps.

1.2 Pump Plan Table Description The pumps included in the Fermi 2 IST Program scope are listed in Part 3 (IST Pump Scope table) of the IST Program Plan. The information contained within this table identifies those pumps which are to be tested to the requirements of Subsection ISTB of the ASME OM Code 2004 Edition, the testing parameters and frequencies, and any associated relief requests. The key headings for the pump tables are delineated below.

System: The plant system in which the pump is located.

Pump PIS: The pumps unique plant identification number.

Description:

The descriptive nare of the pump Div: Identifies which system division, if applicable P&ID: The associated piping and instrumentation drawing number.

ISI Class: The ASME Inservice Inspection (ISI) classification of the component.

. IST Cat: The pump category as defined in ISTB-2000 Cat A Continuous or routinely operated pumps Cat B Standby pumps not operated routinely NOTE: Most pumps which would have been categorized as Cat B pumps per the ASME OM ISTB definition have been conservatively categorized as Cat A pumps. This is in accordance with the NRC SER for Relief Requests PRR-007 and PRR-010.

Type: Identifies the style of pump - centrifugal or positive displacement Driver: Identifies whether the pump is driven by a motor or a turbine IST PROGRAM PLAN PART 2 Page 2

1.2 Pump Plan Table Description (continued)

Exam: The pump test parameters to be measured or observed. The test designators are as follows:

DP Differential Pressure N Speed DISPR Discharge Pressure INLPR Inlet (suction) Pressure

• FLOW Flow Rate OVV(xx) Vibration INLPS Static Inlet Pressure AMPS Motor Running Current Note 1: These parameters are not required IST parameters but are recorded as additional information for component health monitoring.

Frequency: The frequency of testing each pump. The following test designators are used:

OP Once every 92 days (Quarterly) 2Y Once every two years (Biennial)

Procedures: Lists the surveillance procedure numbers used for pump testing Relief Request: Lists any approved relief requests applicable to the pump Technical Position: Lists any IST technical positions applicable to the pump testing 1.3 Measurement of Test Quantities Speed (SPD) Per ASME OM Code ISTB-3530, rotational speed measurement of variable speed pumps shall be taken by a method which meets the requirements of paragraph ISTB-3510. Speed measurement must be accurate to within +/- 2% of full scale per table ISTB-3510-1.

Differential Pressure Differential pressure will be calculated from inlet and discharge pressure measurements or by direct differential pressure measurement.

Pressure Pump suction and/or discharge pressure must be measured to within the accuracy requirements of Table ISTB-3510-1. Relief Requests PRR-007 and PRR-010 allow Fermi to delete the requirement for bi-ennial Comprehensive Pump Testing (CPT) for all but two pumps. This relief was granted because Fermi IST PROGRAM PLAN PART 2 Page 3

quarterly testing of the applicable pumps is sufficient to meet the intent of the CPT. However, to qualify for the relief our quarterly test pressure measurements must meet the CPT 0.5% full scale accuracy requirement.

Flow Rate Flow rate will be measured using a rate or quantity meter installed in the pump test circuit. Flow measurements must be accurate to

+/- 2% of full scale per table ISTB-3510-l.

Vibration Pump vibration will be measured with a digital vibration meter in accordance with the applicable section of ASME OM Code ISTB-3540. Vibration measurements must.be accurate to +/- 5% of full scale per table ISTB-3510-1.

1.4 Allowable Ranges of Test Quantities The applicable allowable ranges specified in ASME OM Code ISTB, Tables ISTB-5121-1, ISTB-5221-1, and ISTB-5321-1 will be used for differential pressure, flow and vibration measurements. Feni may elect to set more restrictive ranges as deemed necessary. Should a measured test quantity fall outside the allowable range, corrective action per ASME OM Code ISTB-6200 shall be followed and records maintained in accordance with ASME OM Code ISTB-9000. For all IST pumps other than EECW Make-up pumps, the maximum DP criteria will be set to 106% (versus the 110%

identified in the ASME OM Code tables. This more limiting value is based on an emerging consensus within ASME and the NRC as documented in ASME Code Case OMN-16. Fermi adoption of the 106% limit is conservative and anticipatory to formal Code changes.

1.5 Instrument Accuracy Allowable instrument accuracies are provided in ASME OM Code ISTB Table ISTB-3510-1. If the accuracies of the station's permanently installed instruments do not meet the requirements of this table/section, temporary instruments meeting those-requirements will be used or approved relief shall be in place.

1.6 Reference Values ASME OM Code ISTB requires that reference conditions be established prior to data collection. Maintaining a reference value over the life of the component is essential for identification of trends in the variable data. Changing the reference value at which testing is performed will only be done when absolutely necessary. Any previously noted degree of lifetime degradation shall be applied conservatively when determining new acceptance criteria for a changed reference. It is possible for pumps to experience a drop in performance over a short timeframe following replacement or inajor rework. This is IST PROGRAM PLAN PART 2 Page 4

'1 caused by initial wear-in when the tolerances between the impellar(s) and the casing or the wear rings are extremely small. These tolerances "open up" slightly due to high flow velocity during the first several. runs of the equipment. If a pump exhibits this short term (first 4 - 5 exams) apparent degradation followed by stable performance over the next 5 -

10 tests it is acceptable to re-establish a new baseline value.

The following is an excerpt from the Summary of Public Workshops Held in NRC Regions on Inspection Procedure 73756, "Inservice Testing of Pumps and Valves," And Answers to Panel Questions on Inservice Testing Issues report issued July 18, 1997.

"3.6.3 Following pump replacement or major maintenance which could affect pump performance, why is the first test data required to be used as the basis for new reference values? With nonstandby pumps (e.g., service water, component cooling) there is no allowance given for break-in or run-in time during which hydraulic parameters can "settle in.

Part 6, Paragraph 4.4, requires a new reference value(s) be determined or the previous set reconfirmed by an inservice test run prior to declaring the pump operable. Licensees may allow the pumps to settle in before taking data, and then declare the pumps operable. Licensees may also run a series of tests to confirm repeatability prior to declaring a pump operable. The requirements of Paragraph 4.3, which state that the reference values shall be determined from the results of the preservice tests or the first inservice test, would not apply if the reference values were affected by repair, replacement, or maintenance. Paragraph 4.4 applies."

During IST pump testing, effort will be made to adjust the fixed reference parameter (FLOW for centrifugal pumps and DISCHARGE PRESSURE for positive displacement pumps) as close as possible to the specific reference value. Small acceptable ranges for reference values may be proceduralized as described in IST Technical Position 09.

IST PROGRAM PLAN PART 2 Page 5

FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES FERMI 2 THIRD 10 YEAR INTERVAL - START DATE 02/15/2010 PART 3: IST PUMP SCOPE TABLE REVISION 0 Revision Summary:

1. Complete rewrite for start of 3rd ten year interval QUAL Prepared: Date: \ PE-03 IST P gram M ager Reviewed: QN Date:  ? PE-03 SI/PEP E ii er Reviewed: E Date: N/A Supervisor, Performance E oneering Approved: Date: / N/A Mana , Performance Engineering INFORMATION AND PROCEDURES DSN: IST Pump Scope Table Rev: 0 Date: 5. r 2i DTC: TM PLAN File: 1715.04 Recipient:

Date Approved: / Release authorized by: A/1 t/,r/a.-

Itp la Cs

DTE ENERGY - FERMI 2. IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat. Pump Type Driver Exam Freq Procedures Request Position.

C4OCOA N/A 6M721-2082 2 A Pos. Motor Displacement North Standby Liquid Control Pump -DISPR OP 24.139.02 PRR-010 FLOW OP 24.139.02 OVVECI OP 24.139.02 OVVEC2 OP 24.139.02 OVVEDI OP 24.139.02 OVVED2 OP 24.139.02 OV VED3 OP 24.139.02 C4000B N/A 6M721-2082 2 A Pos. Motor Displacement South Standby Liquid Control Pump DISPR OP 24.1 39.02 PRR-010 FLOW OP 24.139.02 OVVECI OP 24.139.02 OVVEC2 OP 24.139.02 OVVED1 OP 24.139.02 OVVED2 *OP 24.139.02 OVVED3 OP 24.139.02 E1102CO02A 1 6M721-2084 2 A Centrifugal Motor Residual Heat.Removal Pump A DISPR OP 24.204.01 PRR-007 DP OP 24.204.01 FLOW OP 24.204.01 INLPR OP 24.204.01 INLPS OP 24.204.01 OVVEAI OP 24.204.01 PRR-004 OVVEA2 OP 24.204.01 PRR-004 OVVEA3 OP 24.204.01 PRR-004 OVVECI OP 24.204.01 PRR-004 OVVEC2 OP 24.204.01 PRR-004 Page I of 15

DTE ENERGY - FERMI 2 IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat.- Pump Type Driver Exam* Freq Procedures Request Position E1102CO02B 2 6M721-2083 2 A Centrifugal Motor Residual Heat Removal Pump B DISPR -OP 24.204.06 PRR-007 DP OP 24-204.06 FLOW OP 24.204.06 INLPR OP 24.204.06 INLPS OP 24.204.06 OVVEAI OP 24.204.06 PRR-004 OVVEA2 OP 24.204.06 PRR-004 OVVEA3. OP 24.204.06 PRR-004 OVVECI OP 24.204.06 PRR-004 OVVEC2 OP 24.204.06 PRR-004 E1102CO02C 1 6M721-2084 2 A Centrifugal Motor Residual Heat Removal Pump C DISPR OP 24.204.01 PRR-007 DP OP 24.204.01 FLOW OP 24.204.01 INLPR OP 24.204.01 INLPS OP 24.204.01 OVVEAI OP 24.204.06 PR-R-004 OVVEA2 OP 24.204.06 PRR-004 OVVEA3 OP 24.204.06 PR-R-004 OVVECI OP 24.204.01 PRR-004 OVVEC2 OP 24.204.01 PR R-004 Page 2 of 15

DTE ENERGY - FERMI 2 IST PROGRAM PLAN PART 3 - PUMP SCOPE TAiBLE REV. 0 Relief Technical DIV P&ID Class .Cat. Pump Type Driver Exam Freq Procedures Request Position E1102CO02D 2 6M721-2083 2 A Centrifugal Motor Residual Heat Removal Pump D DISPR OP 24.204.06 -PRR-007 DP -OP 24.204.06 FLOW OP 24.204.06 INLPR OP 24.204.06 INLPS OP 24.204.06 OVVEA1 OP 24.204.06 PR-R-004 OVVEA2. OP 24.204.06 PRR-004 OVVEA3 OP 24.204.06 PRR-004 OVVECI OP 24.204.06 PRR-004 OVVEC2 OP 24.204.06 PRR-004 E1151COOIA------6M721N-2052 3 A - Centrifugal Motor RHR Service Water Pump A DISPR OP 24.205.05 PRR-009 TP-12.

DP OP .24.205.05 PRR-007 FLOW OP 24.205.05 INLPR OP 24.205.05 PRR-006 MOTCUR OP 24.205.05 OVVEAI OP 24.205.05 OVVEA2 , OP 24.205.05 OVVEA3 OP 24.205.05 OV VECI1 OP 24.205.05 PRR-005 OVVEC2 OP 24.205.05 Page 3 of 15

DTE ENERGY - FERMI 2 IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat. Pump Type Driver Exam Freq Procedures Request Position E1151CO01B 2 6M721N-2053 3 A Centrifugal Motor RHIR Service Water Pump B DISPR OP 24.205.06 PRR-009 TP-12 DP OP 24.205.06 PRR-007 FLOW OP 24.205.06 INLPR OP 24.205.06 PRR-006 MOTCUR OP 24.205.06 OVVEAI OP 24.205.06 OVVEA2 OP 24.205.06 OVVEA3 OP 24.205.06 OVVECI OP 24.205.06 PRR-005 OVVEC2 OP 24.205.06 PRR-005 E1151COOIC......6M721N-2052......A. Centrifugal Motor.

DISPR OP 24.205.05 PRR-009 TP-12 RHR Service Water Pump C DP OP 24.205.05 PRR-007 FLOW OP 24.205.05 INLPR OP 24.205.05 PR-R-006 MOTCUR OP 24.205.05 OVVEAI OP 24.205.05 OVVEA2 OP 24.205.05 OVVEA3 OP .. 24.205.05 OVV'ECI OP 24.205.05 PRR-005 OVVEC2 OP 24.205.05 Page 4 of 15

DIE ENERGY - FERMI 2 IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&D Class Cat. Pump Type Driver Exam Freq Procedures Request Position E1151COOlD 2 6M721N-2053 3 A Centrifiigal Motor RHIR Service Water Pump D DISPR OP 24.205.06 PRR-009 TP-12 DP OP 24.205.06 PRR-007 FLOW -OP 24.205.06 INLPR OP: 24.205.06 PRR-006 MOTCUR OP 24.205.06 OVVEAI OP 24.205.06 OVVEA2 OP 24.205.06 OVVEA3 OP 24.205.06 OVVECI OP 24.205.06 PRR-005 OVVEC2 OP 24.205.06 PRR-005 E2101CO01A I 6M721-2034 2 B Centrifugal Motor Core Spray Pump A DISPR OP 24.203.02 DP OP 24.203.02 PRR=002 TP-12 FLOW OP 24.203.02 INLPR OP 24.203.02 INLPS OP 24.203.02 OVVEAI OP 24.203.02 OVVEA2 OP 24.203.02 OVVEA3 OP 24.203.02 OVVECI OP 24.203.02 O V VEC2 OP 24.203.02 Page 5 of 15

DTE ENERGY - FERMI12 IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat. Pump Type Driver Exam Freq Procedures Request Position E2000B 2 .6M721-2034 2 B - Centrifugal Motor Core Spray Pump B DISPR OP 24.203.03 DP OP 24.203.03 PRR-002 TP-12 FLOW OP 24.203.03 INLPR OP 24.203.03 INLPS OP 24.203.03 OVVEAI OP 24.203.03 OVVEA2 OP 24.203.03 OVVEA3 OP 24.203.03 OVVECI OP 24.203.03 OVVEC2 OP 24.203.03 E2101C01 C 1 6M721-2034 -2 -- B Centrifuigal Motor Core Spray Pump C DISPR 24.203.02 FLOW 24.203.02 PRR-002 TP-12 INLPR 24.203.02 OVVEAI OP 24.203.02 OVVEA2 OP 24.203.02 OVVEA3 OP 24.203.02 OV VEC I OP 24.203.02 OVVEC2 OP 24.203.02 Page 6 of 15

DTE ENERGY - FERI 12 IST PROGRAM PLAN PART 3 - PUMP SCOPE-TABLE REV. 0 Relief Technical DIV PMID Class Cat. Pump Type Driver Exam Freq Procedures Request Position E2000D 2 6M721-2034 2 B - Centrifiugal Motor Core Spray Pump D DISPR 24.203.03 FLOW 24.203.03 PRR-002 TP-12 INLPR 24.203.03 2OVVEAI OP 24.203.03

!hOVVEA2 OP 24.203.03 OVVEA3 OP 24.203.03 OVVECI OP 24.203.03 OVVEC2 OP 24.203.03 E4101CO01A N/A 6M721-2043 .2 A Centrifuigal Turbine HPCI - Main Pump DISPR OP 24.202.01 PRR-007

-DP OP 24.202.01 FLOW OP 24.202.01 INLPR OP 24.202.01 INLPS OP 24.202.01 OVVECI OP 24.202.01 OVVEC2 OP 24.202.01 OVVEC3 OP 24.202.01 OVVEDI OP 24.202.01.

OVVED2 OP 24.202.01 SPEED OP 24.202.01 TDHact OP 24.202.01 TDHmnin OP 24.202.01 Page 7 of 15

DTE ENERGY - FERMI 2 IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat. Pump Type Driver Exam Freq Procedures Request Position E4101COO1B N/A 6M721-2043 2 A Centrifugal -Turbine HPCI - Booster Pump OVVECI OP 24.202.01 O VVEC2 OP 24.202.01 OVVEDI OP 24.202.01 OVVED2 OP 24.202.01 OVVED3 OP 24.202.01 P4400COO1A 1 6M721-5444 3 A Centrifugal Motor Emergency Equip Cooling Water Div 1 Pump DISPR OP 24.207.68 PRR-007 DP OP 24.207.08 PRR-003 TP-12 FLOW OP 24.207.08 INLPR OP 24.207.08 INLPS OP 24.207.08 OVVECI OP 24.207.08 PRR-005 OV VEC2 OP 24.207.08 OVVEDI OP 24.207.08 OVVED2 OP 24.207.08 PRR-005.

OVVED3 OP 24.207.08 PRR-005 P40C0B 2 -6M721-5357 3 A Centrifugal Motor Emergency Equip Cooling Water Div 2 Pump -DISPR OP 24.207.09 PRR-007 DP OP 24.207.09 .PRR-003 TP-12 FLOW OP 24.207.09 INLPR OP 24.207.09 INLPS OP 24.207.09 OVVECI OP 24.207.09 OVVEC2 OP 24.207.09 OVVEDI OP 24.207.09 PRR-005 OVVED2 OP 24.207.09 OVVED3 OP 24.207.09 Page 8 of 15

DTE ENERGY - FERMI 2 IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat. Pump Type Driver Exam Freq Procedures Request Position P40iO2 6M721-5444 3 B Centrifugal Motor EECW Makeup Div 1 Pump DISPR OP 24.208.02/.14 PRR-009 TP-12 DP OP 24.208.02/.14 FLOW OP 24.208.02/.14 INLPR OP 24.208.02/.14 OVVECI OP 24.208.02/.14 PRR-005 OVVEC2 OP 24.208.U2/.14 PRR-005 OVVEDI OP 24.208.02/.14 PRR-005 OVVED2 OP 24.208.02/.14 PRR-005 OVVED3 OP 24.208.02/.14. PRR-005 P44000O02B 2 6M721-5357 3 B Centrifugal Motor EECW Makeup Div 2 Pump DISPR OP 24.208.03/.14 PRR-009 TP-12 DP OP 24.208.03/.14 FLOW OP 24.208.03/.14 INLPR OP 24-208.03/.14 OVVECI OP 24.208.03/.14 PRR-005 OVVEC2 OP 24.208.03/.14 PRR-005 OVVEDI OP 24.208.03/.14 PRR-005 OVVED2 OP 24.208.03/.14 OVVED3 OP 24.208.03/.14 PR-R-005 Page 9 of 15

DTE ENERGY - FERMI 2 IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical Div P&ID Class Cat. Pump Type Driver Exam Freq Procedures Request Position P45000O02A 1 6M721N-2052 3 A Centrifugal Motor Emergency Equip Service Water South Pump DISPR OP 24.208.02 PRR-007 DP OP 24.208.02 FLOW OP 24.208.02 INLPS OP 24.208.02 PRR-006 OVVEAI OP 24.208.02 OVVEA2 OP 24.208.02 OVVEA3 OP 24.208.02 OVVECI OP 24.208.02 PRR-005 OVVEC2 OP 24.208.02 PRR-005 P4000B 2 6M721N-2053 3 A - Centrifugal Motor Emergency Equip Service Water North Pump DISPR OP 24.208.03 PRR-007 DP OP 24.208.03 FLOW OP 24.208.03 INLPS OP 24.208.03 PRR-006 OV VEA I OP 24.208.03 OVVEA2 OP -24.208.03 OVVEA3 OP 24.208.03 PRR-005 OVVECI OP 24.208.03 PRR-005 OVVEC2 OP 24.208.03 PRR-005 R3000CO01 1 6M721N-2048 3 A Pos. Motor Displacement EDG 11 Diesel Fuel Oil Xfer Pump A .DISPR OP 24.307.34 PRR-010 FLOW OP 24.307.34 OVVEA3 OP 24.307.34 PRR-005 OVVECI OP 24.307.34 PRR-005 OVVEC2 OP 24.307.34 PRR-005 Page 10 of 15

DTE ENERGY - FERMI 2 IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat. Pump Type Driver Exam Freq Procedures Request Position R3000CO02 1 6M72 IN-2048 3 A Pos. Motor Displacement-EDG 12 Diesel Fuel Oil Xfer Pump A DISPR OP 24.307.35 PRR-010 FLOW OP 24.307.35 OVVEA3 OP 24.307.35 PRR-005 OVVECI OP 24.307.35 PRR-005 OVVEC2" OP 24-307.35 PRR-005 R3000CO03 1 6M721IN-2048 3 - A - Pos. Motor Displacement EDG 11 Diesel Fuel Oil Xfer Pump B DISPR OP 24.307.34 PRR-0l10 FLOW OP 24.307.34 OVVEA3 OP 24.307.34 PRR-005 OVVECI OP 24.307.34 PRR-005 OVVEC2 OP 24.307.34 PRR-005 R30C0 1 6M72iN-2048 - A Pos. Motor Displacement EDG 12 Diesel Fuel Oil Xfer Pump B .DISPR OP 24.307.35 PRR-0 FLOW OP 24.307.35 OVVEA3 'OP 24.307.35 PRR-005 OVVECI OP 24.307.35 OVVEC2 OP 24.307.35 PRR-005 R30CO9 2 6M721N-2049 3 A Pos. Motor Displacement EDG 13 Diesel Fuel Oil Xfer Pump A DISPR OP 24.307.36 PRR-010 FLOW OP 24.307.36 OVVEA3 OP 24.307.36 PRR-005 OVVECI OP 24.307.36 PRR-005 OVVEC2 OP 24.307.36 PRR-005 Page 11 of 15

DIE ENERGY - FERMI 2 IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat. Pump Type Driver Exam Freq Procedures Request Position R3000CO10 2 6M721N-2049 3 A Pos. Motor Displacement EDG 14 Diesel Fuel Oil Xfer Pump A DISPR OP 24.307.37 PRR-010 FLOW OP 24.307.37 OVVEA3 OP 24.307.37 PRR-005 OVVECI OP 24.307.37 PRR-005 OVVEC2 OP 24.307.37 PRR.-005 R3000C011 2 6M721N-2049 3 A Pos. Motor Displacement EDG 13 Diesel Fuel Oil Xfer Pump B DISPR OP 24.307.36 PRR-010 FLOW OP 24.307.36 OVVEA3 OP 24.307.36 PRR-005 OVVECI OP 24.307.36 PRR-005 OVVEC2 OP 24.307.36 PRR-005 R3000CO12---2 6M721IN-2049 3 A Pos. Motor Displacement EDG 14 Diesel Fuel Oil Xfer Pump B DISPR OP 24.307.37 PRR-010 FLOW OP 24.307.37 OVVEA3. OP 24.307.37 OVVECI OP 24.307.37 PRR-005 OVVEC2 OP 24.307.37 PRR-005 Page 12 of 15

DTE ENERGY - FERI 2 IST PROGRAM PLAIN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat. Pump Type Driver Exam- Freq Procedures Request Position R3001C005 1 6M721N-2052 3 A Centrifugal Motor EDG 11 DG Service Water Pump D[SPR OP 24.307.34 PRR-007 DP OP 24.307.34 FLOW OP 24.307.34 INLPR OP 24.307.34 PRR-006 OVVEAI OP 24.307.34 OVVEA2 OP 24.307.34 OVVEA3 OP 24.307.34 PRR-005 OVVECI OP 24.307.34 PR-R-005 OVVEC2 OP 24.307.34 PRR-005 R300 1 006 1.6M721N-2052 3 A Centrifugal Motor EDG 12 DG Service Water Pump DISPR OP 24.307.35 PRR-007 DP OP 24.307.35 FLOW OP 24.307.35 INLPR OP 24.307.35 PRR-006 OVVEAI OP 24.307.35 OVVEA2 OP 24.307.35 OVVEA3 OP 24.307.35 PRR-005 OVVECI OP 24.307.35 PRR-005 OVVEC2 OP 24.307.35 PR-R-005 Page 13 of 15

DTE ENERGY - FERMI 2 IST PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat. Pump Type Driver Exam Freq Procedures Request Position R3001C007 2 6M721N-2053 3 A Centrifugal Motor EDG 13 DG Service Water Pump DISPR OP 24.307.36 PRR-007 DP OP 24.307:36 FLOW OP 24.307.36 INLPR OP 24.307.36 PRR-006 OVVEAI OP 24-307.36 OVVEA2 OP 24.307.36 OVVEA3 OP 24.307.36 PRR-005 OVVECI OP 24.307.36 PRR-005 OVVEC2 OP 24.307.36 PRR-005 R3001C008 2 6M721N-2053 3 A Centrifugal Motor EDG 14 DG Service Water Pump DISPR OP 24.307.37 PRR-007 DP OP 24.307.37 FLOW OP 24.307.37 INLPR OP 24.307.37 PRR-006 OVVEM! OP 24.307.37 PRR-005 OVVEA2 OP 24.307.37 PRR-005 OVVEA3 OP 24.3 07.37 PR-R-005 OVVECI OP 24.307.37 PR-R-005 OVVEC2 OP 24.307.37 PRR-005 Page 14 of 15

DTE ENERGY - FERMI 2 IST -PROGRAM PLAN PART 3 - PUMP SCOPE TABLE REV. 0 Relief Technical DIV P&ID Class Cat. Pump Type Driver Exam Freq Procedures Request Position' T10 40 2 6M721-4325 3 A Centrifugal Motor South CCHVAC Chilled Water Pump DISPR OP 24.413.01 PRR-007 DP OP 24.413.01 PRR-009 TP-12 FLOW OP 24.413.01 INLPR OP 24.413.01 MOTCUR OP 24.413.01 OVVECI OP 24.413.01 OVVEC2 OP 24.413.01 OVVEDI OP 24.413.01 OVVED2 OP 24.413.01 OVVED3 OP 24.413.01

.T41000O41 1 6M721-4325 3 A Centrifugal Motor North CCHVAC Chilled Water Pump DISPR OP 24.413.01 PRR-007 DP OP 24.4 13.01 PRR-009 " TP-12 FLOW OP 24.413.01 INLPR OP 24.413.01 MOTCUR OP 24.413.01 OVVECI OP 24.413.01 OVVEC2 OP 24.413.01 OVVEDI OP .24.413.01 OVVED2 OP 24.413.01 OVVED3 OP 24.413.01 Page 15 of 15

FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES FERMI 2 THIRD 10 YEAR INTERVAL - START DATE 02/15/20 10 PART 4: IST VALVE TESTING PROGRAM REVISION 0 Revision Summary:

1. Complete rewrite for the 3rd. ten year interval OUAL Prepared: _____ Date: Z PE-03 IST Pr ram Mai a er/

Reviewed: -Date: 'z' 12/ '/ PE-03 L~

Programs Ei gineer Reviewed: Ld!A~~ ub AGQUeDate:7f/ N/A Supervisor, Per n-n anc-e Engineering Approved: -"'~ Date: 71____G N/A M ager, Perform-ance Engineering INFORMATION AND PROCEDURES DSN: IST Valve Testing Programn Rev: 0 Date:

DTC: TM PLAN File: 1715.04 Recipient:__________

Date Approved: AP)A x51r2 . Release authorized by: s5AL IST Program Plan Part 4. Page 1 csv

IST PROGRAM PLAN PART 4 IST VALVE TESTING PROGRAM VALVE EXAM AND TABLE DESCRIPTION Section 1.0 - Valve Table layout description Section 2.0 - Valve Exam Codes and exam descriptions Section 3.0 - Valve Exam Interval Codes and descriptions IST Program Plan Part 4 Page 2

Inservice Testing Program - Valve Scope Tables The Valve Scope Tables list all ISI Class 1, 2, 3 and non-ISI Class valves that have been incorporated into the IST Pump and Valve Program. The following information is included for each valve:

1.0 Table Description

• COMPONENT (PIS No.): The valve identification number. A Plant Identification System (PIS) Number is identified.

• COMPONENT NAME: The standard nomenclature name given for the valve.

• DIVISION: Component identified as to which Division it belongs.

• CLASS: The ISI Classification of the valve. For valves located on lines with no ISI classification, either the CECO classification or "NC," Non-Class will be entered, indicating that the component is not an ASME Section III component.

• VALVE CATEGORY: The category(s) assigned to the valve is based on the definitions of ISTC-1300. Four (4) separate categories are defined in the Code.

CATEGORY A - Valves for which seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their safety function(s).

CATEGORY B - Valves for which seat leakage in the closed position is inconsequential but which require stroke testing to verify their ability to fulfill their safety function to open and/or close.

CATEGORY C - Valves which are self-actuating in response to some system characteristic, such as pressure (relief valves) or flow direction (check valves), for fulfillment of the required safety function.

CATEGORY D - Valves which are actuated by an energy source capable of only one operation, such as rupture disks or explosively actuated valves.

• VALVE SIZE: The nominal pipe size of the valve in inches.

• VALVE TYPE: The valve body design (globe, gate, etc).

• ACTUATOR TYPE: The type of valve actuator (air operator, motor operator, etc.)

" ACTIVE/PASSIVE: Requirement for obturator movement to fulfill its safety function as defined in ISTA-2000 for Valves - Active and Valves - Passive.

• NORMAL POSITION: The normal position of the valve during typical plant operation.

IST Program Plan Part 4 Page 3

• SAFETY POSITION: The direction(s) which an active valve must stroke to perform its safety function.

• FAIL POSITION: This is the direction the valve will move by design, if applicable, upon loss of electrical power or air/hydraulic source.

" EXAM: The test(s) which will be performed to fulfill the requirements of ISTC. The exam definitions and abbreviations used are identified in Section 2.0.

- TEST INTERVAL: The frequency at which the above mentioned exams will be performed. Defined IST exam intervals are described in Section 3.0

• PROCEDURE NUMBER: The respective surveillance procedure numbers which implement required testing.

• DEFERRED JUSTIFICATION: Identifies any related Cold Shutdown Justifications or Refueling Outage Justifications.

o RELIEF REQUESTS: Identifies any related Valve Relief Requests.

• TECHNICAL POSITION: Identifies any related IST Technical Positions.

2.0 IST Exam Definitions The inservice test descriptions are given below along with corresponding test abbreviations and a description of the test being performed.

IST Exam Definition table TEST TEST UNITS TEST DESCRIPTION NAME AT-1 Type C Air scfh The containment isolation valves on lines which Leak Test penetrate the drywell and on lines which enter primary containment in the drywell or torus airspace (except lines which terminate below the torus minimum water level) will be seat leak tested with air in accordance with Technical Specifications and the 10CFR50, Appendix J, Option B, performance based testing program. (ISTC-3620 and NRC SER dated 02/17/2000). NOTE: An exam code of AT-IS is also used in the IST database for valves that have specific stem leakage tests.

IST Program Plan Part 4 Page 4

IST Exam Definition table TEST TEST UNITS TEST DESCRIPTION NAME AT-2 Type C Water ml/min The containment isolation valves on lines which connect Leak Test directly to the torus below torus minimum water level and on lines which penetrate the torus in the airspace but terminate below the torus minimum water level will be seat leak tested with water in accordance with Technical Specifications and the 10CFR50, Appendix J, Option B, performance based testing program. NOTE: The population covered by this testing is limited based on conservative application of the "closed systems outside containment" designation.

AT-3 Seat Leakage scfm A leakage test performed on non Appendix J valves to Test , ensure the valve can perform its intended safety function.

AT-4 Bypass scfh Bypass leakage valves will be Type C tested per ISTC-Leakage 3630, to verify that the total potential bypass leakage does Valve not exceed TS limits for bypass leakage. Containment Leak Test isolation valves (which are also bypass leakage valves) shall be tested in accordance with the 10CFR50, Appendix J, Option B, performance based testing program. (Reference NRC SER dated 02/17/2000) For further information on bypass leakage valves, see UFSAR Section 6.2.1.2.2.3.

AT-8 Purge/Vent scfh In addition to Type C tests for the purge/vent isolation Isolation valves, leakage integrity tests are perfonned as required Valve Leak by Technical Specifications.

Test NOTE: An exam code of AT-8S is also used in the IST database for valves that have specific stem leakage tests.

AT-9 MSIV Leak scfh The MSIVs are Type C tested at a reduced pressure. NRC Test SSER 5 granted Fermi exemption from the full pressure-testing requirement of 10CFR50 Appendix J. The MSIV leakage is excluded from the summation of the measured local leak rate tests. The allowable combined leak rate for all four main steam lines shall be in accordance with the Technical Specifications.

AT-10 Pressure gpm Pressure isolation valves (PIVs) will receive periodic Isolation leakage tests in accordance with Technical Specifications Valve Leak requirements. Note: Fermi Relief Request VRR-013 Test allows performance-based scheduling of PIV tests.

IST Program Plan Part 4 Page 5

IST Exam Definition table TEST TEST NAME UNITS TEST DESCRIPTION AT-11 Drywell to inches Drywell to Torus Vacuum Breakers will receive periodic Suppression drop leakage tests in accordance with Technical Specifications Chamber requirements.

Bypass Leak Test AT-14 System Total gpm Trends total system water leakage from each EECW Water System, Division 1 and Division 2 (System ID P45P44D1 Leakage and P45P44D2).

BTC Full Stroke sec Exercise testing, verified by stroke time measurements, TIMED will be performed to confirm the full stroke capability of Exercise Test each valve. The stroke direction timed for this exam is to the CLOSE full open to full closed. Where this test is prescribed for position stop/check valves, it is intended to be an exercise only of the operator and valve stem since the valve disk is presumed to be in its normally closed position prior to exercising.

BTO Full Stroke sec Exercise testing, verified by stroke time measurements, TIMED will be performed to confirm the full stroke capability of Exercise Test each valve. The stroke direction timed for this exam is to the OPEN full closed to full open..

position BT-M Full Stroke P /F Exercise test for a manual valve which verifies that the Exercise Test valve is capable of operating through a full valve stroke.

for a manual This test is accomplished by fully opening the valve to valve. either the back seat or other mechanical stop and closing the valve to its seated position.

BTP . Partial Stroke P /F Partial stroke exercise test performed on MSIVs during Exercise Test normal operation.

CT-C Check Valve P/F Check valve exercise test closed. The exam shall be Exercise Test sufficient to verify that the disk moves freely to the closed to the CLOSE seat from the open position.

position IST Program Plan Part 4 Page 6

IST Exam Definition table TEST TEST NAME UNITS TEST DESCRIPTION CT-DI Check Valve P /F Check -valves will be disassembled and internals inspected Exercise by per 43.000.010 to verify valve operability and to monitor disassembly for degradation in accordance with ASME OM Code Appendix II (NUREG-1482 Section 4.1.4).

CT-EF Excess Flow P /F Excess flow check/valves will be tested in accordance Check Valve with Technical Specifications (see also Relief Request Test VRR-011).

CT-F Check Valve lbs Check valves will be checked for freedom of operation in Exercise Force the open and/or closed directions by'measurement of the Measurement force required to operate the check valve. Acceptance criteria is.established-per ASME OM Code ISTC-5221.

CT-O Check Valve P/F Check valve exercise test open. The exam shall be sufficient Exercise Test to to verify that the disk moves freely to the open position the OPEN from the close seat. Verification of acceptable system flow position through a check valve shall be adequate demonstration that the valve is full open.

CT-OL Check Valve P/F Check valve exercise verification through routine system testing normal operation or system testing. This exam is only applicable for operations the non safety function direction - no specific exam results are documented. Degradation or failure of the check valve to stroke properly would be identified in the site corrective action program.

CT-OP Partial Check P/F A check valve cannot be exercised in such a manner as to Valve Exercise demonstrate full stroke capability to the open position to the OPEN during normal flow testing. However, it can be stroked Position sufficiently to demonstrate that some motion of the obturator'has occurred as evidenced by an observed change in a parameter such as flow, temperature, etc.

CT-OV Pressure Control P/F Pressure Control Valve (PCV) is caused to go from the Device Exercise closed position to the open position and then return again to the closed position by increasing pressure to above the minimum pressure control set point and then decreasing pressure to below the set point.

IST Program Plan Part 4 Page 7

IST Exam Definition table TEST TEST NAME UNITS TEST DESCRIPTION CT-SP Relief Valve Set lbs Relief and safety/relief valve set points will be verified in Point accordance with ASME OM 2004 Appendix I. -

DT Rupture Disk P /F Explosive valves will be-tested in accordance with ASME and Explosive OM Code ISTC-5260. Rupture disks will be replaced on Valve Test a periodic cycle in accordance with manufacturer's instructions and per ASME OM Code ISTC-5250.

FST Fail-Safe Test P/F All valves with fail-safe actuators will be tested to verify proper fail-safe operation upon loss of actuator power.

FST is typically accomplished by performance of BTO/BTC exams on AOVs in the safety direction. For MSIVs, the FST is performed using a special "springs-only" stroke time test.

PIT Position P /F All valves with remote position indicators will be checked Indication Test to verify that remote valve indicators accurately reflect valve operation. This exam is typically accomplished by local observation of stem movement during a remotely controlled full stroke test. For valves which do not periodically and routinely experience flow conditions the PIT exam should be supplemented with other indications capable of verifying proper valve obturator movement.

(ASME OM Code ISTC-3700).

SMC Skid-Mounted N/A Skid-mounted components are components for which Conponent testing of the major component and/or system adequately tests the skid-mounted component. Testing of the major system/component verifies the operational readiness of the skid-mounted and component subassemblies (NUREG-1482, Chapter 3.4). This exam code is informational only.

IST Program Plan Part 4 Page 8

Miscellaneous Test Definitions As Fermi has matured, it has become useful to optionally trend other system parameters. These additional tests are not required to be trended or recorded by ASME Code or Federal Regulations. Applicable tests are listed below:

IST Miscellaneous Exam Definition table TEST TEST UNITS TEST DESCRIPTION NAME CT-D Check Valve N/A Check valve periodic disassembly and inspection per disassembly 47.000.13. These exams are a supplemental treatment, not a

& inspection Code compliance exam (see CT-DI above). Inclusion of these exam codes in the Valve Tables is informational; these exams are not ASME In-Service Tests.

MINFLO Minimum gpm Trends minimum acceptable pump flow rate as a "go-no-Required go" acceptance test. Inclusion of these exam codes in the Pump Flow Valve Tables is informational; these exams are not ASME Rate In-Service Tests.

MOTCUR Motor Driven amps Pump motor current at pump reference flows. Inclusion Pump Current of these exam codes in the Valve Tables is informational; these exams are not ASME In-Service Tests.

PIT-RS Position P/F Valves with position indication on the Remote Shutdown Indication for Panel are checked to verify that remote valve indicators Remote accurately reflect valve operation. PIT-RS exams are not Shutdown required by ASME OM Code. Inclusion of these exam Valves codes in the Valve Tables is informational.

GL9605 Motor- N/A This code identifies MOVs with Periodic Verification Operated testing to meet the requirements of Generic Letter 96-05, Valve an on-going program of periodic verification of design Diagnostic basis capability of MOVs. The required testing frequency Test for GL 96-05 MOVs is determined using a test matrix approved by the BWROG in NEDC-32719. This is often referred to as the JOG Matrix. Test frequency is a function of both thrust margin and risk-ranking. The diagnostic testing and test analyses are performed in accordance with approved technical procedures.

IST Program Plan Part 4 Page 9

3.0 Test Intervals The following table lists the codes used in the valve tables to describe the intervals at which various tests are performed IST Exam Interval table Frequency Frequency in Frequency Description Code Days (app.)

OP 92 Quarterly RR 735 Reactor Refuel CS 735 Cold Shutdown OB N/A Per Appendix J Option B OL N/A Continuous online 2Y 732 2 Years SP1 N/A EFCV's testing per TS 3.6.1.3.9 SP2 N/A CRD Valves per TS 3.1.4 184D 184 .184 Days 78W 546 78 Weeks 18M 547 18 Months 2R 1080 2 Refuels 3Y 1080 3 Years 5Y 1825 5-Years 4R 2160 4 Refuels 6Y 2200 6 Years 6R 3240 6 Refuels 10Y 3652 10 Years GP N/A Per GL 96-05 / JOG Plan NOTE: Per CARD 10-32070, Fermi is committed to apply the surveillance testing requirements of Tech Specs 3.0.2 and 3.0.3 to all Inservice Testing. That includes standard 25% grace allowance (up to a maximum grace of 6 months).

Additional interval codes associated with non-IST supplemental exams Frequency Frequency in Frequency Description Code Days (app.)

lY 365 Annually 4Y 1464 4 Years 3R 1620 3 Refuels 5R 2700 5 Refuels 8Y 2922 8 Years 8R 4320 8 Refuels 10R 5400 10 Refuels Code N/A Code Based Frequency SP N/A Special Test Frequency 1ST Program Plan Part 4 Page 10

FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES FERMI 2 THIRD 10 YEAR INTERVAL - START DATE 02/15/2010 PART 5: IST VALVE SCOPE TABLE REVISION 0 Revision.Summary:

1. Complete rewrite for the 3rd ten year interval Prepared: Date: In1 ttPE-03 1ST Pro -am Man er Reviewed: ________________ Date: Si 26 ol PE-03 *

(I$I/PEP n ineer Reviewed: L}jXA x9 Date: ' S~/ N/A Supervisor, Perfo ' ance Engineering Approved:"Dt: 3 N/

Ma ger, Performance Engineering

-- INFORMATION ANT) PROCEDURES DSN: IST Valve Scope Table Rev: 0 Date: -l'12 DTC: TM PLAN File: 1715.04 Recipient:_______

Date Aprvd Release authorized by:A/4 '.' - i

DTE ENERGY - FERIII2 ISI/1IST Prooramn Plan - Part 5 Valve Scope Table Sytni 20 Test Procedure Deferred Relief T&chnical

- Exam Frequency Nuimber JlustiIication Request Position PIS B210O010A Nuclear Boiler (NB) Feedwater Supply Inboard Primary DIV'ISION 1 Containment Check Valve.

Class Cat Size valve Actuator Active / Normal Position Safety Fail Type Type Passive Position 'Position 1 A/C 20 CK SA Test A System Dependent Both AT- I OB 43.401.303 AT-4 OB 43.401.511 CT-C RR 43.401.303 ROJ-001 CT-0 CS 24.107.01 CSJ-002 PIS B2100FOlOB Nuclear Boiler (NB) Feedwater Supply Inboard Prim,ar),

DIVISION 2 Containment Check Valv'e.

Class Cat Size Valve Actuator Active / Normal Position "Safety .Fail Type -Type Passive Position P~osition I A/C 20 CK SA Test A System Dependent .Closed AT-I 0B 43.40 1.304 AT-4 GB 43.401.511 CT-C RR 43.401.304 ROJ-001 CT-0 CS 24.107.01 CSJ-002 PIS B210OF029A Nuclear Boiler (NB) Air AccumuulatorA,O02C Inlel Check DIVISION N/A Valve.

Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Ty~pe Typ1 e P~assiv'e Position Position 3 A/C I CK Self Act A System Dependent Both AT-3 2Y 24.137.02, CT-C RR 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 PIS B210OF029B Nuclear Boiler (NB) Air Accumulator A002D Ilet Check DIVISION N/A Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passiv'e Position Position 3 A/C I CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 Page I of 18 For System: "B2100

DTE ENERGY - FERMVI 2 ISI1 I1ST Propramn Plan - Part 5 Valve Scope Table Sse : B 10 Test Procedure Deferred Relief Technical Sytm:r10 xanj Frequency Number Justification Request Position PIS B210OF029C Nuclear Boiler (NB) Air AccumulatorA002A Inlet Check D)IVISION N/A Valve.

Class Cat Size Valve. Actuator Active/ NormalPositiot Safety Fail Type Type Passive Position Position 3 A/C I CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT.-C RR 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 PIS B210OF029D Nuclear Boiler (NB) Air"A ccunulator A 002B Inlet Check DIVISION N/A Valve.

Class Cat Size Valve Actuator Active /- Normal Position Safety Fail Type Type Passive 'Psition Position 3 A/C I CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 PIS 'B2 100F031lA Nuclear Boiler (NB) M'SIV 82! 03F028A OperatorAir IIV ISION N/A Accu,nulator B21l03A 002C Class. Cat Size Valve Actuator Active I Normal Position Safety Fail Type Type Passive Position Position 3 C 3/4 RLF Self Act A Closed Open-CT-SP IOY 43.000.020 PIS B210O031B Nuclear Boiler (NB) MSI V B2103FO28B OperatorAir DIVISION N/A Accumulator B2103A 0021)

Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type Type P'assive Position Position 3 C 3/4 RLF Self Act A Closed Open CT-SP IOY 43.000.020 PIS B21 0OF031 C Nuclear Boiler (NB)l MSIV 821 03FO28C Operator Air DI1VISION N/A Accumulator 82103O002A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C - 3/4 RLF Self Act A Closed Open CT-SP MOY 43-000.020 Page 2 of 18 For System: B2100

DTE ENERGY -FERMI 2 IStI I1ST Pro ram Plan - Part 5 Valve Scope Table System: B2100 Test Procedure Deferred Relief Technical Exam Fr-equency Number Justification Request Position PIS B210O031D Nuclear Boiler (NB) MSIV 82103FO28D OperatorAir lDIVIS ION N/A Accumulator B2l103A 002B Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position position 3 C 3/4 RLF Self Act A Closed Open CT-Sp loy 43.000.020 PIS B210OF037A Nuclear Boiler (NB) Safety /Relief Valve F013P Vacuum DIVISION N/A Breaker Valve.

C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 8 CKC Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-019 PIS B210OF037B Nuclear Boiler (NB,Safety /Relief Valve EQ0131 Vacuum D)IVISION N/A Breaker Valve.

Class Cat . Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 8 CKC Self Act *A - System Dependent Both .

CT-F RR 24.201.01 ROM-019 PIS B210OF037C Nuclear Boiler (NB) Safety /Relief Valve FEQI3R Vacuum D)IVISION N/A Breaker Valvie..

Class C:at Size Valve Actuator Active / Normal Position Safety Fail

-Type Type Passive Position Position 2 C' 8 CK Self Act . A System Dependent Both CT-F RR 24.201.01 ROJ-019 PIS B2100F037D Nticlear Boiler (NB) Safety /Relief Valve F013D Vacuum DIJVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail

'Type Type Passive .Position Position 2 C 8 CK Self Act A System Depenldent Both CT-F KR 24.201.01 .ROJ-019 PIS B21I0OF037E Nuclear Boiler (NB) Safety / Relief Valve FQ0/3K Vacuum D)IVISION- N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Salctv Fail Type Type P~assive Position __ Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROM-019 Page 3 of 18 For System: B2100

DTE ENERGY - FERMI 2 ISI / IST Program Plan - Part 5 Valve Scope Table System: B2100 Test Procedure Deferred Relief Technical

-BExam Frequency Number -Justification Request Position PIS B2100F037F Nuclear Boiler (NB) Safety /Relief Valve F013F Vacuum DIVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-019 PIS B2100F037G Nuclear Boiler (NB) Safety/ Relief Valve F013H Vacuum DIVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-019 PIS B2100F037H Nuclear Boiler (NB) Safety/ Relief Valve F013G Vacuum DIVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive . Position Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-019 PIS B2100F037J Nuclear Boiler (NB) Safety/ Relief Valve F013B Vacuum DIVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type . Passive Position Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-019 PIS B2100F037K Nuclear Boiler (NB) Safety /Relief Valve FO13E Vacuum DIVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-19 PIS B2100F037L Nuclear Boiler (NB) Safety /Relief Valve F013C Vacuum DIVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-019 Page 4 of 18 For System: B2100

DTE ENERGY - FERMI 2 ISI / IST Program Plan - Part 5 Valve Scope Table System: B2100 Test Procedure Deferred Relief Technical Exam Frequency Number Justification Request Position PIS B2100F037M Nuclear Boiler (NB) Safety /Relief Valve F013M Vacuum DIVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-019 PIS B2100F037N Nuclear Boiler (NB) Safety/ Relief Valve F013N Vacuum DIVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-019 PIS B2100F037P Nuclear Boiler (NB) Safety / Relief Valve F013A Vacuum DIVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-019 PIS B2100F037R NuclearBoiler (NB) Safety/ Relief Valve F013L Vacuum DIVISION N/A Breaker Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 8 CK Self Act A System Dependent Both CT-F RR 24.201.01 ROJ-019 PIS B2100F076A Nuclear Boiler (NB) A FeedwaterSupply Check Valve.

DIVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 1 A/C 20 CK SA Test A System Dependent Closed AT-1 OB 43.401.303 AT-4 OB 43.401.511 CT-C RR 43.401.303 ROJ-001 CT-0 CS 24.107.01 CSJ-002 PIT 2Y 24.107.01 Page 5 of 18 For System: B2100

DTE ENERGY - FERMI 2 ISI /I1ST Pro2ram Plan - Part 5 Valve Scope Table Sse : B 10Test Procedure Deferred . Relief Technical Sytm B10Exatn Frequency Number Justitication Request Position' PIS B210OF076B Nuclear Boiler ('NB) B Feedwater Supply Check Valve D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fa il Type Type Passive Position Position I A/C 20 CK SA Test A System Dependent Closed AT-I 0B 43.401.304 CT-C RR 43.401.304 ROJ-001 CT-a CS 24.107.01 CSJ-002 PIT 2Y 24.107.01 PIS B210OF248A Nuclear Boiler (NB) Division I RPV Water Level DIVISION 1 Instrumentation Backfill Line Check Valve.

Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position NC A/C 3/8 CK Self Act A Open Closed AT-4 RR 43.401.511 CT-C RR 43.401.511 ROJ-013 CT-OL OL N/A TP-01 PIS B210OF248B Nuclear Boiler (NB) Div II RPV Water Level Instrumentation D)IVISION 2 Backfill Line Check Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC A/C 3/8 CK Self Act A .Open Closed AT-4 R~R 43.401.511 CT-C RR 43.401.511 ROJ-013 CT-OL- OL N/A TP-01 PIS B210OF249A Nuclear Boiler (NB) Division I RPV Water Level D)IVISION 1 Instrurnentation Backfil Line Check Valve.

Class Cat Size Valve Actuator Active / Normal Position .Safetv. Fail Type Type Passive Position lPositionm NC A/C 3/8 .CK Self Act A Open Closed AT-4 RR 43.401.511 CT-C RR 43.401.511 ROJ-013 CT-OL OL N/A .TP-01 Page 6 of 18 For System: B2100

DIE ENERGY - FERIVII1 2 ISI / IST.Proarani Planl - Part 5 Valve Scope Table Sse ' B 1OTest P roceduire Deferred Relief Technical Sse: B10-Exam Frequency Number Justification Request Position PIS B210OF249B Nuclear Boiler (NB) Div HI RPV Water Level Instrumientation IVISION 2 Baclfill Line Check Valve.

C:lass Cat Size Valve Actuator Active / Normal P~osition Safetr Fail Type Type Passive Position Position NC A/C -3/8 CK Self Act A Open Closed AT-4' RR 43.401.511 CT-C RR 43.401.511 ROJ-013 CT OL N/A TP-0[-

PIS B21F501A Main Steam Line 'A'Excess Flow Check Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P~osition I A/C 1 XFC Self Act A Open Closed CT-EF SPI 44.220.1 13 VRR-01 1 PIT SPI 44.220.113 VRR-011 PIS B21F501B Main Steam Line 'B' Excess Flow Check Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Typei Type Passive Position Positionl I A/C I XFC Self Act A Open Closed CT-F SPI1 44.220.113 VRR-0I I PIT SPI 44-220.113 VRR-01I PIS B21F501C Main Steam Line 'C' Excess Flow Check Valve D)IVISION N/A C;lass Cat Size Valve Actuator Active / Normal Position S:ifetc Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-F SPI 44.220.110 VRR-0I I PIT SPI 44.220.110 'VRR-01.1 Page 7 of 18 Foi Sy'stemi: B2100

DTE ENERGY - FERN1I12 ISI/1IST Programn Plan - Part 5 Valve Scope Table Sse: B 10Test Procedure Deferredl Relief Technical Sse: B10Exam Frequencv Number Justification Request Position PIS B21F501D Main Steam Line 'D'. Excess Flow Check Valve DIVISION N/A Class Cat Size Valve 'Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.110 VRR-01l PIT SPI 44.220.110 VRR-01l PIS B21F502A Main Steant Line 'A'. Excess Flow Check Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail

- Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.113 VRR-0lI PIT SPI 44.220.113 VRR-01I PIS B21F502B Main Steam Line 'B. Excess Flow Check Valve DIVISION N/A Class Cat Size V~alve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.113 VRR-0II PIT SPI 44.220.1 13 VRR-01 I PIS B21F502C Main Steam Line 'C'. Excess Flow Check Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Typse Passive Position Position I A/C I XFC Self Act A Openi Closed CT-EF SPI 44.220.1 10 VRR-0I I PIT SPI 44.220.1 10 VRR-01 l PIS B21F502D Maini Steam Line 'D'. Excess Flow Check Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fa il Type Type Passive . Position Position 1 A/C 1 XFC Self Act A Open Closed CT-EF SPI 44.220.1 10 VRR-0I I PIT SPI 44-220.110 VRR-0II Page 8 of 18 For System: B2100

DTE'ENERGY - FERMI 2 ISI1/IST Program Plan - Part 5 Valve Scope Table Sse : B 10Test Procedlure Deferred Relief Technical Syte: 210Ex am Freqtuency Nutmber .1ustificati on Request Position PIS B21F503A Main Steam Line 'A'. Excess Flow Check Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive P'osi tin Posi tin I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.110 VRR-011 PIT SPI 44.220.110 VRR-011 PIS B21F503B Main Steam; Line 'B. Excess Flow Check Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail fype Type Passive P~osition Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.115 VRR-0II PIT SPI 44.220.115 VRR-0l1 .

PIS B21F503C Main"Steamz Line 'C'. Excess Flow Check Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position safety Fail Type .Type Passive P'osition Position 1 A/C I XFC Self Act A Open Closed CT-EF SP I 44.220.1 12 VRR-01 1 PIT SPI 44.220.112 VRR-O01 PIS B21F503D Maini Steam Line 'D'. Excess Flow Check Valv'e D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.115 VRR-0I Y PIT SPI 44.220.115 VRR-0I1 PIS B21F504A Main Steam Line 'A'. Excess Flow Check Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 1 A/C I XFC Self Act A Open Closed CT-EF SPI1 44.220.1 10 VRR-01 1 PIT SPI, '44.220.110 VRR-0I1 Page 9 of 18 For Svsteln: B2100

-DTE ENERGY - FERMI 2 ISI /I1ST Prop-ram Plan - Part 5 Valve Scope Table System: BI2100 Test Procedure Deferr"eti Relief Technical

______Exam Frequency Number Justification Request Position PIS B21F504B Main Steam Line YB.Excess Flow Check Valve D)IVISION N/A C'lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Pos5ition~

I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.115 V'RR-01l PIT SPI 44.220.115 VRR-011 PIS B21F504C Main Steam Line 'C'. Excess Flow Check Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type 'Type Passive Position Position I A/C I XFC- Self Act A Open . Closed CT-EF SPI 44.220.1 12 VRR-0I1I PIT SP1 44.220.112 VRR-0l1 PIS B21F504D Main Steanm Line 'D'. Excess Flow Check Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type -Type Passive Position 'Position I A/C I XFC Self Act A . Open Closed CT-EF SPI 44.220.1 15 VRR-01 1 PIT SP1 44.220.115 VRR-011 PIS B21F506 Reactor Vessel Excess Flow Check Valve DIVISION N/A C:lass Cat Size Valve Actuator Active / Normal Position Saf'etv Fail Type Ty'pe Passive' Posi tinon Posi tion I A/C I XFC Self Act A Open Closed CT-EF SP1 44.220.115 VRR-01l PIT SP1 44.220.115 VRR-01I PIS B21F507 Reactor Vessel Excess Flow Check Valve DI1VISION, N/A Class Cat. Size Valve Actuator Active / Normal Position Safety Pail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI ~44.220.115 VRR-0II PIT SPI 44.220.115 . VRR-0II Page 10 of 18 For System: B2100

DTE ENERGY - FERMI2' 181I / IST Programn Plan - Part 5 Valve Scope Table Sse : B 10Test Procedure Deferred Relief Technical Sse: B 10- Evam Freqjuency Number Justification Request Positiou PIS B21F508 Reactor Vessel Excess Flbw Check Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safty Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SP I 44.220.111 VRR-01 1 PIT SPI 44.220.111 VRR-011 PIS B21F509 Reactor Vessel Excess Flow Check Valve DIVISION' N/A Class ('at Size Valve Actuator Active / Normal Position Safety Fail Tye Type Passive .. Position Position I A/C I XFC Self Act . A Open Clo"sed CT-EF SPI 44.220.111 , VRR-0II PIT SPI 44.220.111 VRR-0l1 PIS B21F510 Reactor Vessel. Excess Flow Check Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type .Type Passive .Position Position I A/C I XFC Self.Act A Open Closed CT-EF SPI 44.220.115 VRR-0II PIT SPI 44.220.115 . VRR-0II PIS B21F511 Reactor Vessel Excess Flowv Check Valve D)IVISION N/A Class Cat. Size Valve- Actuator Active / Normal Position Safety Fail Type Type Passive .. Position Position I A/C 1 XFC Self Act- A Open. Closed CT-EF SPI 44.220.111 VRR-0I1 PIT SPI 44.220.111 VRR-0l1 PIS B21F512 Reactor Vessel Excess Flow Check Valve DIlVISION N/A

(:lass.C:at. Size Valve .Actuator Active / Norinal P~osition Safety Fail Type Type Passive Position Position I A/C. I XFC Self Act A Open Closed CT-EF SPI 44.220.111 VRR-0I 1 PIT SPI 44.220.111 VRR-0II Page 11 of 18 For System: B2100

DIE ENERGY - FERMI 2 ISI1/IST Program Plan - Part 5 Valve Scope Table Sse: B 10Test Procedure Deferred Relief Technical Syte: 210Exam Frequency Number aJustitication Request Position PIS B21F513A Reactor Vessel Jet Pump No. 15 Division I Excess Floiv D)IVISION N/A Check Valve (Class Cat Size Valve .Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I -XFC Self Act A -Open Closed CT-EF SPI 44.220.112 VRR-OII PIT SPI 44.220.112 VRR-01l

---

~--.---... ..- -. - .-.- -. . . . .. . . .. . . .. . . .

PIS B21F513B Reactor Vessel Jet Pump No. 5 Div HI Excess Flow Check DIVISION 2 Valve (Class Cat Size Valve . Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act . A Open Closed CT=El SPI 44.220.111 VRR-0l1 PIT SPI 44.220.111 .VRR-01I PIS B21F513C Reactor Vessel Jet Pump No. 20 Division I Excess Flow D)IVISION ICheck Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF ,SP I 44.220.115 VRR-011 PIT SPI 44.220.115 VRR-011 PIS B21F513D Reactor Vessel Jet Ptump No. 10 Div HI Excess Flow Check l)IVISION N/A Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220-111 VRR-01 1 PIT SPI 44.220.111 VRR-01I PIS B21F514A Reactor Vessel Jet Pump No. 15 Division I,Excess Flow D)IVISION I Chteck Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF .SPI 44.220.110 VRR-01I PIT SPI 44.220.110 VRR-01I Page 12 of 18 For System: B2100

DIE ENERGY - FERMI 2 ISI / IST Pro2ram Plan - Part 5 Valve Scope Table S te : B10Test Procedure Deferredl Relief Technical Syte:F210 xain Frequency Nutmber Justification Req uest. Position PIS B21F514B Reactor Vessel Jet Pump No. 5 Div II Excess Flow Ch1eck DIVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Sarety Fail Type Type P~assive Position Position I A/C I XFC Self Act A Open Closed CT-EF SP I 44.220.111 . VRR-01 I PIT SPI 44.220.111 VRR-011 PIS B21F514C Reactor Vessel Jet Pump No. 20 Division I Excess Flow DIVISION I Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Poisitioni I A/C 1 XFC Self Act A Open Closed CT-EF SPI 44.220.1 10 VRR-01 l PIT SPI 44.220.1l'0 VRR-01J PIS B21F514D Reactor Vessel Jet Pump No. /0 Div 11 E.rcess Flow Clieck DIVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 1 A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.111 VRR-0I1 PIT. SPI 44.220.111 VRR-0l1 PIS B21F515A Reactor Vessel Jet Pump No. 11 Div 1 Exvcess Flow C7heck DIVISION 1 Valve Class Cat Size Valve Actuator Active / Normal- Position Safets' Fail Type Type Passive posiion Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.110 VRR-0Il PIT SPI1 44.220.110 VRR-0 II PIS B21F515B Reactor Vessel Jet Pump No. I Div IHExcess Flow Check D)IVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safvty Fail Type Type Passive Position Positioii I A/C I XFC Self Act A Open Closed CT-EF .SP I 44.220.111 VRR-01 I PIT SPI 44.220.111 VRR-011 Page 13 of 18 For System: B2100.

DTE ENERGY - FEFJV1.12 [SI / IST Pro2ram Plan - Part 5 Valve Scope Table Procedure Deferred Relief Technical Sse ' B 10Test Sse: B10Esam Frequency Number ,Justification Request Position PIS B21F515C Reactor Vessel Jet Pump No. 12. Div 1 Excess Flow Check D)IVISION I Valve Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type . Passive Position Position I A/C I XFC Self Act . A Open Closed CT-EF SP1 44.220.1 12 VRR-0llI PIT SPI -44.220.112 . VRR-0II PIS B21F515D Reactor Vessel Jet Pump No. 2 Div/I1 Excess Flow Check DIVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SP1 44.220.111 VRR-Ob1 PIT SPI 44.220.111 VRR-0II PIS B21F515E Reactor Vessel Jet Pump No. 13 Div I Excess Flow Check DIVISION I Valve Class, Cat Size Valve Actuator Active I Normal Position Safety Fail Type Type Passive Pousition Position I A/C I XFC Self Act A Open Closed CT-EF SF1 44.220.112 VRR-01I PIT SF1 44.220.112 VRR-01I PIS B21F515F Reactor Vessel Jet Pump No. 3 Div HIExcess Flow Check DIVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safety - Fail

-Type Type Passive Position' Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.111 VRR-011 PIT SF1 44.220.111 VRR-0l1 PIS B21F515G. Reactor Vessel Jet Pump No. 14 Division I Excess Flow D)IVISION I Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive .. Position Position I A/C I XFC Self Act A Open Closed CT-EF SF1 44.220.1 12 VRR-011I FIT. SF1 44.220.112 VRR-011 Page 14 of -18 For System: B2100

DTE ENERGY - FERMI 2 ISI / IST Pro2ram Plan - Part 5 Valve Scope Table Sytm 2 0Test . P rocedunre Deferred Relief Technical tsxam Prequency Number 3ustitication Request Position PIS B21F515H Reactor Vessel Jet Pump No. 4 Div/I Excess Flow Check DIV'ISION 2 Valve Class _ Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open . Closed CT-EF SPI 44.220.1 14 VRR-0l1 PIT SPI 44,220.114 VRR-011 PIS. B21F515L Reactor Vessel Jet Pump No. 16 Division [,Excess F/ow.

DIVISION i CTheck Valve Class Cat Size Valve Actuator 'Active/I Normal Position Safety Fail Type Type Passive .Position Position 1 A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.1 12 VRR-01 1 PIT SPI 44,220.112 VRR-0lI PIS B21F515M Reactor Vessel Jet Pump No. 6 Div [I Excess Flow Check D)IVISION 2 Valve Class . Cat Size Valve Actuator Active / Normal .Position Safetyv Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44,220.114. -. VRR-011 PIT SPI 44.220.114 VRR-011 PIS B21F515N Reactor Vessel Jet Pump No. 17 Division / Excess Flow DIVISION I Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety . Fail TypeC Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF .SPI .44.220.113 VRR-011 PIT SPI 44,220.113 VRR-0II PIS B21F515P Reactor Vessel Jet Pump No. 7 Div 11 Excess Flow Check IIiSION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fa il Type Type Passive Position Position I A/C I XFC Self Act A Open Closed

- .. CT-EF SPI.44-220.114. VRR-011-PIT SPI 44.220.114 VRR-011 Page 15 of 18 For- Systemn: B2100

DTE ENERGY - FERMI 2 [SI: I 1ST Program Plan - Part 5 Valve Scope Table Sse : B 10Test Procedure Deterred Relief Technical S te: B 10Exam Frequency Number Justification Request Position PIS B21F515R Reactor Vessel Jet Pump No. 18 Division I Excess Flow DIVIlSION 1. Check Valve C:lass Cat Size Valve Actuator. Active / Normal P'osition Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.113 VRR-01I PIT SPI 44.220.113 VRR-0II PIS B21F515S Reactor Vessel Jet Pump No. 8 Div II Excess Flow.Check DIVISION 2 Valve Class Cat Size Valv'e Actuator Active / Normal Position Safety Fail Type Type Passive P'osition Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.114 VR.R-011 PIT SPI 44.220.114 VRR-011 PIS B21F515T Reactor Vessel Jet Pumnp No. /9 Division I Excess Flow DIVISION I Check Valve Class Cat Size Valve- Actuator Active / NormalPosition Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.113 VRR-01I PIT SP1 44.220.113 VRR-0II PIS B21F515U Reactor Vessel Jet Pump No. 9 Div' II Excess Flow Check D)IVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safety ~Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SP1 44.220.114 VRR-011 PIT SPI 44.220.114 VRR-0II PIS B21F516A Reactor Vessel PressureBelow Core Plate Excess Flow D)IVISION N/A Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive ~.Positioni Position I A/C I XFC Self Act A Open Closed CT-EF SF1 44.220.113 VRR-01I PIT SPI 44.220.113 VRR-011 Page 16 of 18 For System: B2100

DTE. ENERGY - FERMI 2 I1 / IST Pro, -am Plan - Part 5 Valve Scope Table System: B2100 'Test Procedu re Deferred Relief Technical.

Exam Frequency Numiber Justification Request Position PIS B21F516B Reactor Vessel Pressure Below Core Plate Excess F/owv D)IVISION N/A Check Va/ye Class Cat Size Valve .Actuator Active] Normal Position Safety Fail Type Type Passive Position Position I A/C 1 XFC Self Act A opep Closed CT-EF SPI 44.220.114 VRR-0II PIT SP1 44.220.114 .VRR-0II PIS B21F516C Reactor Vessel Pressure Beow Core Plate Excess Flow DIVISION N/A Check Valve

-Class Cat Size Valve Actuator Active / Normal Position Safety Fail type Typie Passive Position P'ositioni I A/C 1 XFC Self Act A Open Closed CT-EF SPI 44.220.110 VRR-011 PIT SPI 44,220.1 10 VRR-01 1 PIS B21F517A Reactor" Vessel Pressure Abos'e Core P/ate Excess Flow.

D)IVIS ION N/A Check Valve

• Class C,at Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive P'osition P'ositioni I A/C I XFC Sell' Act A Open Closed CT-EF SPI 44.220,1 11 VRR-0I1I PIT SPI 44.220.)111 VRR-01 I PIS B21F517B Reactor Vessel Pressure Above Core P/ate Excess F/ow D)IVISION N/A Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail.

Type rType Passive Position Position I A/C I XFC Sell' Act A Open Closed CT-EF SPI 44.220.1 12 VRR-0II PIT SP1 44.220.112 VRR-01I PIS B21F517C Reactor Vessel Pressure Above Core Plate Excess Flo1, D)IVISION N/A Check Valve Class Cat Size Valve Actuator Active / Normal Position Safcty Fail Type Type Passive Position Position -

I A/C 1 XFC Self Act A Open . Closed CT-EF SPI 44,220.1 15 VRR-01 I PIT SPl 44,220.115 VRR-0II Page 17 of 18 For System: .B2100

DTE ENERGY - FERMVII2 ISI! 151SPro2 ram Plan - Part 5 Valve Swope Table System: B2100 ______Exam Test Frequency Procedure Number Deferred Jiustification Relief Request Technical Position PIS B21F517D Reactor Vessel PressureAbove Core Plate Excess Flow IVISION N/A Check Valve ClIass Cat Size Valve Actuator Active! Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closcd CT-EF SP.I .44.220.112 VRR-01 I PIT SPI 44.220.112 VRR-01I Page 18 of 18 For Svstem:B20

DTE ENERGY - FERMI 2 I[ / 1ST .ProaramnPlan - Part 5 Valve Scope Table SytmTB131est Procedure Deferred Relief Technical Sse: B 13FYam Frequency Number Justification Request Positico PI,S B2103FO16 Nluclear Bailer (NB) Main Steam Line Drain Line Inboard DIVISION N/A Primary Cantajinnent (PC) Isolation Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail TYpe TYpe Passive P~ositioni Position I A 3 Gate MOV A Closed Closed As-is AT- I OB 43.401.302 AT-4 OB 43,401.51 1 BTC CS 24.137.18 CSJ-018 GL9605 GP 47.306.01 / .03 PIT 2Y 24.137.18 PIS B2103FO19 Nuclear Bailer (NB)1 Main Steam Line Drain Line Outboard DIVISION N/A Primary Cantainnient(PC) Isalatian Valve.

Cjlass Cat Size V'alve Actuator Active / Normal Position Safety Fail Type Type Passive -Position Position 1 A 3 Gate MOV A Closed Closed As-Is AT- I OB 43,401.302 AT-4 OB 43.401.511 BTC CS 24.137.18 CSJ-018 GL9605 GP 47.306.01 /.03 PIT 2Y 24.137.18 PIS B2103FO22A Nuclear Bailer (NB) Main Steam Line "A" Ibaard Primary DIVISION N/A Cantainment (PC)Isolation Valve.

Class Cat Size Valve. Actuator Active / -Normal Position Safetv Fail Type Ty'pe Passive Position. Position I A 26 Globe- AG A Open Closed Closed AT-9 GB 43.401.500 BTC CS 24.137.03 CSJ-006 BTP OP 24.137.01 FST .CS 24.137.03 PIT ZY 24.137.03 Page 1 of 4 For. System: B2103

DTE ENERGY - FERiVII 2 ISI / IST Proaram Plan - Part 5 Valve Scope Table' Sse: B 13Test Procedure Deferred Relief Technical Sse: 213Exam Frequency' Number Justification Request Position PIS B2103FO22B Nuclear Boiler (NB) Main Steam Line "B" Inboard Primary DIVISION N/A Containment (PC) Isolation Valve.

Class Cat Size Valve Actuator Active / Norinal Position Safetv Fail Type Type Passive Position Position I A 26 Globe AO A Open Closed Closed AT-9 OB 43.401.500 BTC CS 24:137,03 CSJ-006 BTP OP, 24.137.01 FST CS 24.137.03 PIT 2Y 24.137.03 PIS B2103FO22C Nuclear Boiler (NB) Main Steam Line "C" Inboard Primaly IVnISION N/A Containment (PC) Isolation Valve.

Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type Type Passive Positio n Position I A 26 Globe AO A Open Closed Closed AT-9 OB 43.401.500 BTC CS 24.137.03 CSJ-006 BTP OP 24.137.01 FST CS 24.137.03 PIT 2Y 24.137.03 PIS B2103FO22D Nuclear Boiler (NB) Main Steam Line "D" Inboard Primary DIVISION .N/A Containment (PC) Isolation Valve.

Class Cat Size V'alve Actuator Active! Normal Position Safety Fail "I'pe Type Passive Position Position I A 26 Globe AO A Open Closed Closed AT-9 OB 43.401.500 BTC CS 24.137.03 CSJ-006 BTP OP 24.137.01 FST CS 24.137.03 PIT 2Y 24.137.03 Page 2 of 4 F~or System: B2103

DTE ENERGY - FERMVI 2 ISI / 1ST Program Plan - Part 5 Valve Scope Table System: B2103 Exatn Test Frequency Procedure Number Deferred Justification Relief Request Technical Position PIS B2103FO28A Nuclear Boiler (NVB)Maini Steanti Lirie "A" Outboard Primary' D)IVISION N/A Containment (PC) Isolation Valve.

Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position I A 26 Globe AO A Open Closed Closed AT-9 OB 43.401.500 BTC CS 24.137.03 CSJ-006 BTP OP 24.137.01 FST CS 24.137.03 PIT 2Y 24.137.03 PIS B2103FO28B Nuclear Boiler (NB) Main Steamt Line "B" Outboard Primiary D)IVISION N'/A Containment (PC) Isolation Valve.

Class Cat Size Valve Actuator Active / Normal Position Sart'et Fail

-Type Type P'assive .Position Position I A 26 Globe AO A Open Closed Closed AT-9 OB 43.401.500 BTC CS 24.137.03 CSJ-006 BTP OP 24.137.01 FST CS 24.137.03 PIT 2Y 24.137.03 PIS B2103FO28C Nuclear Boiler (NB) Main Steam Line "C" Outboard DIVISION N/A Primary Containment (PC) Isolation Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 1 A 26 Globe AO A Open Closed Closed AT-9 OB .43.401.500 BTC CS 24.137.03 CSJ-006 BTP OP. 24.137.01 FST CS 24.137.03 PIT 2Y 24.137.03 Page 3 of 4 For System: B2103

DTE ENERGY - FERNI2 ISI/1ST .ProjgramPlan - Part 5 Valve Scope Table Sse: B 13Test Procedure Deterredl Relief Technical Sse: B 13Exam Frequency Number Justification Request Position PIS B2103FO28D Nuclear Boiler (NB) Main Steam Line "D" Outboard DIVISION N/A Prinmay Containmnent (PC) Isolation Valve.

Class Cnt Size Valve Actuator Active / Normal P'ositionl Safe"t) Fail Ty pe Type Passive Position P'osition I A 26 Globe AO A Open Closed Closed AT-9 OB 43.401.500 BTC CS 24. 137.03 CSJ-006 BTP . OP 24.137.01 FST CS 24.137.03 PIT 2Y- 24.137.03 Page 4 of 4 Foi- System: B2103

DTE ENERGY -FERI I2 1SI1/IST Program Plan - Part 5 Valve Scope Table Syte : B2 04Tst Procedure Deferred Relief TIechnical Ssm: B14Exam Frequency Number Justification Request Position PIS B2104F013A Nuclear Boiler (NB) Main Steam Line "D" Relief Valve.

D)IVISION N/A Class Cat Size Valve, Actuator Active / Normal Position -Safety Fail Tv pe Ty pe Passive l'Positio n Position I C 6 SRV SA Pilot A Closed Both CT-SP 5Y 43.137.001 PIS B2104F013B Nuclear Bailer (NB) Main Steam Line "C" Relief Valve DI1VISION. N/A .

Class Cat Size Valve Actuator Active / Normal Position Salety Fail Type Type Passive Position Position" 1 C 6 SRV SA Pilot A Closed Both -

CT-SP 5Y 43,137,001 PIS5 B2104F013C Nuclear Boiler (NB) Main Sleanm Line 'B" Relief Valve..

D)IVISION N/A Class Cat Size Valve Actuator Active! Normal P'osition Safetvy Fail Type Type Passive Position Position I C 6 SRV SA Pilot A Closed Both CT-SP 5Y 43.137.001 PIS B32104F013D Nuclear Boiler (NB) Main Steam Line "B" Relief/Valve. l)

DIVI' SION N/A ReliefRe quest VRR-008.

Class Cat Size Valve Actuator Active / Normal Position Sareoy Fail Type Type Passive Position Position I C 6 SRV SA Pilot A. Closed Both CT-SP. 5Y 43.137.001 PIS B2104F013E Nuclear-Boiler (NB) Main Stearn Line "C" Relief Valve.

D)IVISION N/A Class -Cal Size Valve Actuator :Active / Normal Position Safet1 Fail Type _Type Passive Position Position

-1 B/C 6 SRV SA Pilot A Closed Both BIG RR 24.137.11 CT-SP 5Y 43.137:001 Page 1 of 3 For System: B2104

DTE ENERGY - FERMVIi2 ISI /IST Pro2ram Plan - Part 5 Valve Scope Table Sse : B 14Test Procedure Deferredl Relief Technical Syte: B204- Exam Frequency Number Justification Request Position PIS B2104FO13F Nuclear Boiler (NB) Main Steam Line "B" Relief Valve.

DIVISION N/A Class Cat Size Valve Actuator Active / Normal Positioni Safety Fail Type Type Passive Position Position, I C 6 SRV SA Pilot A Closed Both CT-SP 5Y 43.137.001 PIS B2104FO13G Nuclear Bailer (NB) Main Steam Line "B" Relief Valve.

D)IVISION N/A

(:lass Cat Size Valve Actuator Active / Normal Position Sarety Fail Type Type Passive Position P'osition I C 6 SRV SA Pilot A Closed Both CT-SP 5Y 43.137.001 PIS B2104FO13H Nuclear Boiler (NB) Main Steams Line "C" Relief Valve.

D)IVISION N/A C:lass Cat Size V'alve Actuator Active / Nor-mal Position Safety Fa il Type Tcpre Passive Position Position I B/C 6 SRV SA Pilot A Closed Both BTO RR 24.137.11 CT-SP 5Y 43.137.001 PIS B2104FO13J Nuclear Boiler (NB) Main Steam Line "C" Relief Valve.

D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I B/C 6 SRV SA Pilot A Closed Both BTO RR 24.137.11

• CT-SP 5Y 43.137.001 PIS B2104FO13K Nuclear Boiler (NB) Main Steam Line "B" Relief Valve.

D)IVISION N/A Class Cat Siz.e Valve Actuator Active / Normal Position Safety Fail Type Type Passive Po'si tioni Posi tion I C 6 SRV SA Pilot A Closed Both

• CT-SP 5Y 43.137.001 Page 2 of 3 For System: B2104.

DTE ENERGY - FERMI 2 ISI / IST Pr62ram Plan - Part 5 Valve Scope Table Sytm:r10 est Procedure Deferred Relief Technical Exalm Frequency Number Justification. Request Position PIS B2104FO13L Nuclear Boiler (NB) Main Stearn Line "A" Relief Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety F'ail Type Type Passive Position Position I C 6 SRV SA Pilot A Closed Both CT-SP 5Y 43.137.001 PIS B2104F013M Nuclear Boiler (NB) Main Steamt Line "A" Relief Valve.

D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type T}pe Passive Position Position I C 6 SRV SA Pilot A Closed Both CT-SP 5Y 43.137.001 PIS B2104FO13N Nuclear Boiler (NB) Maint Steam Line "A" Relief Valve D)IVISION N/A Class (Cat Size Valve Actuator Active!/ Norinal P'ositioni Safety Fa il Type Type Passive P Iosition Posi tioni I C 6 SRV SA Pilot A Closed Both CT-SP 5Y 43.137.001 PIS B2104F013P Nuclear Boiler (NB) Main Steanm Line "D" Relief Valvye.

D)IVISION N/A C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 1 B/C 6 SRV SA Pilot A Closed Both BTO RR 24.137.11 CT-SP 5Y 43.137.001 PIS B2104F013R .Nuclear Boiler (NB) Maint Stean Line "C" Relief Valve.

DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Sarety Fail iypc . Type Passive P'ositioni Position I B/C 6 SRV SA Pilot A. Closed Both BTO RR 24.137.11 CT-SP 5Y 43-137.001 Page 3. of 3 For System: B2104 C

DTE ENERGY - FERMI 2 ISI1 I1ST Programn Plan - Part 5 Valve Scope Table System: B3100 Exam Tcest Frequency Procedure Number Deferred Justification Relief-Request Technical Position B310O014A... _.. Rx Recirc Control PIS Rod Drive (CRD) Supply to Div. I Inboard DIVISION I Seal Cavity Inboard Cont.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 3/4 Globe AO A Open Closed Closed AT-I OB 43.401.361 BTC CS 24. 138.02 CSJ-007 FST CS 24.138.02

-__-.-- __-PIT 2Y . 24.138.02------

PIS B310O014B Rx Recirc Control Rod Drive (CRD) Supply to Div. II DIVISION 2 -Inboard Seal Cavity Inboard Con Class . Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive - Position Position 2 A 3/4 Globe AO A Open Closed IClosed AT-I OB 43.401.360 BTC CS 24.138.02 CSJ-007

- FST CS 24.138.02 PIT 2Y - 24.138.02 PIS B3100F016A Rx Recirc Control Rod Drive (CRD) Supply to Div. I Inboar d DIVISION 2 Seal Cavity Outboard Cont. Isol. Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety - Fail Type Type Passive Position P~ositioni 2 A 3/4 Globe AO A Open Closed Closed AT-I GB 43.401.361 BTC CS 24.138.02 CSJ-007 FST CS 24.138.02

• PIT 2Y 24.138.02 Page 1 of 7 For System: B3100

DTE ENERGY - FERMI 2 ISI/IST Pr6gram Plan - Part 5 Yalve Scope Table Sysem B3100 Test 'Proceduire Deferred Relief Technical Exam Frequency Number - Justification Request. Position PIS B310O016B Rx Recirc Control Rod Drive (CRD) Supply to Div. II DIVISION N/A Iniboard Seal Cavity Outboard Con Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive _Position Position 2 A 3/4 Globe AO A Open Closed Closed AT-1 0B 43.401.360 BTC CS 24.138.02 CSJ-007 FST CS 24.138.02 PIT 2Y 24.138.02 PIS B310OF019. Rx.Recirc Reactor Water Samtple Line Inboard Cont. Isol.

D)IVISION N/A Valve:

Class Cat Size Valve Actuator Activ'e/ Normal Position Safety Fail Type Type Passive Position Position I A 3/4 Globe AO A Keylocked Closed Closed Closed AT-I .OB 43.401.330 BTC OP 24.138.04/.02 FST OP 24.138.04/.02 PIT 2Y 24.138.02 PIS B310OF020 Rx Recirc R eactor Water Sample Line Outboard Cont. IsolI.

DI1VISION N/A Valve:

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type' Type Passive, Position .Position 1 A 3/4 Globe AO A; Keylocked Closed Closed Closed AT-I 08 43.401.330 BTC OP 24.138.04/.02 FST OP 24.138.04/.02 PIT 2Y 24.138.02 PIS B31F501A Recirc Pump Discharge B3101C0001B Header FeederLine DIVISION I Division I Excess Flow Chseck Valve Class Cat Size Valve Actuator Active / Normsal Position Safety Fail Type Type Passive Position Position I A/C' 1 XFC Self Act A Open Closed

• CT-EF SPI 44.220.115 VRR=01.1

• PIT SPI 44.220.115 VRR-011 Page 2 of 7 For System: B3100

DTE ENERGY - FERMI 2 ISI /I ST Program Plan - Part 5 Valve Scope Table Relief Technical Sse: B 10Test Procedure Deferred

______Exam Frequency Number Justification Request. Position PIS B31F501B Recirc Pump Discharge B3101JCO01B Header Feeder Line DIVISION 2 Div HI Excess Flow Check Valve Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive -Position Position I A/C I XFC Self Act A Open - Closed CT-EF SPI 44.220.114 VRR-011 PIT SPI" 44.220.114 VRR-0II PIS B31F501C Recirc Pump Discharge B3101JCOO]B Header FeederLine DIVISION I - Division I Excess Flow Check Valve Class Cat Size Valve Actuator Active / Normial Position Safety Fail Type Type Passive -Position Position I A/C I XFC Self Act A -Open Closed CT-EF SPI 44.220.115 - VRR-011

- _-PIT SPI- 44.220.115 VRR-011 PIS B31F501D Recirc Pump Disc/harge B3101JCOO]B Header Feeder Line D)IVISItON 2 Div HI Excess Flow Check Valve Class- Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act - A Open Closed CT-EF SPI 44.220.114 VRR-0 11 PIT SPI - 44.220.114 VRR-0l .I-PIS B31F502A Recirc Pump Discharge B31OJCOOJA Header Feeder Line DIVISION I Division I Excess Flow Check Valve

-Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI - 44.220.115 VRR-0II PIT SPI 44.220.115 VRR-0II PIS B31F502B Recirc Pump Discharge B3JOJ COOIA Header Feeder Line DIVISION 2 " Div II Excess Flow Check Valve -

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed -

CT-EF SPI 44.220.114 - VRR-0l1 PIT SPI 44.220.114 VRR-011 Page 3 of 7 For System: B3100

DTE ENERGY - FERMI 2 ISI /1ST Pmigam Plan Part 5 Valve Scope Table Sse : B 10Test Procedure Deferred Relief Technical Exam Frequency Numbper Justification Request Position PIS B31F502C Recirc Pump Discharge B3101 COOIA Header FeederLine DIVISION 1 Division I Excess Flow Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive :Position Position I A/C I XFC Self Act A Open Closed CT-EF SP I 44.220.115 VRR-0ll1 PIT SPI 44.220.115 VRR-0l1 PIS B31F502D Recirc Pump Discharge B3101]COOI]A Header Feeder Line DIVISION 2 Div II Excess Flow Check Valve Class Cat Size Valve Actuator Active/I Nornmal Position Safety Fail Type Type Passive .Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.114 VRR-011 PIT SPI 44.220.114 VRR-0II PIS B31F503A. Recirc Punip Discharge B3101 COOJA Excess Flow Check DIVISION I Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44,220.110 VRR-011 PIT SPI 44.220.110 VRR-0ll1 PIS B31F503B Recirc Pump Discharge B3101CO01B Excess Flow Check Class. Cat Size Valve Actuator Active!/ Normal Position .Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.110 VRR-011 PIT SPI 44.220.110 VRR-011 PIS B31F504A Recirc Pump Discharge B31O000]A Excess'Flow Check DIVISION I Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 1 A/C I XFC Self Act A Open Closed

• CT-EF SPI 44.220.110 VRR-01I

-PIT . . SPL 44.220.110 VRR-0Il Page 4 of 7 For System: B3100

DTE ENERGY - FERMI 2 ISI/ IST Program Plan - Part 5 Valve Scope Table Test Procedure Deferred Relief Technical System_B310 Exam Frequency Number justification Request Position PIS B31F504B Recirc Pump Discharge B31O1COO1B Excess Flow Check DIVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.110 VRR-01 I PIT SPI 44.220.110 VRR-01l PIS B31F505A Recirc Pump Discharge B3101JCOOIA Excess Flow Check DIVISION I - Valve Class Cat Size Valve Actuator Active / Normial Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.110 VRR-0II PIT SPI 44.220.110 VRR-0ll PIS B31F505B - Recirc Pump)Discharge B3101CO01B Excess Flow Check D)IVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Trype Type Passive - Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.110 VRR-01I PIT SPI 44.220.110 VRR-011 PIS B31F506A Recirc Pump Discharge B3101JCOOJ]A Excess Flow Check DIVISION I Valve Class Cat Size Valve Actuator Active / Normal Position Safely Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.110 VRR-01I PIT SPI 44.220.110 VRR-011 PIS B31F506B Recirc Pump Discharge B310lCOO1B Excess Flow Check DIVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position- Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.113 VRR-011 PIT SPI 44.220.113 .VRR-01l Page 5 of 7 For System: B3100

DTE ENERGY - FERMI 2 ISI I IST Proaram Plan - Part 5 Valve Scope Table System: B3100 "Exam Test Frequency Procedure, Number Deferred justificatiou Relief Request Technical Position PIS B31F510A Reactor Recirculation System (RRS) Pump B3101JC001A DIVISION ISuction Line Excess Flow Check Valve.

Class Cat Size 'Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 1' A/C I XFC -Self Act A Open Closed CT-EF SPI 44.220.113 VRR-011 PIT SPI 44.220.113 VRR-01I P15 B31F510B Reactor Recirculation System (RRS) Pump B3101JC001B DIVISION 2 Suction Line Excess Flow Check Valve.

-Class. Cat Size Valve Actuator. Active /. Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF . SPI 44.220.114 VRR-01I PIT SPI 44.220.114 VRR-011 PIS B31F511A Recirc Pump Discharge B3101JC001A Excess Flow Check DILVISION I Valve Class Cat Size Valve Actuator Active / Nornnal PIosition Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI1 44.220.113 VRR-0 11 PIT SPI 44.220.113 VRR-0II PIS B31F51.1B Recirc Pump DischargeB3101]C001B Excess Flow Check DIVISION 2 Valve Class Cat Size Valve Actuator Active/ Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.114 VRR-0II PIT SPI 44.220.114 VRR=011 PIS B31F512A .Recirc Pump DischargeB3101C00JA Excess Flow Chteck DIVISION I Valve.

C:lass Cat Size Valve Actuator Active/, Normal Position Safety Fail

- Type Type Passive, Position Position I A/C 1I XFC Self Act A Open Closed CT-EF SPI 44.220.113 VRR-01I PIT SPI 44.220.113 . VRR-011 Page 6 of 7. For System: B3100

DTE ENERGY - FERMI 2 ISI!/ ST Proaram Plan - Part 5 Valve Scope Table Trest Procedure Deferred Relief Technuc5il System: B3100 Exam Frequency Number JsiiainRqet Psto PIS B31F512B Recirc Pump Discharge B3JOJCOOIB Excess Flow Check DI VISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SRIl 44.220.1 14 VRR-01 1 PIT SPI 44.220.114 VRR-01 1 PI1S B31F515A RecircPump B3101]COOIA Seal Cavity No. 2 Excess Flow DIVISION I Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.113 VRR-01I PIT SPI 44.220.113 VRR-011 PIS B31F515B Recirc Pump B3101ICOOIJB Seal Cavity No.]I Excess Flow D)IVISION 2 Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SP I 44.220.1 14 .VRR-61 I PIT SPI 44.220.114 VRR-0l 1 PIS B31F516A Recirc Pump B3101JCOOIA Seal Cavity No. 1 Excess Flow DIVISION ICheck Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.113 VRR-01 I PIT SPI 44.220.113 VRR-011 B31F516B RecircPump P B31O1CO0lB

__._............._ ..... Seal Cavity No.1 Excess Flow DIVISION 2 Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I - XFC Self Act A Open Closed CT-EF S PI 44.220.1 14 VRR-01 1 PIT SPI 44.220.114 VRR-011 Page 7 of 7 For System: B3100

DTE ENERGY - FERMI 2 ISI / IST Program Plan - Part 5 Valve Scope Table System: B3105 Exam Test Frequency Procedurc Number Deferred Justification Relief Rcquest Technical Position PIS B3105FO31A Rx Recirc Recirculation Pump "A" Discharge Valve.

DIVISION I Class Cat Size Valve Actuator Active!I Normal Position Safety Fail Type Type Passive Position Position I B 28 Gate MOv A Open Closed As-Is BTC CS 24.138.02 CSJ-008 GL9605 GP 47.306.01 / .03 PIT 2Y 24.138.02 P15 B3105FO31B Rx Recirc RecirculationPump "B"Discharge Valve.

DIVISION 2 Class Cat Size Valve Actuator Active / Normal Positioni Safety Fail Type Type Passive Position Position I .B 28 Gate MOv A Open Closed As-Is' BTC CS 24.138.02 CSJ-008 GL9605 GP 47.306.01 /.03 PIT 2Y 24.138.02 Page 1 of 1 For System: B3105

DTE ENERGY - FERIVII 2 ISI /IST Prouram Plan - Part 5 Valve Scope Table Sse : C1 Test Procedure Deferred Relief Technical Sse: C10Exam Frequency Number Justification Request Position PIS TC1100F010 Control Rod Drive (CRD) Scram Discharge Volume Vent D)IVISION N/A Valve Class Cat Size Valve Actuitor Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Globe AO A Open Closed Closed AT-I OB 43.401.355 BTC OP 24.106.04 FST OP 24.106.04 PIT 2Y 24.106.04 PIS C1100FOll Conitrol Rod Drive (CRD)I Scram Discharge Header Clean DIVISION N/A Radwaste (CRW) Dramn Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Typ)e Type Passive P'osilion Position 2 A 2 Globe AG A Gpen Closed. Closed AT-i GB 43.401.355

.BTC OP 24.106.04 FST GP -24.106.04 PIT. 2Y 24.106.04 PIS C110OF180 Control Rod Drive (CRD) Scram Discharge Volume Vent DIVISION N/A Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fa~il Type Type Passive Position P'osition 2 A I Globe AO A Open Closed Closed AT-I GB 43.401.355 BTC OP 24.106.04 FST OP 24.1 06.04 PIT' 2Y 24.106.04 Page 1 of 2 For System: C1100

DTE ENERGY - FERMvII2 ISI/1IST Proaramn Plan - Part 5 Valve Scope Table Sse: C 10Test Procedure Deferred Relief Technical Sytm C10Exam Frequency Number Justification Request Position PIS C110OF181 Control Rod Drive (CRD) Scranm Discharge Volume to Torus DI1VISION N/A Room Suip D065 Draiu Valve Class Cat Size Valve Actuator Active / Normal lPosition Safety Fail Type Type Passive Position Position 2 A 2 Globe AO A Open. Closed Closed AT-iI 0O 43.401.355 BTC OP 24.106.04 FST OP 24.106.04 PIT 2Y 24.106.04 Page 2 of'2 For Systetn: C1100

DTE ENERGY - FERVI 2 ISI / IST Propramn Plan - Part 5 Valve Scope Table Sse : C 1 3Test Procedure Deferred Relief Technical Sytm:F10 xam Frequency Number. Justitication Request Position PIS C1103F114 Control Rod Drive (CRD) Scram Discharge Riser Check D)IVISION N/A Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety -Fail Type Type Passive Position Position 2 C 3/4 CK Self Act A System Dependent Open CT-0 SP2 54.000.03 PIS C1103F115 Control Rod Drive (CRD) Accumulator Water Check Valve.

D)IVISION N/A C:lass C:at Size Valve Actuator Active / Normal Position Safetv Fail Type Type Passive Position Position 2 C 1/2 CK Self Act A System Dependent Closed CT-C RR 24.106.08 ROMJ0 CT-OL- OL N/A TP-01 PIS C1103F126 Control Rod Drive ('CRD) Hydraulic System Inlet Scram DIVISION N/A Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type -Type Passive Position P'osition 2 -B 1/2 Globe AD A Closed Open Open BTO SP2 54.000.03 FST SP2 54.000.03 a"PIS C1103F127 Control Rod Drive (CRD) Hydraulic System Outlet Scram D)IVISION N/A Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 B 3/4' Globe AD A Closed Open Open BTO SP2 -54.000.03 FST. SP2 54.000.03 PIS C1103F138 Control Rod Drive (CRD) Hydraulic System Cooling Water D)IVISION N/A C'heck Valve. "

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 -C 1/2 CK Self Act A System Dependent Closed CT-C OP 24.106.01 Page 1 of 1 For System: C1103

DIE ENERGY - FERMI 2 ISI / IST Pro2ram Plan - Part 5 Valve Scope Table System:' C4100 Test Procedutre Deferred Relief Technical

_______Exam Frequency Number Justification Request Position PIS C4100F006 Standby Liquid Control (SLC,) Outboard Check Valve ('OCIV)l.

D)IVISION N/A Class Cat Size Valve Actuator Active I Normal P'osition Safety Fail Type Type Passive Position Position I A/C 1 1/2 CK Self Act A System Dependent Both AT- I GB 43.401:347 CT-C GB 43.401.347 CMP-02 CT-O RR 24.139.03 PIT 2Y 24.139.03 PIS C4100F007 Standby Liquid Control ('SLC.) Inboard Check Valve (ICIV).

D)IVISION N/A Class Cat Size Valve Actuator_ Active / Normal Position Safety Fail Type Type Passive Position Position I A/C 1 1/2 CK Self Act A System Depenident Both AT-I OB 43.401.347 CT-C GB 43.401.347 CMP-02 CT-O RR 24.139.03 PIS C41 0OF029A Standby Liquid Control (SLG,) PtunP "A" Discharge Pressure D)IVISION IRelief Valve.

Class Cat Size Valve Actuator Act! ve / Normal Position Safety _Fail Type Type Passive Position Position 2 C I RLF SelfAct A Closed Open CT-SP MOY 43.000.020 PIS C410OF029B Standby Liquid Control (SLC) Pumtp "B" Discharge Pressure D)IVISION 2 Relief Valve.

Class Cat Size Valve A'ctuator Active/I Normal Position Safety Fail Type Type Passive P'osition Position 2 C.. I RLF, - Self.Act A Closed open CT-SP I0Y 43.000.020 iPage. 1-of 2 Fof Systein: C4100

DTE ENERGY - FERMI 2 1SI/IST Program Plan - Part 5 Valve Scope Table System: C4100 Test Procedure Deferred Relief Technical

______Exam Frequency Number Justification Request -Position PIS C410OF033A Standby Liquid Control (SLQ Pump "A" Dischage Check DIVISION I Valve.

Class Cat Size Vilve Actuator Active / -Normal Position Safety Faill Type Typc Passive Position Position 2 C 2 CK Self Act A System Dependent Both CT-C RR 43.401.709 ROM-018 CT-0 OP 24.139.02 PIS C410OF033B Standby Liquid Control ('SLQ)Pump "B" DischargeCiheck DIVISION 2 Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail rType Type Passive Position P~ositin 2 C .2 CK Self Act A System Dependent Both CT-C RR . 43.401.709 ROJ-018 CT-0 OP 24.139.02 Page 2 of 2 For .Syste n: C4100

DTE ENERGY - FERMI 2 ISI / IST Program-Plan - Part 5 Valve Scope Table System: C4104 ______Exam Trest Frequency Procedure Numnber Deferred Justification

-Relief Request Technical Position PIS C4104FO04A Standby Liquid Control (SLC) Explosive (Squib) Valve.

DIVISION 1 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 D 1 1/2 Gate EXP A Keylocked Closed Open -

DT 3Y 24.139.03 PIS C4104FO04B Standby Liquid Control (SLC) Explosive (Squib) Valve.

DIVISION 2 .

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 D 1 1/2 Gate EXP A Keylocked Closed Open i DT 3Y 24.139.03 Page 1 of 1 For System: C4104

DTE ENERGY - FERMI 2 ISI/1IST Proaram Plan - Part 5 Valve Scope Table System: C50 Test Procedure Defer-reti Relief Technical Examn Frequency Number Justification Request Position PIS C510O001A TIP Channel A S/hear Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type Type Passive Position Position 2 D 3/8 Shear EXP A Open Closed DT 5Y 43.606.001 PIS C5100FOOIB TIP Chta,nel B S/hear Valve D)IVISION N/A Class Cat Size Valve Actuator Active! Normtal Position Safetv Fail Type Type Passive Position Position 2 D 3/8 Shear EXP A Open Closed DT 5Y 43.606.001 PIS C5100FOOIC TIP Chann,el CS/tear Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 D 3/8 Shear EXP A Open Closed DT 5Y 43.606.001 PIS C5100FOOID TIP Channel D S/hear Valve D)IVISION N/A Class C:at Size Valve Actuator Active / Normal Position Sarety Fail Type Type Passive Position Position 2 D 3/8 , Shear EXP . A Open Closed DT 5Y 43.666.001 PIS C5100FOOlE TIP Chiannel ES/tear Valve DI1VISION N/A C:lass Cat Size Valve Actuator Active / Normal Position Safetv Fa il Type .Type Passive Position Position 2 D 3/8 Shear EXP A Open Closed DT 5Y 43.606.001 Page 1 of 3 For System: C5100

DTE ENERGY - FERI 2 ISIJ/1.ST Pro2ram Plan - Part 5 Valve Scope Table Sytm C50 est Procedure Deferred Relief Technical Sse: 510-Examn Frequency Number Justification Request Position PIS C510O002A TIP ChzannelA, Ball Valve D)IVISION N/A Class C:at Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P~osition 2 A 3/8 Ball SOV A Closed Closed Closed AT-I OB 43.401.338 BTC OP 24.606.01 FST OP 24.606.01 PIT GB 43.401.338 VRR-012 PIS C5100F002B 'TIP Channel B Ball Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type Type Passive Position Position 2 A .3/8- Ball SOV A Closed Closed Closed AT-I GB 43.401.337 BTC OP 24.606.01 FST OP 24.606.01 PIT GB 43.401.337 VRR-012 PIS C510O002C TIP Chtannel C Ball Valve DIVISION N/A Clas,s Cat Sizc Valve Actuator Active / Normal Position Salety Fail Type Th'pe , Passive Position Position 2 A 3/8 Ball .SOV A Closed Closed Closed AT-I GB 43.401.339

.BTC OP 24.606.01 FST OP 24.606.01 PIT OB 43.401.339 VRR-012

-Page 2 of 3 For Systemi: C5100

DIE ENERGY - FERMI 2 1S1 / 1ST ProjZ!am Plani - Part 5 Valve Scope Table System: C5100 Ezant Test Frequency Procedure Number Deferred

,Justification

-Relief Technical Request 'Position PIS C510O002D TIP Channel D Bail Valve D)IVISION N/A Class Cat Size Valve Actuator Active I Normal Position Safety Fail Type Type Passive Position P'ositionf 2 A 3/8 Ball SOy A Closed Closed Closed AT- I OB 43.401.341 BTC OP 24.606.01 FST OP 24.606.01 PIT .GB 43.401.341 VRR-012 PIS C510O002E TIP Channel £ Ball Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P~osition 2 A 3/8 Ball SOV A Closed Closed Closed AT-I GB 43.401.340 BTC OP 24.606.01 FST OP 24.606.01 PIT GB 43.401.340 VRR-012 Page 3 of 3 For System: C5100

DTE ENERGY - FERMI 2 ISI /I1ST Pro2r'am Plan - Part 5 Valve Scope Table est

'ytmFE10 Procedure Deferred Relief Trechnical E1 0Exain Sse: Frequency Number JIustification Request Position PIS E1100F001A RHR Div. I Heat Exchanger A Thermal Relief Valve.

DIVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive. Position P'osition 2 C 1/2 TRel Self Act A Closed Both CT-SP IOY 43.000.020 PIS E110O001B RHR Div. IHHeat Exchanger B Thermal Relief Val D)IVISION 2 Class Cal Size Valve Actuator Active / Normal Position Sarety Fail Type *Type Passive Position Position 2 C 1/2 TReI Self Act A Closed Both CT-SP MOY 43.000.020 PIS E110O020A RHR Div. I Heat Exchanger A4Service Water Return Check D)IVISION 1 Valve.

Class Cat Size Valve Actuator Active / Norinal Position, Safety . Fail Type Type Passive Position Position 3 C* 24 CK Self Act A System Dependent Openi CT-Dl 4R 43.000.010 CMP-01 CT-0 OP 24.205.05 PIS E110O020B RHR Div. HI Heat Exchanger B Service Water Return Check D)IVISION 2 Valve.

C;lass Cat Size Valve Actuator Active / Norinal P'ositioni Safety Fail Type Type Passive Position Position 3 C 24 CK. Self Act A System Dependent Open CT-DI 4R 43.000.010 CMP-01 CT-0 OP 24.205.06 PIS E110O025A RHR Div. I H-eat ExchiangerA Outlet Line Relief Valve.

OIVSION 1 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 1 1/2 RLF Self Act - A Closed Both CT-SP- lOY 43.000.020 Page 1 of 10 For System: E1100

DTE ENERGY - FERMI 2 ISI /IST Program Plan - Part 5 Valve Scope Table Test Procedure Deferred Relief Technical System_E110 Exam Frequency Number Justification Request Position PIS E110O025B RHR Div. H Heat ExclhangerB Outlet Line Relief Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type Type Passive Position Position 2 C 1 1/2 RLF Self Act A Closed Both CT-SP 10Y 43.000.020 PIS E110OF029 RHR Shutdown Cooling Relief Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C I RLF Self Act A Closed Both CT-SP MOY 43.000.020 PIS E110O030A RHR Div. I Punmp A Suppression Pool Suction.Line Relief D)IVISION I Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P'osition 2 C I TReI Self Act A Closed Both CT-SP 10Y 43.000.020 PIS E110O030B RH-R Div. HiP up B Suppression Pool Suction Line Relief D)IVISION 2 Valve.

C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C I TReI Self Act A Closed Both CT-SP 1OY 43.000.020 PIS E110O030C RHR Div. Jpump -CSuppression Pool Suction Line Relief D)IVISION I Valve.

Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type Type Passive Position Position 2 C I TReI Self Act A Closed Both CT-SP joy 43.000.020 PIS E110O030D RHR Div. HI pump D Suppression Pool Suction Line Relief DIVISION 2 Valve.

Class Cat Size Valve Actuator Active / Normal Positiotn Safety Fa il Type Type Passive Position Position 2 C I TReI Self Act A Closed Both CT-SP joY 43.000.020 Page 2 of 10 .Foi-System: E1100

EDTE ENERGY - FERMI 2 ISI /IST Program Plan - Part 5 Valve Scope Table Sytm E 1OTest Procedu re Deferred Relief Technical Syte: liOExam Frequency Number- Justification Request Position PIS E110O031A RHR Div. IJPumip A Discharge Check Valve.

DIVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail

'Type Type Passive Position Position 2 C 20 CK Self Act A System Dependent Both CT-C ' OP 24.204.01 CT-O OP 24.204.01 PIS E110O031B RIHR Div. II Pump B Discharge Check Valve.

DIVISION 2 Class - Cat Size Valve Actuator Active / Normal Position Safety Fail

'Type Type Passive P'osition Position 2 C 20 CK Self Act A System Dependent Both CT-C OP 24.204.06 CT-O OP 24-204.06 PIS E1100F031C RIHR Div. I Piup C Discharge Check Valve.

D)IVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Typse Type Passive Position P~ositioni 2 C 20 CK Self Act A System Dependent Both CT-C OP 24.204.01 CT-O OP 24.204.01 PIS E110O031D RHR Div. 1I Pump D Discharge Check Valve.

DIVISION 2 Class Cat Size Valve Actuator Active / :Normal Position Safety Fail Type Type Passive Position Position 2 C 20 CK Self Act A System Dependent Both CT-C OP 24.204.06 CT-O OP 24.204.06 Page 3 of 10 For Systemn: E1100

DTE ENERGY - FERMI 2 1S1 /I1ST Proj4ram Plan - Part 5 Valve Scope Table Test Procelure Deferred Relief Trechnical

_ystem:_E110 Exatn Frequency Number Justification Request Position PIS E110O046A RHR Div. / Pump A Mininuun Flow Line Check Valve.

D)IVISION 1 Class Cat Size Valve Actuator Active / Normal P'osition Safetv Fa iI Type Type Passive .Position Position 2 C 3 CK Self Act A System Dependent Both

- CT-C OP 24.204.01 CT-DI 4R 43.000.010 CMP-03 CT-OP OP 24.204.01 PIS E1 10OF046B RH-fR Div. 11 Ptump B Minintunt Flow Line Check Valve.

DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 3 CK Self Act A System Dependent Both CT-C OP 24.204.06 CT-DI 4R 43.000.010 CMP-03 CT-OP OP 24.204.06 PIS E110OF046C RHR Div. J Pump C Mininium Flow Line Check Valve.

D)IVISION I Class Cat Size Valve .Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 3 CK Self Act A System Dependent Both CT-C OP 24-204.01 CT-DI 4R 43.000.010 CMP-03 CT-OP OP 24.204.01-PIS E110OF046D RHR Div. HlPumip D Minnnan Flow Line Check Valve.

DIVtISION 2 Class Cat Size Valve Actuator Active/ Normal Position Safety Fa il Type .Type Passive Position Position 2 C 3 CK Self Act A System Dependent Both CT-C OP 24.204.06 CT-DI 4R 43.000.010 CMP-03 CT-OP OP 24.204.06 Page 4 of 10 For Svstem: E1100

DIE ENERGY - FERMI 2 I:SI I ST Program Plan - Part 5 Valve Scope Table System: E1100 Esain Test Frequency.

P1rocedure Number Deferred Jiustitication Relief" Request Technical Position-PIS E110O050A RHR Div. I Inboard Isolation Testable Check Valve.

DIVISION I Class Cat Size Valve Actuator Active / Normal P'ositioni Safety Fail Type Type Passive Position P'ositin I A/C 24 CK SA Test AGO A System Dependent Both As-Is AT-10 GB 43.401.516 VRR-013 CT-C RR 24.204.04/.05 ROJ-023 CT-O RR 24.204.04/.05 ROJ-023 PIT 2Y 24.204.05 PIS E110OF050B RHR Div.1 Inboard Isolation Testable Check Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active!/ Normal Position Safety Fail Typ)e Type _Passive' Position Position I A/C 24 CK SA Test AG A System Dependent Both AT-10 GB 43.401.516 VRR-013 CT-C RR 24.204.04/.05 ROJ-023 CT-G RR 24.204.04/.05 ROJ-023 PIT 2Y 24.204.05 PIS E110O056A RHR Div. I Heat Exchanger A to Dirty Radwaste Relief Valve.

DIVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Typ T~y pe Passive . PositinmmPosi tionn 3 C 1/2 TReI Self Act A Closed Both CT-SP IOY 43.000.020 PIS E110O056B RHR Div. 1/Heat Exchanger B to Dirty Radwaste Relief DIVISION 2 Valve.

Class Cat Size Valve Actuator .-Active/I Normal Position Salety Fail Type Type Passive Position Position 3 C 1/2 TReI Self Act . A -. Closed Both CT-SP IOY 43.000.020 Page 5 of 10 For System: E1100

DTE ENERGY - FERMVII2 I81/IST Proizram Plan - Part 5 Valve Scope Table rest Procedure Deferred Relief Technical System: E1100 ______Exam Frequency Number Justification Request Position PIS E110OF078 RHR Reactor Vessel Emergency Inyection Line Check Valve.

IVISION 2 Class Cat Size Valve Actuator Active / Normal P'ositioni Saf'ety Fnail Type Type Passive - Position Position 2 C 12 CK AO A System Dependeiit Closed Fail Closed CT-C OP 24.204.06 CT-O OP 24.204.06 PIT 2Y 24.204.06 PIS E110O079A RHR Div. I I-eat ExchangerA Process Samnple Valve.

D)IVISION I Class' Cat Size Valve Actuator ActiveI/ Normal Position Safety Fail Type Type Passive P'osition Position 2 B 1/2 Globe AO A Closed Closed Closed BTC OP 24.204.01 PIT 2Y 24.204.05 PIS E110O079B RHR? Div. 11 Heat Exchanger B Process Sample Valve.

DIVISION 2 Class Cat Size Valve' Actuator Active / Normal Position Safety Fail Type Type Passive .Position Position 2 B 1/2 Globe AO A Closed Closed Closed BTC OP 24.204.06 PIT 2Y 24.204.05 PIS E110OF089 RHR? Div. II Dentineralized Water Supply Keep Fill Chteck-DIVISION 2 Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail

_ Type Type P'assive Position Position 2 C 4 - CK Self Act A System Dependent Closed CT-C OP 24.204.06 CT-OL OL - N/A TP-0I Page 6 of 10 For System: E1100

DTE ENERGY - FERMI 2 ISI / IST Pro2ram Plan - Part 5 Valve Scope Table Sytm E 10 est Proceduire Defer red Relief Technical Sytm E10Exam Frequency Number JUstificati on Request Position PIS E110OF090 RHR Div. HI Deniineralized Water Supply; Keep Fill Check DIVISION 2 Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 4 CK Self Act A System Dependent Closed CT-C OP 24.204.06 CT-OL OL N/A TP-0I PIS E110OF148A RHRSW Div. I Pump A Discharge Check Valve.

DIVISION I Class Cat Size Valve Actuator Active / Normal P'ositioni Safet Fa il Type Ty'pe Passivxe P'ositio n Posi tin 3 C 16 CK Self Act A System Dependent Both CT-C OP 24.205:05 CT-0 OP 24.205.05 PIS E110OF148B RHRSW Div. HlPump B Discharge Check Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety .Fail Type Type Passive Position Position -

3 C 16 CK Self Act A System Dependent Both CT-C OP 24.205.06 CT-0 OP 24.205.06 PIS E110OF148C RHRSW Div. I Punip C Discharge Check Valve.

D)IVISION 1 Class Cat Size Valve Actuator Active'/ Normal Position salety Fail Type Type Passive Position Position 3 C 16 CK Self Act A System Dependent Both CT-C OP 24.205.05 CT-0 OP 24.205.05 PI S Eli1OOF1 48D RHRSW Div. 11 Pump D Discharge Check Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active I Normal Position Safeth Fail Type Type Passive Position Position 3 .C 16 CK Self Act A System Dependent Both CT-C .. OP 24.205.06

.CT-0 OP 24.205.06 Page 7 of 10 For System: E1100

DTE ENERGY - F.ERMI12 181/1IST Projgram.Plan -Part 5 Valve Scope Table System: E1100 Exam-Test Frequency Procedure Number Deferred Justification Relief" Request Technical Position PIS E110OF184 RHR Div. [Demiineralized Water Supply Keep Fill Check DIVISION I Valve.

Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type Type Passive Position P'osition 2 C 2 CK 'Self Act A System Dependent Closed CT-C OP 24.204.01 CT-OL OL N/A TP-0l

-PIS E110OF185 RHR Div. / Demzineralized Water Supply Return Header DIVISION I Check Valve.

Class Cat Size Valve Actuator Active / Normal P'ositioni Sarety Fail Type , Tpe Passive P'ositioni Position~

2 C 2 CK Self Act A System Dependent Closed CT-C OP 24.204.01 CT-OL OL N/A TP-01 PIS E110OF408 RH-R Div. 11 Shutdown Cooling Bypass Check Valve.

DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position .Safety Fail Type Type Passive Position Position I A/C 3/4 CK Self Act A System Dependent Open AT-1 GB 43.401.307 CT-C 2Y 43.401.307 ROM-012 CT-O 2Y 43.401.307 ROJ-012 PIS E110OF409 RI-R Div. 1/Shutdown Coolintg Bypass Check Valve.

DfIVIS10N 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type P'assive Position Position I C 3/4 CK Self Act A . System Dependent Open CT-C 2Y 43.401.307 ROM-012 CT-O 2Y 43.401.307 ROJ-012 Page 8 of 10 Foi-System: E.1100

DTE ENERGY - FERMVI 2 151I / 1IST Pro$ram Plan - Part 5 Valve Scope Table System: .E1100 Test Proceduire Deferredi Relief Technical

_____Exam Frequency. Number Justification Request Position PIS E11F400A RHRSW Pump El151COOIA Minimum Flow Valve.

D)IVISION I Class Cat Size Valve Actuator Active! Normal Position Safety Fa il Type Type Passive Position Position 3 B 3 Globe AG - A- Closed Closed Closed BTC RR 43.401.701 . ROJ-015 FST OP 24.205.05 PIS E11F400B RHRSW Pwnp E1151CQOIB Minnuun Flow Valve.

DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Poitionm Position 3 B 3 Globe AG A Closed Closed Closed BTC R.R 43.401.702 ROJ-015 FST OP 24.205.06 PIS Eli F400C RHRSW Pump El1151COOl C Minimnnun Flow Valv'e.

D)IVISION I Class Cat Size '. Va l e Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 B3 3 Globe - AG A Closed Closed Closed BTC RR 43.401.701 ROJ-015 FST OP 24.205.05 PIS El1F400D RHRSW Pumzp E1151COOID Minimnum Flow Valve -

DIVISION_ 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail

• -- Type -Type Passive Position -Position .

3 B 3 Globe AG A. Closed .Closed Closed BTC RR -43.401.702 ROJ-015 FST OP 24.205.06 Page 9 of 10 For System: E 1100

DTE ENERGY - FERMI 2 1S1 / ST Prouram Plan - Part 5 Valve Scope Table System: E1100 Exam Test Frequency Procedure Number Deterred Justification Relief Request Technical Position PIS E11F412 RHR Div. HI Primary Containmnent Monitoring Isolation D)IVISION 2 Valve.

(lass Cat Size Valve Actuator Active / Normal P'osition- Safety Fail Type Type Passive Position Position 2 A I Globe SOV A Open Closed As-is AT- I OB 43.401.331 BTC CS, 24.204.04/.05 CSJ-009 PIT GB 43.401.331 VRR-012 PIS E11F413 RHR Div. 11 Printarl-Con,tainmnent Monitoring Isolation DIVISION 2 Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Globe SOV A Open Closed As-Is AT-I GB 43.401.332 BTC CS 24.204.04/.05 CSJ-009 PIT GB 43.401.332 VRR,012 PIS E11F414 RHR Div. I Primarv Containment Monitoring Isolation Valve.

DIVISION I Class Cat Size Valve Actuator Active / -Normal P'osition Sa lety Fail Type Type P'assive Position. Position 2 A I Globe SOV A Open Closed As-is AT-I OB .43.401.350 BTC CS 24.204.04/.05 CSJ-009 PIT GB 43.401.350 VRR-012 PIS E11F415 RHR Div. I Primatry Containment Monitoring Isolation Valve.

DIVISION .

Class Cat Size Valve Actuator Active I Normal Position Safety Fail Type Type Passive Position Position 2 A I Globe SOV - A Open . Closed As-is AT-I GB 43.401.351 BTC CS 24.204.04/.05 CSJ-009 PIT GB 43.401.351 VRR-012 Page 10 of 10 For System: E1100

DTE ENERGY - FERMI 2 ISI / IST Program Plan - Part 5 Valve Scope Table Sse: E 1OTest Procedure Deferred Relief Technical S te: E10Exam Frequency Number Justification Request Position.

PIS El115OF003A RH-R Div. I Heat ExchangerA Outlet Valve.

D)IVISION 1 Class Cat Size Valve Actuator Active / Normal'Positin Safety Fail

-Type Type P'assive Position Position 2 B 20 Gate MOV A Locked Open Open As-Is BTO OP 24.204.01

- GL9605 GP 47.306.01 / .03 PIT 2Y 24.204.05 PIS E1150F003B _ RHR Div. II Heat Exchanger Outlet Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active/I Normal Position _Safety Fail Type Type Passive P'osition Position 2 B 20 Gate MvOV A Keylocked Open Open As-Is BTO OP 24.204.06 GL9605 GP 47.306.01 / .03 PIT . 2Y 24.204.05 PIS E1150F004A RHR Div. I Puiip A Suppression Pool Suction Isola tioni Valve D)IVISION 1 (ClV).

Class Cat Size Valve Actuator. Active / Normal Position Saretv Fail Type Type Passive Positioni Position 2 B 24 Gate MOV A Keylocked Open -Both As-is BTC OP 24.204.01 BTO OP 24.204.01 GL9605 GP 47.306,01 I/.03 PIT 2Y 24.204.05 PIS El1150F004B RHR Div. 11 Pump B Suppression Pool Suction Isolation D)IVISION 2 Valve (OCIV).

Class Cat Size Valve Actuator Active!/ Normal Position Safety Fail Type..l) Type Passive . Position Position 2 B 24 Gate . MOV A Keylocked Open BRoth As-is BTC OP 24.204.06 BTO OP 24.204.06 GL9605 GP . 47.306.01 /.03 PIT 2Y 24.204.05 Pagel1of 16 For SYstemu:E1150

DTE ENERGY - FERMI12 1S I1ST Prolzram Plan IS - Part 5 Valve Scope Table Test Procedu re Deferred Relief Technical System: E1150 Eamn Frequency Number Justification Request Positkidi PIS E115OF004C RHR Div. I Pump C Suppression PoolSuction Isolation D)IVISION I Valve ('OCIV).

C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P'osition 2 B 24 Gate NMV A Keylocked Open Both As-Is BTC OP 24.204.01 BTO OP 24.204.01 GL9605 GP 47.306.01 / .03 PIT .2Y 24.204.05 PIS E1150F004D RHR Div. 11IPump D Suppression Pool Suction Isolation IVISION 2 Valve (OCI V).

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 -B 24 Gate MOV A Keylocked Open Both As-Is BTC OP 24.204.06 BTO OP 24.204.06 GL9605 GP 47.306.01 /.03 PIT 2Y 24.204.05 PIS E1150F006A RHR Div. I Pumop A Shutdown Cooling Isolationi Valve DIVISION 1 Class Cat Size Valvc Actuator Active / Normal Position Safety Fail Type "Type Passive P Iosition Position 2 B 20 Gate MOV A Closed Both As-is BTC OP 24.204.01 BTO OP 24.204.01 PIT 2Y 24.204.05 PIS E1150F006B RHR Div. II Pump B Shutdown Cooling Isolationi Valve DIVISION 2 Class Cat Size Valve Actuator Active/ Normal Position Safety Fail Type Type Passive Position Positioni 2 B 20 Gate MOV A Closed Both As-is BTC OP -24:204.06 BTO -OP 24.204.06 PIT 2Y 24.204.05 Page 2 of 16 For Systein: E1150

DTE ENERGY - FERMI 2 [SI / IST Pro2ram Plan - Part 5 Valve Scope Table Sytm 15 est Procedure Deferred Relief Technical Sytm E 10Exam Frequency Number Justification Request Position PIS E1150F006C RHR Div. I Pump C Shutdown Cooling Isolation Valve DI1VISIONI Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive P'osition Position 2 B 20 Gate MOV A Closed Both As-is BTC OP 24.204.01 BTO OP 24.204.01 PIT 2Y 24.204.05 PIS E115OF006D RHR Div. II Pump D Shutdown Cooling Isolation Valve.

DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type- Type Passive Position Position 2 B 20 Gate MvOV A Closed Both As-Is BTC OP 24.204.06 BTO OP 24.204.06 PIT -2Y 24.204.05 PIS E1150F007A RHR Dir. I Ptumps A & C Miunmunm Flow Valve.

D)IVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 B 4 Gate MIOV A Open Both As-is BTC OP 24.204.01 BTO OP 24.204.01 GL9605 GP 47.306.01 / .03.

PIT 2Y 24.204.05 PIS E1150F007B RHR Dir. II Pumps B.& D Minimum Flow Valve.

Class Cat Size Va lve Act'u ato r Act ive / Normal Posi ti on Sa fety Fail Type Type Passive P'ositioni Position 2 B 4 Gate MOV . A Open Both As-is BTC OP 24-204.06 BTO OP 24.204.06 GL9605 GP 47.306.01 / .03 PIT 2Y 24.204.05 Page 3 of 16 For System: E1150

DTE ENERGY - FERMI 2 IS8/ IST Pro2ram Plan - Part 5 Valve Scope Table Sytm:r15 est Procedure Deferred Relief Technical

_____Exam Frequency Number Justification Request Position PIS E1150F008 RHR Div. I & 11 Shutdown Cooling Outboard Cont. Isol.

D)IVISION 2 Valve.

Class Cat Size Valve Actoator Active/I Normal P'ositioni safety Fa il Type. Type Passive P'ositioni .Positionl I A 20 Gate MOV A Closed Both As-Is AT-I OB 43.401.307 AT-10 OB 43.401.512 VRR-013 BTC RR 24.204.08 ROJ-022 BTO RR 24.204.08 ROJ-022 GL9605 GP 47.306.01 / .03 PIT 2Y 24.204.08 PIS E1150F009 RHR Div. I &e/I Shutdown Cooling Inboard Cont. Isol. Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position I A 20 Gate MOV A Closed Both As-Is AT-I OB" 43.401.307

• AT-10 OB 43.401.512 VRR-013 BTC RR 24.204.08 ROJ-022 BTO RR 24.204.08 ROJ-022

• GL9605 OP 47.306.01 / .03 PIT, 2Y 24.204.08 PIS E115OF010 RH-R Div.1 Cross Tie Isolation Valve.

D)IVISION 1 Class Cat Size Valve Actuator Active / Normal P'osition Safety Fa il Type Type Passive P~ositioni Position 2 B 24 Gate M4OV P Locked Open Open As-Is PIT 2Y 24.204.08 Page 4 of 16 For Systemn:E1150

DITE ENERGY - FERMI 2 ISI / IST Pro2ram Plan - Part 5 Valve Scope Table System: E1150 "Exam Test Frequency Procedure Number Deferred Relief Justification Request Technical

.Position PIS E1150FO15A RH-R Div'. / Low Pressure Coo/ant Injection ('LP(C1) Inboard D)IVISION IIsolation Valve.

Class Cat Size Valve Actuator Active / Normal Position Safetty Fa il Ty pe.. Type Passive Position Position 1 A 24 Gate MOV A Closed Both As-is AT-10) GB 43.401.516 VRR-013 BTC RR 24.204.05 ROJ-022 BTO RR 24.204.05 .ROJ-022 GL9605 GP 47-306.01 / .03 PIT 2Y 24 204.05 PIS E1150F015B .RHR Div. 11 Low Pressure Coolant j,ectiott (LPCI) Inboard D)IVISION 2 Isolation Valve.

(lass Cat Size Va lve - Actuator Active/I Nornmal Position SaI'etp' Fail Ty'pe 'rype P'assive .Position Position I A 24 Gate MOV A Closed Both As-is rAT-10 GB . 43.401.516 VRR-013 BTC RR 24.204.05 ROJ-022 BTO RR 24.204.05 " ROJ-022 GL9605 GP 47.306.01 /.03 PIT 2Y 24.204.05 PIS E1150F016A RHR Div. I Drywell Spray Outboard Isolation Valve.

DIVISION I Class Cat Size Valve Actuator Active/ Normal Position Safetv Fail TYPe Type Passive Position Position 2 A 12 Globe M4OV A Locked Closed Both As-is AT-I GB 43.401.344

• BTC OP 24.204.01 BTO OP 24.204.01

• GL9605 GP 47-306.01I/.03 PIT 2Y 24.204.05 Page 5 of 16 For System: E1150

FERMI 2 151/1ST Program Plan - Part 5 Valve Scope Table DIE ENERGY -

Test Procedure Deferred Relief Technical System: E1150 Essam requency Number ~ Justification Request -Position PIS E115OF016B RHR Div'. 11Drgwell Spray Outboard Isolation Valve.

DIVISION 2 Class Cat Size Valve Actuator Active / Normal P'ositioni Safety Fail Type Type Passive Position Position 2 A 12 Globe MOV A Keylocked Closed Both As-is AT- I OB 43.401.345 BTC OP 24.204.06 BTO OP .24.204.06 GL9605 GP 47.306.01 / .03 PIT 2Y 24.204.05 PIS E115OF017A RHR Div'. I Low' Pressure Coolant Injection ('LPCI) Valve.

D)IVISION I Class Cat Size Valve Actuator Active / Norntal Position Safety Fail Type Type Passive Position Position 2 B 24 Globe MOV A Open 'Both As-Is BTC OP 24.204.01 BTO OP 24.204.01 GL9605 GP 47.306.01 /.03 PIT 2Y 24.204.05 PIS E1150F017B RH-R Div'. 1I Low Pressure Coolaunt Injection (LPCI) Valve.

DIVISION 2 Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position 2 B 24 Globe MOV A Open Both As-Is BTC OP 24.204.06 BTO OP 24.204.06 GL9605 GP 47.306.01 /.03 PIT 2Y 24.204.05 Page 6 of 1-6 For System: E1150

DTE ENERGY - FERMI 2 1SI/IST Pro2ram Plan - Part 5 Valve Scope Table System: E1150 _______Exain Test Frequency Procedu re Number Deferred Justification Relief Request Technical Position PIS E1150F021A RHR Div. I Drrwell.Spray Iniboard Isoltion Valve.

DIVISION I Class Cat Size. Valve Actuator Active I Normal Position Sarths Fail Type 'Type Passive Position Position 2 A 12 Gate MOV A Closed Both As-is AT-I OB 43.401.344 BTC OP 24.204.01 BTO OP 24.204.01 GL9605 GP 47.306.01 /.03 PIT 2Y 24.204.05 PIS E1150F021B '.RHR Div. 11 Drywell Spray Inboard Isolation Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Saths Fail Type Type Passive Position Position 2 A 12 Gate MOV A Closed Both As-Is AT- I OB 43.401.345 BTC OP 24.204.06 BTO OP 24.204.06 GL9605 GP 47.306.01I / .03 PIT 2Y 24,204.05 PIS E1150F022 RHR Head Spiny Inboard Con tain,nent lsol Valve DIVISION 2 ClIass Cat Size Valve -. Actuator Active I Normial Position 'Saf'ety Fa il Type Type Passive Positioni Position 2 A 6 Gate MOtV P Closed Closed As-Is -

AT- I OB 43.401.313 PIT 2Y 24.204.05 P1S E1150F023 RHR Head Spray Outboard Containmient Isol Valve DIVISION 2 Class Cat Size Vahse Actuator Active / Normal Position Sarety Fail Type Type Passive Position Position 2 A 6 Globe MOV P Closed Closed As-Is AT-I OB 43.401.313 PIT 2Y 24.204.05 Page 7 of 16 For Systemn:E1150

DTE ENERGY - FERIVI 2 1S1'/1IST Prosram Plan - Part 5 Valve Scope Table .

Test IProcediu re Deferred Relief Technical System: E115O Exam .Frequency Number JsiiainRqet Psto PIS E1150F024A RHR Div. I Containment Cooling/Test Isolation Valve.

DIVISION I Class Cat Size Valve Actuator Active / Normal P'ositionm Safety Fail Type TYp)e Passive P'osition Position 2 A I8 Globe MGV A Closed Both As-Is AT-I OB 43.401.381 BTC OP 24.204.01 BTO OP 24.204.01 GL9605 GP 47.306.01 /.03 PIT 2Y 24.204.05 PIS E1150F024B RHR Div. HIContainmient Cooling! Test lsolation Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P'osition 2 A I8 Globe MOV A Closed Both As-Is AT-I OB 43.401.380 BTC OP 24.204.06 BTO OP 24.204.06 GL9605 GP -47.306.01 %.03 PIT 2Y 24.204.05 PIS E1150F026B RHR Div. Il Warmt-Up Line Isolation Valve.

DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safeth' Fail Type Type P'assive Position Position 2 B 4 Gate MGV A Closed Closed As-is BTC OP 24.204.06 PIT 2Y . 24.204.05 Page 8 of 16 For Systemn: E1150

DIE ENERGY - FERMY2 1SI1 I1ST PI-o0ram Plan - Part 5 Valve Scope Table System: E1150 Exam

'Test Frequency P~rocedure Number Deferred' Justification Relief, Req uest Technical Position PIS E115OF027A RHR Div. I Suppression Pool Containmient Spray Inboard DIVISION 1 Cont. Isol. Valve.

Class (Cat Size Valve Actuator Active / Normal Position Safety FaIl Type Type Passive Position Position 2 A 6 Globe MOV A Closed .Both As-Is AT-I OB 43.401.381*

BTC OP 24.204.01 BTO OP 24.204.01 GL9605 GP 47.306M0 1/.03 PIT 2Y 24.204.05 PIS El1150F027B 'RHR Div. II Suppression Pool Containment Spray Inboard D)IVISION 2 Cont. Isol. Valve.

C;lass Cat Size Valve Actuator Active / Normal Position SarIety Fail Type Type Passive Position Position 2 .A 6 Globe MOV A Closed Both As-Is AT-I OB 43.401.380 BTC OP 24.204.06 BTO OP 24.204.06 GL9605 GP 47.306.01 / .03 PIT 2Y 24.204.05 PIS E1150F028A RHR Div.l Suppression Pool Containment Spray Test DIVISION 1 Isolation Valve.

Class Cat Size Valve Actuator Active! Normal Position Sarety Fail Type. Type Passive .Position Position 2 A 18 Gate MOV A Keylocked Closed Both As-Is AT-I OB 43.401.381 BTC OP 24.204.01 BTO OP 24.204.01 GL9605 GP 47.306.01 I .03 PIT 2Y 24.204.05 Page 9 of 16 For System: E1150

DTE ENERGY - FERII2 ISI/1IST Pro2ram Plan - Part 5 Valve Scope Table System: E11SO ____ _Esain Test Frequency Procedure Number Deferredl Justitication Relief Request Tec hn icalI Position PIS Eli150F02 8B RHR Div. 11 Suppression Pool Containment Spray / Test D)IVISION 2 Isolation Valve.

C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I8 Gate MOV A Keylocked Closed Both As-Is AT-I OB 43.401.380 BTC OP 24.204.06.

BTO OP 24.204.06 GL9605 GP 47.306.01 / .03 PIT 2Y - 24.204.05 PIS E115OF047A RHR Div. I Heat Exchanger A J,,let Isolation Valve.

D)IVISION I Class Cat Size Valve Actuator. Active/ Normal, Position Sarety Fail Type Type Passive Positioni . Position 2 B 20 Gate MOV A Keylocked Open Both As-Is BTC_ OP 24.204.01 BTO OP 24.204.01 GL9605 GP 47:306.01 / .03 PIT 2Y. 24.204.05 PIS E1150F047B RHR Div. II Heat Exchanger B Inlet Isolation Valve.

_ DIVISION 2 Class Cat Size Valve Actuator Active / Nomal Position Safety Fail -

Type Type Passive " Position Position 2 B 20 Gate MOV .A Keylocked Openi Both As-is BTC. OP 24.204.06.

BTO OP 24.204.06 GL9605 OP 47.306.01 /.03 PIT 2Y 24.204.05 Page 10 of 16 For System: E1150

• DTE ENERGY - FERMI 2 1S1 I 1ST-Pirogram Plan - Part 5 Valve Scope Table Sytm E 1OTest 11rocedu re Deterred Relief Technical Sse: E 50Exam Frequency Number J Ustification Request Position PIS El1150F048A RHR Div. I Heat Exchanger A Bypass Valve.

D)IVISION 1.

Class Cat Size. Valve Actuator Active / Normal Position Safety Fail Type Type P~assive Position l'osition 2 B 24 Globe MOV A Open. Both As-is BTC OP 24.204.01 BTO OP 24,204.01 GL9605 GP 47.306.01 /.03 PIT 2Y 24.204.05 PIS E1150F048B RHR Div ll Heat Exchanger B Bypass Valve.

DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type ryp)e Passive Position Position 2' B 24 Globe MOV A Open Both As-is BTC OP . 24.204.06 BTO OP 24.204.06 GL9605 GP 47.306.01I / .03 PIT 2Y 24.204.05 PIS E1150F068A RHR Div. I Heat Exchanger A Service Water Outlet Isolation DIVISION I Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type [Type Passive P'osition Position 3 B 24 Globe MOV *A Closed Both As-Is BTC OP 24.205.05 BTO OP . 24.205.05

- GL9605 GP 47.306.0L/ .03 PIT 2Y . 24204.05 Page 11 of 16 For Systems:E1150

FERMI 2 ISI1/IST Prouram Plan - Part 5 Valve Scope Table DTE ENERGY -

Test Procedure Deferred Relief Technical S_stem_E115 Exam Frequency* Number Justification Request Position PIS E1150F068B 'RHR Div. H Heat Exchanger B Service Water Outlet IItSION 2 Isalation Valve.

Class Cat Size Valve Actuator Active / Normal Position Saretv Fail Type Type Passive Position Position 3 B 24 Globe MGV A Closed Both As-Is BTC OP 24.205.06 BTO -OP 24.205.06 GL9605 GP 47.306.01/.03 PIT 2Y 24.204.05 PIS E1150F073 RHR Div. HI RHRSW To RHR Crosstie Isolation Valve.

DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P'ositioni 3 B 12 Gate MOV P Closed N/A As-Is GL9605 GP 47.306.01 /.03 PIT 2Y 24.204.05 PIS E115OF075 RHR Div. II RHRSW To RHR Crosstie Isolation Valve.

I)IVISION 2 Class Cat Size Valve Actuator Active / ;Normal Position Sarety Fail Type Type Passive Position Position 3 B 12 Gate MIVOV* P Closed N/A As-is GL9605 GP 47.306.01 / .03 PIT 2Y 24.204.05 PIS E1150F601A RHR Div. I Reservoir North Service Water Cross-Tie Valve D)IVISION 1 C:lass Cat' Size Valve Actuator Active / Normal Position Sarety Fa Il Type Type Passive , Position Position 3 B 10 BalI M4OV A . Open Both As-is BTC OP 24.205.11 BTO . OP 24.205.11 GL9605 .GP . 47.306.03 PIT 2Y 24.205.11 Page 12 of 16 For System: E1150

DTE ENERGY - FERMI 2 18S. / IST'Program Plan - Part 5 Valve Scope Table Sse: E 10Test Procedure Deferredl Relief Technical Sse: Exam Frequency Number Justitication Request Position PIS E115OF601B RHR Div. if Reservoir North Service Water Cross. Tie Valve D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 B 10 Ball MOV A Open Both As-is BTC OP 24.205.11 BTO OP 24.205.11 GL9605 GP 47.306.03 PIT 2Y 24.205.11 PIS E1150F602A RHR Div. I Reservoir South Service Water Cross-Tie Valve DIVISION I Class Cat Size Valve Actuator Active / Noi nal Position Safety Fail Type ' Type Passive. Position P~osition 3 B 10 Ball MOV A Closed Both As-Is BTC OP 24.205.11 BTO OP 24.205.11 GL9605 GP 47.306.03

- PIT 2Y 24.205.11 PIS E1150F602B RHR Div. I Reservoir South Service Water Cross- Tie Valve DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail

- Type Type)( Passive Position IPosi tin 3 B 10 Ball MOV A Closed Both . As-la BTC OP 24.205.11 BTO OP 24.205.11 GL9605 GP 47.306.03 PIT. 2Y . 24.205.11 Page 13 of 16 For System: E1150

DTE ENERGY - FERMI 2 ISI / 181 Pr66-am Plan - Part 5 Valve Scope Table Sse' E 1OTest P~rocedure Deferred Relief Technical Exam F'requency Number Justification Request Position PIS E1150F603A RH-R Div. I Coaling Tower Bypass Valve.

D)IVISION I Class Cat Size Valve Actuator Active / Normal Position Safety- Fail Type Type Passive Positioni Position 3 B 16 Gate MOV A Closed' Bothi As-is BTC OP 24.205:05 BTO OP 24.205.05 GL9605 GP 47.306.01 /.03 PIT 2Y 24.205.05 PIS E1150F603B RHR Div'. 11 Cooling Tower Bypass Valve.

DIVIlSION 2 Class Cat Size Valve Actuator Active / No)rmal Position Safety" Fail Type rype P'assive Position P~ositioni 3 B - 16' Gate MOV A Closed Both As-Is BTC OP 24.205.06 BTO OP 24.205.06 GL9605 GP 47.306.01 /.03 PIT 2Y 24.205.06 PIS E1150F604A RHR Div. 1Cooling Tower BOO01A Isolation Valve.

DIVISION I Class Cat Size Valve A'ctuator Active / Normal Position Safety Fail Type Type) Passive P'ositio n Posi tionI 3 B 18 Gate MOV A Open .Both As-Is

--BTC OP 24.205.05 BTO OP 24.205.05 GL9605 GP 47.306.01 /.03 PIT 2Y . 24.205.05 Page 14 of 16 For System: E1150

DTE ENERGY - FERMI 2 IS]. / 1ST Program Plan - Part 5 Valve Scope Table Sytmr15 est Procedlure- Deferred Relief Technical E15Eamn Fyte: Frequenc~y Nuinber Justification Request Position PIS E1150F604B RHR Div. 11 Cooling Tower B002A Isolation Valve.

D)INISION 2 C:lass Cat Size Valve Actuator Active/ Normal Positioni Safety Fail Type Tv pe Passive Position Position 3 B I8 Gate MOV A Open Both As-is BTC OP 24.205.06 BTO OP .24.205.06 GL9605 GP 47.306.01 / .03 PIT 2Y 24.205.06 PIS E1150F605A RHR Div. I Cooling Tower B001B Isolation Valve.

D)IVISION 1 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position

3. B 18 Gate MOV A Open Both As-Is BTC .OP . 24.205.05 BTO -OP .24.205.05 GL9605 GP 47.306.01 /.03 PIT 2Y 24.205.05 PIS E1150F605B RHR Div. 1I CTooling Tower B002B Isolationt Valve.

DIVISION 2 Class Cat Size Valve Actuator :Active / Normal Position Safety Fail Typ Tpe Passive I'osition Position 3 B 18 Gate MOV A Open Both As-Is BTC OP 24.205.06 BTO OP 24.205.06 GL9605 OP 47-306.01 / .03 PIT 2Y 24.205.06 Page 15 of 16 For Systemn:E1150

DTE ENERGY - FERMI 2 ISI/1ST Pro2ram Plan - Part 5 Valve Scope Table Sse: E 10Test Procedure Deferred Re!lief Technical Sytm E10Exam Frequency Number Justification Request Position PIS E1150F608 RHR Shutdown (Cooling Inboard Inlet Isolation, Bypass V'alve.

D)IVISION 2 Class Cat Size Valve Actuator Activel/ Normal P'ositionl Sarety Fail TYpe Type Passive Position Position I A 20 Gate MOV A Keylocked Closed Closed As-Is AT-I OB 43.401.307 AT-10 OB 43.401.512 VRR-013 BTC RR 24.204.08 ROJ-022 BTO RR 24.204.08 ROJ-022 GL9605 GP 47.306.01 /.03 PIT 2Y 24.204.08 Page 16 of 16 For System: E1150

DTE ENERGY - FERMI 2 ISI / IST Program Plan - Part 5 Valve Scope Table SytmTE1O"est Procedure Deferr-ed Relief Technical Sse: 210Exain Frequency Number Jlustification Request Position PIS E210O003A Core Spray (CS) Div'. I Pump COOIA Discharge Ch:eck Va/lve.

DIVISION 1 C:lass Cat Size Valve Actuator Active / Normal Position Safet Fail Type Type Passive . Position Position 2 C 12 CK Self Act A System Dependent Botlh CT-C OP 24.203.02 CT-DI 4R 43.000.010 CMvP-04 CT-OP OP 24.203.02 PIS E210O003B C'ore Spray (CS) Div. II Pump COOQIB Discharge Check Valve.

D)IVISION 2 Class Cat Size V'alve Actuator Active! Normal Position Safety Fail Type -Type Passive .Position Position 2 C 12 CK Self Act A System Dependent Both CT-C OP .24.203.03 CT-DI 4R 43.000.010 CMP-04 CT-OP OP 24.203.03 PIS E210O003C Core Spray (CS) Div. I Pump COO/C Discharge Check Valve.

IILSION I ClIass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type. Passive Position Position 2 C 12 CK Self Act A System Dependent Bollh CT-C OP. 24.203.02 CT-DI 4R 43.000.010 CMP-04 CT-OP OP 24.203.02 PIS E210O003D Core'Spray(CS) Div. 11 Pump COO ID Discharge Check DIVISION 2 Valve.

Class Cat Size Valve Actuator Active / Normal tPositionm Safety Fail Type 'Type Passive P'osition P~osition 2 C 12 CK Self Act A System Dependent Both CT-C OP 24.203.03 CT-D[ 4R -43.000.010 CMP-04 CT-OP OP 24.203.03 Page 1 of 5 For System: E2100

DIE ENERGY - FERMI 2 ISI/1ST Program Plan - Part 5 Valve Scope Table System: E2100 -Exam Test Frequency Procedure Number Deferred Justitication Relief Request Tech nical Position PIS E210O006A Core Spray (CS) Div. I Inboard Primary Con,taionnenit (PC)

IISION I(heck Valve.

Class Cat Size .Valve .Actuator Active / Normial P'osition Safety Fnail Type - Type Passive Position Position, I A/C 12 CK, SA Test AO A Closed Both AT-1 OB 43.401.312 AT-.lO OB 43.401.513 VRR-013 CT-F RR 43.401.711 ROJ-004 PIT 2Y 24.203.04 PIS E210O006B Core Spray (CS) Div. 11 hi board-PrimaryC'ontaionent (PC)

D)IVISION 2 Check Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Typie Typ1 e P'assive Position Position I -A/C 12 CK SA Test AO A Closed Both AT-I OB 43.401.311 AT-10 OB 43.401.513 VRR-013 CT-F RR 43.401.712 ROJ-004 PIT 2Y 24.203.04 PIS E210O011A Core Spray (CS) Div. I Pumps Discharge PresstureRelief DIVISION I - Valve:

Class Cat Size Valve -Actuator Active / Normal Position Safety Fail Type TypeS Passive Ponsitioni Position 2 C 2 RLF Self Act A Closed Both CT-SP IOY 43.000.020 PIS E210O011B Core Spray (CS) Div. II Pumps Discharge Pressure Relief DIVISION 2 Valve.

Class Cat Size Valve Actuator Active/ Normal Ponsition Safety Fail Type Type Passive Position Positioni 2 C 2 ,RLF Self Act A Closed Both CT-SP 10Y 43.000.020 Page 2 of 5 For System: E2100

DTE ENERGY - FERMIJ2 ISI / 1ST Program Plan - Part 5 Valve Scope Table Sse : E 1OTest P~rocedure Deferred Relief Technical Sytm E 10Exam Frequency Number Justification Request Position PIS E210O012A Core Spray (CS) Div. I Pumps Discharge PressureRelief D)IVISION 1Valve.

Class Cat Size Valve Actuator Active!/ Normal Position Sat'ety Fail Type Type Passive Position Position 2 C 2 RLF Self Act A Closed Both CT-SP I OY 43.000.020 PIS E210O012Bl Core Spray (CS) Div. HI Pumps DischiargePressureRelief D)IVISION 2 Valve.

C:lass Cat Size Valve Actuator Active/! Nosrmal Position Safety Fail Type Type Passiv e Position Position 2 C 2 RLF Self Act A Closed Both CT-SP IOY 43.000.020 PIS E210OF029A Core Spray (CS):Div. I Discharge Header PriminrgSupply DIVISION 1 Check Valve.

Class Cat Size Valve Actuator Active! Normal Position Safety Fail Type Type Passive Position Position 2 C 3 CKC Self Act A System Dependent Closed CT-C .OP . 24.203.0.2 CT-OL OL N/A TP-0I PIS E210OF029B Core Spray (CS) Div. I Discharge HeaderPriming Supply D)IVISION 2 Check Valve.

Class Cat Size Valve Actuator Active / Normal P'ositioni Safety Fail Type Type .Passive . Position Position 2 .C 3 CK Self Act A System Dependent Closed CT-C OP 24.203.03 CT-OL OL N/A .TP-0I PIS E210O030A Core Spray (CS) Div. I Discharge Header Prinming Supply D)IVISION I Check Valve.

Class Cat Size Valve Actuator Active / Normal Position ,-Safety Fail Type T'rpe Passive I'ositioni Position 2 C 3 CK Self Act A System Depenident Closed CT-C OP 24.203.02 CT-OL OL N/A TP-0I Page 3 of 5 For System: E2100

DIE'ENERGY - FERMI 2 1SI/1ST Program Plan - Part 5 Valve Scope Table SytmTE10'est Procedure Deferred Relief Technical Sytm E 10Exam Frequency Number Justification Request Position PIS E210O030B Core Spray (CS) Div'. I Discharge Header Prinming Supply DIVISION 2 Check Valve Class Cat Size Valve Actuator Active / Normal P'ositionm Safety Fail Type Type Passive Position Position 2 C~ 3 CK _ Self Act A System Dependent Closed -

CT-C OP 24.203.03 CT-OL- OL N/A TP-0l PIS E210OF032A Core Spray (CS) Div. I Punmps Suction Pressure Relief Valve.

DIVISION I Class Cal Size Valve Actuator Active / Normal P'ositionm Safety Fa il Type Type Passivye Positino PositIion 2 C I TReI Self Act A Closed Both CT-SP 10Y 43.000.020 PIS E210OF032B Core Spray (CS) Div. HI Pumps Suction Pressure Relief Valve.

DIV'ISION I Class Cat Size Valve Actuator Active/I Normal Position Safety rail Type Type Passive Position P'osition 2 C I TRel Self Act A Closed Both CT-SP IOY 43.000.020 PIS E210OF038A Core Spray (CS) Div. [ Pump COO/A Minimumn Flow!

D)IVISION 1 Recirculation Check Valve Class Cat .Size Valve Actuator Active/ Normal P'osition Safety . Fail Type Type Passive Position Position 2 C 3 CK Self Act A System Dependent Bollh CT-DI 4R 43.000.010 CMP-05 PIS E210O038B Core Spray (CS) Div. 11 Pump CO01B Minimum Flow /

DIVISION 2 Recirculationt Chteck Valve C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Ptosition Position 2 C 3 CK Self Act A System Dependent Both CT-DI 4R 43.000.010 CMP-05 Page 4 of 5 For System: E2100

DTE ENERGY - FERMI 2 1S]. / 1ST Proizram Plan - Part 5 Valve Scope Table Sytm E 10Test Procedure Deferred Relief Technical Sytm. E 10Exam Frequency Number Justifiention Request Position PIS E210OF038C Core Spray (CS) Div'. I Pirmp COO/C Minimum Flow!

D)IVISION 1Recirculation Check Valve Class Cat Size V'alve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 3 CK Self Act A System Dependent Both CT-DI 4R 43.000.010 CMP-05 PIS E210OF038D Core Spray (CS) Div. 11 Pumip C001D Minimumn Flow/

M)VIS ION 2 Recirculation Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail

'Ty'pe Type Passive . Position Position 2 C 3 CK Self Act A System Dependent Both CT-DI 4R 43.000.010 CMP-05' PIS E21F500A Core Spray (CS) Header 'A' to"Spaiger"E.ecess/Foi"v Check D)IVISION IValve C'lass Cat Size -Valve Actuator Active / Normal Position Safety Fa il Type Type Passive Position Position I A/C .I XFC Self Act A . Open Closed CT-EF SP I 44.220.1 12 VRR-01 I PIT SPI 44.220.112 VRR-0II PIS E21F500B Core Spray (CS) Header 'Bto Sparger Excess Flow C'heck D)IVISION 2 Valve Class Cat Size Valve -Actuator Active / Normal P'osition Safety Fail Type 'Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPl 44.220.115 .VRR-011 PIT SPI 44.220.1 15 .VRR-01.1 Page 5 'of 5 For System: E2100

DIE ENERGY - FERMI 2 I81/1ST Prouram Plan - Part 5 Valve ScOpe Table Sytm E 10Test Procedlure Deterred Relief Technical Sytm E 10Exam Frequency Number Justification Request Position PIS E215OF004A Core Spray (CS)I DivI Outboard Isolation Valve.

D)IVISION I Class Cat Size Valve Actuator Active / *Normal Position Safety- Fa il Type Type Passive Position Position 2 B 12 Gate MOV A Open Open As-Is BTO OP 24.203.02 GL9605 OP 47.306.01I/.03' PIT 2Y 24.203.04 PIS E215OF004B Core Spray (CS) Div.IOutboardIsolation Valve.

DIVISItON .2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position, 2 B 12 Gate MOV A Open Open As-Is BTO OP, 24203.03 GL9605 GP 47.306.01 /.03 PIT 2Y 24.203.04 PIS E215OF005A Core Spray (CS). Div.I Inboard Isolation Valve.

D)IVISION I Class Cat Size Valve Actuator Active / Normal Position Saret Fail Type Type Passive Position Position I A 12 Gate MOV A Closed .Both As-Is AT-I OB 43.401..12 AT-I1. OB 43.401.513 .VRR-013 BTC CS24-203.04 CSJ-004 BTO CS 24.203.04 /.02 CSJ-004 GL9605 .GP 47.306.01 /.03

• PIT 2Y 24.203.04 Page 1 of 3 For System: E2150

}

DTE ENERGY - FERMI 2 IS1 / ISTPromram Plan - Part 5 Valve Scope Table Sytm.1UExam 1 Test Procedure Deferred Relief Technical

~y~m I-requencv Number ~ Justitication Request Position PIS E215OF005B Core Spray (CS) Div.Ilinboard Isolation Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type : Type Passive Position Position I A 12 Gate MOV A" Closed Both As-Is AT- I OB 43.461.311 AT-10 GB 43.401.513 V RR-013

\BTC CS 24:203.04. 'CSJ-004 BTO CS 24.203.04 / .03 CSJ-004 GL9605 GP 47.306.01 /.03 PIT . 2Y 24.203.04 PIS E215OF015A Core Spray (CS) Div. I Punp Flow Test Isolation Valve.

D)IVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 B 10 .Globe MOV _A Closed Closed _ As-Is BTC OP 24.203.02 GL9605 GP 47.306.01 /.03 PIT 2Y 24.203.04 PIS E215OF015B Care Spray (CS) Div. 11 Pump Floiv Test Isolation Valve.

DIVISION 2 Class Cat Size Valve Actuator .Active / -Normal Position Safety Fail Type Type . Passive Position PositiJon 2 B 10 .Globe .MOV A .Closed .Closed As-is BC OP 4.30.03 GL9605 OP 403.1.03 PIT 2Y 24.203.04 Page 2 of 3 For Systemn:E2150

DTE ENERGY - FERMI 2 ISI/1IST Program Plan - Part 5 :Valve Scope Table.

Sytm E 1OTest Procedure Deferred Relief Technical Sse: 250Exam Frequency Number Justification Request Position PIS E215OF031A Core Spray (CS) Div. [Mininium Flow/Recirculation D)IVISION I Isolation Valve.

Class Cat Size Valve Actnator Active / Normal Position Safety Fail Type Type . Passive Position Position 2 B 3 Gate MOV A Open. Both As-is BTC OP 24.203.02 BTO OP 24.203.02 GL9605 GP 47.306.01 / .03 PIT 2Y 24203.04 PIS E215OF031B C'ore Spray (CS) Div'. I/ Minimum Flow/Recirculation DIVISION 2 Isolation Valve..

Class Cat Size Valve Actuntor Active!/ Normal Position Safety Fail Type Type P'assive Position Position 2 B 3 Gate MOV A Open .Both As-Is BTC OP _ 24.203.03 BTO OP 24.203.03 GL9605 GP 47.306.01 / .03 PIT 2Y 24203.04 PIS E215OF036A Core Spray (CS) Div. [ Suction from Suppression Chamber" DIVISION I Isolation Valve.

Class Cat Size Valve Actuator Active / Normal P~osition Safety Fail Type Type Passive -Position Position 2 B 20 Gate MOV A Keyl6cked Open Closed As-Is BTC OP 24.203.02 GL9605 GP 47.306.01 /.03 PIT 2Y 24.203.04 PIS E215OF036B Core Spray (CS) Div. II Suction from Suppression Chamber DIVISION 2 . Isolation Valve.

Class Cat Size Valve Actuator Active / Normal Position -Safety Fail Type Type Passive Position Position 2 B 20 Gate MOV A Keylocked Open Closed As-Is BTC OP 24.203.03 GL9605 GP 47.306.01 / .03 PIT 2Y 24.203.04 Page 3 of 3 For System: E2150

DTE ENERGY - FERMI 2 1S1 / IST ProMram Plan - Part 5 Valve Scope Table Sse : E 10Test P~rocedlure Deferred Relief Technical Sytm E10Exam Frequcncy Number Justification Request Position PIS E4100F005 HIPCI Main Peump Discharge Check Valve.

D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive -Position Position 2 C 14 CK Self Act A System Dependent Open CT-0 OP 24.202.01 CT-OL- OL N/A TPOI.

PIS E410O019 HPCI Booster Pump Suction fi-oni Condensate Storage Tank-DIVISION N/A (CST) Chc/ Valve.

Class Cat Size Valve Actuator Active I Normal Position Safety Fail Ty[vie Tfype Passive P'ositio n P'osi tin 2 C 16 CK Self Act A Syistem Depenident Both CT-DI 4R 43.000.010 CMP-06 CT-0 OP 24,202.01 PIS E410OF020 HPCIBooster Pump Inlet PressureRelief Valve.

DIVISION N/A Class Cat Size Valve Actuator Active / Normal P~osition Safety Fail Type Type Passive Position Position 2 C 1 1/2 RLF Self Act A Closed Open CT-SP IOY 43.000.020 PIS E410OF026 HPCI Barometric Conideniser Condensate_ Outlet to Floor tDIVISION N/A Drain Inboard Isolation Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Pail Type Type Passive P'osition Position 2 B 1 Globe AO A Closed;' Closed Closed BTC OP 24.202.01 FST OP .24.202.01 PIT 2Y 24.202.05 Page 1 of 7 For System; E4100

DTE ENERGY - FERiVII 2 SJLST.Prolzram Plan 151 - Part 5 Valve Scope Table Syte : 410 S tm 7lllTest Esamn Frequency Procedure Numnber Deferred

.1ustification Relief Request Technical Position PIS E410OF028 HPCI Turbine Supply Drain Pot to Main Condenser Drain DIVISION N/A Line-Isolation Valve.

Class Cat Size Valve Actuator Active / Normal lPosition Safety Fail Type Type Passive Position Position 2 B I Globe AGO A Open Closed Closed BTC OP 24.202.01 FST OP 24.202.01 PIT 2Y" 24.202.05 PIS E410OF040 H-PCIJ Turbine Exhaust Condensate Drain Pot Outlet Vcilve.

D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety . Fail Type. Type Passive Position Position 2 C 2 CK Self Act A System Dependent Open CT-DI 7Y 43.000.010 CMP-09 CT-O OP. 24.202.01 PIS E410OF045 HPCIBooster Pump Suction from Supp6ression Pool Ciheck

-DIVISION N/A 'Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type- Type P'assive Position Position 2 C 16 CK Self Act *A System Dependent Open CT-DI 4R 43-000.010 CMP-06 PIS E410OF048 HPCI Barometric Condenser C7ondensate Pump Return Line DIVISION N/A C'heck Valve.

Class Cat Size Valve .Actuator Active / Normal Position Safety Fail Typ)e Type Passive .Position' Position -

2 C 2 CK Self Act A :System Dependent Open CT-DI 7Y .43.000.010 CMP-09 CT-O O~P 24.202.01 PIS E410OF049 HPCI Tturbine Exhaust Check Valve.

D)IVISION N/A Class Cat Size Valve Actuator Active/I Normsal Position Safety Fail Type Type Passive .Position Position.

2 C 20 CK Self Act A System Dependent Open CT-DI 6Y 43-000.010 CMP-10 CT-O OP 24.202.01 Page 2 of 7 For System: E4100

DTE ENERGY - FERMI 2 1SI1 / IST. Ptogram Plan - Part 5 Valve Scope Table Sse : 10Test P'rocedu re Deterred Relief Technical Examn Frequency' Number Justification Request Position PIS E410OF050 HPC'ILube Oil Cooler Inlet Pr~essure Relief Valve.

D)IVISION N/A Class Cat Size V'alve 'Actuator Active / Normal Positioni Safety Fail Type Type Passive Position Position 2 C 3 RLF Self Act A Closed Open CT-SP lOX' 43.000.020 PIS E410OF053 HPCI Turbine Exhaust Drain Pot Condensate Drain Valve.

D)IVISION N/A C:lass Cat Size Valve Actuator Active / Normal P'osition Sarety Fail Type Type Passive Position P'osition 2 B I Globe AO A Closed Closed Closed BTC OP 24.202.01 FST OP 24.202.01 PIT 2Y 24.202.05 PIS E410OF057 H-PCILube Oil Cooler Outlet Check Valve.

DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 C 2 CK( Self Act A System Dependent Open CT-DI 7Y 43.000.010 CMP-09 CT-0 OP 24.202.01 PIS E410OF067 H-PCI Turbine Steam; Isolation Valve.

D)IVISION N/A Class Cat Size Valve Actuator Active I Normal Position Safety Fail Typse Type Passive Position Position 2 B 10 Gate HO A Closed Open As-is BTO. OP 24.202.01 PIT. 2Y 24.202.05 P1S E410OF068 HPCI1 Turbine Steam Control "Valve..

D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position - Safety Fail Type Type Passive . Position Position 2 B 10 Globe HO A Closed Open As-is BTO .RR 24.202.08 SMC Page 3 of 7 For System: E4100

DTE ENERGY - FERMVI 2 181 / IST Pro2ram Plan - Part 5 Valve Scope Table S te: E 1OTest Pr"ocedure Deterred Relief Technical Sse: E10Exam Frequency Number ~ Justification Request Position PIS E410OF076 HPCI Turbine Exhaust Line Vacuum Breaker Check Valve.

D)IVISION N/A Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type Type Passive Position Position 2 C 4 CK Self Act A System Dependent Both CT-C CS 24.202.07 CSJ-020 CT-O CS 24.202.07 CSJ-020 PIS E410OF077 HPCI Turbine Exhaust Line Vacuum Breaker Check Valve.

DIVISION N/A Class Cat Size Valve Actuator Active/I Normal P'osition Safety Fail Type Type Passive I'osition Position 2 C 4 CK Self Act A System Dependent Both CT-C CS 24.202.07 CSJ-020 CT-O CS 24.202.07 CSJ-020 PIS E410OF220 HPCI Keep Fill Check Valve.

DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive .. Position Position 2 C 3/4 CK Self Act A Open .Closed CT-C CS 24.202.05 CSJ-019 CT-OL- OL N/A TP-01 PIS E410OF221 MPCI Keep Fill Check Valve.

DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P~ositioni 2 C 3/4 CK Self Act A Open Closed CT-C CS 24.202.05 CSJ-019 CT-OL- OL N/A TP-01 Page 4 of 7 For System: E4100

DTE ENERGY - FERMI 2 15 /1ST ProLram Plan ISI - Part 5 Valve Scope Table System: E4100 iNTest Exam Frequency Procedu re Number Deferred Justification Relief Request Technical Position PIS E41FO11 HPCI Test Line Isolation / Pressure Control Valve. Valve is D)IVISION N/A IST bounday, Ref 1ST Eval 99-03 9.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 B 8 Globe AO A Closed Closed Closed BTC OP 24.202.01 FST OP -24.202.01 PIT 2Y. 24.202.05 PIS E41F400 Solenoid Valve: Primoi)-Containment Monitoring (PCII) -

DIVISION N/A Suppression Pool.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Globe SOy A Open Closed As-Is AT-I GB 43.401.379 BTC OP 24.408.03 PIT OB 43.401.379 VRR-012 PIS E41F401 Solenoid Valve: Primary Containment Monitoring ('PCM) -

D)IVISION N/A Suppression Pool.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Globe SOy A Open Closed As-Is AT-2 GB 43.401.401 BTC OP 24.408.03 PIT OB 43.401.401 VRR-02 PIS E41F402 Solenoid Valve: Prinray Containment Monitoring (PCM) -

DIVISION N/A Suppression Pool.

Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail

Tp Type Passive P'osition Position 2 A I Globe SOV A .Open Closed As-is AT- I GB 43.401.378 BIG OP 24.408.04 PIT GB 43.401.378 VRR-012 Page 5 of 7 For System: E4100

DTE ENERGY - FERIVI 2 181/1IST Prollram Plan - Part 5 Valve Scope Table Deferred Relief Technical Sse: E 10Test Procedure Sytm E 10Exam Frequency Number Justification Request Position PIS E41F403 Solenoid Valve: Primar Containment Monitoring (PCM IITSION N/A Suppression Pool.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type - Type Passive Position Position 2 A I Globe SOV A Open Closed As-is -

AT-2 OB 43.401.400 BTC OP 24.408.04 PIT GB 43.401.400 VRR-012 PIS E41F500 Main Steam to HPC1 Turbine Excess Flow Check Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive tPosition Position I A/C I XFC Self Act A Open Closed CT-EF SPI1 44.220.1 12 VRR-01 I PIT SPI 44.220.112 VRR-011 PIS E41F501 Ma in Steam to HPCI Turbine Excess Flow Check Valve DIVISION N/A Class Cat. Size Valve Actuator .Active / Normal Position Safety Fail Type Type t'assive Position Positionj I A/C I. XFC Self Act A Open Closed CT-EF SPI 44.220.1 12 VRR-0l I PIT SPI 44.220.112 VRR-011 PIS E41F502 Main Steam to HPCJ Turbine Excess Flow Check Valve DIVTS1ON N/A C;lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.115 .VRR-01I PIT SPI 44.220.115 VRR-011 Page 6 of 7 For System: E4100

DTE- ENERGY - FERMI 2 ISI1 / IST Program Plan - Part 5 Valve Scope Table Sse E40 Test Procedure Deferred Relief Technical Syte: 410Exam rrequencY Number Justification Request Position PIS E41F503 Main Steam to HPCI Turbine Excess Flow Check Valve D)IVISION N/A Class .Cat Size Valve Actuator Active / Normal Position Sarety Fail Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.115 VRR-011 PIT SPI 44.220.115 VRR-011 Page 7 of 7 For Svstem: E4100

DTE ENERGY - FERMI12 ISI/1ST Pro2ram Plan - Part-5 Valve Scope Table Test Procedure Deferred Relief Technical System: E4150 Examn Frequency Number. Justification Request Position PIS E4150DO03 HPCI Turbine Exhaust Line Rupture Disc.

D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type - Type Passive" Position Position 2 D 16 RD Self Act A Closed Open DT 5YE316 PIS E4150DO04 HPC1 Turbine Exhaust Line Rupture Disc.

DItVISION N/A Class Cat Size Valve Actuator Active / Normal Position safety Fail Type Type Passive -Position Position 2 D 16 RD Self Act A Closed Open DT 5Y E316 PIS E4150F001 HPCI1 Turbine Stea,n Supply Isolation Valve.

D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 B 10 Gate MOV A Closed Open As-Is BTO OP 24.202.01 GL9605 GP 47-306.01 /.03 PIT .2Y 24.202.05 PIS E4150F002 HPCI Turbine Steam Supply Inboard Cont. IsolI. Valve.

D)IVISION N/A Class "Cat Size' Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position ,Position I A 10 Gate MOV A. Keylocked Open Both As-is AT-I OB 43.401.306 AT-4 GOB 43.401.511 BTC CS 24.202.05 CSJ-010 BTO CS 24.202.05 CSJ-010 GL9605 GP 47:306.01/.03 PIT 2Y 24.202.05 Page 1 of 6 For System: E4150

EDTE ENERGY -FERMI 2 ISI / IST PWo2ram Plan - Part 5 Valve Scope Table Sse: E 1OTest Procedure Deferred Relief Technical Syte: 410Exam Frequency Number Justification Request Position PIS E4150F003 HPCI Turbine Steami Supply Outboard Cont. Isol. Valve.

DIVISION N/A C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive' Ponsition. Position 1' A 10 Gate MOV A Closed Both As-Is AT-I OB 43.401.306 AT-4 OB 43.401.511 BTC OP 24.202.01/.05 BTO OP 24.202.01 GL9605 GP 47.306.01 1.03 PIT 2Y 24.202.05 PIS E4150F004 HPCIY Boaster Pualp Suction froni Condensate Storage Tankc D)IVIS ION N/A (CST') Isolation Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type -. Type Passive Position Position 2 B 16 Gate MOV A Open .Both As-Is BTC OP 24.202.01.

BTO OP 24.202.01 GL9605 OP 47.306.01 /.03 PIT 2Y 24.202.05 PIS E4150F006 HPCI Main Pumup Outlet to Feedwater Isolation Valve.

DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type .Type Passive . ~ Position Position 1 A 14 Gate MOV A Closed Both As-is AT-I OB 43.401.303 AT-.10 GB .43.401.5 14 VRR-013

'AT-4 OB 43.501.511 BTC CS 24.202.05 CSJ-004 BTO CS 24.202.05 CSJ-004 GL9605 OP 47.306.01 / .03 PIT 2Y' 24.202.05 Page 2 of 6 For System: E4150

DTE ENERGY - FERMI 2 ISI / IST Proigram Plan - Part 5 Valve Scope Table SytmTE10'est Procedure Deferred Relief Technical Syte: 410Exam Frequency Number Justification Request Position PIS E4150F007 HPCI Main Pump Discharge Isolation Valve.

D)IVISION N/A Class -Cat Size Valve Actuator Active / Normal [Positin- Safety Fa il Type Type Passive Position Position 2 A 14 Gate MOV A Open Both As-Is AT-1O OR 43.401.514 VRR-013 BTC .OP 24.202.01 BTO OP 24.202.01 PIT 2Y 24.202.05 PIS E4150F008 HPCI Pump Test Line Isolation Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type tPassive Position Position 2 B 10 Globe MOV A Closed Closed As-is BTC OP 24.202.01 GL9605 GP ,47.306.01 /.03 PIT . 2Y 24.202.05 PIS E415OF012 HPCIMain Pump E4101ICOOIA Minimunt Flow to DI1VISION N/A Suppression Chanmber Isolation.Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 B 4 Globe MOV A Closed Both As-Is BTC OP 24.202.01 BTO OP 24:202.01I GL9605 GP 47.306.0] / .03 PIT 2Y 24.202.05 Page 3 of 6 For System: E4150

DIE ENERGY - FERMI 2 IS1/1ST Prngram Plan - Part 5 Valve Scope Table Sse: E 1OTest Procedure Deferred Relief Technical Syte: 410Exam Frequency Number ~Justification Request Position.

PIS E415OF021 HJPCI Turbine Exhaust Stop Globe Valve.

D)IVISION N/A Class -Cat Size Valve Actuator Active!/ Normal Position Safety -Fa il

-. Type 'Type Passive Position Position

.2 B/C 16 Stop CK MOV A Keylocked Open Both As-Is BTC OP 24.202.01 CT-0 OP 24.202.01 GL9605 GP 47.306.01 / .03 PIT .2Y 24.202.05 PIS. E415OF022 HPCJ Turbine Exhaust Condensate to Suppression Pool Stop D)IVISION N/A C7heck Valve.

Class Cat Size Valve Actuaztor' Active I Nornmal Position Saf'ety Fail Type T'ype Passive Position Position 2 B/C 2 Stop CK MOV A Keylocked Open Both As-Is BTC OP 24.202.01 CT-0 OP . 24.202.01 GL9605 GP .47.306.01 / .03 PIT 2Y 24.202.05 PIS E415OF041 H'PC'IBooster Pump Suction From Suppression Pool DIVISION N/A Isolation Valve.

Class Cat Size Valve Actuator Active/I Normal Position Safety Fail

'Type Typje Passive -Position Position 2 B 16 Gate MOV A Closed Both As-is BTC OP 24.202.01, BTO OP 24.202.01 GL9605 GP ' 47.306.01 / .03 PIT 2Y 24.202.05 Page 4 of 6 For System: E4150

DTE ENERGY - FERMI 2 ISI / IST Pro gram Plan - Part 5 Valve Scope Table S te: E 1OTest Procedure Deferred Relief Technical Exam Frequency Number Iustification Request Position PIS E415OF042 H-PCI Booster Punip Suction from Suppression Pool Isolation D)IVISION N/A Valve.

Class Cat Size V'alve Actuator Active / Normal P'osition Safety Fail Type Type P~assive Position Position 2 B 16 Gate MOV A Closed Both As-Is BTC OP 24.202.01/.05 BTO OP 24.202.01 GL9605 GP 47.306.01 / .03 PIT 2Y 24.202.05 PIS E4150F059 HPCI Lube Oil Cooling Water Supply Isolation Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type - Type Passive Position Position 2 B 2 Globe - MGV A Closed _ Open As-Is BTO OP 24.202.01 GL9605 GP 47.306.01 / .03 PIT 2Y 24.202.05 PIS E415OF075 H'-PCI Turbine Exhaust Line Vacuum Breaker Isolation Valve.

D)IVISION N/A Class Cat Size Valve Actuiator Active / Normal P'osition- Safety Fail Type . Type Passive Position Position 2 A 4 Gate MGV A Open Closed As-Is AT-I OB 43.401:382 BTC OP 24.202.01/.05 GL9605 GP 47.306.01 / .03 PIT 2Y 24.202.05 Page 5 of 6. For System: E4150

DTE ENERGY - FERMI 2 1S1 / IST Prof!ram flan - Part-5 Valve Scope Table Sytm E45 est Procedure Deferred Relief Technical

-~Ezam Frequency Number ~Justification Request Position PIS E415OF079 HPCI Turbine Exhiaust Line Vacuun Breaker 1solation Valve.

D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Sarety Fail Type Type Passive Position Position 2 A 4 . Gate MOV A Open Closed As-Is AT-1 GB 43.401.382 BTC OP 24.202.01/.05 GL9605 GP 47.306.01 / .03 PIT 2Y. 24.202.05 PIS E415OF600 HPCI Turbine Steam Supply Line E4150FOO3 Byp ass Valve.

DIVISION N/A C;lass Cat Size Valve Actuator Active I Normal Position .. Safety Fail Type Type Passive Position Position I A 1 Globe MvOV A Keylocked Open Closed As-Is AT-I GB 43.401.306 AT-4 OB 43.401.511 BTC OP 24.202.01/.05 GL9605 GP 47.306.01 / .03 PIT 2Y 24.202.05 Page 6 of 6 For System: E4150

DTE ENERGY - FERIVII 2 ISI / IST Pro2ram Plan - Part 5 Valve Scope Table System: E5100 Exain Test Frequency Procedure Number Deferredl Justification Relief Technical Request Position PIS E5100FOl l Reactor Core Isolation Cooling ('RCIC) Pump Supply Fromn DI)VISION N/A Condensate Storage Tank (CST) Check Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 - N/A 6 CK Self Act A System Dependent Open N/A CT-C . OP 24.206.01 CT-OL- OP N/A . TP-01 PIS E51F503 Reactor Core fsolation Coolintg (RCIC) Steam Flow To DIVISION N/A Turbine Excess Flow Check Valve-Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type 'Type Passive P'osition Position I A/C 3/4 XFC Self Act A Open Closed CT-EF SP I 44.220.111 VRR-011I PIT SPI 44.220.111 V RR-0I1 PIS E51F504 Reactor Core Isolation Coolinmg (RCIC) Steam Flow To D)IVISION N/A Turbine Excess Flow Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P~ositioni I A/C 3/4 XFC Self Act A Open Closed CT-EF SPI 44.220.111 VRR-0II PIT SPI 44.220.11.1 .VRR-011 PIS E51F505 Reactor Core Isolation Coolintg (RCIC) Steam Flow To DIVISION N/A Turbine Excess Flow Check-Valve Class Cat Size Valve Actuator Active!/ Normal Position Safety Fail Type Type Passive Position Position I A/C 3/4 XFC Self Act - A Open Closed CT-EF SPI 44.220.112 VRR-0II PIT SPI 44.220.112 VRR-0II PIS E51F506 Reactor Core Isolation Coolinzg ('R CIc) Steamn Flow To D)IVISION N/A Turbine Excess Flow Chteck Valve Class Cat Size Valve Actuator -Active /, Normal Position Sarety Fail Type, Type Passive Position Position I A/C 3/4 XFC Self Act A Open Closed CT-EF SPI 44.220.112 VRR-011 PIT SPI 44.220.112 VRR-01I Page 1 of 1 For System: E5100

DTE ENERGY - FERMI 2 1S1. /.[ST Pr62i"am Plan -Part 5 Valve Scope Table Sytmr55 est Proceduire Deferredl Relief Technical Exam Frequiency Number - Justification Request Position PIS E5150F001 Reactor Core Isolation Cooling (RCIG,) Turbine Exhaust DIJVISION N/A Line Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail

-- Type Type Passive Position Position 2 B/C 10 Stop CK MOV A Keylocked Open Closed As-is BTC OP 24.206.01 GL9605 GP 47.306.01 / .03 PIT 2Y 24.206.02 PIS E5150F002 Reactor Core Isolation Cooling ('RCIC) Barometric D)IVISION N/A Conideniser Vactun~ Pumip Discharge Stop Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 B/C 2 Stop CK MOV A Keylocked Open Closed As-Is BTC OP 24.206.01 GL9605 GP 47.306.01 /.03 PIT 2Y 24.206.02 PIS E5150F007 RCIC Turbine Steam Supply Inbd C'ont. Isol. Valve D)IVISION N/A C:lass Cat Size Valve Actuator Active / Normal P'osition safety Fail Type Type Passive Position Position I A 4 Gate MOV A Keylocked Open Closed As-Is AT-I OB 43.401.305 AT-4 OB 43.401.511 BTC OP 24.206.01/.02 GL9605 OP 47.306.01 /0.3.

PIT 2Y 24.206.02 Page 1"of 5 For System: E5150

DTE ENERGY - FERMI 2 LSI / IST Prop-rami Plan - Part 5 Valve Scope Table Test Procedure Deferred Relief Technical System: E5150 Examn Frequency Number Justitication Request Position PIS E5150F008 RCIC Turbine Steam Supply Outbd Cont. Isol. Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Positioni Safety Fail Type Type Passive Position Position I A 4 Gate MOV A Keylocked Open Closed As-is AT-I OB 43.401.305 AT-4 OB 43.401.511 BTC - OP 24.206.01/.02.

GL9605 GP 47.306.01 / .03 PIT 2Y 24206.02 PIS E515OF010 Reactor Core Isolation Cooling (RCIC) Pump Supply From D)IVISION N/A Condensate Storage Tank (CST) Isolation Valve Class Cat Size Valve Actuator Active / Nornmal Position Safety Fail Type Type Passive Position Position 2 N/A 6 Gate MOV A Open Close As-is BTC OP 24.206.01 BTO OP 24.206.01 GL9605 GP 47.306.01 /.02 PIT 2Y 24.206.02 IS5 E515OF012 Reactor Core Isolation Cooling (RCIC) Pump Discharge DIVISION N/A Isolation Valve Class Cat Size Valve Actuator Active / Norinal Position Safety Fail Type Type Passive Position Position 2 A 6 .Gate MOV A Open Closed As-Is AT-10 GB 43.401.515 V RR-013 BTC OP 24.206.01 PIT 2Y 24.206.02 Page 2 of 5 For System: E5150 -

DTE ENERGY -FERMI 2 ISI/1IST Pro2i-am Plan - Part 5 Valve Scope Table Sytm E 10'est Procedu re Deferred Relief Technical Sytm E10Exam Frequency Number Justification Request Position PIS E515OF013 Reactor-Core Isolation Cooling (RCIC) Punp Supply To D)IVISION N/A Feedwater Header Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type P~assive Position Position I A 6 Gate MOV A Closed Closed As-is AT-I OB 43.401.304 AT-10 OB 43.401.515 VRR-013 AT-4 GB 43.401.511 BTC CS 24.206.02 CSJ-004 GL9605 OP 47.306.01 /.03 PIT 2Y 24.206.02 PIS E5150F019 Reactor Core Isolation Cooling (RCIC)Pump Minimum DINVISION N/A Flow Recirculation Bypass Valve.

C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive _Position Position 2 B 2 Gate MOV A Closed Closed -As-Is BTC OP 24.206.01 GL9605 GP 47.306.01 / .03 PIT 2Y 24.206.02 PIS E51.5OF022 Reactor Core Isolation Cooling (RCJC) Supply to D)IVISION N/A Condensate Storage Tank (CST) Test Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Tye lype Passive Position Position 2 B 4 Globe MOV A Closed Closed As-Is BTC OP 24.206.01 GL9605 GP 47.306.01 /.03 PIT 2Y 24.206.02 Page 3 of 5 For System: E5150

DTE ENERGY - FERMI 2 ISI. /.IST Prooram Plan - Part 5 Valve Scope Table System: E5150 Exam 1'est Frequency Procedlure Number Deferred Relief Justification Request -

Technical Position PIS E515OF029 Reactor Core Isolation Cooling (RCIC) Pump Supply Fronn D)IVIS ION N/A Torus Isolation Valve Class Cat. Size Valve. Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position 2 N/A 6 Gate MOV A Closed Close As-Is BTC OP 24.206.01 BTO OP 24.206.01 GL9605 OP 47.306.01 / .02 PIT 2Y 24.206.02 PIS E515OF031 Reactor Core Isolationt C'ooling (RCIC) Pump Supply From DIIVIS ION N/A Torus Isolation_ Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 B 6 Gate MOV A Closed - Closed As-Is BTC OP 24.206.01 GL9605 GP 47-306.QI1 / .03 PIT 2Y 24.206.02.

PIS E5150F045 Reactor Core Isolation Cooling (RCIC) Turbine Steamii Inlet D)IVISION N/A Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 N/A 4 Gate MOV A Closed Open As-Is GL9605 GP 47.306.01 / .02 PIS E515OF046 Reactor Core Isolation C'ooling ('RCIC) Lube Oil Cooler DI1VISION N/A .Cooling Water Supply Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 N/A 2 Globe MOV .A Closed Open As-is GL9605 GP 47.306.01I /.02 Page 4 of 5 For Systemi: E5150

DTE ENERGY - FERMI 2 tSI / IST Pro;"~am Plan - Part 5 Valve Scope Table Sytmr55 est Procedlure Deferred Relief Technical Ssm: E50Examn Frequency Number Justification Request Position PIS E515OF062 Reactor Core Isolation Cooling (RCIC) Turbine Exhaust D)IVISION N/A Line Vacuum Breaker Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 3 Gate MOV A Open Closed' As-is y AT-I OB 43.401.382 BTC OP 24.206.01/.02 GL9605 GP 47.306.01 / .03

• PIT 2Y 24.206.02 PIS E515OF084 Reactor Core Isolation Cooling (RCIC) Turbine. Exhaust DIVISION N/A . Line Vacuum Breaker Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 3 Gate MOV A Open Closed As-Is AT-I GB 43.401.382 BTC. -OP 24.206.0 1/.02 GL9605 OP 47.306.01 /.03 PIT 2Y 24.206.02 PIS E515OF095 Reactor Core Isolation Cooling ('RCIC) Warm-Up Bypaxss DIVISION N/A Inlet Valve Class Cat Size Valve Actuator Active / Normal P~ositionl Safety Fail Tye TypeC Passive P'osition Position 2 N/A I Globe MOV A Closed Closed. As-is GL9605 -GP 47.306.01 /.02 Page 5 of 5 For Systetn: M50S

• DTE ENERGY - FERMI 2 1S1 / IST Program Plan - Part 5 Valve Scope Table Sse: G 10Test Procedure Deferred Relief Technical Sse: G10Exam Frequency Number Justification Request Position PIS G1100D077 Rupture disc/for Drywell Floor Drains Sump Con tainmnent D)IVIS ION N/A Penetration, X-1IS C:lass Cat Size Valve Actuator Active/I Normal ['ositionm Safety Fail Type Type Passive Position Position 2 D I RD Self Act A Closed Open DT 5Y E313 PIS .G1100D078 Rupture disc for Dgnvell Equipment Drains Sumnp D)IVISION N/A C7ontainmnent Penetration, XY49 Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type Type Passive Position Position 2 D I RD Self Act A Closed Open DT 5Y E314 PIS G1100F003 Sumnp Pumps (SP) Drywell Floor Drains Area Sump Pumps D)IVISION N/A C00IA & C00IB To Floor Drain Collector Tank Out Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 3 Gate AG A Open Closed Closed AT-I GB 43.401.314 AT-4 GB 43.401.511 BTC OP 24.702.01 FST OP 24.702.01 PIT 2Y 24.702.01 PIS G1100FO19 Sumnp Pumps (SP) Drywell Equipment D,-ains Area Sumnp DIVISION N/A Pumps C006A & C006B Collector Tank Outboard Conta Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type "Type tPassive -Position Position 2 A _3 .Gate AG A Open Closed Closed AT-I GB 43.401.315 AT-4 GB 43.401.511" BTC 'OP 24.702.01.

FST OP 24.702.01 JPIT 2Y 24.702.01 Page 1 of 1 For System: G1100

DTE ENERGY - FERMI 2. I1. /IST Prb2ram-Plan Part 5 Valve Scope Table Sytm I5 est Procedure Deferred Relief Technical Sytm G14Exanm Frequency Number Justification Request Position PIS G1154FO18 Drywell Equipment DrainsArea Swmp Pump C006A &

DIVISION N/A O06B Waste Collector Tank Inboard Containment Isol Valve CIass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 3 Gate MOV A Open Closed As=Is AT- i OB 43.401.315 AT-4 OR 43.401.511 BTC CS 24.702.01 CSJ-010 GL9605 GP 47.306.01 /.03

• PIT 2Y 24.702.01 PIS Gil154F600 Drynwell Floor DrainsArea Sump Pumps COO/A & COO/B To D)IVISION N/A Floor Drain Collector Tank Inboard C'ontainmnent Isol Valve C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type_ Type Passive Position Position 2 A 3 Gate MOV A Open Closed As-Is AT-i OB 43.401.314 AT-4 OB 43.401.511 BTC CS 24.702.01 CSJ-O0 GL9605 GP 47.3601 / .03 PIT 2Y 24.702.01 Page 1 of 1 For System: G1154

DTE ENERGY - F.ERIII2 ISI/1IST Program Plan -*Part 5 Valve Scope Table System: G3300 '[est Procedure Deferred Relief Technical Exain Frequency Number Justification Request Position PIS G33FS83 Reactor Water Clean-Up (RWCU) Bottom Head Drain Flow D)IVIS ION N/A Excess Flow Check Valv'e Class Cat Size Valve Actuator Active/I Normal Pousition Safety Fa il Type Type Passive Position Position I A/C I XFC Self Act A Open Closed CT-EF SP I 44.220.1 13 VRR-01l PIT SPI 44.220.113 VRR-011 Page I of 1 For System: G3300

DTE ENERGY - FERMI 2 ISI/ IST Program Plan - Part 5 Valve Scope Table Sse: G 32Test Procedure Deferred Relief Technical Sytm G32Exam Frequency Number 3ustification Request Position PIS G3352F001 Reactor Water Clean-Up (RWCU)Inboard Cont. Isol. Valve DIV'ISION N/A Class Cat Size Valve Actuator Active I Normal Position Safety Fail Type Type Passive Position Position 1 A 6 Gate MOV A Open Closed As-Is AT-i OB 43.401.348 BTC RR 24.707.01 ROJ-006 GL9605 GP 47.306.01 / .03 PIT 2Y 24.707.01 PIS G3352F004 Reactor Water Clean-Up (RWCU) Outboard Cont. Isol. Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 1 A 6 Gate MOV A Open Closed As-Is AT-I 0OB 43.401.348 BTC RR 24.707.01 ROJ-006 GL9605 GP 47.306.01 / .03 PIT 2Y 24.707.01 PIS G3352F220 Reactor Water Clean-Up (RWCU) Division 2 Cont. Isol.

DIVISION N/A Motor Operated Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 1 A 4 Gate MOV A Open Closed As-Is AT-i OB 43.401.304 AT-4 OB 43.401.511 B3TC RR 24.707.01 ROJ-006 GL9605 GP 47.306.01 / .03 PIT 2Y 24.707.01 Page 1 of 1 For System: G3352

DTE ENERGY - FERI'v 2 ISI / 1ST Program Plan - Part 5 Valve Scope Table Technical Sse: G 10Test Procedu re Deferred. Relief Sytm G10Exant Frequency Number Justification Request Position PIS G510OF600 Torus Water Management (TWM) Torus Drain AZ-I1/2-30 D)IVISION N/A Inboard Isolation Valve Class Cat Size Valve Aetuator Active/I Normal Position Safety Fail Type Type Passive Position Position 2 A 6 Gate MOv A Closed Closed As-is AT-2 OB 43.401.407 BTC OP 24.144.01 GL9605. GP 47.306.01 / .03 PIT. 2Y 24.144.01 PIS G510OF601 Torus Water Management (TWM) Torus Drain AZ-112-30 D)IVIS ION N/A Outboard Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive P~ositioni Position 2 A- 6 Gate MOV A Open Closed As-Is AT-2 OB 43.401.407 BTC OP 24.144.01" GL9605 GP 47.306.01 / .03 PIT 2Y 24.144.01 PIlS G510OF602 Torus Water Management (TWM) Torus Drain AZ-192-30

• DIVISION N/A Inboard Isolation Valve Class Cat Size Valve Actuator Active I Normnal Position Safety Fail Type ype Passive I'osition P'ositin 2 A 6 Gate MOV A Closed Closed As-Is AT-2 OB 43.401.408 BTC OP 24.144.01 GL9605 GP 47.306.01 / .03 PIT 2Y 24.144.01 Page 1 of 3 For System: G5100

DTE ENERGY - FERMI-2 ISI / 1IST Pro;~ram Plan - Part 5 Valve Scope Table Sse'. G 10Test Procedure Deferred Relief Technical Examn Fe~equency Number Justification Request Position PIS G510OF603 Torus Water Management (TWM{) Torus Drain AZ-292-30 D)IVISION N/A OutboardIsolation Valve Class. Cat Size Valve Actuatoir Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 6 Gate MOV A Open Closed As-Is AT-2 OB 43.401.408 B3TC . OP 24.144.01 GL9605 GP 47.306.01 /.03 PIT 2Y 24.144.01 PIS G510OF604 Torus Water Management (TWM) To Residual Heat Remo val DIVISION N/A (RHR)~ Test Line In board Isolation Valve Class Cat Size Valve Aciuator Active / Normal Position Safety Fail Typ.e Type Passive Position Position 2 A 4 Gt MV AClosed Closed As-is AT-2 OB 43.401.405 BTC OP 24.144.01 GL9605 GP 47.306.01 /.0'3 PIT -2Y 24.144.01 PIS G510OF605 Torus Water Management (TWM) To Residual Heat Removal DIVISION N/A (RHR. Test Line Outboard Isolation Valve Class Cat Size Valve Actuatoi Active / Normal Position Safety Fail Type Tylpe Passive Position P'ositioni 2 A 4 ,Gate MOV A Open Closed As-Is AT-2 OB 43.401.405 BTC OP 24.144.01 GL9605 OP 47.306.01 / .03 PIT 2Y 24.144.01 Page 2 of 3. For Systemn: G5100

DTE ENERGY - FERMI 2 181 I1ST'Proeram Plan - Part 5 Valve Scope Table Sse: G 10Test Procedure Deferred Relief Tech nical Syte: 510Ex am Frequency Number Justitication Request Position PIS G510OF606 Torus Water Management (TWM) To Core Spray (CS) Test D)IVISION N/A Line Inboard Isolation Valve Class Cat Size Valve Actuator Active / Normal P'osition Safetv Fail Type Type Passive Position Position 2 A 4 Gate MOV A Closed Closed As-Is AT-2 GB 43.401.420 BTC OP 24.144.01 GL9605 OP 47.306.01 /.03 PIT 2Y 24.144.01 PIS G510OF607 Torus Water Management (TWM) To Core Spray (CS) Test DIVISION N/A Line Outboard Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P'ositioni 2 A 4 Gate MOV A Open Closed As-Is AT-2 OB 43.401.420 BTC OP 24.144.01 GL9605 GP 47.306.01 /.03 PIT 2Y 24.144.01 Page 3 of 3 For Systemn: G5100

\ Z DTE ENERGY - FERLVI 2 ISI1/1IST Pro;;ram Plan - Part 5 Valve Scope Table Procedure Deferred Relief Technical SytmT20 Iest Sytm N10Exam Frequency Number Justification Request Position PIS N21F539A Feedwater Entering Reactor Pressure Vessel Excess Flow D)IVISION ICheck Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive P~osition Position I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.112 VRR-01 I PIT SPI 44.220.112 VRR-01I PIS N21F539B Feedwater Entering Reactor Pressure Vessel Excess Flow ICheck DIVISON Valve.

Class Cat Size Valve Actuator .Active / Normal Position Safety Fail Type Type Passive Position Positin I A/C I XFC Self Act A Open Closed CT-EF SPI 44.220.1 10 VRR-01 I PIT SPI 44.220.110 VRR-011 Page 1 of 1 For System: N2100

DTE ENERGY - FERMI 2 ISI / [ST Pro2ram Plan - Part 5 Valve Scope Table S te: 110Test Procedure Deferred Relief Technical Sytm P10Exam Frequency Number Justification Request Position PIS P1 10OF126 Demineralized Service Water Risers (DSWR) Dr-yiwell Supply%

D)IVIS ION N/A HeaderInboard Cont. Isol. Valve.

Class Cat Size Valve Actuator Active!/ Normal Position Safety Fail Type Type. Passive Position Position 2 A 6 Gate MAN P Locked Closed CLOSED N/A AT-1 OB 43.401.316 Page 1 of 1 For System: P1100

DTE' ENERGY - FERMI 2 ISI1/IST Program Plan - Part 5 Valve Scope Table System: P3400 Exam Test Frequency Procedure Numnber Deferred Justification Relief Request Technical Position PIS P34F401A Solenoid Valve. Post Accident Sampling (PAS V13-7360 D)IVISION 2 Class Cat Size V'alve Actuator Active I Normal Position Safety Fail Type Type Passive Position Position I A 3/4 Globe SOy A Closed Closed Closed AT-I OB 43.401.329 AT-4 OB 43.401.511 BTC OP 24.714.01 PIT OB 43.401.329 VRR-012 PIS P34F401B Solenoid Valve: Post Accident Sampling (PAS) V13-7361 DIVISION I Class Cat Size Valve Act ator Active / Normal P~osition Safety Fail Type Type P'assive Position Position I A 3/4 Globe SOV A Closed Closed Closed AT- I GB 43.401.346 AT-4 GB 43.401.511 BTC OP 24.714.01 PIT GB . 43.401.346 VRR-012 PIS P34F402A Solenoid Valve: Post Accident Sampling ('PAS) V13-7363 DIVISION 2 Class Cat~ Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position losition P

2 B 3/4 Globe SOy A Closed Closed Closed BTC OP 24.714.01 PIT 2Y 78.000.17 PIS P34F402B Solenoid Valve: Post Accident Sampling (PAS5) V13-7362 D)IVISION I Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Typse Passive Position Position 2 B 3/4 Globe SOV A Closed Closed Closed BTC OP 24.714.01 PIT 2Y 78.000. 17 Page 1 of 5 For System: P3400

DTE ENERGY - FERIVI 2 ISI/ IST Propram Plan - Part 5 Valve Scope Table System: P30 340Test xm Frequency Procedlure Number Deferred Justification Relief Request Technical Position PIS P34F403A Solenoid Valve: Post Accident Sampling (PAS) 1V13-7364 D)IVISON 2 Class Cat Size Valve Actuator' Active/I Normal Position Sarety Fail Type Type Passive Position Position 2 A 3/4 Globe SOV A Closed Closed Closed AT-I 0OB 43.401.324 AT-4 013 43.401.511 BTC OP 24.714.01 PIT 0OB 43.401.324 VRR-012 PIS P34F403B. Solenoid Valve: Post Accident Sampling (PAS) V13-7365' DIVISION  !

Class Cat .Size Valve -Actuator Active? Normal Position Safety Fail Type Type .Passive Position P~osition 2 A 3/4 Globe SOV A .Closed Closed Closed AT- I OB 43.401.359 AT-4 OB 43.401.511 BTC OP 24.714.01 PIT GB 43.401.359 VRR-012 PIS P34F404A Solenoid Valve: Post Accident Samipling (PAS) V13-7374 DIVISION 2 Class .Cat Size Valve' Actuator Active / Normal Position Safety Fail Type Type Passive ['ositioni Position 2 A 3/4 Globe SOV A Closed Closed Closed AT-I GB 43,401.324 AT-4 OB 43.401.511 BTC OP 24.714.01 PIT OB 43,40.1.324 VRR-012 Page 2 of 5 Foi- System: P3400

DIE ENERGY - FERVII 2 1S1 / 1ST Pro2ram Plan - Part 5 Valve Scope Table Test Proceclure Deferred Relief Technical System: P3400 Exam Frequency Number Justitication Request Position-PIS P34F404B Solenoid Valve: Post Accident Samnpling (PAS) V13-7375 D)IVISION I Class Cat Size Valve Actuator Active / Normal Positin Safety Fa il Type Type Passive Position Position 2 A 3/4 Globe SOV A Closed Closed Closed AT-I OB 43.401.359 AT-4 OB 43.401.511 BTC OP 24.714.01 PIT OB 43.401.359 VRR-012 PIS P34F405A Solenoid Valve: Post Accident Sampling (PAS) V13-7366 DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety' Fail Type Tylpe Passive Position. Position 2 A 3/4 Globe SOV A Closed Closed Closed AT-I GB 43.401.387 AT-4 GB 43.401.511 BTC OP 24-714.01 PIT GB 43.401.387 VRR-012 PIS P34F405B Solentoid Valve: Post Accident Sampling (PAS) V13-7367 DIVIlSION 1 Class Cat Size V'alve Actuator Active / Normal Position Safety Fail Type TIype Passive Positionm Position 2 A 3/4 Globe SOV A Closed Closed Closed AT-I GB 43.401.386 AT-4 GB 43.401.511 BTC OP 24.714.01 PIT GB 43.401.386 VRR-012 Page 3 of 5 For System: P3400

DTE ENERGY -FERMI 2 ISI/1ST Program Plan - Part 5 Valve Scope Table Sytm'P40rest Procedure Deferred Relief Technical Sysem: P34in Frequency Number .1ustitication Request Position.

PIS P34F406A Solenoid Va/ve: PostA ccident Sampling (P/AS) V13-7376 D)IVISION 2 Class 'Cat Size Valve Actuator Active / Normal P'osition Safety Fa il

- Type Type Passive Position Position 2 A 3/4 Globe SOy A Closed Closed Closed AT-I OB 43.401.387 AT-4. GB 43.401.511 BTC OP 24.714.01 PIT GB 43.401.387 VRR-012 PIS P34F406B Solenoid Valve: Post Accident Sampling (PAS) V13-7377 DIVISIONI Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 3/4 Globe Sov A Closed Closed Closed AT-I GB 43.401,386 AT-4 GB 43.401.511 BTC .OP 24.714.01 PIT GB 43.401.386 VRR-012 PIS P34F407 Solenoid Valve: Post Accident Sampling (PAS) V13-7368 DIVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Typ)e Passive Position Position 2 A 3/4 Globe SGV A Closed Closed Closed AT-2 GB 43.401.405 BTC OP 24.714.01 PIT GB 43.401.405 VR.R-012 Page 4 of 5 For Systemn: P3400

DTE ENERGY - FERLVII2 ISI1/1IST Program Plan - Part 5 Valve Scope Table Test P~rocedure Deferred Relief Technical Sytm-3 0 Exam Frequency Number Justification Request Position PIS P34F408 Solenoid Valve: Post Accident Sampling ('PAS) V13-7369 D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 3/4 Globe SOV A Closed Closed Closed AT-I OB 43.401.383 AT-4 OB 43.401.511 BTC OP 24.714.01

-PIT GB 43.401.383 VRR-012.

PIS P34F409 Solenoid Valve: Post Accident Sanrpling (PAS) V13-7378 D)IVISION I Class Cat Size .Valve ACtUator' Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 3/4 Globe SOV A Closed Closed Closed AT-2 OB 43.401.405 BTC OP 24.714.01 PIT GB 43.401.405 VRR-012 PIS P34F410 .Solenoid Vailve: Post Accident Sampling ("PA S) V13-7379 D)IVISION 2 Class Cat Size V'alve Actuator Active / Normal P'osition Safety Fail Type Type Passive -Position Position 2 A 3/4 Globe SOV A Closed Closed Closed AT-I GB 43.401.383 AT-4 OB 43.401.511 BTC OP 24.714.01 PIT GB 43.401.383 VRR-012.

Page 5 of 5 For Systetm: P3400

DTE ENERGY - FERMI 2 ISI1/1ST Program Plan - Part 5 Valve Scope Table S te: P 20Test Procedure Deferred Relief Technical Sytm P20Exam Frequency Number Justification Request Position PIS P420OF105 RBCCW Make-up Tank Relief Valve.

D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC >.C I RLF Self Act A Closed. Open, CT-SP MOY 43.000.020 Page 1, of 1 For System: P4200

DTE ENERGY - FERMVII2 ISI/1ST Prog3ram Plan - Part 5 Valve Scope Table P 4 0 Tytm est Procedure Deterred Relief Technical Sse: P 40Exa1n Frequency Number Justification Request Position PIS P440OF003A EECW Div. I Pump COO/A4 Discharge Check Vahre.

D)IVISION I Class Cat Size Valve Actuator Active / Normal lPosition safety Fail Type Ty,pe Passive Position Position 3 C 8 CK Self Act A System Dependent Open CT-DI 6R 43.000.010 CMP-08 CT-0 OP 24.207.08 PIS P440OF003B EECW Div. HIPump COO/B Discharge Chzeck Valve.

DIVISION 2 Class Cat Size Valve Actuator Active/ Normal Position Safety Fail Type. Type Passive Position Position 3 C 8 CK Self Act A System Dependent Open CT-DI 6R 43.000.010 CMP-08 CT-0 OP 24.207.09-PIS P440OF038 EECW Div. I Battery Room Space C'oler B033 Retuirn Check DIVISION I Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 1 112 CK Self Act A System Dependent Closed AT-14 2R 43.401.605 CT-C OP 24.207.08 CT-OL OL N/A TP-01 PIS P440OF051 EECW Div. / Essenstial Equipment Return Check Valve.

DIVISION I Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type T,ype Passive Position Position 3 C 6 CK Self Act A System Dependent Open CT-DI .4R .43.000.010 CMP-07 CT-OP OP 24.207.08 Page 1 of 15 For- System: P4400

DTE ENERGY - FER I 2 181 / IST ProjZram Plan - Part 5 Valve Scope Table Sytm 4 0 Test P~rocedu re Deferred Relief Technical SytmGP40Eain Frequency Numtber Justitication Req uest Position PIS P440OF077A EECW Div. 1Pwrnp A Supply to Essential Equipment Check DIJVISION IValve.

Class Cat Size Valve Actuator Active I Normal Position Safety Fail Type Type Passive' Posi tioni Position

3. C 8 CK Self Act A System Dependent Open CT-DI 6R 43.000.010 CMP-08 CT-0 OP 24.207.08 PIS P440OF077B EECW Div. If Pumnp COOIB Supply to Essential Equipment DIVISION 2 Check Valve.

Class Cat Size Valve Actuiator Active / Normal Position Safety Fail Type Type Passive P'ositioni Position 3 C 8 CK Self Act A System Dependent Open CT-DI 6R 43.000.010 CMP-08 CT-0 OP 24.207.09 PIS P440OF1033A Emergency Equipment Cooling Water (EECW) Plate and DIVISION I Frame Heat Exchanger BOOMI Relief Valve Class Cat Size V'alve Actuator Active / Normal Position Safety Fail Type Type Passive . Position Position 3 C I TReI Self Act A Closed Open CT-SP 1OY 43,000.020 PIS P440OF1033B Emtergency Equipment Cooling Water ('EECW) Plate and D)IVISION 2 Framre Heat Exchanger BOOIB Relief Valve Class Cat Size. Valve Actuator Active/I Normal Position Safety FailI Type Type Passive Position Position 3 C I TReI Self Act A Closed .Open CT-SP lIOY 43,000.020 PIS P440OF1033C Div I EECW Plate and Frame Heat Exchanger BOO IC Relief DIVISION I Valve Class Cat Size Valve iActiiator~ Active I Nornial Position Safety Fail Type Type Passive .Position P'osition 3 C I TReI Self Act A . Closed Open CT-SP lOY 43.000.020

/ Page 2 of 15 For System: P4400

DTE ENERGY - FERMI 2 181 / IST Propgram Plan - Part 5 Valve Scope Table System: P4400 Exam Test Frequency Procedure-Number Deferred Justification Relief' Request Technical Position PIS P440OF1033D Div 2 EECW Plate and FraiiieHeat Exchanger BOO ID Relief DIVISION 2 Valve Class Cat Size Valve Actuator Active/ Normal P'osition, Sarety Fail Type Type Passive Position Position 3 C I TRel SelfAct A Closed Open CT-SP MOY 43.000.020 PIS P440OF111A EECW Div. I Reactor Bldg.Equipment SumnpHt. Exchanger. -

D)IVISION IB002 Return CTheck Valve.

C:lass Cat Size Valve Actuator Active/I Normal Position Sal"etv Fail Type Typc Passive .Position Position 3 C 2 CK Self Act A System Dependent Closed AT-14 2R 43.401.605 CT-C OP 24.207.08

- CT-OL- OL N/A TP-01 PIS P440OF111B EECW Div. lIIReactor Bldg.Equipmntt Stimp Ht. Exchanger DIVISION 2 B002 Return Check Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 1 1/2 CK Self Act A System Dependent Closed AT-14 2R 43.401.606 CT-C OP 24.207.09 CT-OL OL N/A TP-01 PIS P440OF116A EECW Div. I Return Header Chteck Valve.

DIVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail "Type Type Passive Position P'osition 3 . C 6 CK Self Act A System Dependent Open CT-DI 4R 43.000.010 CMP-07 CT-OP OP 24.207.08

- Page 3 of 15 For System: P4400

DTE ENERGY - FERMI 2 ISI / 1ST Pro, -am Plan. Part 5 Valve Scope Table System: P4400 Test U.requency Procedu,re Number Deferred Justification Relief Request Technical Position Exam PIS P440OF116B EECW Div. 11 Return. Header Check Valve.

D)IVISION 2 Class Cat Size Valve Actuator Active!/ Normal ['osition 'Safety Fa il Type . Type Passive Position P'osition 3 C 8 CK Self Act A System Dependent Open CT-DI 4R 43.000.010 CMP-67 CT-OP OP 24.207.09 PI S P440OF126A EECW Div. I Make- Up Tank A 00/ Relief Valve.

DIVISION I Class Cat Size Valve Actuator. Active / Normal Position Safety Fail Type Type Passive Position Position

.3 A/C I KLF SelfAct A Closed Open AT-14 1R 43.401.600 CT-SP joy 43.000.020 PIS P440OF126B EECW Div. 11 Make-Up Tank A002 Relief Valve.

DIVISION 2 C;lass Cat Size Valve Actuator Active!/ Normal Position Safety, Fail Type Type Passive Position Position 3 A/C 1 RLF Self Act A Closed Open AT-14 1lR 43.401.601 CT-SP lOY 43.000.020 PIS P440OF165 EECW D,v. 11 Return Header Check Valve.

DIVISION 2 Class Cat Size Valve Actuator Active! Normal Position Safety, Fail Typ.e Type tPassive Position Position 3 C 6 . CK Self Act A System Dependent Open CT-DI 4R 43.000.010 CMP-07 CT-OP OP 24.207.09 Page 4 of 15 For System: P4400

DTE ENERGY - FERI I2 IS1 / 1IST Program Plan - Part 5 Valve Scope Table Sse : P 4 0Test Procedlure Deferredl Relief Technical Sytm: P 40 xamn Frequency Number Justification Request Position PIS P440OF182 EECW Div. HI CRD Pump Coolers Return Clheck Valve.

D)IVISION 2 Class Cat Size V'alve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 2 CK Self Act A System Dependent Closed AT-14 2R 43.401.606 CT-C CS 24.207.11 CSJ-003 CT-OL- OL N/A TP-0I PIS ,P440OF245A EECW Div. I Relief/Valve.

DIVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 1 1/2 TReI Self Act A Closed Open CT-SP IOY 43.000.020 PIS P440OF245B EECW Div'. 2 Relief/Valve.

DIVISION 2 Class Cat Size Valve Actuator Active! Normal Position Safety Fail Type Type Passive Position Position 3 C 1 1/2 TReI Self Act A Closed Open CT-SP lOY 43.000.020 PIS 'P4400F246 EECW Div IDryweli Penetration Coolers Return Check D)IVISION iValve.

Class' Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive. Position Position 3 C 2 CK Self Act A System Dependent Closed AT-14 2R 43.401.605 CT-C RR .24.207.04 ROJ-009 CT-O1L OL N/A TP-0l Page 5 of 15 For System: P4400

DTE ENERGY - FERMVII2 181 / IST Pr62ram Plan - Part 5 Valve Scope Table Sse: P 40Test Procedure Deferred Relief Technical Sse: P40Exam Frequency Number Justification Request Position PIS P440OF274 EECW Div. 11 Drywell Sump Heat Evchsanger Return C?heck lDIVISION 2 Valve.

Class Cat Size Valve Actuator Active I Normal Position Safety Fa il Type Type Passive Position Position 3 C 2 1/2 CK Self Act A System Dependent Closed AT-14 2R 43.401.606 CT-C RR 24:207.11 ROJ-009 CT-OL OL N/A TP-01 P440OF282A

_._.: ... EECW....Div. I Supply

.... to Drywell

...... Equipntent Check Valve

._..PIS D)IVISION I Class Cat Size Valve Actuator Active I Normal Position Safety Fail Type Type Passive Position Position 3 A/C 6 CK Self Act A System Dependent Closed AT-I OB 43.401.319 AT-4 OB 43.401.511 CT-C RR 43.401.319/.607 ROJ-002 CT-OL OL N/A TP-01 PIS P440OF282B EECW Div. II Supply to Drywell Equipment Clheck Valve D)IVISION 2 Class Cat Size Valve Actuator Active / Norma[ P'osition Safety Fail Type .Type Passive Position Position 3 A/C 6 CK Self Act A System Dependent .Closed AT-I OB 43.401.335 AT-4 OB 43.401.511 CT-C 2Y 43.401.335/.608 ROJ-002 CT-OL OL N/A TP-0I PIS P440OF387A EECW Div. I Nitrogen Supply to EECW Make-uip Tank A001 DIVISION I Relief Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 A/C- 1 RLF Self Act A Closed Open AT-14 IR 43.401.600 CT-SP IOY 43.000.020 Page 6 of 15 For System: P4400,

DTE ENERGY - FERMVI 2 ISI1 /.IST Proaram Plan - Part 5 Valve.Scope Table Sse : P 40Test Procedure Deferred Relief Technical Sytm P 40Examn Frequency Number Justification Request Position PIS P440OF387B EECW Div. 1I Nitrogen Supply to EECW Make-up Tank A002 D)IVISION 2 Relief Valve.

Class Cat Size Valve Actuator Active / Normal P'ositioni Safety Fail Type Type Passive Position Position 3 A/C I RLF Self Act A Closed Open .

AT-14 IlR 43.401.601 CT-SP IOY 43.000.020 PIS P440OF504A Div I EECW Makeup Pump Discharge Isolation Valve DIVISION I Class Cat Size V'alve Actuator Active/ Normal Position Safety Fa il Type Type Passive Position Pos itin 3 B 1.5 Gate AO A Closed Open Open BTO OP 24.208.02 FST OP 24.208.02 PIT 2Y 24.208.02 PIS P440OF504B Div 11 EECW Makeup Ptump Discharge Isolation Valve DIVISION 2 ClIass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type P'assive Position Position 3 B 1.5 Gate AO A Closed Open Open BTO OP 24.208.03 FST OP 24.208.03 PIT 2Y 24.208.03 PIS P440OF601A RBCCW Div. I Return Isolation Valve.

D)IVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 B 8 Gate MOV A Open Closed As-Is AT-14 2R 43.401.605 BTC OP 24.207.08/.05 GL9605 GP 47.306.01 /.03 PIT 2Y 24.207.05 Page 7 of 15 For System: P4400

DTE ENERGY - FERMVI 2 ISI / 1ST. Pro; ram Plan'- Part 5 Valve Scope Table System: P4400 Trest Frequiency Procedure Nuimber Deferred Justitication Relief Request Technical Position Exam PIS P440OF601B RBCCW Div/If Return Isolation Valve.

D)IVISION 2 C'lass ('at Size Valve Actuator Active / Normal Position Sarety Fail Type Type Passive Position Position 3 B 10 Gate MOV A Open Closed Asas AT-14 2R 43.401.606 BTC OP 24.207.09/.05 GL9605 GP 47.306.01 /.03 PIT 2Y 24.207.05 PIS P440OF602A EECWDiv. [Ma/ke-up Water Tan/c P4400A001 Outlet DIVISION I Isolation Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety. Fail TypeL Type Passive Position Position 3 B 4 Gate MOV A Closed Open As-Is BTO OP 24.207.08/.05 GL9605 GP 47.306.01 /.03 PIT 2Y 24.207.05 PIS P440OF602B EECW Div. I Make-up Water Tank P440OA001 Outlet DIVISION 2 Isolation Valve.

Class "Cat Size Valve Actuator Active!/ Nor'ial Position, Safety Fail Type Type Passive .Position P'osition 3 B 4 Gate MOV A Closed Open As-is BTO OP 24.207.09/.05 GL9605 GP 47-306.01 / .03 PIT 2Y 24.207.05 PIS P440OF603A EECW Div. I Supply Isolation Valve.

DIVISION I Class Cat. Size Valve Actuator Active!/ Normal Position Safety Fail Type Type Passive Position Position 3 B 8 Gate MOV A open Closed As-Is AT-14 2R 43-401.605 BTC OP 24.207.08/.05 GL9605 OP 47.306.01 / .03 PIT 2Y .24.207.05 Page 8 of 15 For System: P4400

DTE ENERGY - FERMVI2 ISI/IST Pro2ram Plan - Part 5 Valve Scope Table Sse: P 40Test Procedure Deferred -Relief Technical Syte: 440Exam Frequency Number Justification Request Position PIS P440OF603B EECW Div. 11 Supply Isolation Valve. 2) F603B D)IVISION -2 automatically closes upon EECW initiation to iso/at Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type V Passive Position .Position 3 B 10 Gate MOV A Open Closed As-is AT-14 2R 43.40L.606 BTC OP 24.207.09/.05 GL9605 GP 47.306.01 /.03 "

PIT 2Y 24.207.05 PIS P440OF604 EECW Div. HI Supply to Control Rod Drive Pumps Isola D)IVISION 2 Class .Cat Size Valve Actuator Active I Normal Position Safety Fail Type Type Passive .Position Position 3 B 2 Globe MOV A Open Closed As-Is AT-14 2R 43.401.606 BTC CS 24.207.11 CSJ-003 GL9605 GP 47.306.01 / .03 PIT 2Y 24.207.11 PIS- P440OF605A EECW Div. I Supply to Reactor Building Equipment Suntp DIVISION I Heat Exchanger B002A Isolation Valve Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type Type Passive. P'osition Position 3 B 2 Globe MOV A Open. Closed As-Is AT-14 2R 43.401.605 BTC OP 24.207.08/.05 GL9605 GP 47.306.01 / .03 PIT. 2Y 24.207.05 Page 9 of 15 For System: P4400

DTE ENERGY - FERIVI 2 ISI I1ST"Program Plan -. Part 5 Valve Scope Table Sytm 40 est Procedure Deferred Meied Tfechnical Sytm P40Exam Frequency Number Justification Request Position PIS P440OF605B EECW Div'. 11/Supply to Reactor Building Equipment Sumup DIVISION 2 Heat Exclhanger B002A Isolation Valve.

Class Cat Size Valve. Actuator Active! Normal P'osition Safety Fail Type Type Passive Positioni Position 3 B 1 1/2 'Globe MOV A Open Closed As-is AT-14 2R 43401.606 BTC OP 24.207.09/.05 GL9605 GP 47.306.01 /1.03 PIT 2Y 24.207.05 PIS P440OF606A EECW Div. I Drywell Supply Outboard Isolation Valve.

DIVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Typse Passiv e Position P~osition 2 A 6 Gate Mov A Open Closed As-Is AT- I OB 43.401.319 AT-4 OB 43.401.511 BTC CS 24.207.04 CSJ-015 GL9605 OP 47-306.01 /.03 PIT 2Y 24.207.04 PIS P440OF606B EECW Div. 11 Drywvell Supply Outboard Isolation Valve.

DIVISION 2 Class Cat Size Valve Actuator Active!t Normal Position Safety Fail Type Type Passive Position Position 2 A 6 Gate .MOV A Open Closed As-Is AT-I .OB 43.401.335 AT-4 OB . 43.401.511 BTC CS 24.207.11 CSJ-015 GL9605 GP 471306.01 /,.03 PIT 2Y 24.207.11 Page 10 of 15, For System: P4400

DTE ENERGY -FERMVI 2 IS1 / IST Pro2ram Plan - Part 5 Valve Scope Table SytmT40 est Procedure - Deferred Relief Technical Sytm P40Examr Frequency Number Justification Request Position PIS P440OF607A EECW Div. I Drywvell Relurn Outboard Isolation Valve.

D)IVISION I Class Cat Size V'alve Actuator Active / Normal Position Safety Fail Type Type Passive Position P'osition 2 A 6 Gate MOV A Openi Closed As-is AT- I OB 43.401.320 AT-4 GB 43.401.511 BTC CS 24.207.04 CSJ-015 GL9605 OP 47.306.01 /.03 PIT 2Y 24.207.04 PIS P440OF607B EECW Div. II Dryvell Equipment Return Outboard Isolation D)IVISION 2 Valve..

Class Cat Size Valve Actuator Active/I Normal Positioii Safety Fail Type Type P'assive Position P'osition-2 A 6 -Gate MOV A Open Closed As-is AT-I GB 43.401.336 AT-4 GB 43.401.511 BTC CS 24.207.I1 CSJ-015 GL9605 GP 47.306.01 / .03 PIT 2Y 24.207.11 PIS P440OF608 EECW Div. /1 Supply to Reactor Buildintg Equipment Sunmp

- DIVISION 2 Heat Exchanger B002A Isolation Valve.

Class Cat Size Valve Actuator Active / Nornml Position Safet~ Fail Type Type Passive Position P~ositionm 3 B 2 1/2 Gate MOV A Open . Closed As-is AT-14 2R 43.401.606

• BTC OP 24.207.09/.I1 GL9605 GP 47.306.01 / .03 PIT 2Y 24.207.11 Page 11 of 15 - For System: P4400

DTE ENERGY - FERMI 2 rISU! IST Pro2ram Plan - Part 5 .Valve Scope Table Sse: P 40Test Procedure Oererrecl Relier Technical Sse: P40Exam Frequency Number .Justification Request Position PIS P440OF613 EECW Div. I Suppl v to Battery Room Space Cooler B033 D)IVISION I Isolation Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type. Type Passive Position 'Position 3 B 11/2 Globe MOV A Open Closed As-is AT-14 2R '43.401.605 BTC OP 24.207.03/.05 GL9605 GP . 47.306.01 1 .03 PIT 2Y 24.207.05 PIS P440OF614 EECW Div.:ISupply to Drywell Penetration Coolers DIVISION I Isolation Valve Class .Cat Size Valve Actuator 'Active/ Normal Position Safe'ty Fail Typ 1 e Typ)e P'assiv'e Position P~osition 2 *B 2 Globe MOV A Open .Closed As-Is AT-1l4 2R 43.401.605 BTC OP 24.207.08/.04 GL9605 GP 47.306.01 / .03 PIT 2.Y 24.207.04 PIS P440OF615 EECW Div. II Drywell Equipment hIboard Return Isolation DIVISION 2 . Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Positio Position 2 A 6 .Gate MOV A Keylocked Open Closed As-Is AT-I. GB 43.401.336 AT-4 GB 43.401.511 BTC CS 24.207.11 .CSJ-015 GL9605 OP . 47.306.01 / .03 PIT 2Y 24.207.11 Page 12 of 15 For System: P4400

DTE ENERGY - FERiVII 2 I1IST Propram Plan - Part 5 Valve Scope Table System: P4400 ______Esain

'rest Frequency Procedure Number Deferred

.1ustification ReliefTe~chnical Request Position PIS P4400F616 EECW Div. I Diyvvel/ Equipment Inboard Return Isolation D)IVISION I Valve.

Class Cat Size Valve Actuator Active / Normal Position Sarety Fa il Type Type Passive Position Position 3 A 6 Gate MOV A Keylocked Open Closed As-is AT-I OB 43.40L.320 AT-4 OB 43.401.511 BTC CS 24.207.04 CSJ-015 GL9605 OP 47-306.01 /.03 PIT 2Y 24.207.04 PIS P440OF625A Div I EECW Makeup Pump Discharge Check Valve DIVISION 1 Class Cat Size Valve Actuator Active / Normal Position Saf'ety Fail Type Type Passive Position Position 3 C 1.5 CK Self Act A System Dependent Both CT-C OP 24.208.02 CT-0 OP 24.208.02 PIS P440OF625B Div HI EECW Makeup Pump Disciharge Check Valve D)IVISION 2 Class ('at Size Valve Actuator Active / .Normal Position Safety Fail Type .Type Passive Position Position 3 C 1.5 CK Self Act A System Dependent Both CT-C_ OP 24.208.03 CT-0 OP 24.208.03 PIS P440OF972A EECW Div. I Dentin Water to Make-up Tank A00I Check DIVISION I Valve.

Class Cat' Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 A/C 4 CK Self Act A System Dependent Closed AT-14 IR 43.401.600 CT-C - OP 24.207.08 CT-0 OP 24.207.08 Page 13 of 15 For System: P4400

DTE ENERGY - FERMI 2 1SI51 I1ST Proaram Plan - Part 5 Valve Scope Table Sse' p 40Test P~rocetlure Deferred Relief Technical Sse: P 40Exam Frequency Number jIustiticationi Request Position PIS P440OF972B EECW Div'. [I Dentin Water to Make-up Tank A002 Check D)IVISION 2 Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type. Type Passive Position Position

.3 A/C 4 CK Self Act A System Dependent Closed AT714 IR 43.401.601 CT-C OP 24.207.09 CT-0 OP 24.207.09 PIS P440OF974A EECW Div. I Nitrogen Supply to EECW Make-up Tank A00I D)IVISION I Check Valve.

Class Cat .Size Valve Actuator' Active / Normal. Position Safety Fail Type Type' Passive Position Position 3 A/C i CK Self Act. A System Dependent Closed AT-14 IR 43.401.600 CT-C OP 24.207.08 CT-OL OL N/A TP-0l PIS P440OF974B EECW Div. H Nitrogen Supply to EECW Make-up Tank A002 DINIISION 2 Chcek Valve.

C:lass Cat Size Valve Actuator Active / Normal Position Sarety Fail Type Type Passive Position Position 3 A/C I CK Self Act A System Dependent Closed AT-14 IR 43.401.601 CT-C OP 24.207.09 CT-OL OL N/A TP-0 I PIS P440OF978A EECW Div. IAlt. Nitrogen Supply to EECW Make-tip Tank DIVISION I A001 Check Valve.

Class Cat Size Valve Actuator Active!/ Normal Position Safety Fail

- Type . Type. Passive Position Position 3 A/C 3/4 CK Self Act . A System Dependent Both AT-14 IR 43.401.600 CT-C OP 24.207.08 CT-0 OP ' 24.207.08 Page 14 of 15 For System: P4400

DIE ENERGY - FERMI 2 181. / IST Program Plan - Part 5 Valve Scope Table Sse : P 40Test Procedure Deterred Relief Technical Sse: P40Exam Frequency Number Justification Request Position PIS P440OF979A EECW Div. I Alt. Nitrogen Supply to EECW Make-Lip Tank DIVISION I A001 Check Valve.

Class Cat Size Valve Actuator Active / Normal Ponsition Safty Fail Type Type Passive Position Position 3 C 3/4 CK Self Act A Closed Open CT-C OP 24.207.08 CT-0 OP 24 207.08 PIS P440OF985A EECW Div. I Nitrogen Make-Up to Tank A001 Relief Valve..

DIVIlSION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P'ositioin 3 C . 3/8 RLF Self Act A Closed Open CT-SP MOY 43.000.020 PIS P44F400A EECW Dii'. I Modulating Temperature Control Valve (TCV).

DIVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 B 10 Globe AO A Open Open Open

-. .. BTO OP 24.208.02 FST OP 24.208.02 PIT 2Y 24.208.02 PIS P44F400B EECW Div'. 11 Modulating Temperature Control Valve (TC V).

DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Typ)e rvpe Passive -Position Position 3 B 10 Globe AO A Open Opein Open BTO OP 24.208.03 FST OP .. 24.208.03 PIT 2Y 24.208.03 Page 15 of 15 For System: P4400

DTE ENERGY - FERMI 2 ISI / IST Program Plan - Part 5 Valve Scope Table Sse: P 50Test Procedure Deferred Relief Technical Sytm P50Exam Frequency Number Justification Request Position PIS P450OF002A Emergency Equipment Service Water (E'ESW) Pump COO2A D)IVISION IDischarge Check Valve.

(Class Cat Size Valve Actuator Active / Normal P'osition Saretv Fa iI Type Type Passive Position Position 3 C 10 CK Self Act , A System Dependent Open CT-C OP 24.205.05 CT-O OP 24.208.02-PIS P450OF002B Emergency Equipment Service Water (EESW) Pump C002B DIVISION 2. Discharge Check Valve.

(Class Cat Size Valve Actuator Active / Normal Position Safety Fa il Type TIype Passive Po~sitioni Position

• 3 C 10 CK Self Act A System Dependent Open CT-C OP. 24.205.06 CT-O OP 24.208.03 PIS P450OF181A Div. I EESW Plate and Frame Heat Exchantger BOO IA D)IVISION i Relief Valve.

Class Cat Size Valve Actuator Active!/ Normal Position Safety Fail Type Type Passive . Position P~osition 3 C I TReI Self Act A Closed Open CT-SP IOY 43.000.020 PIS P450OF181B Div'. 2 EESW Plate and Frame Heat Exchanger BO0IB DIVISION 2 Relief Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive P'osition Position 3 C I TReI Self Act A Closed - Open CT-SP IOY 43.000.020 PIS -P450OF181C Div I EESW Plate and Frame Heat Exchanger BOO/C Relief D)IVISION I Valve.

Class Cat Size V'alve Actuator Active / Normal Position Safety Fail Type Type Passive .Positioni Positioni 3 .C I TReI Self Act A Closed Open CT-SP 1OY 43.000.020 Page 1, of 2 For System.: P4500

DTE ENERGY - FERMI 2 ISI/1IST Program Plan - Part 5 Valve Scope Table Sse : P 50Test Procedure Deferred Relief Technical Sse: P 50Exam Frequency Number Justification Request Position PIS P450OF181D Div 2 EESW Plate and Frame Heat Exchanger BOOID Relief D)IVISION 1 Valve.

Class Cat Size Valve Actuator Active / Normal P'ositiont Safety Fail.

Type Type Passive Position Position 3 C I TRel Self Act A Closed Open CT-SP MOY 43.000.020 PIS P45F400 PressureConttrol Valve: Emergency Equipmtent Service D)IVISION 2 Water Pump Mintinmunt Flow C:lass Cat Size Valve Actuator Active / Normal Positiont Safety Fail Type .Type Passive Positioni Position 3 B 2 Globe Self Act A Closed Closed Closed CT-C OP 24.208.03 PIS P45F401 Pressure Control Valve: Emtergency Equipment Service D)IVISION I Water Puntp Minintnt Flow Class Cat Size Valve Actutator Active/ Normal Positiont Safety Fail Type Type Passive Positiont Position 3 B 2 Globe Self Act A Closed Closed Closed CT-C OP 24.208.02 Page 2 of 2 Foir System: P4500

DTE'ENERGY - FERMI 2 ISI / ISTTroaratn Plan - Part 5 _Valve Scope Table System: P5000 Esatn Test Frequency Pt"oceduire Number Deferred Justification Relief Request Technical Position PIS P5000F207A Non-Interruptable Control Air System North Control Air D)IVISION I Compressor DOWJ Aftercooler Relief Valve.

Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position 3 C 3/4 RLF SelftAct A Closed Open CT-SP toY 43.000.020 PIS P5000F207B Non-Iterruptable Control Air System South Control Air D)IVISION 2 Compressor D002 Aftercooler Relief Valve.

Claass .Cat Size Valve Actuator Active / Normal Position .Safety Fail Type . Type Passive Position Position 3 C 3/4 RLF Self Act A Closed Open CT-SP tOY 43-000.020 PIS P5000F208A Non-Inzterruiptable Control Air System North Control Air D)IVISION ICompressor DOQI Aftercooler Discharge Check V Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 3 CK Self Act A System Dependent Open CT-C OP 24.129.01 CT-0 OP 24.129:01/.04 PIS P5000F208B Non-Interrup table Control Air Systemn South Control Air D)IVISION 2 Compressor D002 Aftercooler Discharge Check Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive P'osition Position 3 C 3 CK Self Act A System Dependent Openi CT-C OP 24.129.01 CT-O OP 24.129.01/.04 PIS P5000F219A Non-Interruptable Control Air Systemt Dehydration Untit DIVISION 1 Discharge Check Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Positio n _Position 3 C 3 CK Self Act A System Dependent Both CT-C OP 24.129.01/.04 CT-0 OP 24.129.01/.04 Page 1 of 4 For System: P5000

DTE ENERGY - FERMI 2 ISI/ IST Prkgram Plan - Part 5 Valve Scope Table Sytm: PrO est Procedu re Deferred Relief Technical Sytm P 00Exam Frequency Number Justification Request Position PIS P5000F219B Non-Iterruptable Control Air System Dehydration Unit DIVISION 2 Discharge Check Valve.

Class Cat Size Valve Actuator Active / Normal Position Safetv Fa il Type Type Passive Position Position 3 C 3 CK Self Act A System Dependent Both CT-C OP 24.129.01/.04 CT70 OP 24.129.01/.04

.PI S P5000F223A Non-fnterruptable ControlAir System Control Air Receiver DIV ISION I P5002A 001 Relief Valve. -

Class Cat Size Valve Actuator Active I Normal P'osition Safety Fail

-- Type Type Passive Position Positionf 3 C 3/4 RLF Self Act A Closed Open CT-SP MOY 43.000.020 PIS P5000F223B Non-InterruptableControl Air System Control Air Receiver DIVISION 2 P5002A 002 Relief Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type' Passive P'osition P'osition

• 3~ C 3/4 RLF Self Act A Closed Open CT-SP lOY 43.000.020

• PIS P5000F403 Non-Interruptable ControlAir System Isolation Valve D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type Type Passive Position Position 3 B .2 Globe AO A Closed Closed Closed -

BTC OP 24.129.01/.04 FST OP 24.129.01 PIT 2Y 24.129.04 Page 2 of 4 For-Systemn: P5000

DTE ENERGY - FERMI 2 1ISL/ 1ST Program Plan - Part 5 -Valve Scope Table Sse: P 00Test. Procedure Deferred Relief Technical Syte: 500Exam Frequency Number Justitication Request Position PI.S P5000F440 Non-Iterruptabie Control Air System Station Air to Control DIVISION 1 Air Isolation Valve Class Cat Size Valve Actuator Active!/ Normal Position Safety Fail Type Tyvpe Passive Position Position 3 A 3 Gate - AO A Open Closed Closed AT-3 2Y . 24.129.04 BTC OP 24.129.01/.04 FST OP 24.129.01

- PIT 2Y 24.129.04 PIS P5000F441 Non-IterruptableControl Air Sy,stemn Station Air to C7ontrol DIVISION 2 Air Isolation Valve Class Cat "Size "ValWe Actuator Active!/ Normal Position Safety Fail Type Type Passive Position Position 3 A 3 Gate AG A Open Closed Closed AT-3 2Y' 24.129.04 BTC OP 24.129.01/04 FST OP 24.129.01

• PIT 2Y 24.129.04 PIS P5000F541A NIAS North C7ontrolAir Dryer West Chamber Relief Valve DIVISION I Class Cat Size Valve -Actuator Acti!e!/ Normal Position Safety Fail Typse Type Passive l'osition P~osition NC C 1/2 RLF Self Act A Closed Open CT-SP IOY 43.000.020 PIS P5000F541B NIAS Sooth Control Air Dryer East ChamberRelief Valve DIVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type. - Type -Passive Position Position NC C 1/2 RLF Self Act A Closed Open CT-SP JOY 43.000.020 Page 3 of 4 For System: P5000

DTE ENERGY - FERNII 2 1.81 / [ST Program Plan - Part 5 Valve Scope Table Relief Technical Sse: 500Test Procedure Deferred Sse: P00Examn Frequency Number Justitiation Request Position PIS P5000F542A NIAS Nortli Control Air Dryer East Chamber Relief Valve D)IVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC C 1/2 RLF Self Act A Closed Open CT-SP MY 43.000.020 PIS P5000F542B NIAS Sout/h ControlAir Dryer West Chamber lief Valve D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type passive Position Position NC C 1/2 RLF. Self Act A Closed Open CT-SP l0Y 43.000.020 Page 4 of 4 For System: P5000

DTE ENERGY - FERMI 2 I1SI/1IST Program Plan - Part 5 Valve Scope Table SytmT3 0 1est Procedure Defer red Relief TFechnical 0Exam yse. 30 Frequency Number Justification Request Position PIS R3000F015A EDG No. 11 Engine Driven Jacket Coolant (JQ Pumtp DIV ISION I Suction C'heck Valve C lass Cat Size Valve .Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 N/A 5 CK( Self Act A System Dependent Open N/A SMC OP 24.307.14 PIS R3000F015B EDG No. 13 Engine Driven Jacket Coolant (JC) Puntp D)IVISION 2 Suction Check Valve

(:lass Cat Size Valve Actuator Active / Normal Position Safety Fail

'Type Type Passive Position Position 3 N/A 5 CK Self Act A System Dependent Open N/A SMC OP 24.307.15 PIS .R3000F015C EDG No. 12 Engine Driven Jacket C'oolant (JQ,Pump D)IVISION I Suction Check Valve Class Cat .Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 N/A 5 CK Self Act A System Dependent Open N/A SMC OP 24-307.16 PIS R3000F015D EDG No. 14 Engine Driven Jacket Coolant (JQ Pump D)IVISION 2 Suction Check ValveI Class Cat Size Valve Actuator Active I Normal Position Safetv Fail Type Type Passive Position Position 3 N/A 5 CK Self Act A System Dependent Open N/A SMIC OP 24.307.17 PIS R3000F018A EDG No. /IJacket Coolant Pressure Relief Valve DI1VISION. 1 Class C:at Size Valve Actuator Active / Normal Position Sa fetv Fail Type Type Passive Position Position NC C 3/4 RLF Self Act A Closed Open CT-SP IOY 43.000.020 PIS ' R3000F018B EDG No. 13 Jacket Coolanit Pressure Relief Valve D)IVISION 2

-Class Cal Size Valve Actuator Active / Normal Position Saflet~ Fail Type Type Passive P'osition Position NC C 3/4 RLF Self Act A Closed Open CT-SP lOY 43.000.020 Page 1 of 11 Foi" SYsteln: R3000

DTE ENERGY - FERMI 2 ISI./1IST Program Plan - Part 5 Valve Scope Table System: R3000J4 Test Procedure Deferredi Relief Technical Exam Frequency Number Justification Request Position PIS R3000F018C EDG No. 12 Jacket Coolant PressureRelief Valve D)IVISION I Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position NC C 3/4 RLF Self Act A Closed Open CT-SP lOY 43.000.020 PIS R3000F018D EDG No. /4 Jacket Coolant PressureRelief Valve D)IVISION 2 Class Cat Size Valve Actuator Active/I Normal Position Saretv Fa il Type Type Passive Position Position NC C 3/4 RLF Self Act A Closed Open CT-SP IOY 43.000.020 r

PIS R3000F029A EDG No. 11 Air Coolant System (ACS) HX Outlet C7heck D)IVISION I Valve Class Cat Size Valve Actuator Active I Normal Position Safety Fail Type Type Passive - Position Position 3 N/A 4 t CK SelfAct A -System Dependent Open N/A SMC OP 24.307.34 PIS R3000F029B EDG No. 13 Air Coolanit Systent (A(CS) HX' Outlet Check D)IVISION 2 Valve C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive .Position P'osition 3 N/A- 4 CK Self Act A System Dependent Open N/A SMC OP 24.307.35 PIS R3000F029C EDG No. 12 Air Coolant System (A CS) HX Outlet Check D)IVISION I Valve C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type P~assive Position Position 3 N/A 4 CK Self Act A System Dependent Open N/A-SMC OP 24.307.36 PIS R3000F029D EDG No. 14 Air Coolant Systent (A CS) HX Outlet Check D)IVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position' Saretv Fail Type .Type Passive Position Position 3 N/A -4 CK Self Act A System Dependent Open N/A SMC OP .24.307.37 Page 2 of 11 For System: R3000

DTE ENERGY - FERMI 2 1S1 /IST Prouram Plan - Part 5 Valve Scope Table Sytm R 0 0Test Procedu re DeferredI Relief Technical Exam Prequency Number Justification :..Request Position PIS R3000F031A EDG No. 11 West StartingAir-ReceiverA01] Inlet Check D)IVISION I Valve Class Cat Size Valve Actuator Activel/ Norinal P'osition Safetv Fail Type Type Passive Position Position 3 C 3/4 CK Self Act A System Dependent Closed CT-C OP 24.307.34 CT-OL OL N/A TP-01 PIS R3000F031B EDG No. 13 West StartingAir Receiver A015 hillet Check DIVISION 2 Valve Class Cat Size -. Valve Actuator Active / Normal Position Sarety Fail Type Type Passive Position Position -

3. C 3/4 CK Self Act A System Dependent Closed CT-C OP 24.307:36 CT-OL OL N/A TP-01 PIS R3000F031C EDG No. 12 West StartingAir Receiver A012 Inlet Check D)IVISION I Valve -

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 3/4 CK Self Act A System Dependent Closed CT-C OP 24.307.35 CT-OL OL N/A TP-0I PIS R3000F031D EDG No. -14.West Starting Air Receive- A016 Inlet Check D)IVISION-2 Valve Class Cat Size Valve Actuator Active/ Normal Position Safety Fail Type -"1ype Passive Position Position 3 C 3/4 CK Self Act A System Dependenit Closed CT-C OP 24.307.37 CT-OL 'OL N/A TP-01 PIS R3000F032A EDG No. 11 East Starting Air Receiver A009 Inlet Check IItSION I Valve Class :Cat Size Valve Actuator A&ctive / Normal Position Sarety Fail Type Type. Passive P.osition Position 3 C- . 3/4 CK Self Act A System Dependent Closed CT-C OP 24.307.34 CT-OL- OL N/A TP-01 Page 3 of 11 'For System: R3000

DTE ENERGY - FERMI 2 181 / IST Propram Plan - Part 5 Valve Scope Table Sytm R 0 0Test Procedure Deferred Relief Technical Exam Frequency Number Justification Request Position PIS R3000F032B EDG No. /3 East Starting Air Receiver A013 Inlet Check D)IVISION 2 Valve Class Cat Size Valve Actuator .Active / Normal P'ositioni Saretv Fail Type Type Passive P'ositioni Position 3 C 3/4 CK Self Act A System Dependent Closed CT-C OP 24.307.36 CT-CL- OL N/A TP-0l PIS R3000F032C EDG No. 12 East Starting Air Receiver A010 hnlet Check DIVISION I Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type -Type Passive Position P'ositioni 3 C 3/4 CK Self Act A System Dependent Closed CT-C OP 24-307.35 CT-CL- OL N/A TP-01 PIS R3000F032D EDG No. 14 East Starting Air Receiver A014 Inlet Check DIVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 3/4 CK Self Act A System Dependent Closed CT-C OP 24.307.37 CT-CL- CL N/A TP-01 PIS R3000F035A EDG No. 11 West Starting Air Receiver A011 PressureRelief D)IVISION I Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive~ Position Position NC D 3/4 RLF Self Act A Closed Cpen CT-SP IOY 43.000.020 PIS R3000F035B EDG No. 13 West Starting Air Receiver A0/5 Pressure Relief DIVISION 2 Valve t Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC C 3/4 RLF Self Act A Closed Cpen CT-SP IOY 43.000.020 Page 4 of I11 For System: R3000

DTE ENERGY - FERMI 2 1SI /1IST Pro2ram Plan - Part 5 Valve Scope Table Sytm R 0 0Test Procedure Deferred. Relief Technical Exam Frequency Number. Justification Request Position PIS R3000F035C EDG No. /2 West Starting Air Receiver A012 Pressure Relief D)IVtS10N i Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC C 3/4 RLF Self Act A Closed Openi CT-SP joMY 43.000.020 PI,S R3000F035D EDG No.l14 West StartingAir Receiver A016 Press'ure Relief D)IVISION 2 Valve C'lass Cat Size Valve Actuator Active / Normal Position Sarety Fail Type Type Passive Position Position

>NC C 3/4 RLF Self Act A Closed Open CT-SP IOY 43.000.020 PIS R3000F036A EDG No. I ! East Starting Air Receiver A009 Pressure Relief*

IVISION I Valve Class (Cat Size .Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC, C 3/4 RLF Self Act A Closed Open CT-SP 10Y 43.000.020 PIS R3000F036B EDG No. 13 East StartingAir Receiver A013 PressureRelief D)IVISION 2 Valve C:lass Cat .Size Valve Actuator Active / Normal Position Sarety Fail Type Type Passive Position Position NC C 3/4 RLF Self Act A Closed Open CT-SP 10Y 43.000.020 PIS R3000F036C . EDG No. 12 East Starting Air Receiver-A010 Pressure Relief D)IVISION I Valve (Class Cat Size Valve Actuator Active / Normal Position Saflety' Fail Type 7;lpe Passive Position Position NC C 3/4 RLF .Self Act A Closed Open CT-SP lOY 43.000.020 PIS R3000F036D EDG No. 14 East Starting Air Receiver A014 Pressure Relief DIVISION 2 Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail ,

Type .Type Passive Position Position NC C 3/4 RLF Self Act A Closed , Open CT-SP IOY 43:000.020 Page 5 of 11 :Foi- System: R3000

DTE ENERGY - FERII2 181 / IST Program Plan - Part 5 Valve Scope Table Relief Technical Sse : R 00Test Procedu re Deferred Sse: R00Exam Frequency Number Justification Request Position PIS R3000F048A EDG No. IIl Engine Air Conztrol Header Relief Valve D)IVISION I Class Cat Size Valve Actuator Active/ Normal Position Safetv Fail Type Type P~assive P'osition Position NC C 1/4 RLF Self Act A Closed Open CT-SP IOY 43.000.020 PIS R3000F048B EDG No. 13 Engine Air Control Header Relief Valve D)IVISION 2.

Class Cat Size Valve Actuator Active/. .Normal Position Safety FTail Type Type Passive _ Position Position NC C 1/4 RLF Self Act A Closed Open CT-SP IOY 43.000.020 PIS R3000F048C EDG No. 12 Engine Air Control Header Relief Valv'e D)IVISION 1-Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type Type Passive Position Position NC C 1/4 RLF Self Act A . Closed Open -

CT-SF IOY 43.000.020 PIS R3000F048D EDG No. 14 Engine Air Control Head.rRelief Valve. .......

D)IVISION 2 C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC C 1/2 RLF Self Act :A Closed Open CT-SF IOY 43.000.020 PIS R3000F083A EDG No. 11 Transfer Pump C001 Discharge Check .Valve D)IVISION I Class Cat Size Valve Actuator Activef Normal Position Saletv Fa il Type Type Passive Position Position 3 C 1 1/2 CK Self Act A System Dependent Both CT-C OF 24.307.34 CT-O OP 24.307.34 Page 6 of 11 For System: R3000

r DTE ENERGY - FERMI 2 ISI/1ST Prouwam Plan - Part 5 Valve Scope Table Sse:

Sse : R 00Test Exam F.requency Procedure Number Deferred J ustification Relief Request Technical Position PIS R3000F083B EDG No. 13 Transfer Punmp C009 Discharge Check Valve D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 1 1/2 CK Self Act A System Dependent Both CT-C OP 24.307.36 CT-O OP 24.307.36 PIS R3000F083C EDG No. 12 Transfer Pump C002 Discharge Check Valve DIVISION .I Class Cat Size V'alve Actuator Active/ Normal Position Safety Fa il

'Type Type Passive .Position Position 3 C 1 1/2 CK Self Act A System Dependent Both CT-C OP 24.307.35 CT-O OP 24.307.35 PIS R3000F083D EDG No. 14 Transfer Pump C010 Discharge Check Valve DIVISION 2 Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position 3 C 1 1/2 CK Self Act A System Dependent Both CT-C OP 24.307.37 CT-O OP 24.307.37 PIS R3000F084A EDG No. IIl Transfer Pump 0003 Discharge Check Valve D)IVISION I Class Cat Size Valve Actuator Active / Normal Position- Safety Fail Type lType Passive Position Position 3 C ,1 1/2 CK Self Act A System Dependent Both CT-C OP 24.307.34 CT-O OP 24.307.34 PIS R3000F084B EDG No. 13 Transfer Pumrp C01l Discharge Check Valve D)IVISION 2 Class Cat Size Valve Actuator Active / Normal Position Saf'ety Fail Type. Type Passive N Position Position 3 C 1 1/2 CK . Self Act A System Dependent Both CT-C OP 24.307.36 CT-0 OP 24-307.36 Page 7 of 11 For System: R3000

DTE ENERGY - FERMI 2 181 / IST Pro2riam Plan - Part 5 Valve Scope Table Test Procedlure Deferred Relief- Technical System: R3000 Exam Frequency Number Justification Request Position PIS R3000F084C EDG No. 12 Transfer Pump C004 Discharge Check Valve D)IVISION I Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 1 1/2 CK Self Act A System Dependent Both CT-C OP 24.307.35 CT-O OP 24.307.35

- ..... ~~~~~~~...

PIS R3000F084D EDG No. 14 Transfer Pump C012 Discharge Check Valve DIV'ISION 2 Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type Type Passive Position P'osition 3 -C 1 1/2 CK Self Act A System Dependent Bath CT-C OP 24.307.37 CT-O OP 24.307.37 PIS R3000F142A EDG 1l Service Water ('DGSW)l Pump COOS Outlet Check DIVISION I - Valve C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 8 CK Self' Act A System Dependent Both CT-C OP 24.307.35/.49 CT-O OP 24.307.34/.49 PIS R3000F142B EDG 13 Service Water (DGSW) Pumnp C007 Outlet Ch/eck DIVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 8 CK Self Act A System Dependent Both CT-C OP 24.307.37 /.49 CT-O OP 24.307.36/.49 PIS R3000F142C EDG 12 Service Water ('DGSW) Pump C006 Outlet Check D)IVISION 1Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 8 CK Self Act A System Dependent Both CT-C OP 24.307.34/.49 CT-O , OP 24.307.35/.49 Page 8 of I1 For System: R3000

DIE ENERGY - FERI 2 ISI/1ST Pro2ram Plan - Part 5 Valve Scope Table Sytmr3 0 est Procedure Deferred Relief Technical Exam Frequency Number Justification Request Position PIS R3000F142D EDG 14 Service Water (DGSW) Pumip C008 Outlet Check DIVISION 2 Valve Class Cat Size Valve Actuator Active / Normal Positioni Safety Fail Type Type Passivec Position Position 3 C 8 CK Self Act A System Dependent Both CT-C OP 24.307.36/.49 CT-O OP 24.307.37/.49 PIS R30F400 EDG 13 Service Water Pump Minimum Flow Pressure DIVISION I Control Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passivse P'ositio n P~ositIion 3 B 2" Globe AO A Closed Closed Closed BTC RR 43.401.705 ROJ-015 FST OP 24.307.36 PIS R30F401 EDG 14 Service Water Pump Minimumn Flow Pressure D)IVISIOJN I Control Valve Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive P'osition Position 3' B 2 Globe AG A Closed Closed Closed BTC . RR 43.401.706 ROJ-015 FST OP 24.307.37 PIS R30F402 EDG I / Service Water Punp Mininmum Flow Pressure D)IVISION 2 Control Valve Class . Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 B 2 Globe AG A. Closed Closed Closed BTC RR 43.401.703 ROJ-01]5 FST OP 24.307.34 PIS R30F403 EDG 12 Service Water Pumtp Minimtum Flow Pressure' D)IVISION 2 Control Valve C:lass Cat Size Valve Actuator Activec/ Normal Position Safety Fail Type Type Passive Position ,Position 3 B 2 Globe AG A Closed Closed -Closed BTC RR 43.401.704 ROJ-015 FST OP 24.307.35 Page 9 of 11 For System: R3000

DTE ENERGY - FERMI 2 ISI / IST Program Plan - Part 5 Valve Scope Table Test Procedure Deferred Relief Technical System: R3000 Exam Frequency Number Justification Request Position PIS R30FA04A Emergency Diesel Generator (EDG) No. I I Three Way Air DIVISION I Start Solenoid Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 B 1 1/2 3 Way SOV A Closed Open Closed SMC OP 24.307.14 PIS R30FA04B Emergency Diesel Generator(EDG) No. /3 Three Way Air DIVIS ION 2 . Start Solenoid Valve Class Cat Size Valve Actuator Active/ Normal Position Safety Fail Type Type Passive Position Position 3 B 1 1/2 3 Way SOV A Closed Open Closed SMC OP 24.307.16 PIS R30FA04C Emergency Diesel Generator(EDG) No. 12 Three Way Air DIVISION 1 Start Solenoid Valve Class Cat Size Valve Actuator Active/ Normal Position Safety Fail Type - Type Passive Position Position 3 B 1 1/2 3 Way SOV A Closed Open Closed SMC OP 24.307.15 PIS R30FA04D Emergency Diesel Generator(EDG) No. 14 Three Way Air DlIVISION 2 Start Solenoid Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 B 1 1/2 3 Way SOV A . Closed Open Closed SMC OP 24.307.17 PIS R30FA05A Emergency Diesel Generator(EDG) No. II Three Way Air DlIVISION 1 Start Solenoid Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 B 1 1/2 3 Way SOV - A Closed Open Closed SMC OP 24.307.14 PIS R30FA05B Emergency Diesel Generator(EDG) No. 13 Three Way Air DIVSION 2 Start Solenoid Valve Class Cat Size Valve Actuator Active/ Normal Position Safety Fail Type . Type Passive - Position Position 3 B 1 1/2 3 Way SOV A Closed Open Closed SMC OP 24.307.16 Page 10 of 11 For Systein: R3000

DTE ENERGY - FERMI 2 181] / IST Prouram Plan - Part 5 Valve Scope Table SytmT3 0 est Proce(htre Deferred Relief Technical

______Exam Frequency Number Jlustinication Request Position PIS R30FA05C Emergency, Diesel Generator(EDG) No. 12 Three Way Air DIVISION I Start Solenoid Valve Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type Type Passive Position Position

3. B 1 1/2 3.Way SOV A Closed Open Closed SMC OP 24.307.15 PIS' R30FA05D Emergency Diesel Generator ('EDG) No. 14 Three Way Air DIVISION 2 Start Solenoid Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type passive .Positioni Position 3 B 1 1/2 3 Way SOV A Closed Open Closed SMC OP 24.307.17 Page 11 of 11 Foir System: R3000

DTE ENERGY - FERMI 2 ISI1/1ST Prom-am Plan - Part 5 Valve Scope Table Relief Technical Sytm T 3OTest Procedure Deferred

_______Exam Frequiency Number Justification Request Position PIS T230OF400A Primary Containment (PC) Vacuum Breaker Check Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type Type Passive - Position Position 2 A/C 18 CK SA Test AO A System Dependent Both AT- I I RR 24.402.06 BTC RR 44.220.203 CT-C CS 24.402.01 App. I CT-F RR 44.220.203 CT-0 CS 24.402.01 App. I PIT 2Y 44.220.203 PIS T230OF400B PrinmaryContainment (PC) Vacuumi Breaker Check Valve DIVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A/C 18 CK SA Test AO A System Dependent Both AT-I I .RR 24.402.06 BTC RR 44.220.203 CT-C CS 24.402.01 App. I CT-F RR 44.220.203 CT-0 CS 24.402.01 App. I PIT 2Y 44.220.203 PIS T230OF400C Primary Containment (PC) Vacuum Breaker Check Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Posilion 2 A/C 18 CK SA Test AO A System Dependent Both AT:! I RR 24.402.06 BTC -RR 44.220.203 CT-C CS 24.402.01 App. I CT-F RR 44.220.203 CT-0 CS 24.402.01 App. I PIT 2Y 44.220.203 Page 1 of 6 For System: T2300

DIE ENERGY - FERPII 2 ISI [I.ST Prngram Plan - Part 5 Valve Scope Table Sse: T 30Test P~rocedu re Deferred Relief Technical Sytm T 30Exam Frequenev Number Justification Request Position PIS T230OF400D Primary Containment (PC) Vacuum Breaker Check Valve D)IVISION N/A Class Cat Size Valve _Actuator Active / Normal Position Safety Fail Type Type. Passive Position Position

-2 A/C 18 CK SA Test AO A Systemi Dependent Both AT-I1I RR . 24.402.06 BTC RR 44.220.203 CT-C CS 24.402.01 App. I CT-F RR 44.220.203 CT-0 CS 24.402.01 App.I1 PIT 2Y 44.220.203 PIS T230OF400E Primary Containment (PC) Vacuum Breaker Check Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal.Position Safety Fail Type Type Passive Position Position 2 A/C 18 CK SA Test AO A System Dependent Both AT-I I RR 24.402.06 BTC RR 44.220.203 CT-C CS 24.402.01 App. I CT-F RR 44.220.203 CT-O CS 24.402.01 App.I1 PIT 2Y 44.220.203 PIS T230OF40OF Primay Containment (PC) Vacuum Breaker Check Valve D)IVISION N/A Class Cat Size Valve. Actuator Active / Normal Position Safety Fail Type Type Passive .. Position Position 2 A/C 18 CK SA Test AO A System Dependent Both AT- I I RR 24.40206 BTC RR 44.220.203 CT-C. CS 24.402.01 App.I CT-F. RR 44.220.203 CT-O CS. 24.402.01 App. I PIT 2Y 44.220.203 Page 2 of 6 For System: T2300

DTE ENERGY - FERMVI 2 1S1 / [ST Pr-ouam Plan -Part 5 Valve Scope Table Sytm T 30Test Procedure Deferred Relief Technical Syte: 230Exam Frequency Number Justification Request Position PIS T230OF40OG Primtary Containment (PC) Vacuum Breaker Check Valve D)IISION N/A Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type T),pe Passive Position Position 2 A/C 18 CK SA Test AO -A* System Dependent Both AT-I I RR 24.402.06 BTC RR 44.220.203 CT-C CS 24.402.01 .App. I

- CT-F RR 44.220.203 CT-O CS 24.402.01 App. I PIT 2Y . 44.220.203 PIS 'T2300F400H Printaty Containment (PC) Vacuum Breaker Check Valve DIVISION N/A Class Cat Size - Valve - Actuator Active / Normal Position Safety Pail Type Type Passive Position Position 2 A/C 18 CK .SA Test AO A Systeni Dependent Both AT-I RR .24.402.06 BTC RR .44.220.203 CT-C CS 24.402.01 App. I CT-F RR 44.220.203 CT-O .CS -24.402.01 App.

PIT 2Y 44.220.203 PIS T230OF400J Primary Containment (PC) Vacuum Breaker Check Valve DIVISION N/A C:lass Cat Size Valve ,Actuator Active / Normal Position Safety Pail Type Type Passive Position Position

2. _A/C 18 CK SA Test AO A .System Dependent Both AT-IlI RR 24.402.06 BTC . RR 44.220.203 CT-C CS 24.402.01 App. I CT-F RR 44.220.203 CT-O CS 24.402.01 App. I PIT 2Y 44.220.203 Page 3 of 6. For System: T2300

DTE ENERGY - FERAII 2 IS]1 /I1ST Piomuam Plan - Part 5 Valve Scope Table T20 est Procedure Deferred Relief Technical System: 130NExam Frequency Number Justiicati6~n Request .Position PIS T230OF400K Primary Containment (PC) Vacuum Breaker Check Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Positioni Safety Fa il Type Type Passive Position Position 2 A/C 18 CK SA Test AD A System Dependent Both AT-.II RR 24.402.06 BTC . RR 44.220.203 CT-C CS- 24.402.01 App. I CT-F RR. 44.220.203 CT-0 CS 24.402.01 App. I PIT 2Y 44.220.203 PIS T230OF400L Primary Containmnent (PC) Vacuum Breaker Check Valve DIVISION N/A Class Cat Size Valve Actuator Active /- Normal Position Safety Fail Type Type Passive Position Position 2 A/C 18 CK SA Test AO A System Dependent Both AT-I II RR 24.402.06 BTC RR . 44.220:203 CT-C CS 24.402.01 App. I CT-F RR 44.220.203 CT-0 CS 24.402.01 App. I PIT .2Y 44.220:203 PIS T230OF400M Primary C7ontainment (PC) Vacuum Breaker Check Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position .Sarety Fail Type Type Passive Position .Position 2 A/C 18 CK .SA Test AG A System Dependent Both AT-I II RR 24.402.06 BTC RR 44:220,203 CT-C CS 24.402.01 App. I CT-F . RR 44.220.203 CT-O CS 24.402.01 App. I PIT 2Y 44.220.203 Page 4 of 6 For System: T2300

DTE ENERGY - FERMI 2 1SI/1ST Program Plan - Part 5 Valve Scope Table System: 12300 Test Procedure Deferred Relief Technical

_____Exam Freqtienc Number Justification Request Position.

PIS T230OF409 Primary Containiment (PC) Suppression Chamber - Reactor D)IVISION 2 Building Vacuum Breaker Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 20 BTF AG A Closed Both Open AT-1 GB 43.401.375 AT-IS GB 43.401.375 BTC OP 24.402.01 BTO OP 24.402.01 FST OP 24.402.01 PIT 2Y 24.406.02 PIS T230OF410 Primnary Containment (PC) Suppression Chamber - Reactor D)IVISION I Building Vaculum Breaker Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive lPosition P'osition

• 2 A 20 BTF AG A Closed Both Open AT-I GB 43.401.374 AT- IS GB 43.401.374 BTC OP 24.402.01 BTO GP 24.402.01 FST OP 24.402.01 PIT 2Y 24.406.02 PIS T230OF450A Primtary Containmnent (PC) Suppression Chamber - Reactor D)IVI.SION I Building Vacuum Breaker Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Positiotn 2 A/C 20 CK SA Test AG A System Dependent Both AT-1 GB 43.401.375 CT-C OP 24.402.01

- CT-F - RR 44.220.204 CT-0 OP 24.402.01 PIT 2Y 44.220.204 Page 5 of 6 For System: T2300

DTE ENERGY - FERMI 2 11 /. ST ProjZram Plan - Part 5 Valve Scope Table Sytm T 30'esl Procedure Deferred Relief Technical Syte: 230Exam Frequency Number Justification Request -Position PIS T230OF450B Primar)y Con tarim)ent (PC) Suppression Chamber - Reactor DIVISION 2 Building Vacuum BrealcerC/heck V'ale C:lass Cat Size Valve Actuator 'Active / Normal Position Safety Fail Type Type Passive P'osi tion0 Position 2 A/C 20 CK SA Test AO A System Dependent Both AT-I OB 43.401.374 CT-C OP 24.402.01 CT-F RR 44.220.204 CT-O OP .24.402.01 PIT 2Y 44.220.204 Page 6 of 6 For System: T2300

DTE ENERGY'- FERMVI 2 ISI/1ST Pro2ram Plan - Part 5 Valve Scope Table Relief Technical Sse: T 10Test Procedure Deferred Syte: 1400-Exam Frequency Number Justification. Request Position PIS T4100F008 Heating Ventilating & Air Conditioning (H VA C) Exhaust Air D)IVISION 2 Isolation Damper.

Class Cat Size Valve Actuator Active/I Normal P'ositionm Safety Fa il Type Type Passive Position Position NC B 72 BTF AO A Open Closed Closed BTC OP 24.404.04 FST OP 24.404.04 PIT 2Y 24.404.04 PIS T4100F009 Heating Ventilating &Air Conditioning ('HVA C) Exhaust Air D)IVISION I Isolation Damper.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC B 72 BTF AO A Open Closed Closed BTC OP 24.404.02 FST OP 24.404.02 PIT 2Y 24.404.02 PIS T410O010 Heating Ventilating & Air Conditioning(H VA C) Supply Air D)IVIS ION 2 Isolation Damper..

C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC B 72 BTF AO A Open Closed Closed BTC OP 24.404.04 FST OP 24.404.04 PIT 2Y 24.404.04 PIS T4100FO11 H-eating Ventilating & Air Conditioning (HVA C) Supply Air DIVISION I Isolation Damper.

Class Cat Size Valve Actuator Active/ I Normal Position -Safety Fail Type Type .Passive P'osition Position NC B 72 BTF AO -A Open Closed Closed BTC OP 24.404.02 FST OP 24.404.02 PIT 2Y 24.404.02 Page 1 of 2 For System:' T4100

DTE ENERGY - FERiVI2 1S1 / 1ST Program Plan - Part 5 Valve Scope Table System: 14100 Fxalm Test Frequency Procedure Number Deferred Justification Relief Request Technical Position PIS T410OF352A Heating Ventilating & Air Condition ing (H-iVA Q Division I D)IVI.SION IChidled Water Pump C041 Discharge Check Vat Class Cat Size 'Valve Actuator Active / Normal Position Safety Fail Type Type Passive Positin lositlion P

NC C 4 CK Self Act A System Dependent Open CT-O OP 24.413.01 CT-OL OL N/A TP-01 PIS T410OF352B Heating Ventilating & Air Conditioning(HVAC) Division 2 DIVISION 2 Chilled Water Pumnp C040 Discharge Check Val Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC C 4 CK Self Act A System Dependent Open CT-O. OP 24.413.01 CT-OL OL N/A TP-01 PIS T410OF600 Reactor Building Heatinig Ventilating & Air Conditioning I V ISION N/A (RBHVA Q Main Steam Supply Header Secondary Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P~osition NC N/A 12 Oate MOV A Open As-Is GL9605 OP 47,306.01 /.03 PIS T410OF601 Reactor Building Heating Ventilating & Air Conditioning DIVISION N/A (RBHVAQ Main Steamr Supply Header Secondary Class Cat Size Valve Actruator Active / Normal Position Safety Fail Type Type Passive P'osition Position NC N/A 12 Gate MOV A Open . As-Is GL9605 GP 47.306.01 /.03 Page 2 of 2 For Syst&in: T4100

DTE ENERGY - FERMI 2 ISI / 1ST Prol?ram Plan - Part 5 Valve Scope Table T 60'est Tytm Procedure Deferred Relief Technical Sytm 160Exam Frequency Number Justification Request Position PIS T460OF400 Standby Gas Treatment (SGT) Suppression Chamber Purge D)IVISION N/A Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 20 BTF AO A Closed Closed Closed AT-I OB 43.401.377 AT-8 I84D 43.401.510 AT-8S 184D 43.401.510 BTC OP 24.404.03 FST OP 24.404.03 PIT 2Y 24.404.03 PIS T460OF401 Standby Gas Treatment ('SGT) Suppression Chamber Purge D)IVISION N/A Line Isolation Valve C:lass Cal Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 20 BTF AO A Closed Closed Closed AT-I OB 43.401.377 AT-8 184D 43.401.510 BTC . OP 24.404.03 FST OP 24.404.03 PIT 2Y 24.404.03 P15 T460OF402 Stantdby Gas Treatment (SGT) Drywell Purge Isolation Valve D)IVISION N/A Class Cat Size Valve Actuator Active / Normal Position Safetv Fail Type Type Passive Position Position 2 A 24 BTF AO A Closed Closed Closed AT-I 0B 43.401.321 AT-8 184D 43.401.510 BTC OP 24.404.03 FST OP 24.404.03 PIT 2Y 24.404.03 Page 1 of 3 For System: T4600

BIDTE ENERGY - FERMI 2 ISI 1 IST Prouram Plan - Part 5 Valve Scope Table System: T4600 _____Exam fest Frequency Procedure Number Deferred

~Justification Relief Request Technical Position PIS T460OF407 Standby Gas Treatment ('SGT) From Reactor Building l)IVISION N/A Exhaust System Isolation Valve C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position NC B -24 BTF AO A Closed Open Open BTO OP 24.404.03 FST OP 24.404.03 PIT 2Y 24.404.03 Pis T460OF408 Standby Gas Treatment ('SGT) Secondary Containment to Div D)IVISION 2 II Standby Gas Treatment (SGT) Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Ty-pe Type Passive Position P~ositioni NC B 24 BTF AO A Closed Both Closed BTC OP 24.404.03 BTO OP 24.404.03 FST OP 24.404.03 PIT 2Y 24.404.03 PIS T460OF409 Standby Gas Treatmnent (SGT)I Secondary Containment to D)IVISION 1Division I Standby Gas Treatment ('SGT) Isolation Valve Class Cat Size Valve Actuator Active / Normal Position safety Fail

'Type Type Passive Position Position NC B 24 BTF AO A Closed Both Closed BTC OP 24.404.03 BTO OP 24.404.03 FST OP 24.404.03 PIT 2Y 24.404.03 PIS T460OF410 Standby Gas Treatment ('SGT) From. Air Inlet Refueling Area D)IVISION N/A Isolation Valve Class Cat Size Valve Actuator Active! Normal Position Safety Fail Type 'Type Passive Position P~ositionm NC B 24 BTF AG A Closed Open, Open BTG OP . 24.404.03 FST OP 24.404.03 PIT 2Y -24.404.03 Page 2 of 3 For System: T4600

DTE ENERGY - FERMVI 2 ISI1/IST ProjZram Plan - Part 5 Valve Scope Table Test Procedure Deferred Relief Technical Sse: 160Exam Frequency Number Justification Request Position PIS T460OF411 Standbv Gas Treatment (SGT) Drywell Purge Line Isolation D)IVISION N/A Bypass Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fa il Type Type Passive Position Position 2 A 6 BTF AO A Closed Closed Closed AT-I OB 43.401.321-AT-8 184D 43.401.510 BTC OP 24.404.03 FST OP 24.404.03 PIT . 2Y 24.404.03 PIS T460OF412 Standby Gas Treatment (SGT) Diywell Purge Line Isolation D)IVISION N/A Bypass Valve ClIass Cat Size Valve Actuator Active / Normal Position Sarety Fail Type Type Passive* Position Position 2 A 6 BTF - AO A Closed Closed Closed AT-I OB 43.401.377 AT-8 184D 43.401.510 BTC OP 24.404.03

-FST OP 24.404.03 PIT 2Y 24.404.03 Page 3 of 3 For System: T4600

DTE ENERGY - FERMI 2 1St /1IST Proj2ram Plan - Part 5 Valve Scope Table System: 14800 ________Exaln Test

[req uency -

Procedure Nutmber Deferred J1ustification Relief Request Technical Position PIS T480OF404 Nitrogen Inerting (NI) Suppression Pool Nitrogen (N2)

D)IVISION N/A Supply Isolation Valve Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type Type Passive Position Position 2 A 20 BTF AO A Closed Closed Closed AT-I OB 43.401.376 AT-8 184D 43.401.510 AT-8S 184D 43.401.510 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 PIS T480OF405 Nitrogen Inerting (NI) Suppression Pool. Vent Valve D)IVISION N/A Class Cat Size Valve. Actuator Active/I Normal Position Sa Nty Fail Type Type Passive Position P~osition 2 A 20 BTF AO A Keylocked Closed Closed Closed AT- I OB. 43.401.3 76 AT-8 I84D 43.401.510 BTC OP 24.406.0 1 FST OP 24.406.01 PIT 2Y 24.406.02 PIS T480OF407 Nitrogen Inerting ('NI) Drywi ell Air Purge Inlet Supply Vent D)IVISION N/A Valve Class. Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive .Position Position 2 A 24 BTF AO A Koylocked Closed Closed Closed AT-I OB 43.401.322 AT-8 184D 43.401.510 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 Page 1 of 8 For System: T4800

DTE ENERGY - FERII2 181 I1ST Pro2ram Plan - Part 5 Valve Scope Table Technical Sytm T 80Test Procedure Deferred Relief xam F_____ Frequiency Number Justification Request Position PIS T480OF408 Nitrogen hnerting(NI) Drywell Nitrogen ('N2,) Supply D)IVISION N/A Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 10 BTF AG A Closed Closed Closed AT- I GB 43.401.322 AT-S 184D 43.401.510 BTC OP 24.406.01 FST OP 24.406.0!

PIT 2Y 24.406.02 PIS T480OF409 Nitrogen Inerting (NI) Suppression Pool Nitrogen (N2)

D)IVISION N/A Supply Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 6 BTF AO A Closed Closed Closed AT-I GB 43.401.376 AT-8 184D 43.401.510 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 PIS T480OF410 -- Nitrogen Inerting (NI) Nitrogen (NM) Supply to Standby Gas D)IVISION N/A Treatmnt (SGT)l.

Class Cat Size Valve Actuator Active / Normal Position Saf'etv Fail Type -Type Passive Position Position 2 A 6 BTF AG A Closed Closed Closed AT-I GOB 43.401.377 AT-S 184D 43.401.510 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 Page 2 of 8 IFor Systern: T4800

DTE ENERGY - FERMI 2 1SI1 / IST Pro2ram Plan - Part 5 Valve Scope Table Sse : T 80Test P~rocedIure Deterred Relief Technical 0Exain Sytm 18 Frequency Number Justification Request Position PIS T480OF416 Nitrogeun hnerting ('NJ) To Vacuum Breaker Valve T23-F400A, D)IVISION N/A Nitrogen (N2) Supply Isolation Valve Class C:at Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position P'osition 2 A I Globe AO A Locked Closed Closed Closed AT-I GB 43.401.362 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 PIS T480OF417 Nitrogen Inerting (NI) To Vacuum Breaker Valve T23-F400B DIVISION N/A Nitrogens (N2,) Supply Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Globe AG A Locked Closed Closed Closed AT- I GB 43.401.363 BTC GP 24.406.01 FST GP 24.406.01 PIT 2Y 24.406.02 Is T480OF418 Nitrogen Inerting ('NJ) To Vacuum Breaker Valve T23-F4000 DIVISION N/A Nitrogen (N2) Supply isolation, Valve Class Cat Size Valve Actuator' Active / Normal Position Safety Fail Type Type Passive P'ositioni Positioni 2 A. 1 Globe AG A Locked Closed Closed Closed AT-I' GB 43.401.364 BTC OP 24.406.01 FST OP . 24.406.01 PIT 2Y 24.406.02 Page 3 of 8 For System: T4800

DTE ENERGY FE- / IST Pro2ram- Plan 181S - Part 5 Valve Scope Table Relief 'Technical Sse: T 80Test Procedutre Deferred

_____Esain Frequency Number Justification Request Position PIS T4800F419 Nitrogen Ierting (NI) To Vacuumn Breaker Valve T23-F400D D)IVISION N/A Nitrogen (N2) Supply Isolation Valve Class Cat. Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position 2 .A I Globe AG A Locked Closed Closed Closed AT-I OB 43.401.365 BTC OP 24.406.01 FST OP -24.406.01 PIT 2Y 24.406.02 PIS T480OF420 Nitrogen Inerting ('NI) To Vacuum Breaker Valve T23-,F400E DIVISION N/A Nitrogen (N2) Supply, Isolation Valve Class -Cat Size Valve Actuator Active./ Normal Position Safety Fail Type.- Type Passive Position Position 2 A I Globe AO A Locked Closed Closed Closed AT-I O.B 43.401.366 BTC.- OP 24.406.01 FST OP 24.406.01 PIT 2Y -24.406.02 PIS T480OF421 Nitrogen Inertintg (NI) To Vacuun Breaker Valve T23-F400F DIVISION N/A Nitrogen ('N2,) Supply Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type .Passive Position Position 2 A I Globe AO A Locked Closed Closed Closed AT-I OB 43.401.367 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406,.02 Page 4 of 8 For System: T4800

DTE ENERGY - FERMI 2 181 / IST Proaram Plan - Part 5 Valve Scope Table System: 14800 Exam Test Frequency Procedure Number Deferred Relief Justification' Request Technical Position PIS T480OF422 Nitrogen Inerting (NI) To Vacutun Breaker Valve T23-F400G D)IVISION N/A Nitrogen ('N2) Supply Isolation Valve Class Cat Size V'alve Actuator Active / Normal P'osition Safety Fa il Type Type Passive Position P'osition 2 - A I Globe AG A Locked Closed Closed Closed AT-I 0 OB 43.401.368 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 PIS T480OF423 Nitrogen Inierting (NI) To Vacuum Breaker Valve T23-F400H DIVISION N/A Nitrogen ('N2,) Supply Isolation Valve Class Cat Size Valve Actuator' Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Globe AO A Locked Closed Closed Closed AT-.l OB 43.401.369 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y. 24.406.02 PIS T480OF424 Nitrogen Inerting (NJ) To Vacuum Breaker Valve T23-F400J DIVISION N/A Nitr=ogen (N2) Supply Isolation Valve Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type Type Passive Position . Position 2 A 1 Globe AG A Locked Closed Closed Closed AT-I GB 43.401.370 BTC OP 24.406.01 FST OP 24.406.01 PIT' 2Y 24.406.02 Page 5 of 8 For System: T4800 -

DTE ENERGY - FERMI 2 ISI/1IST Proizram Plan - Part 5 Valve Scope Table Test P~rocedIure Deferred Relief Technical System:_T480 Ex~am Frequency Number Justification Request Position PRIS T480OF425 Nitrogen Inerting ('NI)l To Vacuum Breaker Valve T23-F400K D)IVISION N/A Nitrogen (N2) Supply Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fa il Type Type P'assive Position Position 2 A I Globe AO A Locked Closed Closed Closed AT-I GB 43.401.371 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 PIS T480OF426 Nitrogen Inerting (NJ) To Vacuum Breaker Valve T23-F400L D)IVISION N/A Nitrogen (N2.) Supply Isolation Valve Class Cat Size Valve Actuator' Active / Normal Position Safety Fail Type Type Passive Position P~ositionm 2 A I Globe AO A Locked Closed Closed Closed AT-I GB 43.401.372 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 PIS T480OF427 Nitrogen Inerting (NI) To Vacuum Breaker Valve T23-DIVISION N/A F400M Nitrogen (N2) Supply Isolation Valve Class -Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type - Passive tPosition Position 2 A I Globe AG A Locked Closed Closed Closed AT- I OB 43.401.373 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 Page 6 of 8 For System: T4800

DTE ENERGY - FERMI 2 ISI. / 1ST Proaram Plan - Part 5 Valve Scope Table Sytm '80Test Procedure Deferred Relief Technical Sse: 180Exam F,requency 'Number Justification -'Request Position PIS T480OF453 Containment Atmosphere Control Nitrogen Inerting Drywell D)IVISION N/A Pressure Con,trol Vent Valve Class Cat Size Valve.. Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 1 Globe AO A Open Closed Closed AT-I GB. 43.401.334 BTC OP 24.406.01 FST *.OP 24.406.01 PIT 2Y 24.406.02 PIS T480OF454 Containment Atmosphere C'ontrol Nitrogen Inert ing Drywell I)IVISION, N/A Pressure Control Vent Valve Class : Cat Size .Valve Actuator Active!/ Normal Position Safety Fail "Type Tyvpe Passive Position P~osition 2 A 1 Globe AG A Open Closed Closed AT-I GB 43.401.334 BTC GP 24.406.01 FST GP 24.406.01 PIT 2Y 24.406.02 PIS T480OF455 Containment Atmosphere Control Nitrogen Inerting Drywell DIVISION N/A Pressure Control Vent Valve Class Cat Size Valve Actuator ,Active / Normal Position Safety Fail T1ype Type -Passive . Position Positioni 2 A I Globe AO A Open Closed Closed AT-I OB 43.401.334 BTC OP '24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 Page 7 of 8 For System: T4800

DTE ENERGY - FERMI: 2 ISI1/IST Pro2ram Plan - Part 5 Valve Scope Table Defer red Relict Technical Syte: 4Ois Test Procedure Sse: 1 UUExain Frequency Number Justification Request Position PIS T480OF456 Nitrogen Inerting (ND) To Standby Gas Treatment ('SG) -

D)IVISION N/A Nitrogen (N2) Supply Bypass Isolation valve Class Cat Size Valve Actuator ActiveI 'Normal Position Safety Fnil Type Type Passive .Position Position 2 A I Globe AO A Open Closed Closed AT-I OB . 43.401.377 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 PIS T480OF457 Nitrogen Inzerting (NI) To Standby Gas Treatment ('SGT)

DI1V ISION N/A Nitrogen ('N2) Supply Bypass Isolation valve Class Cat Size Valve Actuator Active/ Normal Position Safety Fail Type Type Passive Position Plositionm 2 A I Globe AO A Open Closed Closed AT-I OB 43.401.377 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y .24.406.02 PIS T480OF458 Nitrogen Inerting (NI) To Standby Gas Treatment ('SGT)

DIVISION N/A Nitrogen (N12) Supply Bypass Isolationi valve Class Cat 'Size Valve Actuator Active / Normal Positionm Safety Fail Type . Type Passive Position Position 2 A I Globe AO A Open Closed Closed AT- I GB 43.401.377 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 Page 8 of 8 For System: T4800

DTE ENERGY - FERMI 2 ISI/1ST ProjZram Plan - Part 5 Valve Scope Table S te: T 83Test P~rocedu re Deferred Relief Technical Sse: 183Exam Frequency Num6er, Justification Request Position PIS T4803F601 Nitrogen. Iertinzg (NI) Dryweli Air Purge Inlet Suipply; Valve D)IVISION N/A C'lass Cat Size Valve Actuator Active!/ Normal Position Safety Fail Ty'pe Type Passive P~osition P'osition 2 ' A 24 BTF MOV A Closed Closed As-Is AT- I OB 43.401.322 AT-8 184D 43.401.510 BTC CS 24.406.01 CSJ-017 GL9605 GP 47.306.03 PIT 2Y 24.406.02 PIS T4803F602 Nitrogen Inerting (NI) Dryweli Inboard Exhaust Isolation D)IVISION N/A Valve C:lass Cat Size Valve .Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 24 BTF MOV A Closed Closed As-Is AT-I OB 43.401.321 AT-S 184D 43.401.510 BTC CS 24.406.01 CSJ-017 GL9605 GP 47.306.03 PIT 2Y 24.406.02 Page 1 of 1 For System: T4803

DTE ENERGY - FERMI12 ISI / IST Pro2ram, Plan - Part 5 Valve Scope Table System: T4804 Exam Test Frequency 11rocedure Number Deferred Justification Relief Request Technical Position PIS T4804FO01A Cooling Water Front Division I Residual H-eat Removal D)IVISION I (RHR) To Division I Hydrogen Recomnbiner Control Class Cat Size V'alve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 B 3/4 Globe MOV A Closed Close As-Is BTC OP 24.409.02 PIT 2Y 24.409.02 PIS T4804FO01B Cooling Water Front Division I Residual [-eat Removal DIVISION 2 (RIHR) To Div [IHydrogen Recomnbiner Control Class Cat Size Valve Actuator Active / Normal Position Saretv Fa il Typec Typse Passive tPosition0 PositIion 2 B 3/4 Globe MOV A Closed Close As-Is BTC OP 24.409.03 PIT 2Y 24.409.03 PIS T4804FO16A Hydrogen Recomnbiner (HR) Return Line For Division I DIVISION I F601A and F604A Bypass Relief Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A/C 2 RLF Self Act .A Closed Open AT-I OB 43.401.384 CT-SP IOY 43.000.020 PIS T4804FO16B Hydrogen Recomibiner ('HR) Return Line For Div II F601IB D)IVIS ION 2 and F604B Bypass Relief Valve.

Class Cat Size Valve Actuator Active!/ Normal P~osition Safety Fail Typse Type Passive Position Position 2 A/C 2 RLF Self Act A Closed Open AT-I OB 43.401.384 CT-SP MOY 43.000.020 Page 1 of 5 For System: T4804

DTE ENERGY -FERMI 2 1S81 I ST Proaram.Plan - Part 5 Valve Scope Table Sse : T 84Test P~rocedlure Deferred Relief Technical Sytm 184Exatr Frequency Number Justification Request Position PIS T4804F601A Hydrogen Reconmbiner (HR) To Torus Division I Hydrogen D)IVIS ION I (H2) Control Return Isolation Valve Class Cat Size Valve Actuator Active / Normal Positin Safety Fail Type Type Passive Position Position 2 A 8 BTF MOV A Closed Closed As-Is AT-I OB 43.401.384 AT-IS OB 43.401.384 BTC OP 24.409.02 GL9605 GP 47.306.03 PIT 2Y 24.409.02 PIS T4804F601B H)dr-ogen Reconrbiner (HIR) To Torus Div HI H drogen (H12)

D)IVISION 2 Control Return Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Salchv Fa il Type Type P~assive Position Position 2 A 8 BTF MOV A Closed Closed As-is AT-I GB 43.401.384 AT-IS GB 43.401.3 84 BTC OP 24.409.03 GL9605 GP 47.306.03 PIT 2Y 24.409.03 PIS T4804F602A H)drogen Reconrbiner (HR) Division I Hydrogen (112)

DIVISION I Control Torus.Suction Isolation Valve C;lass Cat Size Valve Actuator Active / Normial Position Safctv Fail "Type T'yPC Passive Position Position 2 A 4 BTF MOV A Closed' Closed As-Is AT-I OB 43.401.383 AT- IS GB 43.401.383 BTC OP 24.409.02 GL9605 GP 47.306.03 PIT 2Y 24.409.02 Page 2 of 5 For System: T4804

DTE ENERGY - FER III12 ISI/1ST Proj4ram Plan - Part 5 VN'alve Scope Table Sytm 40 'Test Procedure Deferred Relief Trechnical Syte: 484Exam Frequency Number J ustitication Request Position PIS T4804F602B Hydrogen Reconmbiner (H-R,) Div II Hydrogen (H2) Control DIVISION 2 Torus Suction Isolation Valve Class Cat Size Valve Actuator -Active / Normal Position Safety Fail Type Type -Passive Position Position 2 A 4 BTF MOV A Closed Closed As-Is AT-I -GB 43.401.385 AT-IS GB 43.401.385 BTC OP 24.409.03 GL9605 GP 47.306.03 PIT 2Y" 24.409.03 PIS T4804F603A - Hydrogen Reco,nbiner:.(HR) Div ision f Hydrogen (H12)

D)IVISION IControl Drywell Suction Isolation Valve Class Cat. Size Valve Actuator Active/ Normal Position Saretv Fail Type Type Passive P~osition Position 2 A 4 BTF MOV A Closed Closed As-Is AT-I OB 43.401.310 AT-IS GB 43.401.310 BTC OP 24.409.02 GL9605 GP 47.306.03 PIT 2Y 24.409.02.

PIS T4804F603'B Hydrogen Recomsbiner (HR) Div HI Hydrogen (H2) Control DIVISION 2 Dr-ywell Suction Isolation.Valve Class Cat Size Valve Actuator Active / NornnllPosition3 Safety Fail Type Type Passive Position Position 2 A 4 BTF -MOV .A Closed Closed As-is AT-I OB 43.401.349 AT-lS GB 43.401.349 BTC. OP 24.409.03 GL9605 GP 47.306.03 PIT 2Y 24.409.03 Page 3 of 5 For System: T4804

DTE ENERGY - FERMI 2 . ISI / 1ST Pro2ram Plan - Part 5 Valve Scope Table System: 140 -Exam Test Frequency Procedure Number Deferredi Justiticatitin Relief Request Technical Position PIS T4804F604A Hydrogen Recomibiner (HIR) Division I Hydrogen (Hf2)

D)IVISION I Control Return Out board Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 8 BTF MOV A Closed Closed As-is AT-I OB 43.401.384 BTC OP 24.409.02 GL9605 GP 47.306.03 PIT 2Y 24.409.02 PIS T4804F604B Hydrogen Recoibiner (HR) Div 1I Hydrogen (HJ2) Control DIVISION 2 Return Outboard Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive' P~osition Position 2 A 8 BTF MOV A Closed Closed As-is AT-I OB 43.401.384 BTC OP 24.409.03 GL9605 GP 47.306.03 PIT 2Y 24.409.03 PIS T4804F605A Hydrogen Recomnbiner ('HR) Division I Dr rvell Outboard DIVISION I Suction Isolation Valve Class Cat Size Valve Actuator Active / Normal P'osition Safety Fail Type _Type P~assivye Positino Posi tioni 2 A 4 BTF MOV A Closed Closed As-Is

• AT-I OB 43.401.310 BTC . OP 24.409.02 GL9605 GP 47.306.03 PIT 2Y 24.409.02 Page 4 of 5 For System: T4804

DTE ENERGY - FERMI 2 181 I1ST.Prog3ram Plan - Part 5 Valve Scope Table Sytm T 84Test P~rocedu re Deferred Relief Tech nical Sytm T 84Exam Frequency Number Justification Request Position PIS T4804F605B Hydrogen: Recomnbiner (HR) Div 11 Drywell Outboard Suction D)IVISION 2 Isolation Valve Class Cat Size Valve Actuator Active I Normal Position Safety Fail Type Type Passive Position P'osition 2 A 4 BTF MOV A Closed Closed As-Is AT-I OB 43.401.349 BTC OP 24.409.03 GL9605 GP 47.306.03 PIT 2Y 24.409.03 PIS .T4804F606A Hydrogen Recomnbiner (HR),-Division I Torus Outboard DIVISION I Suction Isolation Valve Class Cat Size Valve Actuator Active/I Normal Position Safety Fail TypeC Type Passive Position Position 2 A 4 BTF MOV A Closed Closed As-is AT-I OB 43.401.383 BTC OP 24.409.02 GL9605 - GP 47.30603 PIT -2Y 24.409.02 PIS T4804F606B Hydrogen Recomnbiner" (HR) Div 11 Torus Outboard Suction DIVISION 2 Isolation Valve Class Cat Size- Valve Actuator Active/I Normal Position Safety Fail Type Type Passive P'osition Position 2 A 4 BTF MOV A Closed Closed As-is AT-I OB 43.401.385 BTC OP 24.409.03 GL9605 GP 47.306.03 PIT 2Y 24.409.03 Page 5 of 5 Foi- System: T4804

DTE ENERGY -FERMI 2 1S1 / IST. Pro2ram Plan - Part 5 Valve Scope Table Sse ' T 9 1Test Procedure Deferred Relief Technical Sytm 140 Exam Frequency Number Justitication Req uest Position PIS T4901F004 . Primtary Containment Pneumatic (PCP) Division I DIVISION I Instrument Nitrogen Inerting (N2) Supply To Outboard Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 1 1/2 RLF Self Act A Closed Open CT-SP IOY 43.000.020 PIS T4901F007 Primtary Containment Pneumatic (PCP) Division I Supply D)IVISION 1Outboard Primtary Cont. Isol. Valve B Class Cat Size Valve Actuator Active / Normal.Position Safety Fail Type Type Passive Position Position 2 A 1 1/2 Globe MAN P Locked Closed CLOSED N/A AT-I OB 43.401.318 PIS T4901FO16 Primary Containment Pneumatic (PCP) Div 11 Supply D)IVISION 2 Outboard Primtary Cant. Isol. Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fa il Type Type Passive Position Position 2 A 1 1/2 Globe MAN P Locked Closed CLOSED N/A AT- I OB 43.401.343 PIS T4901FO19 Printary Containment Pneumatic (PCP) Division I Supply To D)IVISION I Accumulator Tank B2104AO03A In let Check Valve Class Cat Size Valve Actuator Active / Normal Position Sarety Fail Type Type . Passive Position Position 3" A/C., I CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 PIS T4901FO21IAcu PrimtarylaoTnkB14 Containmtent Pneumatic 03Reifav.

('PCP) Division-IDVSO Class Cat Size Valve Actuator Active /.Normal Position Safety. Fail Type Type Passive Position P~osition 3 C -3/4 RLF Self Act A Closed Open CT-SP IOY 43.000.020 Page 1 of 8 For System: T4901

DTE ENERGY - FERMI 2 1SI/1ST ProjZram Plan - Part 5 Valve Scope Table Procedure Deferred Relief Technical Sse: T 91Test Sytm 191Exam I'requency Number Justitication Request Position PIS T4901FO22 Primtarj Containment Pneumatic (PCP) Division I Supply To D)IVISION IAccumulator Tank B2104AO03E Inlet Check Val Class Cat Size Valve Actuator Active/I Normal P'osition Safety Fail Type Type Passive Position Position 3 A/C I CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-O RR 24.137.02 ROJ-003 PIS T4901F024 Primhry Containment Pneumatic (PCP) Division I DIVISION I Accumulator Tank B21 04AO003E Relief Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Positiont Position 3 C 3/4 RLF Self Act A Closed Open CT-SP MOY 43.000.020 PIS T4901F025 Prinaiy Containment Pneumatic (PCP) Division I Supply to DIVISION I Accumulator Tank B2104AO03D hilet Check Val Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive ['osition Position 3 A/C I CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-O RR 24.137.02 ROJ-003 PIS T4901FO27 Primagy Containment Pneumatic (PCP) Division I DIVISION IAccumulator Taiik B2104AO03D Relief Valve.

Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position 3 C 3/4 RLF Self Act A Closed Open CT-SP I0Y 43.000.020 Page 2 of 8 For System: T4901

DTE ENERGY - FERIVI 2 ISI/1IST Promram Plan - Part 5 Valve Scope Table Sse: T 91Test Procedure Deferred Relief Technical Sytm 191Exam f'requiency Number ~Justification Request Position PIS T490IF028 Primary; Contaiment Pneumatic ('PCP) Division I Supply To lIVISION D IAccumurlator" Tank B2104A003B Inlet Check Valve Class Cat Size Valve -Actuator Active / Normal Position Safety Fail "Tcre Type Passive Position P'osition 3 A/C I CK Self Act A System Dependent Both FAT-3 2Y 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 PIS T490IF030 Primary Containment Pneumatic ('PCP) Division I DIVISION I Accu'nruldtor Tank B21I04A 003B Relief Valve.

Class Cat Size Valve Actuator Active / Normal P~osition Safety Fail Type Type .Passive Position .Position 3 C 3/4 RLF Self Act A Closed Open CT-SP IOY 43.000.020 PIS T4901FO31 Primary Containmuent Pneumatic (PCP)Division l Supply To D)IVISION I Accuntulator Tank B2104AO03C In-let Check Vol Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 .A/C I CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-O RR 24.137.02 ROJ-003 PIS T4901FO33 Primary Containment Pneumatic (PCP)J Division I DIVISONIAccunmulator Tank B2104AO03C Relief Valve.

laVssO Ca ize Vle Atao cie/Nra oiin Sft ai Type Type Passive - Position Position 3 C 3/4 RLF Self Act A Closed Open CT-SP 1OY 43.000.020 Page 3 of 8 For System: T4901

DTE ENERGY - FERMI 2 ISI/1IST Pro2ram Plan - Part 5 Valve Scope Table System: 14901 Exm Test Exm Frequency Procedlure Number Deferred Justification Relief Request Technical Position PIS T4901FO34A Primary C'ontainmnent Pneumatic (PCP) Division I Supply To D)IVISION IAccumulator Tank B2103AOOIC Inlet Check Valve Class Cat Sizc Valve - Actuator Active / Normal Position Safety Fail Type Type Passive .Position Position 3 A/C I CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 PIS T4901FO34B Primary Containment Pneumatic (PCP) Division I Supply To DIVISION I Accumulator Tank B2103AO00ID Inlet Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive P'osition Position 3 A/C I CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT-C R.R 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 PIS .T490IF034C Primary Containmnent Pneumatic (PCP) Division I Supply To D)IVISION IAccumulator Tank B2103AOOIA Inlet Check Valve Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position 3 A/C 1 CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 PIS T4901FO34D Primary C?ontainment Pneumatic (PCP) Division I Supply To DIVIlSION IAccumulator- Tanik B2103AOOIB Imilet Check Valve Class Cat Size Valve Actuator Active / Normal P'osition Safety Fa il Type Type Passive Position Position 3 A/C I CK Self Act A System Dependent Both AT-3 2Y 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 Page 4- of -8 For System: T4901

DIE ENERGY -FERMI 2 151I /1IST Prokram Plan - Part 5 Valve Scotie Table Sytm: T 90rest Procedure Deferred Relief Technical Sytm 191Exam Frequency Number Justification Request Position PIS T4901F036A Pruntary Containmnent Pneumatic (PCP) Division I D)IVISION i Accnumulator Tank B2103A001 C Relief Valve.

Class Cat _Size "Valve Actuator Active / Normal Position Saretv Fail Type Type Passive Position Position 3 C 3/4 RLF Self Act A Closed Open CT-SP lOY 43.000.020 PIS T4901FO36B Primary Containment Pneumatic (PCP)I Division I D)IVISION IAccumulator Tankc B2.103A001/D Relief Valve.

Class Cat Size Valve Actuator Active / Normal Position Saretv Fail Type Type Passive P'ositioni Position 3 C 3/4 RLF Self Act A Closed Open CT-SP IOY 43.000.020 PIS. T4901F036C Printary Containmntet Pneumatic ('PCP) Division I D)IVISI ON . Accumulator Tank B21I03A 001A.Relief Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type ~Type Passive . Position Position 3 C 3/4 RLF . Self Act A Closed Open CT-SP IOY 43.000.020 PIS T4901FO36D Primary Containmtent Pneumtatic (PCP) Division I D)IVIS10N 1Accumulator Tank B2103AOOIB Relief Valve.

Class Cal Size Valve Actuator Active / Normal Position Safety Fail Type .TYP'e Passive .Position Position 3 C 3/4 RLF Self Act A Closed' Open CT-SP IOY 43.000.020 PIS T4901FO37 Printarl) Containtmenmt Pneumatic (PCP) Division I D)IVISION I . Accumulator Tank B2104AO04B Relief Valve.

C:lass Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 C 3/4 RLF Self Act A Closed Open CT-SP lOY 43.000.020 Page 5 of 8 For System: T4901

DTE ENERGY - FERMI 2 181 I1ST Pro";rani Plan - Part 5 Valve Scope Table Sytm '91Test Procedure Deferredl Relief Technical Sytm 191Exam Frequency Number Justification Request Position PIS T490IF039 Primary Containment Pneumatic (PCP) Divisionz I Supply To D)IVISION IAccumulator Tank B2104AO04B TIet Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 A/C I CK Self Act A System Dependent N/A AT-3 RR 24.137.02 CT-C RR 24.137.02 ROJ-003 CT-0 RR 24.137.02 ROJ-003 PIS T4901FO40 PrimaryContainment Pneumatic (PCP)Division I Supply To DIVISION 2 Accumulator Tank B2104AO004ChInlet Check Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Tytie Passive Position Position 3 A/C I CK .Self Act A System Dependent N/A AT-3 RR 24.137.02 CT-C RR 24.137.02 RGJ-003 CT-G RR 24.137.02 ROJ-003 PIS T4901F465 Primary Contaiznment Pneumatic (PCP) Division I Supply D)IVISION IOutboard Primary Containmentt (PC) Isolation Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 1 1/2 Globe AO A Open . Closed Closed AT-I GB 43.401.318 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 T4901F466

.... . Primamy Containment PIS Pnteumatic (PCP) Division I Nitrogen D)IVISION I (N2)l Supplyi Isolation Valv'e Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 B 1 1/2 Globe AG A Open Closed Closed

-BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406*02 Page 6 of 8 For System: T4901

DTE .ENERGY - FERMI 2 ISI /I1ST Pro2ram Plan - Part 5 Valve Scope Table Sse" T 91Test Procedure Deferred Relief Technical Sytm T91Exam Frequency Number Justification Request Position PIS T4901F467 Primary Containment Pneumatic (PCP) Div I Nonz-DIVISION IInterruptible Air Supply (NIAS) Isolation Valve Class Cat Size V'alve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 3 B I Globe AG A Closed Both Closed BTC OP 24.406.01 BTO OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 PIS T4901F468 Primary Containmenst Pneumatic (PCP) Div 11 Supply Outbd DIlVISION 2 Primary' Containment (PC) Isolation Valve Class Cat Size Valve Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position 2 A 1 1/2 Globe AG A Open Closed Closed AT-I GB 43.401.343 BTC OP 24.406.01 FST OP 24.406.01 PIT 2Y 24.406.02 PIS .T4901F601 Pri Cont Pneumatic (PCP) Div I Instnnt Nitrogen Inerting DIVISION I Supply Insbd Primnary Cont Isolation Valve Class Cat Size Valve Actuator Active/I Normal Position Safety Fail

'Type 'Type Passive P iosition Position

• 2 A 1 1/2 Globe N4OV A open Closed As-Is AT- I OB 43.401.318 BTC OP 24.406.01 GL9605 GP 47,306.01 /.03 PIT 2Y 24.406.02 Page 7 of 8 For System: 14901

DTE ENERGY'- FERMI112 '1S1 / IST Pro2ram Plan - Part 5 Valve Scope Table System: 14901 rest Procedure Deferred Relief Technical Fsamn Frequenic) Number Justification Request Position PIS T4901F602 Pri Conat Pneumatic (PCP) Div [IInsia Nitrogen inerting DIVISION 2 Supply Iabd Primmay Cont Isolation Valve Class Cat Size Valve Actuator Active / Normal P'ositioni Safety Fail Type Type Passive Position Position 2 A 1 1/2 Globe MOV A Open Closed As-Is AT- I OB 43.401.343 BTC OP 24.406.01 GL9605 GP 47.306.01 / .03 PIT 2Y 24.406.02 Page 8 of 8 For System: T4901

DTE ENERGY - FERMI 2 18 1 / ST Pfonram Plan - Part 5 Valve Scope Table Sse: 50 Test Procedure Deferred Relief Technical Exam Frequency Number Justification Request Position PIS T5000F401A Primary Containment Atmosp here Monitoring (PCAM)

D)IVISION IT5OL400A CT Outboard Sample Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Ball AO A Open Closed Closed AT-I GB 43.401.354 BTC OP 24.408.03 FST OP 24.408.03 PIT 2Y 24.408.03 PIS T5000F401B Primary C'ontainmnent Atmosphere Monitoring ('PCAM)

DIVISION 2 T5OL400B CT Outboard Sample Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type' Type Passive Position Position 2 A 1 Ball AO A Closed .Closed Closed AT-I GB 43.401.323 BTC GP 24.408.04 FST GP 24.408.04 PIT 2Y 24.408.04 PIS T5000F402A Primary ContaisnentAtmosphere Monitoring ('PCAM).

DIVISION I T5OL401A CT Outboard Sample Valve Class Cat Size Valve Actuator Active / Normal Position Safety' Fail

'Type 'Type Passive P'osition Position 2 A I Ball AO A Open Closed Closed AT-I GB 43.401.354 BTC OP 24.408.03 FST GP 24.408.03 PIT 2Y 24.408.03 Page 1 of 8 For System: 15000

DTE ENERGY - FERMI 2 ISI / IST Pro2ram Plan - Part 5 Valve Scope Table System: T5000 Test Procedure Deferred Relief Technical Exam Frequency Number Justification Request Position PIS T5000F402B Primary Containment Atmosphere Monitoring (PCAM)

DIVISION 2 T50L401B CT OutboardSample Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Ball AO A Closed Closed Closed AT-I OB 43.401.324 AT-4 OB 43.401.511 BTC OP 24.408.04 FST OP 24.408.04 PIT 2Y 24.408.04 PIS T5000F403A Primary Containment Atmosphere Monitoring (PCAM)

DIVISION I T50L402A CT OutboardSample Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Ball AO A Open Closed Closed AT-I OB 43.401.354 BTC OP 24.408.03 FST OP 24.408.03 PIT 2Y 24.408.03 PIS T5000F403B Primary Containment Atmosphere Monitoring (PCAM)

DIVISION 2 T50L402B CT OutboardSample Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 1 Ball AO A Closed Closed Closed AT-1 OB 43.401.323 BTC OP 24.408.04 FST OP 24.408.04 PIT 2Y 24.408.04 Page 2 of 8 For System: T5000

DTE ENERGY - FERMI 2 ISI / IST Program Plan - Part 5 Valve Scope Table System: T5000 Test Procedure Deferred Relief Technical Exam Frequency Number Justification Request Position PIS T5000F404A PrimaryContainment Atmosphere Monitoring (PCAM)

DIVISION I T50L403A CT OutboardSample Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Ball AO A Open Closed Closed AT-1 OB 43.401.354 BTC OP 24.408.03 FST OP 24.408.03 PIT 2Y 24.408.03 PIS T5000F404B Primary ContainmentAtmosphere Monitoring (PCAM)

DIVISION 2 T50L403B CT OutboardSample Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A I Ball AO A Closed Closed Closed AT-1 OB 43.401.323 BTC OP 24.408.04 FST OP 24.408.04 PIT 2Y 24.408.04 PIS T5000F405A Primary ContainmentAtmosphere Monitoring (PCAM)

DIVISION 1 T50L404A CT OutboardSample Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 1 Ball- AO A Open Closed Closed AT-1 OB 43.401.354 BTC OP 24.408.03 FST OP 24.408.03 PIT 2Y 24.408.03 Page 3 of 8 For System: T5000

DTE ENERGY - FERIVI 2 151/1ST Promram Plan - Part 5 Valve Scope Table Sse: T 00Test Procedure Deferred Relief Technical Syte: 500Exam Frequency Number Justification Request Position PIS T5000F405B Primary Containent Atmosphere Moniitoring (PCAM)

IN'ISION 2 T50L404B CT OutboardSannple Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fa il Type Type Passive Position Position 2 A I Ball AO A Closed Closed Closed AT-I GB 43.401.323 BTC OP 24.408.04 FST OP 24.408.04 PIT 2Y 24.408.04 PIS T5000F407A Printany Contajinment Atmosphere Monitoring (PCAM)

DIVISION I T5OL410A CT OutboardSample Valve Class Cat Size Valve Acttuator Active/I Normal Position Safety Fail Type Type Passive Position Position 2 A I Ball AG A Closed Closed Closed AT-I GB 43.401.386 BTC OP 24.408.03 FST OP 24.408.03 PIT 2Y 24.408.03 PIS T5000F407B Primary Containment Atmosphere Monitoring (PCAM)

DIVISION 2 T5OL410B CT OutboardSample Valve Class Cat Size Valve Actuator Active/ ..Normal Position Safety Fail

_Tviie Type Passive PositinaPosition 2 A I Ball AG A Gpen Closed Closed AT-I GB -43.401.387 BTC OP 24.408.04.

FST OP 24.408.04 PIT 2Y 24.408.04 Page 4 of 8 For System: T5000

DIE ENERGY - FERMII 2 / IST fl-oeram Plan 151.S - Part 5 Valve Scope Table Sse: T 00Test Procedure Deferred Relief Technical Sytm 100Exam Frequency Numibei 3ustification Request Position PIS T500OF408A .Primary C?oltaimentAtmosphere Monitoring (PCAM)

D)IVISION IT50L411IA CT OutboardSample Return. Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type Passive Position Position 2 A 1 Ball AG A Open Clased Closed AT-I GB 43.401.383 BTC GP 24.408.03 FST GP 24.408.03 PIT 2Y 24.408.03 PIS T5000F408B Primar-y Contaiznent Atmosphere Mon itoring ('PCA M)

DIVISION 2 T50L411lB CT Outboard Sample Valve Class Cat Size Valve - Actuator Active/I Normal Position Safety Fail Type Type Passive Position Position 2 A I Ball AO A Open Closed Closed AT-1 GB 43.401.385 BTC OP 24.408.04 FST OP 24.408.04 PIT 2Y 24.408.04 PIS T5000F420A Primnary Containment Atmosphere Monitoring (PCAM)

DIVISION IT50L406A PT Outboard Sample Valve Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type lType Passive Position Position 2 A I Ball AG A .Open C]osed Closed AT-1 GB 43.401.353 BTC OP 24.408.03 FST OP 24.408.03 PIT 2Y 24.408.03 Page 5 of 8 For System: T5000

DTE ENERGY - FERMI 2 ISI1/1IST Pro2ram Plan - Part 5 Valve Scope Table System: 15000 Exam Test Frequency Procedure Number Deferred Justification Relief -Technical Request Position PIS T5000F420B Prinary Contaitnent Atmosphere Monitoring ('PCAM)

D)IVISION 2 T5OL406B PT OutboardSample Valve Class Cat Size Valve Actuator Active / Norinal Position Safety Fail Type Type Passive Position Position 2 A I Ball AO A Open Closed Closed AT-I GB 43.401.333 BTC -OP 24.408.04 FST OP 24.408.04 PIT 2Y 24.408.04 PIS T5000F455 Primary Containment Radiation Monitor Rack H21P284 DIVISION 2 Outlet Secondary Isolation Valve Class Cat Size Valve -Actuator Active / Normal Position Safety Fail Type Type Passive Position P'ositionm 2 A 1 Ball AO A Open Closed Closed AT=1 GB 43.401.383 BTC OP. 24.408.03 FST OP 24.408.03 PIT 2Y 24.408.03 PIS T5000F456 Primary Containment Radiation Monitor Rack H211P284 DIVISION 2 Inlet Seconsdary Isolation Valve Class Cat Size Valve Actuator Active/ Normal Position Safety Fail Type Type Passive Position Position 2 A I Ball AG A Open Closed Closed AT-I GB 43.401.354 BTC OP 24.408.03 FST OP 24.408.03 PIT 2Y 24.408.03 Page 6 of 8 For System: T5000

DTE ENERGY - FERMI 2 ISI /.1ST Prnriam Plan.- Part 5 Valve Scope Table Sse: T 00Test Procedure Deferred Relief Technical Sse: 100Exam Frequency Number Justification Request Position PIS T50F412A Solenoid Valve: Priniary Containment Tortis Level D)IVISION 1Monitoring Division / Solenoid Valve.

Class Cat. Size Valve Actuator Active / Normal Position Safety Fa il Ty'pe Type P'assive Posi tioni PositWin 2 A I Globe SOV A Open Closed As-is AT-2 OB 43.401.402 BTC OP 24.408.03 PIT OB 43.401.402 VRR-012 PIS T50F412B. Solenoid Valve: PritnaiyContainment Torus Level D)IVISION 2 Monitoring Division 2 Solenoid Valve.

Class Cat Size Valve Actuator Active!/ Normal Position Safety Fail Type Type Passive Positioni Position .

2 A I. Globe SOV A. Open . Closed As-Is AT-2 OB 43.401.403 BTC OP 24.408.04 PIT OB 43.401.403 VRR-012 PIS T50F450 Solenoid Valve: PrinaryContainnient Radiation Monitoring D)IVISION I System Inlet Isolation Valve.

Class Cat Size Valve Actuator Active / Normal Position Safety Fail Type Type_ Passive Positioni Position 2 A 3/4 Globe SOV A Open Closed Closed AT- I OB 43.401.354 BTC OP 24.408.03 FST OP 24.408.03 PIT OB 43.401.354 VRR-012 PIS T50F451 Solenoid Valve: Primntay Containment Radiation Mon itorinig DIVISION I System Outlet.Isolation Valve.

Class Cat Size Valve Actuator. Active / Normal Position Saftyh Fail Type Type Passive P'osition Position 2 A 3/4 Globe .SOV A Open Closed Closed AT-I . OB 43.401.383 BTC OP 24.408.03 FST OP. 24.408.03 PIT OB 43.401.383 VRR-012'

/ Page 7 of: 8 For System: T5000

DTE ENERGY - FERMI12 1S1 / IST Pro2i-am Plan - Part 5 Valve Scope Table System: 15000 'rest Procedure Deferred Relief Technical

______Exam Frequency Number Justification Request Position PIS T50F458 Primzary Containment Atmospheric Monitoring (PCAM)

D)IVISION 2 Division 2 Penetration.X-27F Remote Manttal Solenoi Class Cat Size V'alve Actuator Active / Normal P'ositioni Safety Fa il Type Type P~assive P'ositionm Position 2 A I Globe SOV A Open Closed As-is AT-I OB 43.401.389 BTC OP 24.408.04 PIT OB 43.401.389 VRR-012 Page 8 of 8 For System: 15000

FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES FERMI 2 THIRD 10 YEAR INTERVAL - START DATE 02/15/2010 PART 6: IST CHECK VALVE CONDITION MONITORING PLANS REVISION 0 Revision Summary:

1. Complete rewrite for start of 3rd ten year interval OUAL Prepared: Date: _____o__u _ PE-12 IST ogram anager Reviewed: . D. 2 Date: PE-12 ISI/PEP Engineer Reviewed: Ob / EL 1A1(c"I (doDate: N/A Supervisor, Performance Engineering Approved: / Date: N/A M ger, Performance Engineering INFORMATION AND PROCEDURES DSN: IST CVCM Plans Rev: 0 Date: yI  ? y DTC: TM PLAN File: 1715.04 Recipient:

Date Approved: A s1ii/2 Release authorized by: A4 s r,di-it 6 e

i 1

Z-

IST PROGRAM PLAN PART 6 CVCM PLANS INDEX PLAN # DESCRIPTION VALVES E110OF020A CMP-01 RHIR Service Water Return Checks E110OF020B C4100F006 CMP-02 Standby Liquid Control CIV Checks C4100F007 E110OF046A E110OF046B CMP-03 RHR Min Flow Checks E110OF046C Eli10OF046D E210OOF003A E2 10OF003B CMP-04 Core Spray Pump Discharge Checks E210OF003C E210OOF003D E210OF038A E21 00F038B CMP-OS Core Spray Pump Min Flow Checks E210OF038C E21 0OF038D E410OOFOI19 CMP-06 HPCI Booster Pump Suction Checks E410OF045 P440OF051 P440OF116A CMP-07 EECW Return Checks P440OF116B P440OF1 65 P440OF003A CMP-08 EECW Pump Discharge Checks P44007A P440OF077B E41 0OF040 CMP-09 HPCI Turbine Check Valves E410OF048 E410OF057 CMP-10 HPCI Turbine Exhaust Check ValveE40F9 3

r t

Fermi Nuclear Station Check Valve Condition Monitoring Plan CMP-01 RHR Service Water Return Checks Rev.9

Fermi Nuclear Station CMP-01 RHR Service Water Return Checks 1.0 GROUP INFORMATION 1.1 Valve List E1100F020A RHR DIV1 HX "A" SERVICE WATER RETURN CHECK VLV E1100F020B RHR DIV2 HX "B" SERVICE WATER RETURN CHECK VLV 1.2 Manufacturing Data Manufacturer: Powell Valve Type: Swing Model: 1561AWE Size: 24 Valve Body Material: SA216 Disc Material: HF SS CA15 BODY SEAT HF COCR Design Feature: Bolted bonnet 1.3 Service Conditions Service Duty: Water System Flow: 9000 gpm System Pressure: 175 System Temperature: 155 1.4 Grouping Bases.

These valves are grouped together based on having the same manufacturer, model, and service application.' The following were considered in group determination:

R Same Mfg W Like Orientation O Service Conditions W Like Design

© Identical Application D Maximum Flow Unachievable Q Identical Test Methodology Q Similar Upstream Dowstream Flow Turbulence 0 Frequency of Operation Q Other 1.5 Safety Function Discussion These check valves have a safety function to open from the closed position to allow RHRSW cooling water return flow from the RHR Heat Exchangers.. The check valves must be capable of opening to allow for a RHRSW flowrate of 9000 GPM (via the cold weather bypass line). This is based on calculations within IST Evaluation 99-071.

Rev.

Page 2 of 11

Fermi Nuclear Station CMP-01 RHR Service Water Return Checks 2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience IST Testing results have been very good overall. The valves were open exercise tested each quarter by passing a minimum of 9000 gpm through the valves. No failures have occurred in the last 10 years.

One OE originated at Fermi on similar valves. OE18668 - Dissimlar Metals in Swing Check Valves Experience Corrosion, is based on events at Fermi U2 on 10 inch Powell swing checks, model 1561 AWE in the service water system. The problem was also identified in 20 inch service water check valves. The root cause was determined to be galvanic corrosion between the disc post and the retaining nut due to dissimilar metals. The disc is carbon steel (A216 GR WCB) and the nut (and swing arm) stainless steel (SA217 GR CA15). The problem can cause the check valve's disc to fail such that the.disc can be cocked into the in-body seats, resulting in failure to fully close. The corrective action was to replace the carbon steel disc with a stainless steel disc, and was performed on the valves in this Group in 2001.

The valves have been disassembled and inspected, and refurbished as needed, under the site 86-03 check valve program by procedure 47.000.13. The current frequency of inspection once every 4 cycles addresses know corrosion issues and ensures preventive maintenance is performed prior to degradation to the point of potential failure.

2.2 Industry Service Experience Generic Notices All Generic Notices available from the NRCs reading room were reviewed. No relevent Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevent Generic Letters were found.

All'Information Notices available from the NRCs reading room were reviewed. No relevent Information Notices were found.

LER/OE Notices Reviewed INPOs Nuclear Network for LERs and OE Notices pertaining to Powell swing check valves with a model number containing 1561. The following items were reviewed for applicability:

LER 87-001-01 (Fitzpatrick) reports the LLRT failure of the HPCI turbing exhaust check valves. The leakage was due to normal wear and was repaired by lapping the disc and seat.

Applicability: Not Applicable. The valves in Group CMP-01 are not containment isolation valves and have no closed safety function. The valves are not required to meet any seat leakage requirements.

LER 87-009-01 (Hatch U1) reports the LLRT failure of the HPCI turbing exhaust check valves. The leakage was due to normal use and wear and was repaired by replacing/cleaning the disc and seat rings as required.

Applicability: Not Applicable. The valves in Group CMP-01 are not containment isolation valves and have no closed safety function. The valves are not required to meet any seat leakage requirements.

OE18668 - Dissimlar Metals in Swing Check Valves Experience Corrosion. This OE was based on events at Fermi U2 on 10 inch Powell swing checks, model 1561 AWE in the service water system. The problem was also identified in 20 inch service water check valves. The root cause was determined to be galvanic corrosion between the disc post and the retaining nut due to dissimilar metals. The disc is carbon steel (A216 GR WCB) and the nut (and swing arm) stainless steel (SA217 GR CA15). The problem can cause the check valve's disc to fail such that the disc can be cocked into the in-body seats, Rev.

Page 3 of 11

Fermi Nuclear Station CMP-01 RHR Service Water Return Checks resulting in failure to fully close. The corrective action was to replace the carbon steel disc with a stainless steel disc.

Applicability: Applicable. This failure occurred at Fermi in valves similar to those in Group CMP-01. As a result of the OE review, the carbon steel discs in the valves in this Group were replaced with stainless steel discs in 2001. Failure to close due to corrosion is considered a potential failure mode, and periodic maintenance is performed to address this known condition.

NIC Database Review The NIC Check Valve Performance Database was reviewed for failures of Powell swing check valves with similar model numbers. Although no failures of 24 inch valves were found, several failures of 16 inch, 18 inch and 20 inch were identifed, including several from Fermi U2. Since the failures at Fermi were similar to those of other utilities, only the Fermi events are discussed below. The following Failure Record Numbers were reviewed for applicability:

FRN 88-021 (Fermi) reported the seat leakage of an RHR service water pump discharge check valve due to wear that resulted in disconnection of valve parts. The valve was rebuilt and worn parts replaced.

Nearly identical failures were reported for other RHR service water pump discharge checks in FRNs88-019, 88-001 Applicability: Applicable. Although the valves in Group CMP-01 have no specific seat leakage criteria, normal wear could result in failure to close or broken/detached parts. These are considered potential failure modes for this Group.

FRN 89-086 (Fermi) reported the failure to close of an RHR service water pump discharge,check valve due to corrosion on the disc stud. He valve was cleaned and adjusted and will be replaced when a spare is available. FRN 99-149 later reported a failure to close of an EESWP pump discharge check, and determined the corrosion was galvanic corrosion between the carbon steel disc stud and the stainless steel disc retaining nut. This cause was tied to previous failurs of other service water check valves. The corrective action is to replace the carbon steel discs with stainless steel discs. A similar failures was reported in FRN-99-123 Applicability: Applicable. Failure to close due to corrosion of.parts is a potential failure mode for this Group. The discs were repaced in 2001 and periodic maintenance is performed to address this know issue.

EPIX Review INPOs EPIX database was reviewed for failures of Powell swing check valves with similar model number, size and application. The following Failure Numbers were reviewed for applicability:

FN 155 (Browns Ferry U2) reported the failure to open of a HPCI suction check valve. The cause was errosion/corrosion process, and specified as chemical attack. The valve was repaired.

Applicability: Not applicable. There was not enough information in the FN to determine if this is applicable to the valves in Group CMP-01. The valves in this Group have been periodically disassembled and inspected since 1991, and although corrosion has been identified, there is no indication it would prevent the valves from opening.

FN 101 (Hatch U1) reports the failure to fully close of a service water pump discharge check valve when the pump was shut down. Inspection of the valve determined the hanger and disc were worn . The cause was equipment age and wear.

Applicability: Applicable. Failure to close due to normal wear is a potential failure mode for this Group.

Rev.

Page 4 of 11

Fermi Nuclear Station CMP-01 RHR Service Water Return Checks Vendor Input There was no vendor input or Part 21 Reports associated with 24" Powell swing check valves.

Industry Template There was no Powell Swing Check Valve Industry Template available on the Nuclear Industry Check (NIC) Valve Group's website.

2.2.1 References Generic Notices None LER/OE Notices LER 87-001-00 (Fitzpatrick), LER 87-009-01 (Hatch U1), and OE18668. .

NIC Database Review Failure Record Numbers FRN 88-021,88-019, 88-001,89-086, 99-149 and 99-123.

EPIX Review FN-155 and FN-101 Vendor'Input None IndustryTemplate None.

Rev.

Page 5 of 11

Fermi Nuclear Station CMP-01 RHR Service Water Return Checks 2.3. Valve History Information Prior to the implementation of Conditon Monitoring, the valves inGroup CMP-01, were open exercise tested each quarter under 24.205:05 (E1100F020A) and 24.205.06 (E1100F020B) by passing a minimum of 9000 gpm through the valves. No failures have occurred inthe last 10 years.

Although not a requirement'of the IST Program, the valves have been disassembled and inspected, and refurbished as needed, under the site 86-03 check valve program by procedure 47.000.13. The current frequency of inspection once every 4 cycles addresses know corrosion issues and ensures preventive maintenance isperformed prior to degradation to the point of potential failure.

E1100F020A WO# Date Complete Examination Results 039D900609 4/16/1991 DI - Expected aged condition. Corrosion excessive - decided to replace disc, clean the rest E115950216 10/25/1996 DI - Good condition. Minor corrosion / scale 000Z002597 11/13/2001 DI - Poor / Unsat condition (this was an expected-aging condition due to the known

-_galvantic corrosion issue) Significant corrosion on disc - replaced disc and holder arm (carbon steel disc replaced with stainless steel disc to address galvantic corrosion iss of OE 18668)

A111070100 4/4/2006 DI - Good condition. Minor corrosion throughout E1100F020B WO# Date Complete Examination Results 043D900609 5/5/1991 DI - Good condition. Minor corrosion - installed replacement disc E131971107 9/16/1998 DI - Good condition: No abnormal conditions were noted - minor corrosion. Cleanded seat surfaces.

000Z002598 11/3/2001 DI - Expected aged condition. Disc corroded / degraded, disc pin to nut corrosion. Dis replaced (carbon steel disc replaced with stainless steel disc to address galvantic corrosion issue of OE 18668 ).

E131070100 10/8/2007 DI - Good condition. Normal DI PM. Had to rig disc/hanger partially out of valve to en adequate inspection. Minor corrosion/MIC.

Rev.

Page 6 of 11

Fermi Nuclear Station CMP-01 RHR Service Water Return Checks 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO) Q Failure to Close (FTC).

Internal Leakage (IL) D External Leakage (EL) Q Disk Separation (DS) Q Hinge Pin Wear (HPW) Q Not Applicable (NA) Q Restricted Motion (RM)

Broken/Detached Pars (BDP F 3.2 Failure Causes Normal Wear O Maintenance Error Q Abnormal Wear E- Manufacturing Error Q Design El Corrosion Human Error Q Foreign Material E Procedure El Stress Corrosion Cracking E Erosion/Corrosion Q Improper Installation E Other .

Remarks:

Due to these valves being in a raw water environment, they are susceptible to corrosion and the buildup of corrosion products that could potentially result in failure to close, restricted motion or broken/detached parts. Historical inspection results have identified degradation due to corrosion, and PM activities restore the component's integrity, minimizing the potential for failure.

Rev.

Page 7 of 11

Fermi Nuclear Station CMP-01 RHR Service Water Return Checks 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/lnspection'Activity Effectiveness of Activity to Faiiure Modes

-Detect Failure Detect Degradation LJetected Full Open Stroke w/Flow High Low FTO, RM, Partial Open Stroke w/Flow NA NA Back Flow/Reverse Flow NA NA Manual Exercise NA NA Leak Test NA NA Disassembly &.Inspection High High .All Temperature Monitoring NA NA Radiography NA NA Ultrasonic Testing NA NA Magnetics NA NA Acoustics NA NA Routine Operator Rounds NA NA Eddy Current Testing NA NA Test Effectiveness Rating: High - probability of detection >75%

Medium - <75% probability of detection but >25% '

Low - probability of detection <25%

N/A - test method not available Rev.

Page 8 of 11

Fermi Nuclear Station CMP-01 RHR Service Water Return Checks 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMP) PLAN 5.1 Test and Inspection Requirements Prior to CMP Implementation Prior to the implementation of Conditon Monitoring, the valves in Group CMP-01 were open exercise tested each quarter under 24.205.05 (El 100F020A) and 24.205.06 (El 100F020B) by passing a minimum of 9000 gpm through the valves. No failures, have occurred in the last 10 years Although not a requirement of the IST Program, the valves have been disassembled and inspected, and refurbished as needed, under the site 86-03 check valve program by procedure 47.000.13. The carbon steel discs in these valves were replaced in 2001 with stainless steel discs to address galvanic corrosion issues identified in OE18668. The current frequency of inspection once every 4 cycles addresses know corrosion issues and ensures preventive maintenance is performed prior to degradation to the point of potential failure.

5.2 Condition Monitoring Program Plan Status: - Interim Plan 7 Final Plan.

5.2.1 Condition Monitoring Test and Inspection Program Plan The following activities together represent the Condition Monitoring Program Plan for this group.

1 . Plan Activity: Full Open Stroke w/Flow Demonstrate functionality to open to pass required flow.

Frequency:

Quarterly Tasks:

24.205.05 (E1 10OF020A) 24.205.05 (E1100F020B)

Notes:

Demonstration that each valve passes the required 9000 gpm RHR service water flow is demonstrated in conjunction with quarterly RHRSW pump testing. The recorded flow rates provide trendable indication of degradation in the ability of the valve to open.

NOTE-THIS COULD BE CHANGED TO A PARTIAL OPEN TEST IF THERE IS A REASON TO NOT WANT TO RUN BOTH RHRSW PUMPS. THE FLOW OF ONE PUMP IS SUFFICIENT TO DEMONSTRATE THE CHECK VALVE OPENS AND THE.SINGLE PUMP FLOWRATE COULD BE TRENDED.

2. Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from full closed to full open and back to full closed, with no evidence of binding, or indication of excessive buildup of corrosion products on the internals.

Frequency:

Each valve in the Group will be inspected once every 4 refuel cycles.

Tasks:

47.000.13 with 35.000.232 Notes:

The inspection results from disassembly and inspection shall be trended to evaluate for degradation. Specifically, the ability of the as-found valve to stroke full open and full closed Rev.

Page 9 of 11

Fermi Nuclear Station CMP-01 RHR Service Water Return Checks without binding, no evidence of excessive wear, and no evidence of excessive corrosion buildup on the internals of the valve. This activity is also'a PM to refurbish the valve as required.

5.2.2 Basis for Testing and Inspection Strategy (Analysis) -

For optimization of condition monitoring activities, the CMP tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance. The quarterly open test demonstrates the valve can perform its open function, and flowrates provide trendable indication of degradation. Historical disassembly arid inspection.

under the SOER 86-03 program. has demonstrated the bidirectional functionality of these valves, and supports placing the Group in a Final Condition Monitorin Plan. Continuing disassembly and inspection will demonstrate the bidirectional functionality of the valves to close, and also perform preventive maintenance as required to address historical corrosion issues prior to degradation to the point of potential failure. Inspection results provide trendable indication to monitor for changes in the rate of degradation.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Rev.

Page 1Q of 11

Fermi Nuclear Station CMP-01 RHR Service Water Return Checks 6.0 CONDITION MONITORING PLAN REVIEW CMP Review Team Check Valve Engineer:

IST Engineer:

System Engineer:

Other:

CMP Review Comments Comment Resolution Review and Approval: Signature Date

- Reviewers:

Check Valve Program Engineer:_

IST Program Engineer:

System Engineer: _______

PRA Engineer Other: -

Approval (Surpervision): 0..NQb. 64 lo Rev.

Page11of11

Fermi Nuclear Station Check Valve Condition Monitoring Plan CMP-02 Standby Liquid Control CIV Checks Rev. Q

Fermi Nuclear Station CMP-02 Standby Liquid Control CIV Checks 1.0 GROUP INFORMATION 1.1 Valve List C4100F006 STANDBY LIQUID CONTROL OUTBOARD CHECK VLV C4100F007 STANDBY LIQUID CONTROL INBOARD CHECK VLV 1.2 Manufacturing Data Manufacturer: Anchor Darling Valve Type: Swing Model: W8622383 AND W8622382 Size: 1.5 Valve Body Material: SS-SA351 Disc Material: NICR AND COCR Design Feature: Bolted, soft seat 1.3 Service Conditions Service Duty: Borated water System Flow: 42 gpm System Pressure: 1400 System Temperature: 150 1.4 Grouping Bases This group is established based on the same manufacturer and service conditions. Both valves are containment isolation valves, one inboard and one outboard. The model number differences are not considered significant. The F006 valve has position indication and the F007 does not. The disc seat hard face material is NiCR for F006 and CoCR for F007.

R Same Mfg Q Lke Orientation W Service Conditions W Like Design Q Identical Application Q Maximum Flow Unachievable

© Identical Test Methodology Q Similar Upstream Dowstream Flow Turbulence 2 Frequency of Operation Q Other 1.5 Safety Function Discussion These check valves must open to provide a flow path to allow injection of borated water into the reactor vessel in the event that control rod insertion is unavailable. These check valves must open to provide a minimum of 41.2 gpm from either train of redundant pumps. These check valves must close on reverse flow to isolate containment and the reactor vessel from the SLCS system. These valves are considered containment isolation valves for Penetration X-42. It should be noted that the outboard valve (F006) has remote position indication to inform the operator that the valve is open when injection is required.

Rev.

Page 2 of 11

Fermi Nuclear Station CMP-02 Standby Liquid Control CIV Checks 2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience IST Testing results have been very good overall. An open test with full flow has been performed each cycle with zero failures.

LLRT has been performed each cycle to satisfy leak test requirements and closure test requirements.

There has been one failure on each valve since 1993.

Disassembly inspection has not identified any failures.

2.2 Industry Service Experience Generic Notices All Generic Notices available from the NRCs reading room were reviewed. No relevent Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevent Generic Letters were found.

All Information Notices available from the NRCs reading room were reviewed. No relevent Information Notices were found.

LER/OE Notices Review of OE9086 - Misorientation of Safety-Related Check Valves This OE informed of the misorientation of a 2", 300 lb, Anderson-Greenwood, swing check valve at Cooper Nuclear Station. The valve is located in the RCIC system down stream of the barometric condenser. The valve installation did not follow the manufacturer instruction, which requires the hinge pin to be installed vertically when the valve is placed in a horizontal line. This wafer (door) style check valve differs from typical gravity action swing check valve. In the wafer (door) style check valve, closure of the valve is not caused by gravity but rather, by the combined action of fluid pressure and spring loaded hinge. Wafer (door) style check valves are designed to be installed like a regular door, i.e. with the hinge pin vertical. If the valve is installed with the hinge pin horizontal, the spring force may not be sufficient to hold the disc against the seat since additional moment due to gravity and differential pressure can cause the flapper to rotate outward from the seat. The OE was reviewed for Fermi application and no action required since the valve type is not the same.

NIC Database Review The NIC Check Valve Performance Database was reviewed for failures of similar valves of 1.5" with resilient seats in a CIV application. This reviewed showed no applicable failure information.

EPIX Review INPOs EPIX database was reviewed for failures of Anchor Darling swing check valves with similar model number, size and application. No items were identified. The following Failure Number for a larger (4 to 11.99 inch) valve was reviewed for applicability:

FN 358 reported the LLRT test failure of an Anchor Darling swing check with a resilient seat in a reactor water cleanup system containment isolation application. The leakage was due to wear of the seat. A new disc and plug assembly was installed.

Applicability: Applicable. Internal leakage due to normal wear is a potential failure mode for this Group due to the valves' function as containment isolation valves.

Vendor Input There was no vendor input or Part 21 Reports associated with 1.5" Anchor Darling swing check valves Rev.

Page 3 of 11

Fermi Nuclear Station CMP-02 Standby Liquid Control CIV Checks with resilient seats.

Industry Template An industry template for Anchor Darling swing check valves, developed by NIC, was reviewed for common failure patterns of valves in like applications as that in Group CMP-02. The template is generic in nature with a total of 459 Anchor Darling swing check valves contained in the 1991 population of 5911 swing check valves. As indicated in the template there were 80 swing check valves serving in an isolation application as the valve in Group CMP-02 (CIVs), although it is unknown how many of those check valves serve in a containment isolation application with SA351 bodies and soft seats. Attachment 1 is provided to identify failure modes and percentage of failures addressed by the industry template.

In addition to normal wear, improper seating-was by far the most common cause of failure as well as the most common cause of failure attributed to the valves in Group CMP-02. The possibility of this occurrence is directly related to the service environment and usage. It is unlikely the valves in Group CMP-02 would experience any of the other failures reflected in Attachment 1, much less a failure affecting the operational readiness of a valve. Current testing imposed on the valves would detect all the failures identified in the population.

2.2.1 References Generic Notices None.

LER/OE Notices OE9086 - Misorientation of Safety-Related Check Valves NIC Database Review None EPIX Review Failure Number FN 358.

Vendor Input None Industry Template INDUSTRY REVIEW TEMPLATE FOR ANCHOR DARLING SWING CHECK VALVES Revision #B 6/3/99 Rev.

Page 4 of 11

Fermi Nuclear Station CMP-02 Standby Liquid Control CIV Checks 2.3 Valve History Information As CIVs, the valves in Group CMP-02 have been subject to Appendix J Type C seat leakage testing, which was also credited to satisfy IST closure test requirements. There has been one LLRT failure on each valve since 1993.

Each valve has been tested in the open direction once per cycle by passing accident flow thru the valve.

No discrepancies were identified as a result of this surveillance testing.

Position indication testing has been performed on the F006 valve each cycle. There have been instances of dual indication. The test methodology has been revised to address this recurring problem. PIT testing is not a part of the Check Valve Condition Monitoring Program. It is still a requirement of ISTC-3700.

C4100F006 000Z922529 10/26/1992 Failed LLRT - would not stroke closed. Repacked and tested successfully 000Z931844 7/12/1994 Failed LLRT - replaced disc and reworked seats G427040100 11/16/2004 Disassembly Inspection - Good condition 000Z043678 11/26/2004 Packing leak - retorqued and did stroke test verification 25892091 10/18/2007 Dual indication during 24.139.03 - finally identified cause of recurring "dual indication" problems. 24.139.03 revised to provide adequate back pressure.

C4100F007 000Z979248 11/11/2001 LLRT failure. DI inspection - found soft seat damaged.

Rev.

Page 5 of 11

Fermi Nuclear Station CMP-02 Standby Liquid Control CIV Checks 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO) D Failure to Close (FTC) Q Internal Leakage (IL) 5 External Leakage (EL) Q Disk Separation (DS)' Q' Hinge Pin Wear (HPW) Q Not Applicable (NA) Q Restricted Motion (RM) .

Broken/Detached Pars (BDP Q 3.2 Failure Causes Normal Wear 0I Maintenance Error L Abnormal Wear - Manufacturing Error L Design - Corrosion L Human Error Q Foreign Material -I Procedure Q- Stress Corrosion. Cracking L Erosion/Corrosion Q Improper Installation L Other Q Remarks:

Leakage has been an occasional problem with each valve in the group failing once since 1993.

The valves in Group CMP-02 are maintained in the closed position and are opened only during surveillance testing. Therefore, wear is minimal.

Rev.

Page 6 of 11

Fermi Nuclear Station CMP-02 Standby Liquid Control CIV Checks 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT

'est Inspection Activity N Effectiveness of Actiityto Falure Modes Detect Failure Detect Degradation Detected Full Open Stroke w/Flow Medium Low FTO, RM Partial Open Stroke w/Flow NA NA Back Flow/Reverse Flow NA NA Manual Exercise NA NA Leak Test High High IL, FTC, RM Disassembly & Inspection NA NA Temperature Monitoring NA NA Radiography NA. NA Ultrasonic Testing NA NA Magnetics NA NA Acoustics NA NA Routine Operator Rounds NA NA Eddy Current Testing NA NA Test Effectiveness Rating: High - probability of detection >75%

Medium - <75% probability of detection but >25%

Low - probability of detection <25%

N/A - test method not available Rev.

Page 7of 11

Fermi Nuclear Station CMP-02 Standby Liquid Control CIV Checks 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMP) PLAN 5.1 Test and Inspection Requirements Prior to CMP Implementation The valves in CMP-02 have been subjected to the following tests and inspections as required by the Inservice Testing Program.

- The valve was exercised open as part of the IST program per 24.139.03. During this test the valve was verified to open by demonstrating the ability to pass the required accident flow.

- The valve was verified closed as part of the IST and CLRT programs by the performance of an Appendix J Type C seat leakage test per 43.401.347.

- Disassembly inspection is currently scheduled every 5 cycles for the F007 valve and every 6 cycles for the F006 valve under the site PM program. This frequency is not driven by IST, but does have a formal process. Any change in frequency requires adequate justifcation and documention, as well as joint concurrence of the IST and CV engineers. If disassembly is performed then the valve will be inspected for the presence of corrosion products, damage to the seat, buildup of debris around the spring etc., and a thorough cleaning of the valve internals prior to reassembly.

5.2 Condition Monitoring Program Plan Status: [O Interim Plan Q Final Plan 5.2.1 Condition Monitoring Test and Inspection Program Plan The following activities together represent the Condition Monitoring Program Plan for.this group.

1 . Plan Activity: Full Open Stroke w/Flow The valves in CMP-02 are exercised during the performance of 24.139.03 each cycle. Full accident flow is verified thru the valves.

Frequency:

Once each cycle.

Tasks:

24.139.03 Notes:

Flowrate through the valves is recorded and provides trendable indication of degradation in the ability of the valve to open.

2. Plan Activity: Leak Test The valves in CMP-02 shall be leak tested as PCIVs per 43.401.347. The Type C seat leakage test also satisfies closure verification.

Frequency:

Seat leakage testing shall be performed at the Appendix J Option B frequency as specified in the Primary Containment Leakage Rate Testing Program Plan. The valve may have a test frequency as often as every outage or as little as every third outage.

Tasks:

43.401.347 Notes:

Leakage results shall be trended to monitor for degradation Rev.

Page 8 of 11

Fermi Nuclear Station CMP-02 Standby Liquid Control CIV Checks 5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMP tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance. The periodic performance of an Appendix J Type C seat leakage test is the primary method of monitoring check valve condition. This testing is a good identifier that the internals are intact with no abnormal wear, provides trending data to monitor for degradation and provides further assurance of operational readiness during the entire interval. Full open stroke testing with flow demonstrates the valves can perform their open function.

Although not part of the recommended testing and inspection activities for Condition Monitoring, the disassembly and inspections performed at the frequencies defined under the site PM program provide additional monitoring for failure mechanisms and assurance that the valves will perform their function.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Rev.

Page 9 of 11

Fermi Nuclear Station CMP-02 Standby Liquid Control CIV Checks 6.0 CONDITION MONITORING PLAN REVIEW CMP Review Team Check Valve Engineer:

IST Engineer:

System Engineer:

Other:

CMP Review Comments Comment Resolution Review and Approval: Signature Date Reviewers:

Check Valve Program Engineer: CI V 8/_/__

IST Program Engineer:

System Engineer: { 0 PRA Engineer Other:

Approval (Surpervision): P M -A U.a Rev.

Page 10 of 11

Fermi Nuclear Station CMP-02 Standby Liquid Control CIV Checks Attachment 1 Failure Modes IndustryTemplate NIC Check Valve Peftrmance Database

. .. JUvw" i1 _...'I" tai '°Svir~iII Check Valve Checks in [Pe rcent of Failure Mode Description Failures , Failure Population Total Part Other Than Disk Broken--22,- 135 16.30%y~

Stuck Closed 81 19 421%

Stuck Open 47j- 303 15.50/ar Restricted Motion 1191 159 -11.90%/.

Improper Seating 871 4241 20,50%/

Unknown 6 .. 59, 10.200X-.-,

Free/Loose Internals 7 57 123 Rev.

Page 11 of 11

Fermi Nuclear Station Check Valve Condition Monitoring Plan CMP-03 RHR Minflow Checks Rev.

Fermi Nuclear Station CMP-03 RHR Minflow Checks 1.0 GROUP INFORMATION 1.1 Valve List E1100F046A RHR Pump A Minflow Check Valve E1100F046B RHR Pump B Minflow Check Valve E1100F046C RHR Pump C Minflow Check Valve E1100F046D RHR Pump D Minflow Check Valve 1.2 Manufacturing Data Manufacturer: Powell Valve Type: Swing Model: 3061A WE Size: 3 Valve Body Material: SA216 Disc Material: HF SS410 BODY SEAT HF COCR Design Feature: Bolted 1.3 Service Conditions Service Duty: Water System Flow: 500 gpm System Pressure: 450 System Temperature: 335 1.4 Grouping Bases Valves A, B, and D are horizontal, while valve B is vertical.

This group is established based on the valves being from the same manufacturer and installed in like service conditions. All 4 valves are tested 'the same and experience the same operation frequency.

W Same Mfg Q Like Orientation QO Service Conditions © Like Design Q Identical Application Q, Maximum Flow Unachievable

© Identical Test Methodology Q Similar Upstream Dowstream Flow Turbulence O Frequency of Operation Q Other 1.5 Safety Function Discussion The individual RHR pump minimum flow paths are designed to provide for a minimum pump flowrate of 500 GPM (reference DBD E11-00). These check valves must open sufficiently to pass the desired 500 GPM flowrate at any time during pump operation when no other pump discharge path is available. The 500 GPM flow rate will prevent overheating damage to the pump. Adequate closure of these check valves will minimize any diversion of operating pump discharge flow back to the Torus, however the magnitude of this flow diversion would have to be significant to adversely impact the minimum system flowrates for accident mitigation.

Rev.

Page 2 of 10

Fermi Nuclear Station CMP-03 RHR Minflow Checks 2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience IST Testing results have been very good overall. A partial open test and a closure test has been performed each quarter with zero failures.

Full open testing can not be performed due to lack of flow instruments on the individual line. Full open testing is satisfied by disassembly inspection. There have been no failures 1991 to present.

2.2 Industry Service Experience Generic Notices All Generic Notices available from the NRCs reading room were reviewed. No relevent Generic Notices were found.

All.Generic Letters available from the NRCs reading room were reviewed. No relevent Generic Letters were found.

All Information Notices available from the NRCs reading room were reviewed. No relevent Information Notices were found.

LER/OE Notices Reviewed INPOs Nuclear Network for OE Notices pertaining to 3" Powell swing check valves. No applicable issues were identified.

A review of the NRC LER and INPO OE data base using key words "valve" and Powell identified no items related to this valve from 1/1/05 through 12/15/08.

NIC Database Review The NIC failure database was reviewed for failures associated with Powell 3 inch swing check valves.

Since the closed function of valves in the CMP group is not associated with a specific leakage criteria, seat leakage test failures were not considered applicable. The results are summarized below:

FRN 87-66 reported the discovery of a damaged hinge pin that allowed the hinge pin and disc assembly to come loose. The cause was corrosion and disc flutter that degraded the yoke support holes Applicability: Not Applicable. The valve in this failure was in a service water (raw water) application and was in frequent use. The valves in Group CMP-03 are in a clean water system and would only see flow during testing or an emergency event requiring RHR to run at low flow conditions. Normal wear and excessive corrosion are not likely to occur in this application.

FRN 94-147 reported the restricted motion of a check valve (failed to initially close) due to normal wear of internal components.

Applicability: Not Applicable. The valves in Group CMP-03 are in a clean water system and would only see flow during testing or an emergency event requiring RHR to run at low flow conditions. Excessive wear and excessive corrosion are not likely to occur in this application.

EPIX Review INPOs EPIX database was reviewed for failures of Powell swing check valves with similar model number, size and application. No items were identified.

Vendor Input There was no vendor input or Part 21 Reports associated with 3" Powell swing check valves.

Industry Template Rev.

Page 3 of 10

Fermi Nuclear Station CMP-03 RHR Minflow Checks There was no Powell Swing Check Valve Industry Template available on the Nuclear Industry Check (NIC) Valve Group's website.

2.2.1 References Generic Notices None.

LER/OE Notices None.

NIC Database Review Failure Record Numbers FRN 87-66 and 94-147.

EPIX Review None Vendor Input None.

Industry Template None.

Rev.

Page 4 of 10

Fermi Nuclear Station CMP-03 RHR Minflow Checks 2.3 Valve History Information There is no means to verify full flow through the minimum flow check valves. The current testing methodology partial strokes the check valves by opening the minimum flow gate valve with the RHR system in the test mode and verifying that pump discharge pressure decreases. The minimum flow line has no flow indicators to indicate the actual flow through the rhinimum flow line.

The use of the RHR flow meter to record a flow difference with the minimum flow valve open has been determined unacceptable based on the magnitude of change of the current pump flow rate during testing.

The change in flow resulting from valving in / out of the minimum flow line cannot be accurately determined to provide a quantified value for full flow exercising of the minimum flow check valve.

IST Testing results have been very good overall. A partial open test and a closure test have been performed each quarter with zero failures.

Full open testing is satisfied by disassembly inspection. There have been no failures from 1991 to present.

E1100F046A E101911008 12/15/1991 DI - Good condition, minor corrosion only E101971107 9/21/1998 DI - Good condition E101971107 11/16/2004 DI - Good condition E1100F046B V1WO# teyC

.~ Ot6rh'

'* ' ="a 'ExTohReslts~ . K E100911008 9/21/1992 DI - Good condition 000Z920239 7/15/1994 Other failure / rework, DI found nothing abnormal - scotchbrite cleaning only. No reason for suspected high seat leakage.

000Z991538 4/28/2000 DI - Good condition Notes DI PM done under OOOZ WR .

A244060100 4/22/2006 DI - Good condition E1100F046C WO Date Cod&plPefe'x , + aminatinRasult 026D900609 4/8/1991 DI - Good condition E543950216 10/19/1996 DI - Good condition Light corrosion - scotchbrite cleaning only A350030100 4/1/2003 DI - Good condition E1100F046D

- (I) DteCopt4, __Examin_________ i__n_______esu______:

E551930414 7/16/1994 DI - Good condition

-_ Light rust - scotchbrite cleaning only A098010100 11/2/2001 DI - Good condition A098070100 10/5/2007 Dl - Good condition Rev.

Page 5 of 10

Fermi Nuclear Station CMP-03 RHR Minflow Checks 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO) Q Failure to Close (FTC) Q Internal Leakage (IL) L External Leakage (EL) Q Disk Separation (DS) L Hinge Pin Wear (HPW)

Not Applicable (NA) [ Restricted Motion (RM) Q Broken/Detached Pars (BDP) L 3.2 Failure Causes Normal Wear © Maintenance Error Qi Abnormal Wear Q Manufacturing Error L Design L Corrosion Q Human Error L Foreign Material L Procedure L Stress Corrosion Cracking Q Erosion/Corrosion L Improper Installation Q Other Q Remarks:

A review fo maintenance history and surveillance history for. valves in this group found no failures from 1991-2008. However, a 6 inch Powell swing check, P4400F051, did have a hinge pin replaced in 1994. Therefore, hinge pin wear was considered a potetial failure mode. Leakage was a common industry failure, but the valves in this group-are not Cat A valves.

Rev.

Page 6 of 10

Fermi Nuclear Station CMP-03 RHR Minflow.Checks 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT 13etFct FailureT DeetDgrdto Drtected Full Open Stroke w/Flow NA NA Partial Open Stroke w/Flow Low Low FTO Back Flow/Reverse Flow Medium Low FTC, RM, HPW Manual Exercise NA NA Leak Test NA NA Disassembly & Inspection High High All Temperature Monitoring NA NA Radiography NA NA Ultrasonic Testing NA NA Magnetics NA NA Acoustics NA NA Routine Operator Rounds NA NA Eddy Current Testing NA NA Test Effectiveness Rating: High - probability of detection >75%

Medium - <75% probability of detection but >25%

Low - probability of detection <25%

N/A - test method not available Rev.

Page 7 of 10

Fermi Nuclear Station CMP-03 RHR Minflow Checks 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMP) PLAN 5.1 Test and Inspection Requirements Prior to CMP Implementation The valves in CMP-03 have been subjected to the following tests and inspections as required by the Inservice Testing Program. If disassembly is performed then the valve will be inspected for the. presence of corrosion products, damage to the seat, buildup of debris around the spring etc., and a thorough cleaning of the valve internals prior to reassembly. Measurement of internal dimensions are taken for trending.

- The valve was exercised partial open as part of the IST program per 24.204.01. During this test the valve was verified to partially open by demonstrating a pressure drop on the pump discharge when the upstream gate valve was opened.

- The valve was verified closed as part of the IST program by the performance of a backflow test per 24.204.01.

- Disassembly Inspection was performed to satisfy full open requirements.

5.2 Condition Monitoring Program Plan Status: FI Interim Plan QQ Final Plan 5.2.1 Condition Monitoring Test and Inspection Program Plan The following activities together represent the Condition Monitoring Program Plan for this group.

1 . Plan Activity: Partial Open Stroke w/Flow Demonstrate the valve partially opens and passes flow.

Frequency:

Quarterly Tasks:

24.204.01 Notes:

There is no way to verify full flow through the minimum flow check valves. Current testing methodology partial strokes the check valves by opening the minimum flow gate valve with the RHR system in the test mode and verifying that pump discharge pressure decreases. The minimum flow line has no flow indicators to indicate the actual flow through the minimum flow line. Trending is on a pass/fail basis.

2. Plan Activity: Back Flow/Reverse Flow Demonstrate the valve closes and prevents flow diversion.

Frequency:

Quarterly in conjunction with pump testing.

Tasks:

24.204.01 Notes:

Each minflow check is closure tested during opposite loop pump testing. The ability of the pump to meet accident flow requirements, verifies that the check valve is closed, thus preventing flow diversion. Trending is a on a pass/fail basis.

Rev.

Page 8 of 10

Fermi Nuclear Station CMP-03 RHR Minflow Checks

3. Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from full closed to full open and back to full closed, with no evidence of binding, or indication of excessive buildup of corrosion products on the internals.

Frequency:

One valve each cycle such that all valves are disassembled and inspected over a four cycle period.

Tasks:

43.000.010 with 35.000.232 Notes:

Due to the limited information obtained by the partial open test, the functionality of the valve to open is confirmed through disassembly and inspection. The inspection results from disassembly and inspection shall be trended to evaluate for degradation. Specifically, the ability of the as-found valve to stroke full open and full closed without binding, no evidence of excessive wear, and no evidence of excessive corrosion buildup on the internals of the valve.

5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMP tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance. The periodic performance of a disassemble inspection test is the primary method of monitoring check valve condition. This testing is a good identifier that the internals are intact with no abnormal wear, provides trending data to monitor for degradation and provides further assurance of operational readiness during the entire interval.

Partial open and closure testing in conjunction with pump operability testing further verifies the ability of the valve to perform its function.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Rev.

Page 9 of 10

Fermi Nuclear Station CMP-03 RHR Minflow Checks 6.0 CONDITION MONITORING PLAN REVIEW CMP Review Team~

Check Valve Engineer:

IST Engineer:

System Engineer:

Other:

CMP Review Comments Comment Resolution Review and Approval: Signature Date Reviewers:

Check Valve Program Engineer: 2Ag/46 c IST Program Engineer: ljb System Engineer: 17s PRA Engineer ____

f~L.

Other: ___________________________ _____

Approval (Surpervision): ~ oe n j o\\, 7 /C0-ii -/l0 Rev.

Pagel10of 10

Fermi Nuclear Station Check Valve Condition Monitoring Plan CMP-04 Core Spray Pump Discharge Checks Rev. 0

Fermi Nuclear Station CMP-04 Core Spray Pump Discharge Checks 1.0 GROUP INFORMATION 1.1 Valve List E2100F003A CS Pump A Discharge Check Valve E210OF003B CS Pump B Discharge Check Valve E2100F003C CS Pump C Discharge Check Valve E2100F003D CS Pump D Discharge Check Valve 1.2 Manufacturing Data Manufacturer: Powell Valve Type: Swing Model: 3061A WE Size: 12 Valve Body Material: SA216 Disc Material: HF SS410 BODY SEAT HF COCR Design Feature: Bolted 1.3 Service Conditions Service Duty: Water System Flow: 3000 gpm System Pressure: 475 System Temperature: 212 1.4 Grouping Bases These valves are grouped together based on having the same manufacturer, model, and service application. The following were considered in group determination:

Q Same Mfg Q Like Orientation O Service Conditions R5 Like Design R Identical Application Q Maximum Flow Unachievable W Identical Test Methodology Q Similar Upstream Dowstream Flow Turbulence 0 Frequent Operation Q Other 1.5 Safety Function Discussion These check valves must open sufficiently to allow for a pump discharge flowrates of at least 3175 GPM (reference DBD E21-00). NOTE: The initial plant licensing basis required each CS division to provide a minimum flowrate of 6350 GPM, however the SAFER-GESTR LOCA analysis assumes a divisional CS flow rate of only 5625 GPM for LOCA mitigation success. These valves must close to limit reverse flow back through the associated pump after the pump has been shutdown in order to retain the discharge side water column maintained by keepfill during standby to prevent waterhammer on pump start, and to decrease the time necessary to discharge CS water to the reactor post-LOCA.

The Core Spray Pumps in each Division are tested in parallel. Thus, Division 1 pumps, E2101C001A and E2101C001C (Check Valves E2100F003A and E2100F003C respectively), are tested in parallel; and Division 2 pumps, E2101C001B and E2101C001D (Check Valves E2100F003B and E2100F003D, respectively), are tested in parallel. Because of this parallel pump operation, the degradation of a single check valve cannot be distinguished from the degradation of either the pumps themselves or the other check valve. Consequently, the current test can only be considered a partial stroke test in the open Rev.

Page 2 of 11

Fermi Nuclear Station CMP-04 Core Spray Pump Discharge Checks direction.

Because of the operating restriction imposed, testing for full stroke capability of these check valves is to be accomplished by disassembly and inspection. These check valves are 12 inch swing checks located in the Core Spray Pump rooms. Draining, disassembly, and inspection is a long process, followed by reassembly, filling and venting of the system, and acceptance testing. All of'these activities result in the accumulation of personal dose, system/division outage time extension, and increased unavailability of a safety system.

Rev.

Page3 of11-

Fermi Nuclear Station CMP-04 Core Spray Pump Discharge Checks 2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience IST Testing results have been very good overall. Numerous disassembly inspections have been performed from1991 to 2008 with no failures.

Closure testing and partial open testing is accomplished quarterly with no failures in the past 10 years.

2.2 Industry Service Experience Generic Notices All Generic Notices available from the NRCs reading room were reviewed. No relevent Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevent Generic Letters were found.

All Information Notices available from the NRCs reading room were reviewed. No relevent Information Notices were found.

LER/OE Notices Reviewed INPOs Nuclear Network for OE Notices pertaining to 12" Powell swing check valves. No applicable issues were identified.

A review of the NRC LER and INPO OE data base using key words "valve" and Powell identified no items related to this valve from 1/1/05 through 12/15/08.

NIC Database Review The NIC failure database was reviewed for failures associated with Powell 12 inch swing check valves.

Since the closed function of valves in the CMP group is not associated with a specific leakage criteria, seat leakage test failures were not considered applicable. The results are summarized below:

FRN 87-66 reported the discovery of a damaged hinge pin that allowed the hinge pin and disc assembly to come loose. The cause was corrosion and disc flutter that degraded the yoke support holes.

Applicability: Not Applicable. The valve in this failure was in a service water (raw water) application and was in frequent use. The valves in Group CMP-04 are in a clean water system and would only see flow during testing or an emergency event requiring CS to run. Normal wear and excessive corrosion are not likely to occur in this application.

FRN 94-147 reported the restricted motion of a check valve (failed to initially close) due to normal wear of internal components.

Applicability: Not Applicable. The valves in Group CMP-04 are in a clean water system and would only see flow during testing or an emergency event requiring CS to run. Excessive wear and excessive corrosion are not likely to occur in this application.

EPIX Review INPOs EPIX database was reviewed for failures of Powell swing check valves with similar model number, size and application. No items were identified.

Vendor Input There was no vendor input or Part 21 Reports associated with 12" Powell swing check valves.

Industry Template Rev.

Page 4 of 11

Fermi Nuclear Station CMP-04 Core Spray Pump Discharge Checks There was no Powell Swing Check Valve Industry Template available on the Nuclear Industry Check (NIC) Valve Group's website.

2.2.1 References Generic Notices None.

LER/OE Notices None.

NIC Database Review Failure Record Numbers FRN 87-66 and 94-147.

EPIX Review None Vendor Input None Industry Template None.

Rev.

Page 5 of11

Fermi Nuclear Station CMP-04 Core Spray Pump Discharge Checks 2.3 Valve History Information Because of this parallel pump operation, the degradation of a single check valve cannot be distinguished from the degradation of either the pumps themselves or the other check valve. Consequently, the current test can only be considered a partial stroke test in the open direction.

Because of the operating restriction imposed, testing for full stroke capability of these check valves is to be accomplished by disassembly and inspection. These check valves are 12 inch swing checks located in the Core Spray Pump rooms.

IST Testing results have been very good overall. Numerous disassembly inspections have been performed from1991 to 2008 with no failures.

These valves are very likely seeing full flow each quarter, however, there is no way to confirm that and satisfy Code requirements for a full open test. Two valves see flow and one could mask the performance of the other.

E2100F003A WO# Date Complete Examination Results 000Z991539 4/7/2000 DI - Expected aged condition AF DI SAT w/e minor pitting on disc face. Cleaned up and restored.

A352060100 4/5/2006 DI - Good condition E210OF003B WO# Date Complete Examination Results E186911008 9/16/1992 DI - Good condition A140010100 10/31/2001 DI - Good condition A140070100 10/5/2007 Dl - Very good condition E2100F003C W__#__D_te___ omplete Fxin nair eut E558950216 10/15/1996 DI - Very good condition A353030100 4/10/2003 DI - Very good condition E2100F003D E559950216 9/8/1998 DI - Very good condition E559040100 11/10/2004 DI - Very good condition Rev.

Page 6o11

Fermi Nuclear Station CMP-04 Core Spray Pump Discharge Checks 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO) Q Failure to Close (FTC)

. Internal Leakage (IL) D External Leakage (EL) D

- Disk Separation (DS) Q Hinge Pin Wear (HPW)

Not Applicable (NA) Q Restricted Motion (RM) Q Broken/Detached Pars (BDP Q 3.2 Failure Causes Normal Wear I Maintenance Error Q Abnormal Wear Ql Manufacturing Error Q Design El Corrosion E.

Human Error Q Foreign Material Q Procedure El Stress Corrosion Cracking E Erosion/Corrosion Q Improper Installation E Other E Remarks:

A review fo maintenance history and surveillance history for valves in this group found no failures from 1991-2008. However, a 6 inch Powell swing check, P4400F051, did have a hinge pin replaced in 1994. Since these valves are pump discharge checks, failure to close due to normal wear or hinge pin wear are potential failure modes. Leakage was a common industry failure, but the valves in this group are not Cat A valves.

Rev.

Page 7 of 11

Fermi Nuclear Station CMP-04 Core Spray Pump Discharge Checks 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Acti ftiveness of Acivity to Failure Modes Detect Failure Detect Degradation LJetected Full Open Stroke w/Flow NA NA Partial Open Stroke w/Flow Low Low . FTO Back Flow/Reverse Flow Medium Low FTC Manual Exercise NA NA Leak Test NA NA Disassembly & Inspection High High All Temperature Monitoring NA NA Radiography NA NA Ultrasonic Testing NA NA Magnetics NA NA Acoustics NA NA Routine Operator Rounds NA NA Eddy Current Testing NA NA Test Effectiveness Rating: High - probability of detection >75%

Medium - <75% probability of detection but >25%.

Low - probability of detection <25%

N/A - test method not available Rev.

Page 8 of 11

Fermi Nuclear Station CMP-04 Core Spray Pump Discharge Checks 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMP) PLAN 5.1 Test and Inspection Requirements Prior to CMP Implementation The valves in CMP-04 have been subjected to the following tests and inspections as required by the Inservice Testing Program. If disassembly is performed then the valve will be inspected for'the presence of corrosion products, damage to the seat, buildup of debris around the spring etc., and a thorough cleaning of the valve internals prior to reassembly. Measurement of internal dimensions are taken for trending.

- The valve was exercised partial open as part of the IST program per 24.203.02. During this test the valve was verified to partial open by demonstrating a parallel flow path. Individual valve flow was not quantified.

- The valve was verified closed as part of the IST program by the performance of a backflow test per 24.203.02. Discharge pressure is verified >50 psi when the pumps are not running. This pressure is provided by the keep fill system. If the discharge check valves were not closed, the keep fill pump would not be able to establish 50 psi since the suction piping is open to the torus.

- Disassembly Inspection was performed to satisfy full open requirements.

5.2 Condition Monitoring Program Plan Status: Q Interim Plan I Final Plan 5.2.1 Condition Monitoring Test and Inspection Program Plan The following activities together represent the Condition Monitoring Program Plan for this group.

1 . Plan Activity: Partial Open Stroke w/Flow Demonstrate functionality to open to pass flow.

Frequency:

Quarterly.

Tasks:

24.203.02 (E2100-F003A and F003C) 24.203.03 (E2100-F003B and F003D)

Notes:

There is no way to verify full flow through the discharge check valves. Current testing methodology partial strokes the check valves testing 2 pumps in parallel. The individual line has no flow indicators to indicate the actual flow through that line. One pump may be putting out more flow and masking the poor performance of the other pump.

Trending is on a pass/fail basis.

2. Plan Activity: Back Flow/Reverse Flow Demonstrates the closed functionality of the valve by indicating the disc is intact and capable of moving to the closed position.

Frequency:

Quarterly.

Tasks:

24.203.02 (E2100-FO03A and F003C) 24.203.03 (E2100-F003B and F003D)

Rev.

Page 9 of 11

Fermi Nuclear Station CMP-04 Core Spray Pump Discharge Checks Notes:

Closure is verified by establishing a DP across the valves. Discharge pressure is verified >50 psi when the pumps are not running. This pressure is provided by the keep fill system., If the discharge check valves were not closed, the keep fill pump would not be able to establish 50 psi since_the suction piping is open to the torus.

Trending is on a pass/fail basis.

3. Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from full closed to full open and back to full closed, with no evidence of binding, or indication of excessive buildup of corrosion products on the internals.

Frequency:

One valve each cycle such that all valves are disassembled and inspected over a four cycle period.

Tasks:

43.000.010 with 35.000.232 Notes:

Due to the limited information obtained by the partial open test, the functionality of the valve to open is confirmed through disassembly and inspection. The inspection results from disassembly and inspection shall be trended to evaluate for degradation. Specifically, the ability of the as-found valve to stroke full open and full closed without binding, no evidence of excessive wear, and no evidence of excessive corrosion buildup on the internals of the valve.

5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMP tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance. The periodic performance of a disassemble inspection test is the primary method of monitoring check valve condition. This testing is a good identifier that the internals are intact with no abnormal wear, provides trending data to monitor for degradation and provides further assurance of operational readiness during-the entire interval.

Partial open and closure testing in conjunction with pump operability testing further verifies the ability of the valve to perform its function.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Rev.

Page 10 of 11

Fermi Nuclear Station CMP-04 Core Spray Pump Discharge Checks 6.0 CONDITION MONITORING PLAN REVIEW CMP Review Team Check Valve Engineer:

IST Engineer:

System Engineer:

Other:

CMP Review Comments Comment Resolution Review and Approval: Signature Date Reviewers: ()

Check Valve Program Engineer: 9/o__

IST Program Engineer: _______

System Engineer: 2t 1 0 PRA Engineer 'I Other: _

Approval (Surpervision):

Rev.

Page 11 of 11

Fermi Nuclear Station Check Valve Condition Monitoring Plan CMP-05 Core Spray Pump Minflow Checks Rev. Q

Fermi Nuclear Station CMP-05 Core Spray Pump Minflow Checks 1.0 GROUP INFORMATION 1.1 Valve List E2100F038A CS Pump A Minflow Check Valve E2100F038B CS Pump B Minflow Check Valve E2100F038C CS Pump C Minflow Check Valve E2100F038D CS Pump D Minflow Check Valve 1.2 Manufacturing Data-Manufacturer: Powell Valve Type: Swing Model: 3061A WE Size: 3 Valve Body Material: SA216 Disc Material: HF SS410 BODY SEAT HF COCR Design Feature: Bolted 1.3 Service Conditions Service Duty: Water System Flow: 150 gpm System Pressure: 475 System Temperature: 212 1.4 Grouping Bases These valves are grouped together based on having the same manufacturer, model, and service application. The following were considered in group determination:

J Same Mfg Q Like Orientation 9d Service Conditions IO Like Design W Identical Application Q Maximum Flow Unachievable O Identical Test Methodology E Similar Upstream Dowstream Flow Turbulence E Frequency of Operation E Other 1.5 Safety Function Discussion These valves are designed to close to prevent backflow, to the torus, through the minimum flow line of a Core Spray pump that does not start, thus preventing the loss of Core Spray capacity to the vessel.

The valves must also open during pump startup to meet minimum flow requirements of the pumps.

The Core Spray Pumps in each Division are tested in parallel. Thus, Division 1 pumps, E2101C001A and E2101C001 C (Check Valves E2100F038A and E2100F038C respectively), are'tested in parallel; and Division 2 pumps, E2101C001B and E2101C001D (Check Valves E2100F038B and E2100F038D, respectively), are tested in parallel. Because of this parallel pump operation, the degradation or failure of a single minimum flow check valve in a Division cannot be distinguished from the other in the same Division. When the motor operated minimum flow valve is opened, there is no way to determine either total flow through each check valve in a Division or flow through a single valve. Therefore, there is no suitable test for either a full stroke test or a partial stroke test.

Rev.

Page 2 of 10

Fermi Nuclear Station CMP-05 Core Spray Pump Minflow Checks 2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience IST Testing results have been very good overall. Numerous disassembly inspections have been performed from1991 to 2008 with no failures.

These valves are very likely seeing full flow each quarter, however, there is no way to confirm that and satisfy Code requirements for a full or partial open test. Two valves see flow and one could mask the

.performance of the other.

2.2 Industry Service Experience Generic Notices All Generic Notices available from the NRCs reading room were reviewed. No relevent Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevent Generic Letters were found.

All Information Notices available from the NRCs reading room were reviewed. No relevent Information Notices were found.

LER/OE Notices Reviewed INPOs Nuclear Network for OE Notices pertaining to 3" Powell swing check valves. No applicable issues were identified.

A review of the NRC LER and INPO OE data base using key words "valve" and Powell identified no items related to this valve from 1/1/05 through 12/15/08.

NIC Database Review The NIC failure database was reviewed for failures associated with Powell 3 inch swing check valves.

Since the closed function of valves in the CMP group-is not associated with a specific leakage criteria, seat leakage test failures were not considered applicable. The results are summarized below:

FRN 87-66 reported the discovery of a damaged hinge pin that allowed the hinge pin and disc assembly to come loose. The cause was corrosion and disc flutter that degraded the yoke support holes Applicability: Not Applicable. The valve in this failure was in a service water (raw water) application and was in frequent use. The valves in Group CMP-05 are in a clean water system and would only see flow during testing or an emergency event requiring CS to run at low flow conditions. Normal wear and excessive corrosion are not likely to occur in this application.

FRN 94-147 reported the.restricted motion of a check valve (failed to initially close) due to normal wear of internal components.

Applicability: Not Applicable. The valves in Group CMP-05 are in a clean water system and would only see flow during testing or an emergency event requiring CS to run at low flow conditions. Excessive wear and excessive corrosion are not likely to occur in this application.

EPIX Review INPOs EPIX database was reviewed for failures of Powell swing check valves with similar model number, size and application. No items were identified.

Vendor Input There was no vendor input or Part 21 Reports associated with 3" Powell swing check valves.

Rev.'

Page 3 of 10

Fermi Nuclear Station CMP-05 Core Spray Pump Minflow Checks Industry Template There was no Powell Swing Check Valve Industry Template available on the Nuclear Industry Check (NIC) Valve Group's website.

2.2.1 References Generic Notices None.

LER/OE Notices None.

NIC Database Review Failiure Record Number 87-66 and 94-147.

EPIX Review None Vendor Input None.

Industry Template None.

Rev.

Page 4 of 10

Fermi Nuclear Station CMP-05 Core Spray Pump Minflow Checks 2.3 Valve History Information Because of this parallel pump operation, the degradation or failure of a single minimum flow check valve ina Division cannot be distinguished from the other inthe same Division. When the motor operated minimum flow valve is opened, there isno way to determine either total flow through each check valve ina Division or flow through a single valve. Therefore, there is no suitable test for either a full stroke test or a partial stroke test.

Numerous disassembly inspections have been performed from 1991 to 2008 with no failures.

E2100F038A 1N0_____ ;Da ompiete _ xmtto ES44950216 10/14/1996 DI - Good condition E544970307 4/9/2003 DI - Good condition E2100F038B JJQO#I xDt 'oplef'e <~ ~~ Ex'ia6 ntReslt ' -

E224911008 9/16/1992 DI - Very good condition 000Z991541 4/21/2000 DI - Good condition E2100F038C 000Z910478 4/18/1991 Other failure / rework Minor leak from cover gasket area - reworked and SAT 029D900609 4/21/1991 DI - Good condition E545971107 9/21/1998 DI - Very good condition E545040100 11/10/2004 DI - Good condition E2100F038D E549930414 7/1/1994 DI - Very good.condition A125010100 10/30/2001 DI - Good condition A125070100 10/4/2007 DI - Very good condition Rev.

Page 5 of 10

Fermi Nuclear Station CMP-05 Core Spray Pump Minflow Checks 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO) Q Failure to Close (FTC) Li Internal Leakage (IL) Q External Leakage (EL) L Disk Separation (DS) Q Hinge Pin Wear (HPW)

Not Applicable (NA) E Restricted Motion (RM) Q Broken/Detached Pars (BDP Q 3.2 Failure Causes Normal Wear R Maintenance Error Q Abnormal Wear L Manufacturing Error Q Design L Corrosion Q Human Error L Foreign Material L Procedure L Stress Corrosion Cracking L Erosion/Corrosion L Improper Installation L Other Q Remarks:

A review fo maintenance history and surveillance history for valves in this group found no failures from 1991-2008. However, a 6 inch Powell swing check, P4400F051, did have a hinge pin replaced in 1994. Leakage was a common industry failure, but the valves in this group are not Cat A valves.

Rev.

Page 6 of 10

Fermi Nuclear Station CMP-05 Core Spray Pump Minflow Checks 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT I net6~ ivity;

~ .RE.- ffe tlvenes :~l7of B,u,

+za- i r-Full Open Stroke w/Flow NA NA Partial Open Stroke w/Flow NA NA Back Flow/Reverse Flow NA NA Manual Exercise NA NA Leak Test NA NA Disassembly & Inspection High High All Temperature Monitoring NA NA Radiography NA NA Ultrasonic Testing NA NA Magnetics NA NA Acoustics NA NA Routine Operator Rounds NA NA Eddy Current Testing NA NA Test Effectiveness Rating: High - probability of detection >75%

Medium - <75% probability of detection but >25%

Low - probability of detection <25%

N/A - test method not available Rev.

Page 7 of 10

Fermi Nuclear Station CMP-05 Core Spray Pump Minflow Checks 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMP) PLAN 5.1 Test and Inspection Requirements Prior to CMP'Implementation Disassembly inspection. One valve each outage.

The Core Spray Pumps in each Division are tested in parallel. Thus, Division 1 pumps, E2101C001A and E2101C001C (Check Valves E2100F038A and E2100F038C respectively), are tested in parallel; and Division 2 pumps, E2101 C001 B and E2101 C001 D (Check Valves E2100F038B and E2100F038D, respectively), are tested inparallel. Because of this parallel pump operation, the degradation or failure of a single minimum flow check valve in a Division cannot be distinguished from the other in the same Division. When the motor operated minimum flow valve is opened, there is no way to determine either total flow through each check valve in a Division or flow through a single valve. Therefore, there is no suitable test for either a full stroke test or a partial stroke test. Each valve is probably being exercised with flow each quarter when the pump-is started, however, there is no way to verify this. One valve could be failed and the other one would mask the test result.

5.2 Condition Monitoring Program Plan Status: O Interim Plan 7 Final Plan 5.2.1 Condition Monitoring Test and Inspection Program Plan The following activities together represent the Condition Monitoring .Program Plan for this group.

1 . Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from full closed to full open and back to full closed, with no evidence of binding, or indication of excessive buildup of corrosion products on the internals.

Frequency:

One valve each cycle such that all valves are disassembled and inspected over a four cycle period.

Tasks:

43.000.010 with 35.000.232 Notes:

The inspection results from disassembly and inspection shall be trended to evaluate for degradation. Specifically, the ability of the as-found valve to stroke full open and full closed -

without binding, no evidence of excessive wear, and no evidence of excessive corrosion buildup on the internals of the valve.

5.2.2 Basis for Testing- and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMP tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance. The periodic performance of a disassemble inspection test is the primary method of monitoring check valve condition. This testing is a good identifier that the internals -are intact with

.no abnormal wear, provides trending data to monitor for degradation and provides further assurance of operational readiness during the entire interval.

Partial open testing is probably accomplished in conjunction with pump operability testing. No acceptance criteria are provided, but the ability of the valve to perform its function is challenged.

No credit is taken for this evolution.

Rev.

Page 8 of 10

Fermi Nuclear Station CMP-05 Core Spray Pump Minflow Checks It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Rev.

Page 9 of 10

Fermi Nuclear Station CMP-05 Core Spray Pump Minfltow Checks 6.0 CONDITION MONITORING PLAN REVIEW CMP Review Team Check Valve Engineer:

IST Engineer:

System Engineer:

Other:

CMP Review Comments Comment Resolution Review and Approval: Signature Date Reviewers:

Check Valve Program Engineer: ________________ _ B/<75%

Medium - <75% probability of detection but >25%

Low - probability of detection <25%

N/A - test method not available Rev.

Page 7 of 10

Fermi Nuclear Station CMP-06 HPCI Booster Pump Suction Checks 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMP) PLAN 5.1 Test and Inspection Requirements Prior to CMP Implementation The valves in CMP-06 have been subjected to the following tests and inspections as required by the Inservice Testing Program. If disassembly is performed then the valve will be inspected for the presence of corrosion products, damage to the seat, buildup of debris around the spring etc., and a thorough cleaning of the valve internals prior to reassembly. Measurement of internal dimensions are taken for trending.

- The E4100F019 valve was exercised open as part of the IST program per 24.202.01. During this test the valve was verified to open by demonstrating capability to pass accident flow.

- Disassembly Inspection was performed to satisfy closure requirements for both valves, and open for E4100F045.

5.2 Condition Monitoring Program Plan Status: O Interim Plan nd Final Plan 5.2.1 Condition Monitoring Test and Inspection Program Plan The following activities together represent the Condition Monitoring Program Plan for this group.

1. Plan Activity: Full Open Stroke w/Flow Open test is performed quarterly with full flow on E4100F0l9.

Frequency:

Quarterly.

Tasks:

24.202.01 Notes:

Flowrate through the valves is recorded and provides trendable indication of degradation in the ability of the valve to open.

2. Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from full closed to full open and back to full closed, with no evidence of binding, or indication of excessive buildup of corrosion products on the internals.

Frequency:

One valve every other cycle such that all valves are disassembled and inspected over a four

.cycle period.

Tasks:

43.000.010 (ISI/PEP inspection) with 35.000.232 (Maintenance)

Notes:

The inspection results from disassembly and inspection shall be trended to evaluate for degradation. Specifically, the ability of the as-found valve to stroke full open and full closed without binding, no evidence of excessive wear, and no evidence of excessive corrosion buildup on the internals of the valve.

5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMP tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance.

Rev.

Page 8 of10

Fermi Nuclear Station CMP-06 HPCI Booster Pump Suction Checks monitoring check valve condition. This testing is a good identifier that-the internals are intact with no abnormal wear,- provides trending data to monitor for degradation and provides further assurance of operational readiness during the entire interval.

Open testing of E4100F019 is performed quarterly and further verifies the ability of the valve to perform its function.

Closure test of E4100F019 is satisfied by disassembly inspection.

The E41 00F045 suction line sees very little service. There is no wear induced degradation.

Closure and open test of E4100F019.is satisfied by disassembly inspection. Extended test interval isjustified based on limited use and good history.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Rev.

Page 9 of 10

• Fermi Nuclear Station CMP-06 HPCI Booster Pump Suction Checks 6.0 CONDITION MONITORING PLAN REVIEW CMP Review Team Check Valve Engineer:

IST Engineer:

System Engineer:

Other:

CMP Review Comments Comment Resolution Review and Approval: Signature Date Reviewers:

Check Valve Program. Engineer: _________________ ___________

IST Program Engineer: lI 22 System Engineer:' ___________________ K PRA Engineer A____________________ ____

Other:.7 Approval (Surpervision): b' c4 tG'L AQ- (bA V Rev.

Page 10 of 10

Fermi Nuclear Station Check Valve Condition Monitoring Plan CMP-07 EECW Return Checks Rev. O

Fermi Nuclear Station CMP-07 EECW Return Checks 1.0 GROUP INFORMATION 1.1 Valve List P4400F051 EECW Return Check Valve P4400F116A EECW Return Header Check Valve P4400F116B EECW Return Header Check Valve P4400F165 EECW Coolers Return Check Valve.

1.2 Manufacturing Data Manufacturer: Powell Valve Type: Swing Model: 3061A WE Size: 6 and 8 Valve Body Material: SA216 Disc Material: HF SS410 BODY SEAT HF COCR Design Feature: Bolted 1.3 Service Conditions Service Duty: , Water System Flow: 349 to 1008 gpm System Pressure: 150 System Temperature: 150 1.4 Grouping Bases Three of the four valves are six inch. P4400F116B is an 8 inch valve. The difference in size is not considered to have much affect on valve performance and does not warrant putting the 8 inch valve in a group by itself. All four valves are installed horizontally.

These valves are grouped together based on having the same manufacturer, model, and service application. The following were considered in group determination:

Same Mfg , Like Orientation WService Conditions 0 Like Design Q Identical Application Q Maximum Flow Unachievable Q Identical Test Methodology El Similar Upstream Dowstream Flow Turbulence

] Frequent Operation Q.Other.

1.5 Safety Function Discussion These check valves have a safety function to 6pen to provide a return flow path from the EECW essential loads to the EECW heat exchanger. This function provides cooling water to these components during conditions when EECW is required to be operating. The valves have no closed safety function.

Rev.

Page 2 of 11

/s

Fermi Nuclear Station CMP-07 EECW Return Checks 2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience IST Testing results have been very good overall. A partial open test has been performed each quarter with zero failures.

All four valves have been disassemble inspected. Results from 1991 to 2008 have always been good.

In 1994, the hinge pin was'replaced on P4400F051.

2.2 Industry Service Experience Generic Notices All Generic Notices available from the NRCs reading room were reviewed. No relevent Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevent Generic Letters were found.

All Information Notices available from the NRCs reading room were reviewed. No relevent Information Notices were found.

LER/OE Notices Reviewed INPOs Nuclear Network for OE Notices pertaining to 6" and 8" Powell swing check valves.

No applicable issues were identified.

A review of the NRC LER and INPO OE data base using key words "valve" and Powell identified no items related to this valve from 1/1/05 through 12/15/08.

NIC Database Review The NIC failure database was reviewed for failures associated with Powell 6 inch swing check valves.

Since the closed function of valves in the CMP group is not associated with a specific leakage criteria, seat leakage test failures were not considered applicable. The results are summarized below:

FRN 87-66 reported the discovery of a damaged hinge pin that allowed the hinge pin and disc assembly to come loose. The cause was corrosion and disc flutter that degraded the yoke support holes Applicability: Applicable. The valve in this failure was in a service water (raw water) application and was in frequent use. The valves in Group CMP-07 are also in a raw water application and in frequent use. Normal wear will occur in this application. CMP testing frequency should identify problems before failure occurs.

FRN 94-147 reported the restricted motion of a check valve (failed to initially close) due to normal wear of internal components.

Applicability: Applicable. The valve in this failure was in a service water (raw water) application and was in frequent use. The valves in Group CMP-07 are also in a raw water application and in frequent use. Normal wear will occur in this application. CMP testing frequency should identify problems before failure occurs.

EPIX Review INPOs EPIX database was reviewed for failures of Powell swing check valves with similar model number, size and application. No items were identified.

Vendor Input There was no vendor input or Part 21 Reports associated with 6" or 8" Powell swing check valves.

Rev.

Page 3 of 11

Fermi Nuclear Station CMP-07 EECW Return Checks Industry Template There was no Powell Swing Check Valve Industry Template available on the Nuclear Industry Check (NIC) Valve Group's website.

2.2.1 References-Generic Notices None.

LER/OE Notices None.

NIC Database Review Failure Record Numbers 87-66 and 94-147.

EPIX Review None Vendor Input None.

Industry Template None.

pr Rev.

Page 4 of 11 l

Fermi Nuclear Station CMP-07 EECW Return Checks 2.3 Valve History Information IST Testing results have been very good overall.. A partial open test has been performed each quarter on all the valves with zero failures. Partial test isperformed by verification that no loads on this cooling water loop have a temperature alarm.

All four valves have been disassemble inspected. Results from 1991 to 2008 have always been good. In 1994, the hinge pin was replaced on P4400F051.

P4400F051 VJO# Date Complete arnat 032D900609 4/10/1991 DI - Good condition 000Z910423 11/17/1991 Other failure / rework Leaking from cover - replaced gsaket and SAT P353911008 10/2/1992 DI - Good condition P353930223 6/4/1994 DI - Good condition Minor indications on pin - replaced pin and disc holder P353940630 4/9/2000 DI - Good condition P353060100 3/27/2006 DI - Good condition P4400F116A r WO#, i Date C6rplete~ tx Exam4~intlon Reut xr, a.; 3.

P549911212 10/3/1992 DI - Good condition P549930223 9/20/1998 DI - Good condition P549040100 4/1/2003 DI - Good condition P4400F116B s~WO Date ,ComniPJ "N.A 034D900609 4/29/1991 DI - Good condition P356911008 . 9/20/1992 DI - Good condition 000Z962703 3/31/1996 DI - Very good condition P356930223 10/4/1996 DI - Very good condition P356961025 9/11/1998 DI - Very good condition P356040100 11/9/2004 DI - Good condition Rev.

Page 5 of 11

Fermi Nuclear Station CMP-07 EECW Return Checks P440OF1 65 WQ# Date Com plete Exmnto Results 035D900609 4/27/1 991 DI - Good condition P360911008 9/20/1992 DI - Good condition P360930223 10/6/1 996 DI - Good condition P360961025 11/1/2001 DI - Good condition P360070100 10/3/2007 DI - Good condition Rev.

Page 6of 11

Fermi Nuclear Station CMP-07 EECW Return Checks 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO) Q Failure to Close (FTC) Q Internal Leakage (IL) Q External Leakage (EL) i Disk Separation (DS) IZ Hinge Pin Wear (HPW) M Not Applicable (NA) Q Restricted Motion (RM) D Broken/Detached Pars (BDP Q 3.2 Failure Causes Normal Wear 0 Maintenance Error Q Abnormal Wear Q Manufacturing Error D .

Design Q Corrosion Q Human Error Q Foreign Material Q Procedure D Stress Corrosion Cracking Q Erosion/Corrosion Q Improper Installation . i Other Q Remarks:

A review fo maintenance history and surveillance history for valves in this group found no failures from 1991-2008. However, a 6 inch Powell swing check, P4400F051, did have a hinge pin replaced in 1994. Leakage was a common industry failure, but the valves in this group are not Cat A valves.

Rev.

Page 7 of 11

Fermi Nuclear Station CMP-07 EECW Return Checks 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/tnspection Activity Effectiveness of Activity to Failure Modes Detect Failure Detect Degradation Detected Full Open Stroke w/Flow NA NA Partial Open Stroke w/Flow Low Low FTO Back Flow/Reverse Flow .NA NA Manual Exercise NA NA Leak Test NA NA Disassembly & Inspection High High All Temperature Monitoring NA NA Radiography NA NA Ultrasonic Testing NA NA Magnetics . NA NA Acoustics NA NA Routine Operator Rounds NA NA Eddy Current Testing NA NA Test Effectiveness Rating: High - probability of detection >75%

Medium - <75% probability of detection but >25%

Low - probability of detection <25%

N/A - test method not available Rev.

Page 8 of 11

Fermi Nuclear Station CMP-07 EECW Return Checks 5.0. RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMP) PLAN 5.1 Test and Inspection Requirements Prior to CMP Implementation The valves in CMP-07 have been subjected to the following tests and inspections as required by the Inservice Testing Program. If disassembly is performed then the valve will be inspected for the presence of corrosion products, damage to the seat, buildup of debris around the spring etc., and a thorough cleaning of the valve internals prior to reassembly. Measurement of internal dimensions are taken for trending.

- The valve was exercised partial open as part of the IST program per 24.207.08 and 24.207.09. During this test the valve was verified to partial open by demonstrating flow sufficient to prevent high tempurature alarms.

- Disassembly Inspection was performed to satisfy closure requirements.

5.2 Condition Monitoring Program Plan Status: F Interim Plan rJ Final Plan 5.2.1 Condition Monitoring Test and Inspection Program Plan

'The following activities together represent the Condition Monitoring Program Plan for this group.

1. Plan Activity: Partial Open Stroke w/Flow Open test is actually a partial open test. Adequate flow is verified by no temperature alarms on the cooling loop.

Frequency:

Quarterly.

Tasks:

24.207.08 (P4400F051 and P4400F116A) 24.207.09 (P4400F165 and P4400F116B)

Notes:

Trending is on a pass/fail basis.

2. Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from full closed to full open and back to full closed, with no evidence of binding, or indication of excessive buildup of corrosion products on the internals.

Frequency:

One of the four check valves will be disassembled (CT-D) and inspected each cycle, such that all four are disassembled and inspected over a four cycle period. As an alternative for system draining scheduling convenience, two of the four check valves can be disassembled (CT-D) and inspected every other cycle, such that all four are disassembled and inspected over a four cycle period.

Tasks:

43.000.010 (ISI/PEP inspection) with 35.000.232 (Maintenance)

Notes:

The inspection results from disassembly and inspection shall be trended to evaluate for degradation. Specifically, the ability of the as-found valve to stroke full open and full closed without binding, no evidence of excessive wear, and no evidence of excessive corrosion buildup on the internals of the valve.

Rev.

Page 9 of 11

Fermi N6lear Station CMP-07 EECW Return Checks 5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMP tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance.

The periodic performance of a disassemble inspection test is the primary method of monitoring check valve condition. This testing is a good identifier that the internals.are intact with no abnormal wear, provides trending data to monitor for degradation and provides further assurance of operational readiness during the entire interval.

Partial open testing further verifies the ability of the valve to perform its function. Flow is not measured, and testing is not performed at accident conditions, so this is considered a partial open test.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Rev.

Page 10 of.11

Fermi Nuclear Station CMP-07 EECW Return Checks 6.0 CONDITION MONITORING PLAN REVIEW CMP Review Team Check Valve Engineer:

IST Engineer:

System Engineer:

Other:

CMP Review Comments Comment Resolution Review and Approval: Signature Date Reviewers:

Check Valve Program Engineer: _ __9_ _9 IST Program Engineer: 3I° LZ System Engineer:'

PRA Engineer Other:

Approval (Surpervision): c .. /b"/ /U Rev.

Page 11 of11

Fermi Nuclear Station Check Valve Condition Monitoring Plan CMP-08 EECW Pump Discharge Header Checks Rev. Q

Fermi Nuclear Station CMP-08 EECW Pump Discharge Header Checks 1.0 GROUP INFORMATION 1.1 Valve List P4400F003A EECW Div. I Pump C001A Discharge Check Valve P4400F003B EECW Div. II Pump 0001 B Discharge Check Valve P4400F077A EECW Div. I Pump A Supply to Essential Equipment Check Valve P4400F077B EECW Div. II Pump 0001 B Supply to Essential Equipment Check Valve 1.2 Manufacturing Data Manufacturer: Powell Valve Type: ) Swing Model: 3061 AWE Size: 8 Valve Body Material: SA216 Disc Material: HF SS410 BODY SEAT HF COCR Design Feature: Bolted bonnet 1.3 Service Conditions Service Duty: Water System Flow: 1650 gpm System Pressure: 150 System Temperature: 150 1.4 Grouping Bases These valves are grouped together based on having the same manufacturer, model, and service application. The following were considered in group determination:

W Same Mfg Q Like Orientation

" Service Conditions R] Like Design

" Identical Application Q Maximum Flow Unachievable

© Identical Test Methodology Q Similar Upstream Dowstream Flow Turbulence 0 Infrequent Operation Q Other 1.5 Safety Function Discussion These check valvse must open to provide a flow path from the discharge of the EECW pumps to the EECW essential loads. This function provides cooling water to these components during conditions when EECW is required to be operating. The valves must open to provide a minimum flow of 1650 gpm in the event of a high energy line.break accident to meet the design cooling water requirements of the associated essential loads. This is the maximum design accident flow rate since the LOCA cooling water requirements are much less. The drywell coolers are isolated during a LOCA. The check valves close to prevent reverse flow when the associated EECW pump is not operating. This function is not required for safe shutdown or accident mitigation since this function is only required when the EECW pumps are in the standby mode.

Rev.

Page 2 of 10

Fermi Nuclear Station CMP-08 EECW Pump Discharge Header Checks, 2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience IST Testing results have been very good overall. An open test has been performed each quarter with no failures since 2005.

All four valves have been disassemble inspected every 6th refuel outage (9 years) uider the SOER 86-03 Program. Results from 1991 to 2008 have always been good.

2.2 Industry Service Experience Generic Notices All Generic Notices available from the NRCs reading room were reviewed. No relevent Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevent Generic Letters were found.

All Information Notices available from the NRCs reading room were reviewed. No relevent Information Notices were found.

LER/OE Notices Reviewed INPOs Nuclear Network for OE Notices pertaining to 8" Powell swing check valves. No applicable issues were identified.

A review of the NRC LER and INPO OE data base using key words "valve" and Powell identified no items related to this valve from 1/1/05 through 12/15/08.

NIC Database Review The NIC failure database was reviewed for failures associated with Powell 8 inch swing check valves in a water application. Since the closed function of valves in the CMP group is not associated with a specific leakage criteria, seat leakage test failures were not considered applicable. The results are summarized below:

FRN 91-117 reported the discovery of a reactor. building closed loop cooling pump discharge check valve to fully close, causing back leakage to the return side of the pump. The seat and disc surfaces were worn due to normal wear, and were repaired. -

Applicability: Applicable. Although the valves in this Group are normally closed and have no reverse leakage acceptance criteria, failure to close due to normal wear is a potential failure mode..

FRN 90-060.reported the failur to close of a service water supply check valve. The hinge arm, hinge pin and disc stud were worn to the point that the disc could catch under the top of the valve seat.The valve was replaced.

Applicability: Not Applicable. The valve in this failure was in a service water (raw water) application and was in frequent use. The valves in Group CMP-08 are also in a raw water application, however are only open when the EECW pumps are in service. Historical internal inspections have shown that the type of excessive wear reported in this FRN is not likely to occur in this application.

EPIX Review INPOs EPIX database was reviewed for failures of Powell swing check valves with similar model number, size and application. No items were identified.

Vendor Input There was no vendor input or Part 21 Reports associated with 8" Powell swing check valves.

Rev.

Page 3 of 10

Fermi Nuclear Station CMP-08 EECW Pump Discharge Header Checks Industry Template There was no Powell Swing Check Valve Industry Template available on the Nuclear Industry Check (NIC) Valve Group's website.

2.2.1 References Generic Notices None.

LER/OE Notices None.

NIC Database Review Failure Record Numbers91-117 and 90-060.

EPIX Review None Vendor Input None.

Industry Template s None.

Rev.

Page 4 of10

Fermi Nuclear Station CMP-08 EECW Pump Discharge Header Checks 2.3 Valve History Information IST Testing results have been very good overall. An open test has been performed each quarter with no

'failures since 2005.

All four valves have been disassemble inspected every 6th refuel outage (9 years) under the SOER 86-03 Program. Results from 1991 to 2009 have always been good.

P4400F003A 1N0# Date Complete ~"~ Examination Reut, '.xA 046D900609 4/9/1991 DI - Good condition A121010100 11/11/2001 DI - Good condition A121100100 3/31/2009 Dl- Good condition. No problems found.

P4400F003B P364971107 9/12/1998 DI - Very good condition P364040100 4/12/2009 DI-Valve was found SAT - invery good condition. Only general light cleaning of internal surfaces was prescribed.

P4400F077A

.O# ;x Date C pete > M Examinatio Reut, 047D900609 4/10/1991 Dl - Good condition A360010100 11/12/2001 DI - Good condition A360100100 3/31/2009 DI-Good condtion. No problems found.

P4400F077B P365971107 9/11/1998 Dl - Very good condition P365040100 10/3/2007 DI - Good condition Rev.

Page 5 of 10

Fermi Nuclear Station CMP-08 EECW Pump Discharge Header Checks 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO) Q Failure to Close (FTC)

Internal Leakage (IL) Q External Leakage (EL) Q Disk Separation (DS) Q Hinge Pin Wear (HPW). Q Not Applicable (NA) Q Restricted Motion (RM) Q Broken/Detached Pars (BDP) Q 3.2 Failure Causes Normal Wear 0 Maintenance Error Q Abnormal Wear Q Manufacturing Error. Q Design Q Corrosion -

Human Error Q Foreign Material L Procedure L Stress Corrosion Cracking L Erosion/Corrosion L Improper Installation Q Other L Remarks:

Failure to close due to normal wear is a potential failure mode for this Group, although the likelihood is low since the valves are normally closed, and are only open when the associated ECCW pump is in service.

Rev.

Page 6 of 10

Fermi Nuclear Station CMP-08 EECW Pump Discharge Header Checks 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT TetIrps ctinActivit 'Effectiveniess of'Activit to, ~~aire Modes  ;;

Full Open Stroke w/Flow High Low FTO, RM Partial Open Stroke w/Flow NA NA Back Flow/Reverse Flow NA NA Manual Exercise NA NA Leak Test NA NA Disassembly & Inspection High High All Temperature Monitoring NA NA Radiography NA NA Ultrasonic Testing NA NA Magnetics NA NA Acoustics NA NA Routine Operator Rounds NA NA Eddy Current Testing NA NA Test Effectiveness Rating: High - probability of detection >75%

Medium - <75% probability of detection but >25%

Low - probability of detection <25%

N/A - test method not available Rev.

Page 7 of 10

Fermi Nuclear Station CMP-08 EECW Pump Discharge Header Checks 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMP) PLAN' 5.1 Test and Inspection'Requirements Prior to CMP Implementation The valves in Group CMP-08 were exercised full open each quarter as part of the iST program per 24.207.08 and 24.207.09. During this test the valves were verified to open by passing the maximum design accident flow rate of at least 1650 gpm. .No failures have occurred since at least 6/2005 Although closed exercise testing was not previously required by the 1ST Program, disassembly inspection was performed on each valve every 6th refuel outage to satisfy the site SOER 86-03 Program under 47.000.13. This is a visual and functional inspection to identify evidence of wear, corrosion, damaged or missing internals, and the condition of locking devices. Each valve has been inspected at least twice since 1991, and inspection results have been good with no failures or degradation identified.

5.2 Condition Monitoring Program Plan Status: D Interim Plan W Final Plan 5.2.1 Condition Monitoring Test and Inspection Program Plan The following activities together represent the Condition Monitoring Program Plan for this group.

1 . Plan Activity: Full Open Stroke w/Flow Demonstrated the ability of the valve to open and pass the maximum design accident flow rate Frequency:

Quarterly Tasks:

24.207.08 (P4400F003A and P4400F077A) 24.207.09 (P4400F003B and P4400F0778)

Notes:

Flowrate through the valves is recorded and provides trendable indication of degradation in the ability of the valve to open.

2. Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from full closed.to full open and back to full closed, with no evidence of binding, or indication of excessive buildup of corrosion products on the internals.

Frequency:

One valve in the Group will be disassembled and inspected every other cycle such that all 4 valves are inspected within 12 years. The individual valve inspection events are at a 6 RFO interval.

Tasks:

43.000.010 (ISI/PEP inspection) with 35.000.232 (Maintenance).

Notes:

The inspection results from disassembly and inspection shall be trended. to evaluate for degradation. Specifically, the ability of the as-found valve to stroke full open and full closed without binding, no evidence of excessive wear, and no evidence of excessive corrosion buildup on the internals of the valve:

5.2.2 Basis for Testing and Inspection Strategy (Analysis)

Rev.

Page 8 of 10

Fermi Nuclear Station CMP-08 EECW Pump Discharge Header Checks For optimization of condition monitoring activities, the CMP tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance.

Quarterly full open exercise testing under the IST Program and periodic internal inspections of the valves under the Site SOER 86-03 program have demonstrated the valves are performing their function with no evidence of wear or degradation. This supports placing this Group in a Final CMP plan.

The periodic performance of a disassemble inspection test demonstrates the bi-directional functionality of the valves and is the primary method of monitoring check valve condition. This testing is a good identifier that the internals are intact with no abnormal wear, provides trending data to monitor for degradation and provides further assurance of operational readiness during the entire interval.

Full open testing further verifies the ability of the valve to perform its function. Flow is measured and provides trendable indication of degradation.

During EECW standby 'periods the pressures on the EECW supply and return headers, as supplied by either RBCCW or SCCW, are at or higher than EECW running levels. Gauges on the EECW pump suction typically reflect normal return header pressure, which is qualitative evidence that these check valves have closed and properly seated.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Rev.

Page 9 of 10

Fermi Nuclear Station CMP-08 EECW Pump Discharge Header Checks 6.0 CONDITION MONITORING PLAN REVIEW CMP Review Team Check Valve Engineer:

IST Engineer:

System Engineer:

Other:

CMP Review Comments Comment Resolution Review and Approval: Signature Date Reviewers:

Check Valve Program Engineer: 0 IST Program Engineer: to System Engineer: " A ALAI PRA Engineer I ___

Other: \j Approval (Surpervision): Lo -lL-O Rev.

Page10of10

Fermi Nuclear Station Check Valve Condition Monitoring Plan CMP-09 HPCI Turbine Check Valves Rev. 0

Fermi Nuclear Station CMP-09 HPCI Turbine Check Valves 1.0 GROUP INFORMATION 1.1 Valve List E4100F040 HPCI Turbine Exhaust Condensate Drain Pot Outlet Valve E4100F048 HPCI Barometric CNDR Condensate Pump Return Line Check Valve E4100F057 HPCI Lube Oil Cooler Outlet Check Valve 1.2 Manufacturing Data Manufacturer: Rockwell Valve Type: Lift Y-Globe Model: - 838YT Size: 2 Valve Body Material: CARBON STEEL SA105 Disc Material: HF COCR BODY SEAT. HF COCR Design Feature: Bolted Bonnet, Spring Loaded 1.3 Service Conditions Service Duty: Clean Water System Flow: 70 gpm, F040 as required System Pressure: Design 460 psig, F040 Design 65 psig System Temperature: DESIGN 140 F, F040 DESIGN 298 F 1.4 Grouping Bases These valves are grouped together based on having the same manufacturer and model number. The following were considered in group determination:

O Same Mfg Q Like Orientation Q Service Conditions O Like Design Q Identical Application .Q Maximum Flow Unachievable O Identical Test Methodology Q Similar Upstream Dowstream Flow Turbulence Q. Infrequent Operation Q Other 1.5 Safety Function Discussion For E4100F040:

This check valve must open to provide a condensate return flow path from the HPCI Turbine Exhaust Line Drain Pot to the Suppression Pool during HPCI operation. The valve closes to isolate the suppression pool from the HPCI steam exhaust piping. However, this function is not required for safe shutdown or accident mitigation since downstream valve F022 is credited for closure as well as containment isolation.

ForE4100F048 and E4100F057:

These check valves open to allow return flow from the HPCI Lube Oil Cooler to the intake of the HPCI Booster Pump. These valves have no closed safety function.

Rev.

Page 2 of 11

Fermi Nuclear Station CMP-09 HPCI Turbine Check Valves 2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience Plant service experience for the valves in this group has been good overall with only one recent inspection failure. During performance of a Disassembly & Inspection PM on valve E4100F040, the valve plug was found in the fully open position and could not be moved in either direction. The cause was identified as corrosion product build up over time. The valve was cleaned, proven functional, and then returned to service. The valves are open exercise tested every quarter under the IST program. There have been no IST failures.

2.2 Industry Service Experience Generic Notices The NRC Document Reading Room was searched for Generic Notices or Information Bulletins pertaining to Rockwell-Edward piston (lift) check valves. None were found that specifically addressed Rockwell piston (lift) check valves. The following results were related to lift checks of similar size in a water application:

Information Notice 97-31, "Failures of Reactor Coolant Pump Thermal Barriers and Check Valves in Foreign Plants." This IN discusses thermal barrier cooling coil isolation check valves in a CCW system that were found to be jammed open. The cause of the jammed-open check valves was attributed to a layer of metallic oxide deposits generated in the CCW system carbon steel piping. The valves were a lift-type check valve. Lift-type check valve internals, particularly in the smaller valves, typically have small clearances and passages for coolant flow and are highly susceptible to corrosion products buildup.

Applicability: Applicable. The Fermi HPCI system piping is also carbon steel and could result in deposits in the check valves. Restricted motion due to corrosion products is a potential failure mode for this Group.

LER/OE Notices INPO's Nuclear Network was reviewed for LER/OE reports on failures of Rockwell Edwards lift check valves with similar model number, size, and application. Seat leakage/LLRT failures were generally not considered applicable since the valves in this group do not have a credited closed safety'function.

However, the following item was reviewed:

LER 05-002-00 and OE21402 (LaSalle) reported the seat leakage failure (LLRT) and possible failure to close of a similar model Edwards lift check. An acceptable test was obtained after the test operator mechanically agitated the check valve. This same valve had failed 7 months earlier. OE21402 (An update to OE20830) determined the cause of the failures to be a less than optimal design application because the valve is susceptible to internal corrosion and binding. Corrective action was to replace the valve with a swing check valve.

Applicability: Applicable. Although the valves in Group CMP-09 do not have a specified credited closed safety function, Restricted Motion (failure to fully open or close) is a potential failure mode. The most likely causes are binding of the disc due to normal wear or foreign material/corrosion products in the valve internals.

IOM Review None NIC Database Review The NIC Check Valve Performance database was reviewed for failures associated with Rockwell Edwards model 838 piston (lift) check valves. Due to the large number of Rockwell check valve failures contained in the database, the.search was limited to valves in like or similar applications and service duty as those in Group CMP-09. Failures of valves in air/nitrogen systems were not considered Rev.

Page 3 of11

Fermi Nuclear Station CMP-09 HPCI Turbine Check Valves applicable to this group. The following failures of valves in a similar application were evaluated:.

FRN 85-089 reports that during the performance of a surveillance test on the high pressure coolant injection (HPCI) system, the HPCI barometric condenser vacuum pump discharge check valve stuck in the closed position causing the vacuum pump to trip. Inspection of the valve found that the check valve internals were'corroded. Corrective action included cleaning internals, installed and lapped new plug in the check valve.

Applicability: Applicable. Although the valves in Group CMP-09 do not have a specified credited closed safety function, Restricted Motion (failure to fully open or close),due to corrosion products is a potential failure mode for this Group.

FRN 92-384 reports the failure of reactor core isolation cooling (RCIC) barometric condenser pump discharge check valve leak rate test: The cause is attributed to the buildup of dirt or corrosion on the valve internals. The valve was cleaned and successfully retested.

Applicability: Applicable. Although the valves in Group CMP-09 do not have a specified credited closed safety function, Restricted Motion (failure to fully open or close) due to corrosion products is a potential failure mode for this Group.

FRN 93-079 reports that during the performance of a surveillance test on the reactor core isolation cooling (RCIC) system, main-control room personnel received a RCIC low vacuum alarm due to a RCIC vacuum pump discharge check-valve being stuck closed on demand. The check valve. was mechanically agitated which allowed the valve to-chatter open. The cause of the failure was not determined. The valve was verified for proper operation and returned to service.

Applicability: Applicable. Although the valves in Group CMP-09 do not have a specified credited closed safety function, Restricted Motion (failure.to fully open or close) due to corrosion products is a potential failure mode for this Group.

FRN 93-297 reports that during a check valve inspection, the check valve component engineer found the RCIC vacuum pump discharge check valve failing to prevent reverse flow. The valve was stuck in the open position due to rust particle buildup between the piston outside diameter and the valve body inside diameter.. The valve is highly susceptible to rust buildup due to intermittent use and exposure to moisture. The valve was replaced with a soft seat swing check valve. Valve operability was verified and returned to service.

Applicability: Applicable. Although the valves in Group CMP-09 do not have a specified credited closed safety function, Restricted Motion (failure to fully open or close) due to corrosion products is a potential failure mode for this Group.

FRN 04-051 reports the seat leak test failure of the RCIC Barometric Condenser Vacuum Pump Discharge Containment Isolation Check Valve. The inspection identified that corrosion product build up on the disc guide rings and valve bore had reduced the internal clearances such that the disc movement

- was hindered. The disc and spring assembly were replaced and the valve was successfully retested.

Applicability: Applicable. Although the valves in Group CMP-09 do not have a specified credited closed safety function, Restricted Motion (failure to fully open or close) is a potential failure mode. The most likely causes are binding of the disc.due'to normal wear or foreign material/corrosion products in the valve internals.

EPIX Review INPOs Equipment Performance and Information Exchange (EPIX) was reviewed for failures of Rockwell Edwards piston (lift) check valves with similar model number, size and application. The following item Rev.

Page4of11

Fermi Nuclear Station CMP-09 HPCI Turbine Check Valves was reviewed:

Failure Number FN-514 reported the failure to meet seat leakage criteria of a 1 inch Edwards model 838Y piston check valve.

Applicability: Not Applicable. The valves in Group CMP-09 do not have a credited closed safety function and therefore no seat leakage criteria..

Vendor Input There was no vendor input or Part 21 Reports associated with 2" Rockwell-Edward piston (lift) check valves.

Industry Template There was no Rockwell-Edward Piston (Lift) Check Valve Industry Template available on the Nuclear Industry Check (NIC) Valve Group's website.

2.2.1 References Generic Notices Information Notice 97-31 LER/OE Notices LER 05-002-00 and OE21402 (LaSalle)

IOM Review None NIC Database Review Failure Record Numbers FRN 85-089,92-384, 93-079,93-297 & 04-051 EPIX Review None Vendor Input None Industry Template None Rev.

Page 5 of 11

Fermi Nuclear Station CMP-09 HPCI Turbine Check Valves 2.3 Valve History Information The valves have been open exercise tested by the IST Program each quarter. Bi-directional closure exercise testing was not previously included in the IST Program for these valves. However, forward and reverse exercise testing has beendemonstrated during periodic internal inspections of the valves under the Site SOER 86-03 program. The historical test result review covered the time period from 1992 to the present. Of the eleven inspections, there was only one reported disassembly and inspection (D&l) failure of the valves in Group CMP-09: During performance of D&l PM C561080100 on valve E4100F040, the valve plug was found in the fully open position and could not be moved in either direction. Scotch-Brite was used to clean off the rough area in the bore to allow the plug to be removed from the valve. The plug guide ribs also had rough areas around their circumference. These rough areas were'also cleaned up on the plug using Scotch-Brite. The cause was identified as corrosion products build up over time which caused the as-found stuck condition. The valve was cleaned, proven functional, and then returned to service.

E4100F040 WO# Date Complete Examination Results E404911008 9/23/1992 D&1 results - Good condition E404950216 10/5/1996 D&l results - Good condition C561020100 3/12/2002 D&f results - Good condition C561080100, 6/2/2008 Unsat condition - Found stuck open - see CARD 08-23654 file. The valve was cleaned, proven functional, and then returned to service.

E4100F048 WO# Date Complete Examination Results E005911008 9/25/1992 D&I results - Good condition P523971107 1/9/2001 D&i results - Good condition P523070100 12/5/2006 D&l results - Good condition E4100F057 WO# Date Complete Examination Results E407911008 ' 10/6/1992 D&I results - Good condition 000Z991545 1/12/2000 D&I results - Good condition C564050100 5/12/2005 D&l results - Good condition C564080100 12/1/2009 D&I results - Very good condition Rev.

Page 6 of 11

Fermi Nuclear Station CMP-09 HPCI Turbine Check Valves 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO) I Failure to Close. (FTC)

Internal Leakage (IL) Q External Leakage (EL) D Disk Separation (DS) Q Hinge Pin Wear (HPW) D Not Applicable (NA) Q Restricted Motion (RM)

Broken/Detached Pars (BDP) D 3.2 Failure Causes Normal Wear W Maintenance Error Q Abnormal Wear Q Manufacturing Error Q Design Q Corrosion Human Error El Foreign Material W Procedure Q Stress Corrosion Cracking Ql Erosion/Corrosion Q Improper Installation Q Other E Remarks:

Restricted Motion (failure to fully open or close) due to normal wear, foreign material or corrosion products in the valve internals is a potential failure mode for this group.

Rev.

Page 7 of 11

Fermi Nuclear Station CMP-09 HPCI Turbine Check Valves 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Effectiveness of Activity to Failure Modes Detect Failure Detect pegradation Detected Full Open Stroke w/Flow NA NA Partial Open Stroke w/Flow Medium Low FTO, RM Back Flow/Reverse Flow NA NA Manual Exercise NA NA Leak Test NA NA Disassembly & Inspection High High All Temperature Monitoring NA NA Radiography NA NA Ultrasonic Testing NA NA Magnetics NA NA Acoustics NA NA Routine Operator Rounds NA NA Eddy Current Testing NA NA Test Effectiveness Rating: . High - probability of detection >75%

Medium - <75% probability of detection but >25%

Low- probability of detection <25%

N/A - test method not available Rev.

Page 8 of 11

Fermi Nuclear Station CMP-09 HPCI Turbine Check Valves 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMP) PLAN 5.1 Test and Inspection Requirements Prior to CMP Implementation Prior to the implementation of Condition Monitoring, the valves in Group CMP-09 were open exercise tested each quarter per the IST Program under surveillance procedure 24.202.01. While closure testing was not a requirement of the IST Program, the valves have been periodically disassembled and inspected at a frequency established by the Site SOER 86-03 Check Valve Program.

There are no different or additional testing requirements imposed prior to CMP implementation.

5.2 Condition Monitoring Program Plan Status: O Interim Plan Iv Final Plan 5.2.1 Condition Monitoring Test and Inspection Program Plan The following activities together represent the Condition Monitoring Program Plan for this group.

1.. Plan Activity: Partial Open Stroke w/Flow Demonstrate the functionality of the valves to open and pass flow.

Frequency:

The valves in the group are tested each quarter during the associated HPCI pump test.

Tasks:

24.202.01 Notes:

Establishing flow through the valves demonstrates the ability of the valves to open and pass flow. The test shall be on a pass/fail basis determined by the ability of the HPCI pump to operate within established parameters without receiving either a hi-level alarm (Annunciator 2D65, HPCI TURBINE EXH DRAIN POT LEVEL HIGH or Annunciator 2D66, HPCI CNDR VAC TANK LEVEL HIGH) or a lube oil hi-temp alarm (Annunciator 2D68, HPCI TURBINE OIL COOLER DISCH TEMP HIGH).

.2. Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from the full closed to full open and back to full closed position, with no evidence of binding of the internals.

Frequency:

At least one valve in the group shall be disassembled & inspected every 24 months, with all valves being disassembled & inspected within 7 years.

Tasks:

43.000.010 Notes:

Procedure inspection / measurement results shall be trended to monitor for evidence of degradation.

5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMP tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance.

Quarterly open exercise testing under the IST Program and periodic internal inspections of the valves under the Site SOER 86-03 program have demonstrated the valves are performing their functions with no evidence of significant wear or degradation. This supports placing this Group in a Rev.

Page 9 of 11

Fermi Nuclear Station CMP-09 HPCI Turbine Check Valves Final CMP plan.

Of the eleven inspections, there was only one reported disassembly and inspection (D&l) failure of -

the valves in Group CMP-09. For valve E4100F040, the valve plug was-found in the fully open position and could not be moved in either-direction. The rough areas in the bore and around the circumference of the plug guide ribs were cleaned up using Scotch-Brite. The cause was identified as corrosion products build up over time which caused the as-found stuck condition. The valve was cleaned, proven functional, and then returned to service. This failure did not prevent the valve from performing its safety function.

The periodic performance of a disassembly and inspection demonstrates the bi-directional functionality of the valves and is the primary method of monitoring check valve condition. This testing is a good identifier that the internals are intact with no abnormal wear, provides trending data to monitor for degradation, and provides further assurance of operational readiness during the entire interval. Open exercise testing further ve-ifies the ability of the valves to perform their functions.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness:

Rev.

Page 10 of11

Fermi Nuclear Station CMP-09 HPC] Turbine Check Valves 6.0 CONDITION MONITORING PLAN REVIEW CMP Review Team Check Valve Engineer:

IST Engineer:

System Engineer:

Other:

CMP Review Comments Comment Resolution Revievi and Approval: Signature Date Reviewers: z9 1 Check Valve Program En ineer:_ _ _ _ _V_

IST Program Engineer: 2 / 5 z-Xolo System Engineer: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ /. h PRA Engiheer/

Other: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Approval (Surpervision): _________________to-l______yqo___

Rev.

Page 11 of 11

Fermi Nuclear Station Check Valve Condition Monitoring Plan CMP-10 HPCI Turbine Exhaust Check Valve Rev.

Fermi Nuclear Station CMP-10 HPCI Turbine Exhaust Check Valve 1.0 GROUP INFORMATION 1.1 Valve List E4100F049 HPCI Turbine Exhaust Check Valve 1.2 Manufacturing Data Manufacturer: Anchor Darling Valve Type: Lift Y-Globe Model: W8221576 Size: 20 Valve Body Material: SA216 Disc Material: HF COCR BODY SEAT HF COCR Design Feature: Bolted bonnet; No spring; Equalizer line 1.3 Service Conditions Service Duty: Wet Steam System Flow:  ? Lb/hr System Pressure: Design 65 psig System Temperature: DESIGN 298 F 1.4 Grouping Bases.

This is a single valve group.

Q Same Mfg Q Like Orientation Q Service Conditions E Like Design Q Identical Application E Maximum Flow Unachievable E Identical Test Methodology - Similar Upstream Dowstream Flow Turbulence E Infrequent Operation Q Other 1.5 Safety Function Discussion The safety related stroke direction of this valve is in the open direction to provide a flow path for exhaust steam from the High Pressure Coolant Injection (HPCI) pump turbine.

Rev.

Page 2 of 11

Formi Nuclear Station CMP-10 HPCI Turbine Exhaust Check Valve 2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience Plant service experience for the valve in this group has been good. The valve is normally closed and sees limited service. Only two Disassembly & Inspection PMs have been done under the Site SOER 86-03 Program on this valve in the last 14 years. Both inspections found the valve in good condition. The valve is open exercise tested every quarter under the IST program. There have been no IST failures.

2.2 Industry Service Experience Generic Notices The NRC Document Reading Room was searched for Generic Notices or Information Bulletins pertaining to Anchor Darling piston (lift) check valves. None were found that specifically addressed Anchor Darling lift check Y-globe valves.

LER/OE Notices INPOs Nuclear Network was reviewed for LER/OE Reports pertaining to Anchor. Darling piston (lift) check valves with similar model number, size, and application. The following item was reviewed for applicability:

LER 387-02007 reports the seat leakage test failure of a HPCI steam exhaust check valve. The resilient seat was missing and valve internals showed wear from chatter.

Applicability: Not Applicable. The valve in Group CMP-10 is not seat leakage tested & does not use a resilient seat. The valve has been inspected twice in the last 14 years and has shown no indication of wear.

IOM Review None NIC Database Review The NIC Chebk Valve Performance database was reviewed for failures associated with Anchor Darling 20 inch carbon steel lift check valves. No failures.of 20 inch valves were identified. The following failures of valves in a similar application were evaluated:

FRN 99-095 reports the restricted motion failure of a RCIC turbine exhaust check valve that caused a turbine trip on high exhaust backpressure. Minor wear indications on the guides combined with a less than perfect repair in 1988 (sharp edges on top of skirt and on gap between guide and upper bore) combined to allow this lift check valve to drag during opening. This caused peak turbine exhaust pressure during the initial startup surge to exceed the trip set point.

Applicability:, Applicable. Restricted motion due to normal wear is a potential failure mode for this Group.

FRN 92-012 and FRN 98-114 report the improper seating of a RCIC exhau~st check valve resulting in failure of the seat leakage tests. The failures were due to scratches on the soft seating material due to normal wear.

Applicability: Not applicable. The valve in Group CMP-10 does not have a soft.seat and has no seat leakage requirements.

FRN 93-262 reports the seat leakage test failure of a HPCI exhaust check valve due to pitting on the resilient seat and that the resilient seat protruded beyond the manufacturer's dimensions. The technical representative and engineering concurred that the original plug dimensions were not correct.and required the plug to be machined. The cause was manufacturing error.

Rev.

Page 3 of11

Fermi Nuclear Station CMP-10 HPCI Turbine Exhaust Check Valve Applicability: Not applicable. The valve in Group CMP-10 does not have a soft seat and has no seat leakage requirements.

EPIX Review INPOs Equipment Performance and Information Exchange (EPIX) was reviewed for failures Anchor Darling piston (lift) check valves with similar model number, size, and application. The following item was reviewed for applicability:

FN #194 reports the seat leakage test failure of a RCIC steam exhaust check valve. The resilient seat was worn due to normal wear.

Applicability: Not Applicable. The valve in Group CMP-10 is not seat leakage tested & does not use a resilient seat. The valve has been inspected twice inthe last 14 years and has shown no indication of wear.

Vendor Input No Part 21 Reports were identified that were applicable to the valve in Group CMP-10. Part 21 reports, 1995-21-0,-1 and 1996-73-0,-1, -2 were related to Anchor Darling 2 in. piston (lift) checks., Based on differences in valve models and service application, these are not considered applicable to the valve in this Group.

Industry Template An industry review template for Anchor Darling lift check valves, developed by NIC, was reviewed for.

applicability to Group CMP-10 check valve. (Note this template was in Draft, and all areas had not been completed). The template is generic in nature with a total of 38 Anchor Darling lift check valves contained in the 1991 population of 4779 lift check valves. As indicated in the template there were 16 check valves with carbon steel body material similar to Group CMP-10. Attachment 1 is provided to identify the failure modes and percentage of failures addressed by the industry template.

Improper seating (20), followed by stuck open (7), were the most prevalent Failure Modes for Anchor Darling-checks and were most likely due to known causes of foreign material (9) and normal wear (7).

Normal wear resulting in restricted motion is the most likely cause for failure of the Group CMP-10 valve.

2.2.1 References Generic Notices None LER/OE Notices None IOM Review None NIC Database Review Failure Record Numbers FRN 99-095,92-012, 98-114 and 93-262 EPIX Review Failure Number FN-194 Vendor Input None Industry Template Industry Review Template for Anchor Darling Piston/Lift Check Valves, Revision A, 1/5/01 Rev.

Page 4 of 11

Fermi Nuclear Station CMP-10 HPCI Turbine Exhaust Check Valve 2.3 Valve History Information The valve has been open exercise tested by the IST Program each quarter. Bi-directional closure exercise, testing was not previously included in the IST Program for this valve. However, forward and reverse exercise testing has been demonstrated during periodic internal inspections of the valve under the Site SOER 86-03 Program. The historical test result review covered the time period from 1996 to the present.

Only two Disassembly & Inspection PMs have been done under the Site SOER 86-03 Program on valve E4100F049 during this time period. Both inspections found the valve in good condition.

E4100F049 WO', 7t CompeteExaminiatin Result E412930223 10/14/1996 D&I results - Good condition E412961116 . 4/6/2004 D&I results - Good condition Rev.

Page 5 of 11

Fermi Nuclear Station CMP-10 HPCI Turbine Exhaust Check Valve 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open. (FTO) Q Failure to Close (FTC) D Internal Leakage (IL) D External Leakage (EL) Q Disk Separation (DS) Q Hinge Pin Wear (HPW) Q Not Applicable (NA) Q Restricted Motion (RM) .

Broken/Detached Pars (BDP) E 3.2 Failure Causes Normal Wear M Maintenance Error D Abnormal Wear D Manufacturing Error. D Design Corrosion Human Error Q Foreign Material Q Procedure Stress Corrosion Cracking Q Erosion/Corrosion . Improper Installation Other Q-Remarks:

Based on a review of the Performance Analysis, the valve in CMP-10 is potentially subject to restricted motion due to normal wear.

Rev.

Page 6 of 11

Fermi Nuclear Station CMP-10 HPCI Turbine Exhaust Check Valve-4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT

~ Testlnspection Activity " Effectiveness'of Aciiyto. Failre>ode Full Open Stroke w/Flow NA NA -

Partial Open Stroke w/Flow Medium Low FTO, RM Back Flow/Reverse Flow NA NA Manual Exercise NA NA Leak Test NA NA Disassembly & Inspection High High All Temperature Monitoring NA NA Radiography NA NA Ultrasonic Testing NA NA Magnetics NA NA Acoustics NA NA Routine Operator Rounds NA NA Eddy Current Testing NA NA Test Effectiveness Rating: High - probability of detection >75%

Medium - <75% probability of detection but >25%

Low - probability of detection <25%

N/A - test method not available Rev.

Page 7 of 11

Fermi Nuclear Station CMP-10 HPCI Turbine Exhaust Check Valve 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMP) PLAN 5.1 Test and Inspection Requirements Prior to CMP Implementation Prior to the implementation of Condition Monitoring, the valve in Group CMP-10 was open exercise tested each quarter per the IST Program under surveillance procedure 24.202.01. While closure testing was not a requirement of the IST Program, the valve was periodically disassembled and inspected, including open &

close exercising, at a frequency established by the Site SOER 86-03 Check Valve Program.

There are no different or additional testing requirements imposed prior to CMP implementation.

5.2 Condition Monitoring Program Plan Status: Q Interim Plan Q/ Final Plan 5.2.1 Condition Monitoring Test and Inspection Program Plan The following activities together represent the Condition Monitoring Program Plan for this group.

1. Plan Activity: Partial Open Stroke w/Flow Demonstrates the functionality of the valve to open and pass flow.

Frequency:

The valve in this group is tested each quarter during the associated HPCI pump test.

Tasks:

24.202.01 Notes:

Establishing steam flow through the valve demonstrates the ability of the valve to open and pass flow. The test shall be on a pass/fail basis determined by the ability of the HPCI pump to operate within established parameters (flow & pressure) without receiving Annunciator 2D52, HPCI TURBINE EXH LINE PRESSURE HIGH, alarm.

2. Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from the full closed to full open and back to full closed position, with no evidence of binding of the internals.

Frequency:

This valve shall be disassembled & inspected at least once every 6 years.

Tasks:

43.000.010 Notes:

Procedure inspection / measurement results shall-be trended to monitor for evidence of degradation.

5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMP tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance.

Quarterly open exercise testing under the IST Program and periodic internal inspections of the valve under the Site SOER 86-03 program have demonstrated the valve is performing its function with no evidence of wear or degradation. This'supports placing this Group in a Final CMP plan.

The periodic performance of a disassembly and inspection demonstrates the bi-directional functionality of the valve and is the primary method of monitoring check valve condition. This testing Rev.

Page 8 of 11

Fermi Nuclear Station CMP-10 HPCI'Turbine Exhaust Check Valve is a good identifier that the internals are intact with no abnormal wear, provides trending data to monitor for degradation, and provides further assurance of operational readiness during the entire interval. Open exercise testing further verifies the ability of the valve to perform its function.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be

-effective for ensuring operational readiness. -

Rev.

Page 9 of 11

Fermi Nuclear Station CMP-10 HPCI Turbine Exhaust Check Valve 6.0 CONDITION MONITORING PLAN REVIEW CMP Review Team Check Valve Engineer:

IST Engineer:

System Engineer:

Other:

CMP Review Comments Comment Resolution Review and Approval: A Signature Date Reviewers: -4l Check Valve Program Engin e r:___:

IST Program Engineer: ___________

System Engineer: 6/l/

PRA Engineer_________________________________

Other: _____________________

f K-1 \ 1V4 Approval (Surpervision): L 6 vlL -(

Rev.

Page 10of 11

F-ermi Nuclear Station CMP-10 HPCI Turbine Exhaust Check Valve Attachment 1 Failure Modes Industry Template NIC Check Valve Performance Database Failure Node Description [Anchor Darling Total Lift %of ILift CV Failure Total

______________ _ jFailures Pop. I_ __

Part Other Than Disk Broken 217 17 1.0 1180%

Stuck Closed 0 651 0%I Stuck Open I7 1541 4.50%I fRestricted Motion f0 301 0%]

~Improper Seating =20514139%

Unknown .1l 341 2.90%J Free/Loose Internals 31 33.3 0%

Rev.

Page 11 of 11

FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES FERMI 2 THIRD 10 YEAR INTERVAL - START DATE 02/15/2010 PART 7: IST PROGRAM RELIEF REQUESTS REVISION 0 Revision Summary:

1. Complete rewrite for start of 3rd ten year interval OUAL Prepared: Date: C Z'k\\ PE-03 IST ogram nager Reviewed: Date: 2 ( PE-03 ISI/PEP Engineer Reviewed: L J I /cA- Date: j --/ N/A Su ervisor, Perfoi nance Engineering Approved: li- Date: // N/A Ma ger, Performance Engineering INFORMATION AND PROCEDURES DSN: IST Program Relief Requests Rev: 0 Date: Z-DTC: TM PLAN File: 1715.04 Recipient:

Date Approved: N //- ha Release authorized by: N/- /

IST PROGRAM PLAN PART 7 RELIEF REQUESTS INDEX Relief Request No. Description PRR-002 Core Spray Pump Testing - Pumps Tested in Parallel and using Curve-based Criteria PRR-003 Emergency Equipment Cooling Water (EECW) Pumps Testing Using Pnmp Curves PRR-004 RHR Pumps Vibration Limits change Alert criteria absolute limit to 0.415 ips PRR-005 Relief for Vibration Criteria on Smooth Running Pumps PRR-006 Service Water Pump Inlet Pressure (INLPR) Accuracy PRR-007 Relief from Comprehensive Pump Testing requirements for Centrifugal IST Pumps PRR-009 Relief to use > 2% variance in test flow for RHR Service Water, EECW Make-up and CCHVAC Chilled Water Pumps PRR-010 - Relief from Comprehensive Pump Testing requirements for Standby Liquid Control (SLC) and EDG Fuel Oil Transfer Positive Displacement pumps VRR-011 Test Frequency of Excess Flow Check Valves per Tech Spec VRR-012 Performance of Position Indication Testing per Option B LLRT frequency VRR-013 Relief to perforn Pressure Isolation Valve (PIV) testing at frequencies coincident with Appendix J Option B testing The following is a short description of the individual Relief Requests, including the components covered. Also included are the NRC Safety Evaluation Reports documenting approval of all the relief requests.

The full content of the submitted Relief Requests can be found in ARMS under DSN: NRC-09-0064 (dated November 3, 2009).

IST PROGRAM PLAN PART 7. Page 2

FERMI 2 RELIEF REQUESTS FOR 3RD TEN YEAR INTERVAL Relief Request Subject Components Affected Number PRR-002 Core Spray Pump Testing - Pumps Division 1 Core Spray Pumps Tested in Parallel and using Curve- (E2101COOlA and E2101C001C) based Criteria Division 2 Core Spray Pumps (E2101C001B and E2101C001D)

Benefit to Fermi: Allows us to continue testing in our present parallel pump configuration and to deviate from new Code-required Comprehensive Pump Testing (CPT) requirements until the Div 1 and 2 test line modifications (EDP-36057) are completed. Following the modifications we will be able to test the Core Spray pumps individually, assess their condition and fully comply with modern ASME Code testing requirements.

NRC Relief approval date: July 6, 2010 Previously submitted relief request: YES (for Elements 1 & 2)

Relief duration(s): Element 1(Parallel pump quarterly testing) duration - 3 years Element 2 (Use of curve-based criteria)duration - 4 years Element 3 (Delay of Comp. Pump Testing) duration - 3 years Notes:

CS Test Line EDP DCAT will provide for full baseline testing of individual pumps, with minimum of 6 Q-P points and will assess degree of flow control with E2150F015A/B. Determine if Ops can consistently adjust to a flow test point +/- 2% of reference inclusive of flow measurement accuracy. If flow control is less than adequate we will have to re-submit for full ten year relief on the use of the curve-based criteria.

IST PROGRAM PLAN PART 7 Page 3

Relief Request Subject Components Affected Number PRR-003 Emergency Equipment Cooling Water P4400CO01A and P4400CO01B (EECW) Pumps Testing Using Pump Curves Benefit to Fermi: Allows us to be able to perform adequate (Code-compliant) testing of EECW pumps even if the system is in an off-normal configuration, such as we see during Refuel Outage Division swaps where several major EECW load paths, such as Drywell Coolers, may reniain isolated. Even in such situations we need to be able to test the pump and declare it operable to support key loads such as Residual Heat Removal / Core Spray pumps.

NRC Relief approval date: July 6, 2010 Previously submitted relief request: YES Relief duration(s): Entire ten year interval PRR-004 RHR Pumps Vibration Limits change Division 1 Residual Heat Removal Alert criteria absolute limit to 0.415 ips (RHR) Pumps (E1102C001A and E1102C001C)

Division 2 RHR Pumps (E1102C001B and El 102CO01D)

Benefit to Fermi: Fermi has routinely had to place these pumps on increased frequency testing due to flow noise induced spikes in vibration data. Having this higher Alert criterion will minimize or prevent the need to take that action. This benefits Operations in not having to run a complex surveillance test twice as often.

NRC Relief approval date: July 6, 2010 Previously submitted relief request: YES - but relief was only granted for Pumps B & C Relief duration(s): Entire ten year interval IST PROGRAM PLAN PART 7 Page 4

Relief Request Subject Components Affected Number PRR-005 Relief for Vibration E 151COOlA, E 115CQOIB, E l51COOlC, Criteria on Smooth E1151C001D, P4400COO1A, P4400COO1B, Running Pumps P4400C002A, P4400C002B, P4500C002A, P4500C002B, R3000C001, R3000C002, R3000C003, R3000C004, R3000C009, R3000CO10, R3000C0I 1, R3000C012, R3001C005, R3001C006, R3001C007, R3001 C008 Benefit to Fermi: Fermi has many pumps/motors which have such low nominal vibration levels that the calculated Alert criteria (2.5 x nominal value) is actually within the accuracy tolerances of the vibration measuring equipment. Readings could exceed Alert criteria due solely to the vibration instrument accuracy. This relief establishes more meaningful criteria that would only be reached if the equipment is truly degrading. Default minimum reference vibration level will be 0.04 ips with associated criteria of Alert = 0.100ips and Required Action = 0.240ips.

NRC Relief approval date: July 6, 2010 Previously submitted relief request: NO Relief duration(s): Entire ten year interval PRR-006 Service Water Pump E1151C00lA, E1151C001B, E1151C001C, Inlet Pressure (INLPR) E1151C001D, P4500C002A, P4500C002B, Accuracy R3001C005, R3001C006, R3001C007, R3001C008 Benefit to Fermi: Allows us to continue using our present method for deriving Service Water (SW) pump suction lift pressure using the RHR reservoir level indication. Without relief, new Code requirements for tighter pressure accuracies would force us to install a more accurate reservoir level indication loop or establish some other means of measuring the suction lift pressure.

NRC Relief approval.date: July 6, 2010 Previously submitted relief request: YES Relief duration(s): Entire ten year interval IST PROGRAM PLAN PART 7 Page 5

Relief Request Subject Components Affected Number PRR-007 Relief from El 102C002A,El 102C002B,E1102C002C, El 102C002D, Comprehensive Pump E1151C001A, E1151C001B, E1151C001C, E1151C001D, Testing (CPT) for IST E4101C001, P4400COOlA, P4400CO01B, P4500C002A, Pumps P4500C002B, R3001C005, R3001C006, R3001C007, R3001C008, T4100C040, T4100C041 Benefit to Fermi: The Code now requires a new test (Comprehensive Pump testing - CPT) performed every 2 years at full flow. Fermi already performs normal quarterly testing at CPT adequate flows and with very accurate instrumentation. This relief request allows us to take credit for our normal quarterly testing being equivalent to the new CPT and avoid the need to run a "special" test, with separate procedures, every 2 years.

NRC Relief approval date: July 6, 2010 Previously submitted relief request: NO Relief duration(s): Entire ten year interval.

PRR-009 Relief to use > 2% E1151C001A, E1151COO1B, E1151C001C, variance in test flow El 151C001D, P44000O02A, P4400C002B, T4100C040, T4100C041 Benefit to Fermi: Present NRC interpretation of ASME OM ISTB requires IST test flow to be set within

+/- 2% of reference value, inclusive of flow measurement accuracy. For the pumps listed above Fermi is unable to set test flow with that degree of precision. This relief allows us to continue testing these pumps without having to modify the process instrumentation and/or the valves used for throttling. Our present testing is adequate for identifying degradation - the expense of the possible modifications is not justified.

NRC Relief approval date: October 5, 2010 Previously submitted relief request: NO Relief duration(s): Entire ten year interval Note:

The ASME OM Code ISTB committee is working to develop guidance which would allow for flow test band of +2% /- 1% exclusive of flow instrument accuracy. This relief may not be necessary during the next ten year interval.

IST PROGRAM PLAN PART 7 Page 6

Relief Request Subject Components Affected Number PRR-010 Relief from CPT for Standby Standby Liquid Control Pumps C4103C001A, Liquid Control and EDG C4103C001B and EDG Diesel Fuel Oil Transfer Diesel Fuel Oil Transfer Pumps R3000C001, R3000C002, R3000C003, Pumps R3000C004, R3000C009, R3000C0 10, R3000CO11, R3000C012 Benefit to Fermi: The Code now requires a new test (Comprehensive Pump testing - CPT) performed every 2 years at full flow. Fermi already performis normal quarterly testing at full flows and with very accurate instrumentation on these positive displacement pumps. This relief request allows us to take credit for our normal quarterly testing being equivalent to the new CPT and avoid the need to run a "special" test, with separate procedures, every 2 years NRC Relief approval date: July 6, 2010 Previously submitted relief request: NO Relief duration(s): Entire ten year interval VRR-011 Test frequency of B21F501A, B21F5011B, B211F501C, B21F501D, B21F502A, EFCVs per TS B21F502B,1B21F502C, B21F502D, B21F503A, 1B211F503B, B21F503C,1B21F503D, B21F504A, B21F504B, B21F504C; B21F504D, B21F506, B21F507, B21F508, B21F509,1B21F5 10, B21F511, 1B21F512, 1B21F513A, 1B21F513B, B21F513C,1B21F513D, B21F514A,1B21F5141B, 1B21F514C, B21F514D,.B21F515A, B21F515B, B21F515C, B21F515D, B21F515E, B21F515F, B21F515G, B21F515H, B21F515L, B21F515M, B21F515N, B21F515P,1B21F515R, B21F515S,1B21F515T, B21F515U, B21F516A, B21F516B, B21F516C, B21F517A, B21F517B, B21F517C, B21F517D, B31F501A, B3IF501B, B31F501C, B31F501D, B31F502A, B31F502B, B31F502C, B31F502D, B31F503A, B31F503B, B31F504A, B31F504B, 1B31F505A,1B31F505B, B31F506A, B31F506B, B31F510A, B31F510B, B31F51IA, B31F51lB, B31F512A, B31F512B, B31F515A,1B31F5151B,B31F516A, B31F516B, E21F500A, E21F500B, E41F500, E41F501, E41F502, E41F503, E51F503, E51F504, E51F505, E51F506, G33F583, N21F539A, N21F539B Benefit to Fermi: We will be allowed to continue testing our Excess Flow Check Valves using the sample test plan described in our Tech Specs. The Code would require 100% testing every cycle - thus relief is necessary.

NRC Relief approval date: September 28, 2010 Previously submitted relief request: YES Relief duration(s): Entire ten year interval IST PROGRAM PLAN PART 7 Page 7

Relief Request Subject Components Affected Number VRR-012 Performance of PIT per Option C5100F002A, C5100F002B, C5100F002C, C5100F002D, B LLRT frequency C510OF002E, E11F412, E11F413, E11F414, E 1IF415, E41F400, E41F401, E41F402, E41F403, P34F401A, P34F401B, P34F403A, P34F403B, P34F404A, P34F404B, P34F405A, P34F405B, P34F406A, P34F406B, P34F407, P34F408, P34F409, P34F410, T50F412A, T50F412B, T50F450, T50F451, T50F458 Benefit to Fermi: In order to perform the once per cycle Position Indication Testing (PIT) on these 32 Solenoid Operated Valves (SOV) all of the equipment and resources necessary to perform their LLRTs must be used. The LLRTs are typically only required once every 3 cycles.

By allowing the PITs to be performed only when the LLRTs are required we will save 80 -100 mRem/year. It will also lower system unavailability and reduce ISI personnel online and RFO resource demands.

NRC Relief approval date: September 28, 2010 Previously submitted relief request: NO Relief duration(s): Entire ten year interval VRR-013 Relief to perform PIV testing at E1100F050A, El 10OF050B, El 150F008, frequencies coincident with Option B El 150F009, El 150F015A, El 150F015B, CIV testing; i.e., use good performer E1150F608, E210OF006A, E2100F006B, basis for PIV's E2150F005A, E2150F005B, E4150F006, E4150F007, E5150F012,E51.50F013 Benefit to Fermi: This relief provides significant reductions in dose and LLRT group resource usage every RFO. Reducing the frequency of these tests, on valves such as the El 10OF05OA/B, will also reduce the complexity of the RFO scheduling and free up Operations resources. LLRT Program Manager will track PIV performance and schedule testing in accordance with the requirements of the 10CFR50 Appendix J, Option B Program.

NRC Relief approval date: September 28, 2010 Previously submitted relief request: NO Relief duration(s): Entire ten year interval IST PROGRAM PLAN PART 7 Page 8

NRC Safety Evaluation Reports Index

1. Dated July 6, 2010 - SER for Relief Requests PRR-002, PRR-003 and PRR-006

2. Dated July 6, 2010 - SER for Relief Requests PRR-004, PRR-005, PRR-007 and PRR-010

3. Dated October 5, 2010 - SER for Relief Request PRR-009

4. Dated September 28, 2010 - SER for Relief Requests VRR-011, VRR-012 and VRR-013 IST PROGRAM PLAN PART 7 Page 9

G6Ji I p RECoG UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 6, 2010 Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - EVALUATION OF RELIEF REQUEST NOS: PRR-002, PRR-003, AND PRR-006 FOR THE THIRD 10-YEAR INTERVAL INSERVICE PROGRAM (TAC NOS. ME2548, ME2549, ME2551)

Dear Mr. Davis:

By letter dated November 3, 2009, DTE Energy (the licensee) submitted eleven requests for relief from certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Fermi 2 for the third 10-year Inservice Testing (IST) Program interval. On January 7, 2010, the NRC requested the licensee to submit additional information to support relief request PRR-006. By letter dated February 19, 2010, the licensee submitted this additional information. On March 23, 2010, the NRC requested the licensee to submit additional information to support relief requests PRR-002 and PRR-003. By letter dated April 22, 2010, the licensee submitted this additional information.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i), in PRR-002 (in part), PRR-003, and PRR-006 the licensee requested to use these alternatives on the basis that the alternatives provide an acceptable level of quality and safety. Pursuant to 10 CFR 50.55a(a)(3)(ii), in PRR-002 (in part) the licensee requested to use this alternative on the basis that complying with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The NRC staff has completed its review of the subject requests for authorization of these alternatives. As documented in the enclosed Safety Evaluation, the NRC staff concludes that the proposed alternatives are justified and that they provide an acceptable level of quality and safety. The analysis and evaluation that the licensee has performed provides reasonable assurance of operational readiness.

Therefore, the NRC staff authorizes alternative request PRR-006 at Fermi 2 for the third 10-year IST program interval, which began on February 17, 2010 and ends on February 16, 2020. The NRC staff grants relief for request PRR-002 at Fermi 2 for the period which began February 17, 2010 (i.e., commencement of the Fermi 2 third 10-year IST program interval) and ends three years later (February 17, 2013), except for the use of reference curves as described in alternative testing requirement 1.

1

J. Davis The use of reference curves may continue until February 17, 2014. The NRC staff grants relief for request PRR-003 at Fermi 2 for the third 10-year IST program interval, which began on February 17, 2010 and ends on February 16, 2020. All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.

Sincerely, Ro ert J. Pascarelli, Branch ief Plant Licensing Branch IlIl-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ

VREG UNITED STATES z' NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NUMBERS PRR-002, PRR-003, AND PRR-006 FOR THE THIRD 10-YEAR INTERVAL INSERVICE TESTING PROGRAM DTE ENERGY FERMI 2 DOCKET.NO. 50-341

1.0 INTRODUCTION

By letter dated November 3, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093140302), DTE Energy (the licensee) submitted eleven requests for relief from certain requirements of the American Society of Mechanical Engineers (ASME)

Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Fermi 2 for the third 10-year Inservice Testing (IST) Program interval. This safety evaluation addresses licensee relief request numbers PRR-002, PRR-003, and PRR-006. On January 7, 2010, (ADAMS Accession No. ML101760333) the NRC requested the licensee to submit additional information to support relief request PRR-006. By letter dated February'19, 2010, (ADAMS Accession No. ML100540147), the licensee submitted this additional information. On March 23, 2010, (ADAMS Accession No. ML100830407), the NRC requested the licensee to submit additional information to support relief requests PRR-002 and PRR-003. By letter dated April 22, 2010, (ADAMS Accession No. ML101120958), the licensee submitted this additional information.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i), in PRR-002 (in part), PRR-003, and PRR-006 the licensee requested to use these alternatives on the basis that the alternatives provide an acceptable level of quality and safety. Pursuant to 10 CFR 50.55a(a)(3)(ii), in PRR-002 (in part) the licensee requested to use this alternative on the basis that complying with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

2.0 REGULATORY EVALUATION

The Code of Federal Regulations (CFR), 10 CFR 50.55a(f), requires that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with the specified ASME Code incorporated by reference in the regulations. Exceptions are allowed where alternatives have been authorized or relief has been requested by the licensee and granted by the Enclosure 3

Commission pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. Pursuant to 10 CFR 50.55a the Commission is authorized to approve alternatives and to-grant relief from ASME Code requirements upon making necessary findings. In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations twelve months prior to the start of each 120-month IST program interval. In accordance with 10 CFR 50.55a(f)(4)(iv),

IST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC approval.

Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met.

In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical due to limitations of design, geometry, and materials of construction for the facility. NRC guidance contained in Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," provides alternatives to ASME Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Revision 1, "Guidance for Inservice Testing at Nuclear Power Plants."

The "Code of Record" for the. Fermi 2, third 10-year IST program interval is the ASME OM Code, 2004 Edition (no Addenda), as required by 10 CFR 50.55a(f)(4)(ii). The Fermi 2, third 10-year IST program interval-that began on February 17, 2010 and ends on February 16, 2020.

The NRC staff's findings with respect to granting relief and/or approving alternatives associated with Fermi 2 relief requests PRR-002, PRR-003, and PRR-006 are as follows:

3.0 TECHNICAL EVALUATION

3.1 RELIEF REQUEST PRR7002-------

3.1.1 Licensee's Relief Request and Proposed Alternative The Core Spray System (CSS) protects the reactor core in the event of a large break Loss Of Coolant Accident if the Feedwater, Control Rod Drive, Reactor Core Isolation Cooling, High Pressure Coolant Injection, or Residual Heat Removal (RHR) systems are unable to maintain reactor water level. The system consists of two independent 100 percent capacity divisions, each containing two parallel pumps. Each pump is capable of providing 50 percent of the required flow for that division. Both pumps in a division are required to be operable in order for the division to be considered operable (Pumps A and C comprise Division 1; pumps B and D comprise Division 2).

The current design of the test line for each division will permit full flow testing of two pumps simultaneously as required by Technical Specification Surveillance Requirement (SR) 3.5.1.8.

However, it is impractical to test the pumps of a given division individually, as required by the ASME OM Code, since the test lines and test valves are sized for two-pump testing. The test line flow control valves are throttled approximately 13 percent open (Division 1)or 9 percent open (Division 2) to control two-pump test flow. The existing flow control valves are not capable

of throttling.low enough.(less than 5 percent open) to accommodate single pump operation without experiencing unstable operation,. cavitation, and severe vibration. Significant damage to the test line valves occurred during attempts to throttle for single pump operation during plant initial startup testing.

Further, due to the oversized test lines and test valves, it is impractical to throttle to a fixed reference value during two pump testing. The flow control valves are opened to a point in their travel in which small changes in valve position result in large changes in flow rate. Thus, it presents an unnecessary challenge to both the equipment and the plant operators to attempt to return to a specific fixed reference value at each pump test.

A modification plan is currently being finalized in which several reducing orifices will be installed in each test line. This modification will allow for individual pump testing as well as provide enhanced throttling capability allowing for standard pump testing with fixed reference values.

The test line modification will be performed during the Fermi 2 Refueling Outage 15 which is scheduled to start on March 30, 2012 and end on April 30, 2012.

In the interim, the licensee has requested relief for core spray pumps E2101C001A, E2101C001B, E2101C001C, and E2101C001D from the requirements of the following three ASME OM Code paragraphs:

. Relief is requested from ASME OM Code ISTB, Inser-vice Testing of Pumps, in order to perform quarterly testing of both core spray pumps in each division simultaneously in parallel. That is, both pumps are to be run together and treated as a single component rather than being tested individually. This relief is requested for the period beginning February 17, 2010 (i.e., commencement of the Fermi 2 third 10-year IST program interval) and ending three years later (February 17, 2013).

. Relief is requested from ASME OM Code ISTB-5121, Group A Test Procedure, in order to utilize a flow reference curve, rather than a single fixed reference value for flow. This relief is requested for the period beginning February 17, 2010 (i.e., commencement of the Fermi 2 third 10-year IST program interval) and ending four years later (February 17, 2014).

• Relief is requested from ASME OM Code ISTB-3400, Frequency of Inservice Test, in order to delay the first performance of the biennial Comprehensive Pump Test (CPT) required for each core spray pump. Specifically, it is requested that the due date of February 17,2012 for the performance of the first CPT on these pumps (i.e., two years after commencement of the Fermi 2 third 10-year IST program interval) be extended by one year to February 17, 2013.

In their original relief request and by supplemental information submitted on April 22, 2010, the licensee has proposed the following alternative testing:

1. Quarterly Group A type testing will be performed for both core spray pumps in each Division in parallel. Hydraulic acceptance criteria will be based on flow reference curves rather than reference points. Reference curves will-be established for each division.

2. Group A type testing will be performed at nominally full flow conditions of greater than or equal to 6,600 gallons per minute (gpm) per division.

3. The following Group A hydraulic acceptance criteria will be used inorder to enhance the ability to detect degradation of a single pump:

Acceptable AP Range - 0.94 to 1.06 APr Alert AP Range - 0.92 to < 0.94 APr Required Action AP Range - Low < 0.92 APr and High > 1.06 APr (Where APr equals the differential pressure reference value)

These acceptance criteria are more stringent than those otherwise specified inTable ISTB-5121-1.

4. The monitoring, analysis, and evaluation requirements of ISTB-6000 will apply using the modified hydraulic acceptance criteria above (Performance trending of the core spray pumps will include normalization of the AP data to a fixed reference value to eliminate scatter within the AP data caused by test flow values above or below a nominal fixed reference flow to provide the ability to detect degradation).

5. When a reference curve may have been affected by repair, replacement, or routine servicing of a pump, a new reference curve will be determined, or an existing reference curve will be reconfirmed.

6. The vibration acceptance criteria of Table ISTB-5121-1 are applicable and will be applied to each pump individually. A single Alert criterion and a single Required Action criterion will be used over the range of the pump curve. Individual vibration reference values for all four pumps were taken during baseline testing in 1984. These reference values range from a ,

low of 0.131 in./sec to a high of 0.315 in.fsec and were relatively consistent over the test flow range. As a result, the .Code maximum limits of 0.325 in./sec. Alert and 0.700 in./sec.

Required Action will be used for all monitoring points on all four pumps.

7. The first CPT will be performed on each of the core spray pumps no laterthan February 17, 2013. The second CPT will be performed 2 years following the first CPT inaccordance with ISTB-3400-1 test frequency requirements.

3.1.2 NRC Staff Evaluation The CSS at Fermi 2 isa unique design which includes two divisions with two pumps ineach division. If one of the two pumps ineither division isdeclared inoperable, then that division is inoperable. There are no functions of the CSS for single pump operation ineither division. The CSS also includes a test line that is used .to test both pumps ineach division simultaneously while the plant isat power. Both pumps are required to operate inorder to achieve the-TS flow rate specified inSR 3.5.1.8 of at least 6350 gpm at a system head corresponding to a reactor pressure of r 100 pounds per square inch gauge (psig).

The ASME OM Code generally requires inSection ISTB that pumps must be tested individually to detect a deviation in hydraulic and mechanical performance at'points of operation readily duplicated during subsequent tests. These points of operation, referred to as reference values, are the baseline points from which the acceptance criteria are established. When maintenance on. a pump has the potential to affect an individual reference value or a set of reference values,

(.

new reference values must be established. If the deviation in hydraulic performance of an individual centrifugal pump falls within the required action range, the pump is declared inoperable until the cause of the deviation is determined and the condition is corrected.

The design of the CSS at Fermi 2 is such that each train is capable of being tested at substantial flow conditions, but it is impractical to test each pump in the train individually because the test flow loop (specifically, the flow control valve) is sized to test both pumps simultaneously. In order to test a pump individually, the flow control valve would be open less than 5 percent of valve stem travel. Operation at this valve setting would be accompanied by unstable operation, cavitation, severe vibration, and possible system damage. Operation of the core spray pumps individually for testing is, therefore, impractical within the limitations of the current system design.

The ASME OM Code test procedure in Section ISTB-5121 requires that pumps must be throttled to a specific hydraulic reference point (either flow or differential pressure) for testing.

Because of the design of the test line and the sizing of the flow control valve, small changes in valve position result in large changes in flow rate presenting a challenge to both the equipment and the plant operators to throttle to a specific reference point. It is, therefore, impractical within the limitations of the current system design to obtain a repeatable reference value in accordance with OM Code requirements.

ASME OM Code Section ISTB-3400 requires that the core spray pumps be tested (1) quarterly per the Group A test procedure, and (2) biennially per the CPT procedure. Procedurally, the CPT is essentially the same as the Group A test except that the CPT seeks to identify relatively smaller changes in hydraulic performance than the Group A test through the use of higher precision in the differential pressure measurement. However, testing the core spray pumps in parallel (i.e., measuring, the combined hydraulic performance of both pumps) has the potential to mask small performance changes in either pump individually, thus defeating the intent of the CPT. Performance of the CPT is, therefore, impractical within the limitations of the current system design.

The future CSS test line modification will allow for individual pump testing as well as provide enhanced throttling capability allowing for standard pump testing with fixed reference values.

This modification, when complete, should eliminate the impracticalities discussed above and should, therefore, obviate the need for relief from these ASME OM Code requirements.

In the interim and pursuant to 10 CFR 50.55a(f)(6)(i), the requested relief from ASME OM Code requirements is granted and alternatives as discussed above are authorized. These alternatives are authorized for the period that began February 17, 2010 (i.e., commencement of the Fermi 2 third 10-year IST program interval) and ending three years later (February 17, 2013), except for the use of reference curves as described in alternative testing requirement 1 above. The use of reference curves may continue until February 17, 2014 to allow some additional time to assess system flow throttling capability following completion of the modification.

3.1.3 Conclusion As set forth above, the NRC staff determined that it is impractical for the licensee to comply with certain requirements of the ASME OM Code for core spray pump testing, and the alternative

testing specified provides reasonable assurance that the core spray pumps will remain operationally ready.

Granting relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life.,

or property or the common defense and security, and isotherwise inthe public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

3.2 Relief.Request PRR-003 3.2.1 Licensee's Relief Request and Proposed Alternative The design of the Emergency Equipment Cooling Water (EECW) system provides essentially a fixed flow resistance with only coarse ability to adjust flow rates by either isolating individual cooling.load paths or by throttling with the manual pump discharge gate valve. Isolating cooling paths may require the system to be inoperable for extended periods of time. Depending on which flow path(s) is isolated (and which flow path(s) may already be isolated due to other plant -

conditions), it isimpractical to establish a specific reference flow value: The ability to control flow using the discharge gate valve is also impractical due to its design as a shutoff valve (rather than as a throttling valve). This makes it difficult to establish a specific reference flow value using this method.

Relief is requested from ASME OM Code ISTB-3300, Reference Values, and ISTB-5121, Group A Test Procedure, for'EECW pumps P44000O01A and P4400C001 B, inorder to utilize a flow reference curve, as needed, rather than a single fixed-reference flow value. This relief is requested for the entire Fermi 2 third 10-year IST program interval that began February 17, 2010 and ends February 16, 2020:

Intheir original reliefrequest and by supplemental information submitted on April 22, 2010, the licensee has proposed the following alternative testing:

1. Quarterly Group A testing.of the EECW.pumps will be performed in accordance with ISTB-5121(c) at reference conditions established by the licensee.

2. If it is impractical due to system conditions to achieve the reference flow condition for the ISTB-5121(c) test, hydraulic.acceptance criteria will be'based on a flow reference curve.

Reference curves will be established for-each pump.

3. All testing will be done at substantial flowrates of greater than or equal to 1,550 gpm.

4. The following hydraulic acceptance criteria will be used inorder to enhance the ability to detect degradation. These acceptance criteria are more stringent than those otherwise specified inTable ISTB-5121-1:

AcceptableAP Range 0.91 to 1.06 APr Required-Action AP Range Low <i0.91 APr and High > 1.06 APr (Where APr equals the differential pressure reference value)'

5. The monitoring, analysis, and evaluation requirements of ISTB-6000 will apply using the.

modified hydraulic acceptance criteria shown above. (Performance trending will utilize a normalization process wherein AP data will be normalized to the reference flow. value to allow for a low scatter time-based trend analysis to provide the ability to detect pump degradation).

6. When a reference curve may have been affected by repair, replacement, or routine servicirig of a pump, a new reference curve will be determined, or an existing reference curve will be reconfirmed.

7. The vibration acceptance criteria of Table ISTB-5121-1 are applicable and will be applied. A single Alert criterion and a single Required Action criterion will be used over the range of the pump. curve (Individual reference values for vibration data were recorded at the primary reference flow. The procedural vibration limits are based on ISTB-5121-1 using those reference values. Vibration data recorded at multiple flow points during pre-service testing did not indicate a statistical relationship between flow and vibration values).

3.2.2 NRC Staff Evaluation ASME OM Code ISTB-5121, Group A Test Procedure, requires that pump tests be conducted with the pump operating at a specified reference point. The licensee has demonstrated that due to the system design it is impractical to establish a repeatable reference value at each test and has requested relief from this requirement-Pursuant to 10 CFR 50.55a(f)(6)(i), the requested relief from the ASME OM Code ISTB-5121 requirement to throttle to a specified reference point is granted and alternatives as discussed above are authorized. These alternatives are authorized for the EECW pumps for the entire Fermi 2 third 10-year IST program interval.

3.2.3 Conclusion As set forth above, the NRC staff determined that it is impractical for the licensee to comply with certain requirements of the ASME OM Code for EECW Pump testing, and the alternative testing specified provides reasonable assurance that the EECW Pumps remain operationally ready.

Granting relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

3.3 Relief Request PRR-006 3.3.1 Licensee's Relief Request and Proposed Alternative The licensee is requesting relief from the requirements of ASME OM Code, 2004 Edition, Paragraph ISTB-3510(a), which states that instrument accuracy shall be within the limits of Table ISTB-3510-1. This table specifies the pressure instrument accuracy for a comprehensive pump test to be +/- 0.5 percent. Paragraph ISTB-3510(a) also states that for digital instruments, the required accuracy is over the calibrated range and for a combination of instruments, the

required accuracy is loop accuracy. This relief request isfor the Residual Heat Removal.

Service Wafer (RHRSW) Pumps, the Emergency Equipment Service Water (EESW) Pumps,.

and the Emergency Diesel Generator Service Water (EDGSW) Pumps. The purpose of these service water pumps is to maintain cooling flow from the Ultimate Heat Sink to the RHR Heat Exchangers, the EECW Heat Exchangers and various heat exchangers on each Emergency Diesel Generator.

The Licensee states:

Due to the design of these pumps (vertical line shaft), the suction pressure (INLPR) [inlet.

pressure] isdetermined using measurement of RHR Reservoir level and correlation to suction lift pressure. The instrumentation for level measurement of the RHR' Reservoir is calibrated to +/- 0.73% at full scale (+/- 0.22 ft @ 30 ft). [T]he instrument calibration is verified at cardinal points of 6, 12, 18, 24, and 30 feet. A query of the IST database showed that over the past ten years the lowest recorded suction pressure for any of the service water pumps was 4.7 psi and the highest was 5.5 psi. This equates to a range of reservoir level of 26.8 feet to 28.6 feet. [T]he degree of error for this instrument is lowest at the maximum reading (30 feet) and higher at lower readings. The cardinal point of 24 feet is bounding inthe lower direction for all the recorded surveillance data. The accuracy at that cardinal point is+/- 0.92% (+/- 0.22 ft @ 24 ft.). For the nominal pressure reading of 5.3 psi this equates to a maximum possible error of 5.3 x .0092 = 0.049 psi.

For the comprehensive test of.these pumps, the Code required accuracy for pressure is 0.5%, or 0.027 psi at a measured INLPR of 5.3 psi. The difference between the permanently installed instrument accuracy and the Code required 0.5% accuracy amounts to 0.022 psi. Temporary digital instrumentation is used to measure the discharge pressure (DISPR) of these pumps. The accuracy of the DISPR measurements is 0.5% of reading or better. For a bounding low DISPR reading of 32 psi the error would be 32 x .005 = 0.16 psi.

The differential pressure-parameter is affected primarily by the accuracy. of the discharge pressure of the pumps. The suction lift pressure derived from the RHR reservoir level has lower impact on the overall calculation of pump differential pressure. Using the installed 0.92% level instrument induces a maximum additional error of 0.022 psi. This is

-well within the 0.1 psi readability expectation for Operations when documenting the.

discharge pressure.

3.3.2 NRC Staff Evaluation The licensee requests relief from the instrument accuracy requirements of ISTB-351 0(a) and Table ISTB 3510-1 for the RHR reservoir level instrument that is used for various, service water pump testing. Specifically, the Code requires pressure instruments to have an accuracy of

+/-0.5 percent for comprehensive and preservice tests. RHRSW, EESW and EDGSW pumps are tested using the installed RHR reservoir level instrument to calculate pump suction pressure and a temporary digital instrument to measure pump discharge pressure. Both of these measurements are used to calculate pump differential. pressure.

The RHR reservoir level isdetected and indicated by a combination of instruments, transmitter, power supply, and indicator/recorder, and is required by ISTB-3510(a) to meet the accuracy requirements as a loop measurement. As stated above, the loop accuracy of the level

instrument is +/- 0.22 ft which is 0.92 percent. Using the licensee's provided nominal suction pressure reading of 5.3 psi, the error is+/-0.049 psi. The discharge pressure for each affected pump ismeasured using a temporary digital instrument with an accuracy of +/-0.5 percent. Using a bounding low pump discharge pressure of 32 psi, the error is+/-0.16 psi. The combined error resulting from calculating the pump differential pressure is0.16 psi + 0.049 psi = 0.209 psi. If the RHR reservoir instrument met the Code required accuracy of 10.5 percent, the reading error would be +/-0.027 psi. The resulting dombined error would be 0.16 psi + 0.027 psi = 0.187 psi.

The difference of 0.022 psi is considered insignificant when monitoring for degradation. The existing accuracy is equivalent to the 1.5 percent minimum accuracy allowed by the combination of instrument full scale range and accuracy as specified inthe ASME OM code for comprehensive pump testing. This accuracy provides adequate assurance of operability.

3.3.3 Summary Based on the above evaluation, the NRC staff concludes that the licensee's proposed alternative to the ASME OM Code comprehensive pump testing requirements for the RHRSW, EESW and EDGSW Pumps are authorized pursuant to 10 CFR 50.55a(a)(3)(i), on the basis that the alternative provides an acceptable level of quality and safety. The licensee's proposed alternative provides reasonable assurance of the operational readiness of the pumps. This alternative is authorized for the third 10-year IST program interval.

4.0 Conclusion As set forth above, the NRC staff determines that for relief requests PRR-002 and PRR-003 the proposed testing provides reasonable assurance that the pumps are operationally ready, and for proposed alternative PRR-006 provides an acceptable level of quality and safety.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in10 CFR 50.55a(f)(6)(i) for relief requests PRR-002 and PRR-003 and 10 CFR 50.55a(a)(3)(i) for alternative request PRR-006, and is incompliance with the ASME OM Code's requirements. Therefore, the NRC staff authorizes alternative request PRR-006 at Fermi 2 for the third 10-year IST program interval, which began on February 17, 2010 and ends on February 16, 2020. The NRC staff grants relief for request PRR-002 at Fermi 2 for the period that began February 17, 2010 (i.e., commencement of the Fermi 2 third 10-year IST program interval) and ends three years later (February 17, 2013), except for the use of reference curves as described inalternative testing requirement 1. The use of reference curves may continue until February 17, 2014. The NRC staff grants relief for request PRR-003 at Fermi 2 for the third 10-year IST program interval, which began on February 17, 2010 and ends on February 16, 2020. All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.

Principal Contributors:

J. Billerback - PRR-002, PRR-003 L. Russell - PRR-006 Dated: July 6, 2010

J. Davis The use of reference curves may continue until February 17, 2014. The NRC staff grants relief for request PRR-003 at Fermi 2 for the third 10-year IST program interval, which began on February 17, 2010 and ends on February 16, 2020. All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.,

Sincerely,

/RAI Peter. Tam for Robert J. Pascarelli, Branch Chief Plant Licensing Branch Ill-1 Division of Operating Reactor Licensing Office of Nuclear'Reactor Regulation Docket No. 50-341

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ DISTRIBUTION:

PUBLIC - LPL3-1 R/F RidsAcrsAcnw_MaiICTR Resource RidsNrrDirsltsb Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl3-1 Resource . RidsNrrPMFermi2 Resource RidsNrrLABTully Resource RidsOgcRp Resource RidsRgn3MailCenter Resource JBillerback LRussell Accession Number: ML101670351 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA DCI/CPTB/BC NRR/LPL3-1/BC NAM MChawla - BTully AMcMurtray RPascarelli /Peter Tam for DATE 07/02/10 .. 06/28/10 07/02/10 07/06/10 OFFICIAL RECORD COPY

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 6, 2010 Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2-210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - EVALUATION OF RELIEF REQUEST NOS: PRR-004, PRR-005, PRR-007, AND PRR-010 FOR THE THIRD-10-YEAR INTERVAL INSERVICE PROGRAM (TAC NOS. ME2552, ME2553, ME2554, ME2559)

Dear Mr. Davis:

By letter dated November 3, 2009, DTE Energy (the licensee), submitted eleven requests to the U.S. Nuclear Regulatory Commission (NRC) for relief from certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Fermi 2 for the third 10-year Inservice Testing Program interval. On February 5, 2010, the NRC requested the licensee to submit additional information to support relief requests PRR-004, PRR-005, PRR-007, and PRR-010. By letter dated March 22, 2010, DTE Energy submitted additional information pertaining to the requests addressed in this Safety Evaluation (SE).

The licensee requested to use the proposed alternative PRR-004 on the basis that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety. Also, the licensee requested to use the proposed alternatives PRR-005, PRR-007, and PRR-010 on the basis that the alternatives provide an acceptable level of quality and safety. The NRC staff has completed its review of the subject requests for authorization of these alternatives. As documented in the enclosed SE, the NRC staff concludes that the proposed alternatives are justified that they provide-an acceptable level of quality and safety. The analysis and evaluation that the licensee has performed provides reasonable assurance of operational readiness. Therefore, the NRC staff authorizes the proposed alternatives pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(ii) for PRR-004 and pursuant to 10 CFR 50.55a(3)(i) for PRR-005, PRR-007, and PRR-010. The Fermi 2 third 10-year Inservice Testing Interval, began on February 17, 2010 and ends on February 16, 2020.

J. Davis All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable.

Sincerely, Ro e J. Pascarelli, Branch Plant Licensing Branch I1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ

R REG" UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NOS. PRR-004, PRR-005, PRR-007, AND PRR-010 FOR THE THIRD 10-YEAR INTERVIAL INSERVICE TESTING PROGRAM DETROIT EDISON FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION

By letter dated November 3, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093140302), DTE Energy (the licensee), submitted eleven requests to the U.S. Nuclear Regulatory Commission (NRC) for relief from certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Fermi 2 for the third 10-year inservice testing (lST) program interval. This safety evaluation (SE) addresses licensee relief request numbers PRR-004, PRR-005, PRR-007, and PRR-010. In an e-mail dated February 5, 2010 (ADAMS Accession No. ML100491856), NRC requested the licensee to provide additional information for relief requests PRR-004, PRR-005, PRR-007, and PRR-010. By letter dated March 22, 2010 (ADAMS Accession No. ML100820061), DTE Energy submitted additional information pertaining to the requests addressed in this SE.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(ii),

the licensee requested to use the proposed alternative PRR-004 on the basis that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety. Also, pursuant to 10 CFR 50.55a(3)(i),

the licensee requested to use the proposed alternatives PRR-005, PRR-007, and PRR-010 on the basis that the alternatives provide an acceptable level of quality and safety.

2.0 REGULATORY EVALUATION

Title 10 of the Code or Federal Regulations 50.55a(f), requires that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with the specified ASME Code and applicable addenda incorporated by reference in the regulations. Exceptions are allowed where alternatives have been authorized or relief has been requested by the licensee and granted by the NRC pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a.

In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to,the start of each 120=month IST program interval. In accordance with 10 CFR 50.55a(f)(4)(iv), IST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met. NRC guidance contained in Generic Letter. (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," provides alternatives to ASME Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482 Revision 1, "Guidelines for Inservice Testing at Nuclear Power Plants." ASME OM code cases that are approved for use by the NRC,are listed in Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code" dated June 2003. The Code of record for the Fermi 2 third 10-year IST program interval is ASME OM Code, 2004 Edition (no addenda), as required by 10 CFR 50.55a(f)(4)(ii). The Fermi 2 third 10-year IST program interval began on February 17, 2010 and ends on February 16, 2020.

The NRC staffs findings with respect to authorizing the proposed alternative to the ASME OM Code are given below:

3.0 TECHNICAL EVALUATION

3.1 RELIEF REQUEST PRR-004 3.1.1 Licensee's Relief Request and Proposed Alternative The applicable ASME OM Code edition and addenda for the Fermi 2 thid 10-year IST interval is the 2004 Edition.

ISTB-3540(a), "Vibration," requires that on centrifugal pumps, except vertical line shaft'pumps, measurements shall be taken in a plane approximately perpendicular to the rotating shaft'in two approximately orthogonal directions on each accessible pump bearing housing. Measurement shall also be taken. in the axial direction on each accessible pump thrust bearing housing.

ISTB-5121(e), "Group A Test Procedure," and ISTB-5123(e), "Comprehensive Test Procedure,"

require that all deviations from reference values shall be compared with the-ranges-of Table ISTB-5121-1 and corrective action taken as specified in,ISTB-6200.

Table ISTB-5121-1, "Centrifugal Pump Test Acceptance Criteria," requires that for Group A and Comprehensive tests, the vibration alert range for pumps (speed 2600 revolutions per minute (rpm)) shall be from >0.325 to 0.700 inches per second (ips).

ISTB-6200(a), "Corrective Action - Alert Range," requires that if measured test parameter values fall within the alert range of Table ISTB-5121-1, Table ISTB-5221-1, Table ISTB-5321-1, or Table ISTB-5321-2, as applicable, the frequency of testing as specified in ISTB-3400 shall be doubled until the cause of the deviation is determined and condition is corrected.

The licensee requested relief from the requirements of Table-ISTB-5121-1 for the residual heat removal (RHR) pumps listed inTable 1-1 below. In lieu of meeting the Code requirements for the vibration alert range from >0.325 ips to 0.700 ips, the licensee proposes to increase the lower end of the alert range.from 0.325 ips to 0.415 ips for the affected pump vibration tests.

TABLE 1-1 Pump Description Pump Group Classification Operating speed (rpm)

E1102C001A RHR Pump A A 1800 E1102C001B RHR Pump B A 1800 E1102C001C RHR Pump C A 1800 E1102C001D RHR Pump D A 1800 (Note: the figures and trend referenced in the basis for requesting relief and alternative testing

'sections were submitted as part of the original package and have not been repeated inthe staff's SE)

Inthis relief request, the licensee states:

Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(i), relief is requested from the vibration criteria requirements of ASME OM Code ISTB Table ISTB-5121-1 during the Group A or biennial comprehensive pump test or any other time vibrations are taken to determine pump acceptability (i.e., post-maintenance testing, other periodic testing, etc.). The proposed alternative would provide an acceptable level of quality and safety.

Relief is requested from ISTB Table ISTB-5121-1 requirements to test the pump on an increased periodicity due to vibration levels exceeding the ISTB alert range absolute limit of 0.325 ips. This request is based on analysis of vibration and pump differential pressure data indicating that no pump degradation istaking place.

Pump Testing Methodology The RHR pumps at Fermi 2 are tested each quarter using a full flow recirculation test line back to the suppression pool. These pumps have a minimum flow line (per division) which is used only to protect the pump from overheating when pumping against a closed discharge valve.

The mini-flow line isolation valve for each division isinitially open when the pump isstarted, and flow isinitially recirculated through the mini-flow line back to the suppression pool. Then, the full-flow test line isolation valve is throttled open to establish flow through the full-flow recirculation test line. The mini-flow line is then isolated automatically, and all flow remains through the full-flow test line for the IST test.

The RHR system isoperated inthe same manner and under the same conditions for each IST test, regardless of whether Fermi 2 is operating or shut down. Consequently, the pumps will experience the same potential for flow-induced, broad band vibration whenever they are tested, whether Fermi 2 isoperating or shut down. As a result, this relief isrequested for the inservice testing of RHR pumps when vibration measurements are required or any other time vibrations

are recorded to determine pump acceptability (i.e., post-maintenance testing, other periodic testing, etc.).

NRC Staff Document NUREG/CP-0152 NRC Staff document NUREG/CP-0152, entitled "Proceedings of the Fourth NRC/ASME Symposium on Valve and Pump Testing," dated July 15-18, 1996, included a paper'entitled Nuclear Power Plant Safety Related Pump.Issues, by Joseph Colaccino of the NRC staff. That paper presented four key components that should be addressed in a relief request of this type to streamline the review process. These four key components are as follows:

1. The licensee should have sufficient vibration history from inservice testing which verifies that the pump has operated at this vibration level for a significant amount of time, with any "spikes" in the data justified.

II. The licensee should have consulted with the pump manufacturer or vibration expert about the level of vibration the pump is experiencing to determine if pump operation is acceptable.

Ill. The licensee should describe attempts to lower the vibration below the defined code absolute levels through modifications to the pump.

IV. The licensee should perform a spectral analysis of the pump-driver system to identify all contributors to the vibration levels.

The following is a discussion of how these four key components are addressed for this relief request.

I. Vibration History A. Testing Methods and Code Requirements Inconsistent and high vibration levels on the RHR pump motors has been a condition that has existed since original installation of these pumps in the 1970's. During preoperational testing in 1984, vibrations were measured in both displacement (mils) and velocity ips at three locations (horizontal in line with flowpath, horizontal perpendicular to flowpath, and axial) on each motor bearing and on the pump bearing. The vibration signals were recorded at multiple pumpflow velocities. The intention was to baseline the vibration data throughout the expected hydraulic use range and to see if hydraulic disturbances were responsible for the observed phenomena.

The data showed conclusively that the motor was vibrating with randomly distributed bursts of energy at the natural frequency of the system, in the range of 9-14 Hertz (Hz). Therefore, it was determined that the hydraulic disturbances found in the piping were the source of the energy.

The monitoring of multiple vibration points was not a requirement of Section XI of.the ASME Code until the adoption of the O&M Standards/Codes. The Fermi 2 first interval IST Program (which began in 1983) was committed to the 1980 Edition, winter 1981 Addenda of Section XI.

Paragraph IWP-4510 of this code required that "at least one displacement vibration amplitude shall be read during each inservice test." This code was in effect at Fermi 2 until the start of the second ten-year interval, which began in February 2000. The Fermi 2 second interval IST

Program was committed to the 1989 Edition of Section XI, which required multiple vibration points to be recorded during IST pump testing in accordance with the ASME/ANSI [Arberican National Standards Institute] Operations and Maintenance Standard, Part 6, 1987 Edition with the 1988 Addenda.

However, at Fermi 2, the first and second ten-year interval'IST Program Plans did include both vibration monitoring of multiple points and use of velocity measurement instead of displacement.

This was a conservative testing regime based on expectations that this level of vibration monitoring would be beneficial in terms of early identification of degradation. Because of this, readily available data exists for two vibration points on each RHR pump from July 1984 to the present and on three motor vibration points from October 1996 to the present. Various analyses of this data are included in the figures provided with this relief request.

B. Review of Vibration History Data RHR Pump IST vibration trend graphs (Figures 1-4 in this relief request), which include data from 2002 through the present, show essentially flat or slightly upward trends. These charts also show that vibration readings for all four pumps occasionally exceed the Code alert range criteria of 0.325 ips.

Differential pressure trend graphs (Figures 7-10) illustrate differential pressure data dating back to 1990 for all four RHR pumps. This data clearly shows no discernible evidence of hydraulic degradation. Average run hours for each RHR pump per cycle is approximately 300-400.

C. Review of "Spikes" in Vibration Data In reviewing the long term trend data for vibration, which includes the code-required frequency ranges (one-third pump running speed to 1000 Hz), random spikes were observed throughout the data that resulted in values above the alert range. Most of the vibration that is measured on the motor casing is due to excitation of the structural resonances of the motor/pump by turbulent flow. These structural resonances are poorly damped and can be easily excited. Many vertical pumps exhibit similar characteristics, and it is not necessarily problematic by itself. A problem occurs when a pump has a continuous forcing function whose frequency coincides with a resonance (i.e., running speed). The forcing function in this case is flow turbulence caused in large part by the 90 degree elbow in the piping just off the pump discharge. The flow through this area generates lateral broadband forces that excite the resonances in a non-continuous fashion.

This is why the amplitude swings so dramatically on the motor and to some degree on the pump casing. See Figure 5 for an example of a single point on RHR Pump C motor that clearly shows significant variation/spiking about a fairly constant mean. Figures 12-14 show frequency spectrum results for three recorded measurements of a single location (RHR Pump motor EA1) taken 1 minute apart. The total peak values which would be recorded for IST purposes were 0.308, 0.253 and 0.195 ips. The system goes from brief periods of excitation to brief periods of no excitation. The discharge riser is also moving side to side from the same forces.- Although the discharge piping configuration is less than optimum for this application, the design poses no threat to the long-term reliability of the pump, motor or the system piping.

As illustrated previously, there have been no significant degrading trends associated with vibration data for the past fifteen years. By analyzing this data using a moving average function (averaging of the last eight data points), the trernds are relatively steady, and without the spikes that the code-required data contains. This further supports the fact that the spikes in the original code data are due to the piping-induced, non-detrimental broadband vibration occurring in the one-third to one-half pump running speed range. These spikes may exceed Code alert criteria, which triggers the corrective action process and the need to increase the testing frequency.

These Code compliance actions are not appropriate or necessary because the true.nominal average of the particular vibration point may be anywhere from 40-60 percent below the individual spike value. The Code alert triggered response is not because of true degradation that warrants remedial action, but merely data fluctuation as illustrated on attached figures 12 through 14.

II. Consultation - Pump ManufacturerNibration Expert A. Expert Analysis of RHR Pump Vibration Issue Each RHR Pump motor is vertically mounted to the pump casing, with the piping entering/exiting the pump casing horizontally. Each 2000 horsepower motor is 8 feet (ft.) tall and 42 inches (in.)

in diameter, weighing approximately 14,000 pounds. The vendor describes the upper motor thrust bearing as having a minimum expected life of 5 years [operation]. With a conservative assumption,of 500 run hours per year and appropriate lubrication activities, these bearings should last over 80 years. The pump casing is mounted on a reinforced floor pad and is approximately 4 ft. high and 6 ft. in diameter. The 24-in. suction piping enters the room level with the pump centerline but elbows horizontally 45 degrees 10 ft. from the pump center and then another 45 degrees 6 ft. from the pump. The 20-in. discharge pipe leaves the pump on nearly the same plane as the suction pipe but then elbows vertically 90 degrees at6 ft. from the pump center. Six ft. up from this elbow is the pump discharge check valve and 3 ft. from the elbow is the 3-in. minimum flow piping connection (See Figures 15 and 16 showing the pump suction and discharge piping isometrics).

Figure 17 shows the vibration monitoring points on the RHR motor/pump assembly. Points Al, A2, A3, C1 and C2 are the specified locations for inservice testing data.

ASME OM Code 2004 Section ISTB-6400 states "If the reference value of a particular parameter being measured or determined can be significantly influenced by other related conditions, then these conditions shall be analyzed' and documented in the record of tests (see ISTB-9000)." The footnote to "analyzed," states "Vibration measurements of pumps may be foundation, driver, and piping dependent. Therefore, if initial readings are high and have no.

obvious relationship to the pump, then vibration measurements should be taken at the driver, at the foundation, and on the piping and analyzed to ensure that the reference vibration measurements are representative of the pump and that the measured vibration levels will not prevent the pump from fulfilling its function." This is exactly the case with the RHR pumps, where the flow noise significantly influences the vibration measurements of the pump,and motor. The data for RHR Pump C was extensively analyzed and documented in IST Evaluation 97-042 by the Fermi 2 Level 3 Vibration Expert. Additionally, Engineering Research Report 85D15-5, Rev. 1, dated 1984, had identified the same resonant peaks in the other three RHR pumps.

This analysis identified a resonant frequency between 9-14 Hz. An impact test was also conducted with the pumps not running which again confirmed the 9-14 Hz resonant frequencies.

on the pumps. This resonance frequency, either alone or incombination with the running speed peak, occasionally results in the overall.vibration amplitude exceeding the 0.325 ips Alert Range limit. Each structure has its own resonance frequency based on the. mass and stiffness of the system. Minor changes ineither of these two components will change the resonance frequency. A.difference inpiping and hanger design between the four RHR pumps isthe cause for slight differences inthe resonance frequency and therefore the vibration levels.' The reason that the vibration levels change from run to run isthat for a resonance frequency to "ring" it must be excited by some forcing function. Inthe RHR pumps this forcing function isflow noise, which causes a broadband forcing frequency that varies slightly during each run.

Ill. Attempts to Lower Vibration As stated earlier, Engineering Research Report 85D15-5, Rev. 1, dated 1984, had identified these frequencies. At that time several attempts were made to stiffen the pump structure.

These attempts only succeeded intransferring the energy to the piping. These supports were removed and the system returned to the previous configuration. When the upper motor bearing vibration data was added to the IST program and the data was found to be high, the shaft locking nut was checked along with the mounting bolts and hangers. No problems were identified. Additional vibration data was also collected and entered into a three-dimensional model (Figure 11) program. This program did not indicate any problems ineither the pump or motor. Analysis of a high-resolution vibration spectrum shows the structural resonance and running speed peaks. These analyses indicate that the running speed spectral peaks remained unchanged while the resonant peak can change with each run. With the resonant frequency being a significant contributor inexceeding the alert vibration range there is little that can be done to the pump or rotating assembly (such as balancing or alignment) that will reduce this resonant vibration peak.

IV. Spectral Analysis Spectral data indicates that the overall vibration levels (IST data) are primarily made up of the broad spectrum from 30 Hz up 100 Hz which undergoes random amplitudinal. increases as a function of flow noise excitation' Spectral data does not indicate any problem with bearings or the rotating elements such as imbalance or misalignment. Uncoupled runs of the motors have shown very low vibration levels compared to pump running conditions. The overall peak amplitude value recorded for IST can vary by as much as 0.150 - 0.200 ips on readings taken a few seconds apart (Figures 12, 13 and 14). These noise-induced oscillations are neither consistent inamplitude or duration.

Basis for Code Alternative Alert Values By this relief request Fermi 2 is proposing to increase the absolute alert limit for vibration from 0.325 ips to 0.415 ips for all four RHR pumps. The flow induced broadband vibration occasionally causes the overall vibration value for these points to exceed 0.325 ips, resulting in the pumps being placed on increased test frequency. Inlate 2005 a single reading on RHR pump A exceeded the Alert criteria. RHR pump Awas placed on increased frequency and planning began for motor replacement. The motor for RHR Pump A was replaced during Refueling Outage 12 as corrective action due to exceeding the vibration alert. Initial

. Z1i

examination of the replaced motor identified no evidence of degradation, and initial average vibration data for the new motor showed only a slight reduction compared to recent data on the old motor (Figure 6). This motor replacement was a high impact work item inthe last refueling outage, incurring significant cost and dose. Expert analyses and maintenance history reviews have shown that this flow-induced vibration has not resulted innoticeable degradation to the pump or motor. Additionally, the overall vibration levels, when dampened using the moving-average technique, have remained essentially steady or risen only slightly over the past 15 years. Therefore, it has been demonstrated that doubling the test frequency and initiating corrective actions such as motor replacement under the current conditions does not provide .

additional assurance as to the condition of the pump and its ability to perform its safety function.

These new alert criteria values are reasonable as they represent an alternative method that still meets the intended function of monitoring the pump for degradation over time while keeping the required action level unchanged. The proposed values encompass all of the historical spiking values, which would eliminate the unnecessary actions associated with exceeding the Code Alert limits due to spiking. However, the more accurate moving average value for these pumps would typically still be within the original Code alert value of 0.325 ips at a point where any spiking inthe data due to the high flow-induced broadband noise would exceed the requested 0.415 ips alert limit. Therefore, corrective actions triggered by exceeding the 0.415 ips alert value would be taken at a point commensurate with the intent of the Code guidance.

The Fermi 2 Vibration Specialist routinely performs a spectral analysis on all data recorded during RHR pump inservice testing per Fermi 2 procedure 47.000.02, "Mechanical Vibration Measurements for Trending". This analysis isin addition to the quantitative rendering of total vibration values recorded inthe IST test procedures. The routine spectral analysis provides additional confidence inour ability to detect degradation at an early stage.

Each RHR Pump motor isalso covered by various predictive maintenance program (PdM) activities. These include:

10 year detailed motor condition inspection/refurb PdM Thermography and analysis every 182 days Oil sampling and analysis every 92 days Annual motor PdM including phase to phase winding tests, insulation checks and exterior cleaning This maintenance and testing reginie inaddition to.trending of IST data provides for early identification and analysis of any degradation.

Conclusions Several expert evaluations have.documented that no internal pump or motor degradation is occurring due to the piping-induced,vibration, which has been present since the pre-operational testing time period. The available vibration data over the past fifteen years and differential pressure data over nearly the past eleven years supports this fact. A maintenance history review and a review of thermography and oil analyses results further support these conclusions.

2~'

Vibration data analysis clearly shows significant variations which are attributable to the external influence of the flow noise. These variations have frequently crossed the ASME Code Alert threshold of 0.325 ips and triggered unnecessary responses.

Based on this information,. Fermi 2 concludes that doubling the test frequency and initiating costly corrective actions for the RHR pump motors at the 0.325 ips Code alert limit does not provide additional information nor does it provide additional assurance as to the condition of the pumps and their ability to perform their safety function. Testing of these pumps on an increased frequency and performing the associated corrective actions places an unnecessary burden on Fermi 2 resources. Establishing an Alert limit of 0.415 ips provides for necessary margin above the normal and expected vibration levels encountered with these components to prevent exceeding the Alert limit due to the data fluctuations caused by the system flow induced hoise.

Figures 1 and 2 contained inFermi RAI response dated March 22, 2010, provides the following details about location of the vibration measurements:

EA1 - Radial 0 degree measurement on top portion of motor inline with upper bearing housing EA2 - Radial 90 degree measurement on top portion of motor inline with upper bearing housing EA3 -.Axial 0 degree measurement on top of motor upper end bell EC1 - Radial 0 degree measurement on top portion of pump casing EC2 - Radial 90 degree measurement on top portion of pump casing 3.1.2 NRC Staff Evaluation ISTB-6200(a), "Corrective Action - Alert Range," requires that if the measured test parameter (vibration) values fall within the alert range (>0.325 ips through 0.7 ips) of Table ISTB-5121-1, the frequency of testing specified in ISTB-3400 shall be doubled until the cause of the deviation isdetermined and the condition.is corrected.

The Code requires that when the overall pump vibration measurement inany one measured direction exceeds 0.325 ips, the pump shall be declared inthe alert range and the testing doubled until the cause of the deviation is determined and the condition iscorrected. Although a pump is considered operable while inthe alert'range, increased vibration at this level may be an indication of degradation which would warrant further investigation. However, if a particular pump has been determined to be ingood operating condition and has a historical record of vibration inspecific measured directions being measured inthe alert range, then it would be appropriate to adjust the alert level to take this into consideration. Requiring more frequent.

testing under these conditions isconsidered a hardship because the reason for the high vibration is understood and is known not to be indicative of pump degradation.

To accept pump vibration at a higher level than the Code-required alert range absolute limits, NUREG/CP-0152 recommends evaluating four key elements (1)vibration history to verify that pumps were operated at this level of vibration for a significant amount of time with justification of "spikes"intest data; (2) consulting with the pump manufacturer/vibration experts to verify that the vibration levels of the pumps are acceptable; (3) attempts to lower the vibration level through modifications to the pumps or the system and structures of the pumps; and (4) perform spectral analysis to identify all contributors to the vibration level. Under the relief request basis, the licensee provided all of this information, and its evaluation of all of these four key elements 2;

for the RHR pumps. Inaddition, the NRC staff found that the licensee has submitted sufficient vibration history to verify that the pumps have operated at this vibration level for a significant period of time with no adverse impacts on performance. Spike data have been justified by consultation with an independent pump expert. The licensee has described-attempts to reduce vibration and has demonstrated that the cause of the vibration appears to be dependent on the piping and support configuration rather than the condition of the pumps. Spectral analysis of the pump-driver system was performed to identify all contributors to.vibration levels. Based on the evaluation and the provided.historical pump vibration data, the NRC staff concluded that these are not indicative of degraded pump performance.

The licensee stated inits basis for the relief request that the four RHR pumps at Fermi 2 have a resonant frequency between 9-14 Hz that is excited by flow noise, which will occasionally result in increased vibration levels above the alert range. These conditions were identified during plant startup and attempts to stiffen the structures of the pumps did not significantly change the vibrations., The licensee's current analysis and assessments of these conditions determined that the vibrations were-not exhibiting any degrading trends and currentvibration levels were not damaging the pumps. From this evaluation, it was determined that the peak vibration levels occur at running speeds and the 9-14 Hz resonant point. Therefore, compliance with the Code requirements would be a hardship if an alternate testing acceptance criterion isnot allowed.

Each RHR pump motor isalso covered by various PdM activities. This maintenance and testing regime, inaddition to trending of inservice test data, provides for early.identification and analysis of any degradation.

The licensee has proposed to raise the vibration alert range. for all four RHR pumps (note that .

the RHR pumps are vertical centrifugal pumps, where the pump and driver form an integral unit and the pump bearings are inthe driver). The NRC staff reviewed the historical vibration information for the four RHR pumps and noted that the vibration parameters cited inthe relief request for RHR pumps A, B, C, and D do exceed the 0.325 ips alert limit. The analysis and evaluation that the licensee has performed provides reasonable assurance of operational readiness. Additionally, the proposed alternative alert limit of 0.415 ips is below the required action limit of 0.700 ips and the licensee has demonstrated that these pumps have a normal operational history at this vibration level with no-adverse consequences.

3.1.3 Conclusion Based on the above evaluation, the NRC staff concludes that the licensee's alternative to use vibration "Alert Range" acceptance criteria of greater than 0.415 ips to 0.700 ips in lieu of the ASME OM Code, Table ISTB-5121-1 requirements of greater than 0.325 ips to 0.700 ips for RHR pumps A, B, C and D, is authorized pursuant to 10 CFR 50.55a(a)(3)(ii). Compliance with the specified requirements would result ina hardship without a compensating increase inthe level of quality and safety. The proposed alternative'is authorized for the third 10-year IST interval at Fermi 2, which began on February 17, 2010 and ends on February 16, 2020.

3.2 RELIEF REQUEST PRR-005 3.2.1 Licensee's Relief Request and Proposed Alternative The applicable ASME OM Code edition and addenda for the third 10-year IST interval at Fermi 2 is the 2004 Edition.

ISTB-3300, "Reference Values," requires that initial vibration reference values be determined from the results of preservice testing or from the results of the first inservice test.

ISTB-5121(e), "Group A Test Procedure," and ISTB-5123(e), "Comprehensive Test Procedure,"

require that all deviations from the reference values shall be compared with the ranges of Table I8TB-5121-1, "Centrifugal Pump Test Acceptance Criteria."

ISTB-5221(e), "Group A Test Procedure," and ISTB-5223(e), "Comprehensive Test Procedure,"

require that all deviations from the reference values shall be compared with the ranges of Table ISTB-5221-1, "Vertical Line Shaft and Centrifugal Pumps Test Acceptance Criteria."

ISTB-5321(e), "Group A Test Procedure," and ISTB-5323(e), "Comprehensive Test Procedure,"

require that all deviations from the reference values shall be compared with the ranges of Table ISTB-5321-1, "Positive Displacement Pump (Except Reciprocating) Test Acceptance Criteria."

ISTB-6200 (a), "Corrective Action - Alert Range," states that ifthe measured test parameter values fall within the alert range of Table ISTB-5121-1, Table ISTB-5221-1, Table ISTB-5321-1, or Table ISTB-5321-2, as applicable, the frequency of testing specified in ISTB-3400 shall be doubled until the cause of the deviation is determined and the condition is corrected.

The licensee requested relief from the vibration testing requirements of Tables ISTB-5121-1, ISTB-5221-1, and ISTB-5321-1. Tables-ISTB 5121-1, ISTB-5221-1, and ISTB-5321-1 establish ranges of acceptability of reference values. Specifically, the tables require the use of 2.5 vibration reference value (Vr) and 6 V, in determining acceptable and alert ranges of vibration unless those calculated values exceed the absolute limits specified in the Tables.

The licensee states that in lieu of applying the vibration acceptance criteria ranges specified in Table ISTB-5121-1, Table. ISTB-5221 -1, or Table ISTB-5321-1, as applicable, smooth running pumps with a measured reference value below 0.04 ips for a particular vibration measure location will have subsequent test results for that location compared to an Acceptable Range limit of 0.100 ips and an Alert Range limit of 0.240 ips (based on a minimum reference value of 0.04 ips). These proposed ranges.shall be applied to vibration test results during both Group A and Comprehensive tests. All Group B pumps are also treated as Group A pumps for vibration measurements. Relief was requested for the following pumps listed in Table 2-1:

Table-2-1 Description Pump Pump Speed Pump No.

Type Group rpm El151C001A RHR Service Water Pump A VLSC A 1800 El 151CO001B RHR Service Water Pump B VLSC A 1800 E1151C001C RHR Service Water Pump C VLSC A 1800 El151C001D RHR Service Water Pump D VLSC A 1800 P4400C001A Emergency Equip Cooling Water Div. CENT B 1800 1 Pump P4400C001B Emergency Equip Cooling Water Div. CENT B 1800 2 Pump P4400C002A Emergency Equip Cooking Water CENT B 1800 Makeup Div 1 Pump P4400C002B Emergency Equip Cooling Water CENT B 1800 Makeup Div 2 Pump P4500C002A Emergency Equip Service Water VLSC B 1800 South Pump P4500C002B Emergency Pump Equip Service Water North VLSC B 1800 R3000C001 EDG 11 Diesel Fuel Oil Xfer Pump A PD B 1200 R3000C002 EDG 12 Diesel Fuel Oil Xfer Pump A PD B 1200 R3000C003 EDG 11 Diesel Fuel Oil Xfer Pump B PD B 1200 R3000C004 EDG 12 Diesel Fuel Oil Xfer Pump B PD B 1200 R3000C009 EDG 13 Diesel Fuel Oil Xfer Pump A PD B 1200 R3000C010 EDG 14 Diesel Fuel Oil Xfer Pump A PD B 1200 R3000C01 1 EDG 13 Diesel Fuel Oil Xfer Pump B PD B 1200 R3000C012 EDG 14 Diesel Fuel Oil Xfer Pump B PD B 1200 R3000C005 EDG 11 DG Service Water Pump VLSC B 1800

-. 13 -

R3000C006 EDG 12 DG Service Water Pump VLSC B 1800 R3000C007 EDG 13 DG Service Water Pump VLSC B 1800 R3000C008 EDG 14 DG Service Water Pump VLSC B 1800

• Pump Type codes inTable 2-1 above:

CENT Centrifugal Pump (except vertical line shaft centrifugal pump)

VLSC Vertical Line Shaft Centrifugal Pump PD Positive Displacement Pump (except reciprocating pumps)

The pumps listed inTable 2-1 have at least one V, that iscurrently less than or equal.to 0.04 ips. For very small reference values, hydraulic noise and instrumentation error can be a significant portion of the reading and therefore affect the repeatability of subseqUent measurements. Also, experience gathered from the PdM has shown that changes invibration levels inthe range of 0.04 ips are not typically indicative of degradation inthe pump or motor condition.

When new reference values are established per ISTB-3310, ISTB-3320 or ISTB-6200(c), the measured parameters will be evaluated for each location to determine if the provisions of this relief request remain applicable. If the measured V, isgreater than 0.04 ips, the requirements of ISTB-3300 will. be applied. Conversely, if a measured V, is less than or equal to 0.04 ips, a minimum value of 0.04 ips will be used for V, for the pumps included inthe list of pumps.

In addition to the requirements of ISTB, the pumps inthe ASME IST Program are included in the Fermi 2 PdM Program scope. The PdM Program currently employs predictive monitoring techniques such as vibration monitoring and analysis beyond that required by ISTB.

All data is collected currently utilizing an accurate data acquisition system, downloaded into the Vibration PdM Program software and then analyzed for vibration magnitude and discrete frequencies. Components exhibiting abnormal vibration trends would be subjected to more advanced diagnostics such as impact testing, thermography and detailed spectral analysis.

Additional parameters typically monitored and trended are bearing temperature and oil sampling and analysis.

If the measured parameters are outside the normal operating range or are determined by analysis to be trending toward an unacceptable degraded state, appropriate actions are taken that may include:

. increased monitoring to establish the rate of change,

- review of component specific information to identify a cause, or

- removal of the pump from service to perform maintenance.

The PdM Program coverage typically entails periodic inspections of seals, bearings and other wear-expectant components. Preventive maintenance intervals vary as a function of component risk importance, type of duty, and operating experience.

All of the pumps inthe IST Program will remain inthe PdM Program scope even if certain pumps have very low vibration readings and are considered to be smooth running pumps.

All of the listed pumps are in standby systems. These pumps are typically run only for testing or other short duration system operations. On average, these pumps will see less than 150 operating hours per year. The residual heat removal service water pumps are operated slightly more often, with an average of 500-600 annual run hours.

Pumps with a measured reference value at or below 0.04 ips for a specific vibration measurement location shall have subsequent test results.for that location compared to an acceptable range based on 0.04 ips. This will result in.a mihimum alert range'of greater than 0.100 ips and required action range of greater than 0.240 ips. In addition to the Code requirements, all pumps inthe IST Program are included inand will remain inthe PdM Program scope regafdless of their smooth running status.

All of the Table-2-1 pumps are treated as Group A pumps. Vibration is measured and evaluated on a quarterly basis. This exceeds the ASME Code requirements for Group B pumps.

3.2.2 NRC Staff Evaluation ISTB-3540(a) requires that for centrifugal pumps, vibration measurements of each pump be taken ina plane approximately perpendicular to the rotating shaft intwo orthogonal directions on each accessible pump-bearing housing. The measurement isalso required to be taken in the axial direction on each accessible pump thrust-bearing housing. For vertical line shaft pumps, ISTB-3540(b) requires vibration measurements be taken on the upper motor-bearing housing inthree orthogonal directions including the axial direction. ISTB-3540(c) requires that for reciprocating pumps, the location shall be on the bearing housing of the crankshaft, approximately perpendicular to both the crankshaft and the line of plunger travel. These measurements are required to be compared with the Code vibration acceptance criteria as specified inTable ISTB-5121-1, Table ISTB-5221-1, or ISTB-5321-1 as applicable, to determine if the measured values are acceptable.

Table ISTB 5121-1, Table ISTB-5221-1, or ISTB-5321-1 states that, if during an inservice test, a vibration measurement exceeds 2.5 times the previously established reference value V,, the pump is considered to be in.the alert range. The frequency of testing isthen doubled in .

accordance with paragraph ISTB-6200(a) until the cause of the deviation isdetermined, the condition is corrected, and the vibration level returns below the alert range. Pumps whose vibration is recorded to be greater than 6 times Vr are considered inthe required action range and must be declared inoperable until the cause of.the deviation has been determined and condition is corrected. The vibration reference values are required by paragraph ISTB-3300 to be determined when the pump isknown to be operating acceptably.

For pumps whose absolute magnitude of vibration isan order of magnitude below the absolute vibration limits inTable ISTB-5121-1, Table ISTB-5221-1, or ISTB-5321-1, a relatively small increase invibration magnitude may cause the pump to enter the alert or required action range.

These instances may be attributed to variation inflow, instrument accuracy, or other noise sources that would not be associated with degradation of the pump. Pumps that operate inthis region are typically referred to as "smooth-running." Based on a small acceptable range, a smooth running pump could be subjected to unnecessary testing and corrective action.

- The NRC has authorized a minimum vibration level of 0.05 ips for smooth running pumps, at several nuclear plants. There have been no reports to the NRC of any degradation issues that have gone undetected inpumps at these facilities. However, at one particular plant, the minimum NRC authorized reference value was 0.1 ips. A pump bearing at this plant experienced significant degradation even though the vibration was below the minimum reference value inthe approved alternative. This degradation was discovered during PdM program activities. After this issue was discovered, the NRC staff noted that only monitoring pump vibration at the approved minimum reference value for smooth running pumps, would not be sufficient to determine pump degradation.

The licensee's proposed alternative combines the minimum reference value Vr method with a commitment to monitor all the IST pumps with a PdM Program even if certain pumps have very low vibration readings and are considered to be smooth-running pumps. The licensee will assign a vibration reference value of 0.04 ips to any pump bearing vibration direction that, inthe-course of determining its reference value, has a measured value below 0.04 ips. Therefore, the acceptable range as defined inTable ISTB-5121-1, Table ISTB-5221-1, or ISTB-5321-1 will be less than or equal to 0.100 ips, the alert range will be greater than 0.100 to 0.240 ips, and the required action range will be greater than 0.240 ips.

The licensee's proposed alternative describes the PdM Program for all IST program pumps.

(Table 2-1) considered important to safe and reliable plant operation. The licensee states the Fermi 2 PdM Program goes beyond the IST requirements for pumps. The program includes bearing temperature trending, oil sampling and analysis, and thermographic analysis. The licensee states that if the measured parameters are outside the normal operating range or are determined by analysis to be trending towards an unacceptable degraded state, appropriate actions will be taken. These actions include increased monitoring to establish the rate of degradation, review of component-specific information to identify cause, and removal of the pump from service to perform maintenance. The proposed alternative is consistent with the objective of the IST which isto monitor degradation insafety-related components. The licensee states that all Group Bpumps as specified inTable 2-1 will have quarterly testing including vibration measurement, which is above and beyond the Code requirements.

As described above, the NRC staff finds that the alert and required action limits specified inthe alternative request sufficiently allows for detection of any pump problems, including degradation through specified PdM: The objective of the licensee's PdM Program is to detect problems involving the mechanical condition, even well inadvance of when the pump reaches its overall vibration alert limit. Therefore, the licensee's proposed alternative will provide an acceptable level of quality and safety.

3.2.3 Conclusion Based on a review of the information provided by the licensee, the NRC staff concludes that the licensee's proposed alternative provides adequate indication of pump performance and an

acceptable level of quality and safety. Therefore, the alternative to the vibration requirements of ISTB-3300, Table ISTB-5121-1, or Table ISTB=5221-1 or Table ISTB-5321-1, of the OM Code is authorized pursuant to 10 CFR 50.55a(a)(3)(i) based on the alternative providing an acceptable level of quality and safety. This relief request isauthorized for pumps shown inTable 2-1 for the third 10-year IST interval at Fermi 2, which began on February 17, 2010 and ends on February 16, 2010. -

3.3 RELIEF REQUEST PRR-007 3.3.1 Licensee's Relief Request and Proposed Alternative ISTB-3400, "Frequency of Inservice Tests," refers to Table ISTB-3400-1, "Inservice Test Frequency," which specifies that a comprehensive test be performed biennially for Group A and

.Group B pumps.

ISTB-5123, "Comprehensive Test Procedure," specifies the specific requirements for the comprehensive test for centrifugal pumps.

ISTB-5223, "Comprehensive Test Procedure," specifies the specific requirements for the comprehensive test for vertical line shaft pumps.

The licensee requested to use a modified quarterly Group A test for the IST in lieu of-a quarterly Group A or Group Btest (as applicable) and a biennial comprehensive test for the following pumps:

TABLE 3-1 Pump Description Current Classification E1102C002A RHR Pump A Group A E1102C002B RHR Pump B Group A E1102C002C RHR Pump C Group A E11020002D RHR Pump D Group A E1151C001A RHR Service Water Pump A Group A E1151C001B RHR Service Water Pump B Group A E1151C001C RHR Service Water Pump C Group A E1151 C001 D RHR Service Water Pump D Group A E4101C001 High Pressure Injection Pump Group B P4400CO01A Emergency Equip. Cooling Group B Water Div. 1 Pump P4400C001B Emergency Equip. Cooling Group B Water Div. 2 Pump P4500C002A Emergency Equip. Service Group B Water South Pump P4500C002B Emergency Equip. Service Group B Water North Pump R3001 C005 EDG 11 DG Service Water Group B Pump R3001C006 EDG 12 DG Service Water Group B

Pump R30010007 EDG 13 DG Service Water Group B Pump R30010008 EDG 14 DG Service Water Group B Pump T41000040 South CCHVAC Chilled Group A Water Pump T41000O41 North CCHVAC Chilled Water Group A Pump The licensee. proposes that inlieu of the requirements of ISTB-5123 and ISTB-5223, modified Group A tests will be"performed quarterly, with instrumentation meeting the instrument accuracy requirements of Table ISTB-3510-1 for the biennial comprehensive test, and the comprehensive test would not be performed. For the centrifugal pumps, the acceptable range for differential pressure would be. 0.90 to 1.06 of the reference value. For the vertical line shaft pumps, the acceptable range for differential pressure would be 0.95 to 1.06 of the reference value, and the .

alert range would be 0.93 to less than 0:95 of the reference value. The licensee is proposing this alternative for the pumps listed inTable 3-1. Pumps E41010001, P44000001A, P44000001 B, P45000002A, P45000002B, R3001 0005, R3001 C006, R3001 0007, and R3001C008 are currently classified as Group Bpumps and would be re-classified as Group A pumps.

All of the pumps inTable 3-1, except P45000O02A and B and R3001 0005, 6, 7, and 8, tested quarterly using this alternative would be tested within +/-20 percent of pump design accident flow rate, as is required for the biennial comprehensive test. Pumps P45000O02A and B and R3001 0005, 6, 7, and 8 will be tested within -+/- 20 percent of pump best efficiency point flow rate.

Pumps that would normally be categorized as Group,B pumps, but are re-categorized as Group A pumps, will be tested according to the provisions of this alternative. As a result of this re-.

categorization from Group B to Group A, per Table ISTB-3000-1, additional data must be obtained quarterly rather than once every two years on the test parameters of vibration for these pumps.

Use of this alternative provides for consistent acceptance criteria for pump differential pressure tests. The licensee would consistently utilize the modified Group A test acceptance criteria (discussed above) for pump IST rather than having to utilize the comprehensive test criterion for one. biennial test. The acceptance criteria for vibration tests would be the same as for Group A tests shown inTables ISTB-5121-1 and ISTB-5221-1.

3.3.2 NRC Staff Evaluation The licensee is proposing to re-classify the Group B pumps listed inTable 3-1 as Group A pumps, and perform IST for all the pumps listed inTable 3-1 in accordance with a modified Group A test procedure.

The ASME OM Code requires that for Group A pumps, a Group A test isperformed every .

quarter, and a comprehensive test isperformed biennially. The Group A test isperformed 31

within +/- 20 percent of the pump design flow rate (if practicable), the pressure instrument accuracy is +/- 2 percent, and the upper limit for the acceptable range for differential pressure is 110 percent of the reference value. The comprehensive test is performed within +/-20 percent of the pump design flow rate, the pressure instrument accuracy is +/- 1/2 percent, and the upper limit of the acceptable range for differential pressure is 103 percent of the reference value.

Vibration monitoring is performed during both the Group A test and a comprehensive test.

The ASME OM Code requires that for Group B pumps, a Group B test is performed every quarter, and a comprehensive test is performed biennially. The Group B.test is performed within +/-20 percent of the pump design flow rate (if practicable), the pressure instrument

'accuracy-is 2 percent, and the upper limit for the acceptable range for differential pressure is 110 percent of the reference value. The comprehensive test is performed within +/-20 percent of the pump design flow rate, the pressure instrument accuracy is +/-1/2percent, and the upper limit,of the acceptable range for differential pressure is 103 percent of the reference value:

Vibration monitoring is only performed during the comprehensive test.

The licensee proposes that for the pumps listed in Table 3-1 (all will-be classified as Group A pumps), a modified quarterly test be performed every quarter, and the biennial comprehensive test is not required. The modified Group A quarterly test would be performed within +/- 20 percent of the pump design accident flow rate for all of the pumps in Table 3-1 except P45000002A and B and R3001C005, 6, 7, and 8. Pumps P4500C002A and B and R30010005, 6, 7, and 8 will be tested within +/-20 percent of pump best efficiency point flow rate, which is acceptable because the pumps will be operating on a sloped portion of the pump curve where degradation. is more detectable. The more accurate pressure instrumentation that is required for a comprehensive test ( 1/2 percent versus +/-2 percent) will be used. This modified quarterly test would replace the comprehensive test. The acceptable range for differential pressure for the modified Group A quarterly test is tighter than the range for the Group A quarterly.test.

The licensee is proposing to perform a modified Group A.pump test every quarter and not perform a comprehensive test. The licensee will use a more limiting upper bound of 106 percent for the Acceptable Range for differential pressure in lieu of 110 percent that is required by the OM Code for Group A tests. This proposed upper bound of 106 percent is greater than the upper bound of 103 percent for the biennial comprehensive test. The, pumps that will be reclassified from Group B to Group A will now have vibration monitoring performed quarterly. The OM Code does not require vibration monitoring for Group B pump tests.. All of the pump tests will be performed with pressure instruments with +/- 1/2 percent accuracy. For the pumps that are currently classified as Group A, the elimination of the comprehensive test (with its more limiting Differential Pressure Acceptable Range upper bound of 103 percent)' is compensated for by using more accurate pressure gauges on every quarterly test. This will provide for better trending of pump performance. Instead of performing seven tests with pressure instruments with +/- 2 percent accuracy, and then performing the eighth test with pressure instruments with +/- 1/2 percent accuracy, all eight tests will be performed with the same +/- 1/2 percent accurate instruments. For the Group B pumps that will be re-classified as Group A pumps, the elimination of the comprehensive test is compensated for by using a tighter Acceptable Range for differential pressure on the quarterly tests, by using more accurate pressure instruments on every quarterly test, and by performing vibration monitoring on every quarterly test. This will provide for better trending of pump performance. Instead of performirg

seven tests with pressure instruments with +/-2 percent accuracy, with no vibration monitoring, and then performing the eighth test with pressure instruments with +/- 1/2 percent accuracy and vibration monitoring, all eight tests will be performed with pressure instruments with the same 1/2 percent accuracy, all eight tests will include vibration monitoring, and seven of the eight tests will have a tighter Acceptable Range for differential pressure. The proposed alternative would provide reasonable assurance of the operational readiness for the pumps listed in Table 3-1 3.3.3 Conclusion As set forth above, the NRC staff finds that the proposed alternative in Request PRR-007 provides reasonable assurance that pumps listed in Table 3-1 are operationally ready.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i), and is in compliance with the ASME OM Code's requirements. Therefore, the NRC staff authorizes the alternative in Request PRR-007 for the third 10-year inservice testing interval, which began on February 17, 2010 and ends on February 16, 2020.

3.4 RELIEF REQUEST PRR-010 3.4.1 Licensee's Relief Request and Proposed Alternative ISTB-3400, "Frequency of Inservice Tests," refers to Table ISTB-3400-1, "Inservice Test Frequency," which specifies that Group A and Group B tests be performed quarterly and a comprehensive test be performed biennially for Group A and Group B pumps.

ISTB-5322, "Group B Test Procedure," specifies the specific requirements for the Group B test for positive displacement pumps.

ISTB-5323, "Comprehensive Test Procedure," specifies the specific requirements for the comprehensive test for positive displacement pumps.

The licensee requested to use a modified quarterly Group A test for the IST in lieu of a quarterly Group B test and"a biennial comprehensive test for the following pumps:

TABLE 4-1 Pump Description Current Classification C4103C001 A Standby Liquid Control Group B SLC Pump A C4103C001B SLC Pump B Grou B R3000CO01 EDG 11 Diesel Fuel Oil Group B I Transfer (DGFOT) Pump A

R3000C002 EDG 12 DGFOT Pump A Group B R3000C003 EDG 11 DGFOT Pump B Group B R3000S004 EDG 12 DGFOT Pump B Group B 3000CO09 EDG 13 DGFOT Pump A Group B EDG11DGOTPump

R3000C010 EDG 14 DGFOT Pump A Group B R3000C011 EDG 13 DGFOT Pump B Group B R3000C012 EDG 14 DGFOT Pump B Group B Standby Liquid Control Pumps The licensee's Technical Specification (TS) 3.1.7.7 requires that each SLC pump shall be capable of delivering greater than 41.2 gallons rper minute at a discharge pressure greater than 1215 pounds per square inch gauge (psig) to be considered operable. The sodium pentaborate concentrations are controlled at levels which support the TS flow rate plus a 25 percent design margin. This 25 percent margin is referenced in both TS B.3.1.7 and Updated Final Safety Analysis Report section 4.5.2.4.3 and is therefore a required aspect of the Fermi 2 licensing basis.

The licensee proposes that in lieu of the requirements of ISTB-5322 and ISTB-5323, modified Group A tests will be performed quarterly with the pumps operating' at a reference discharge pressure of 1230 +/- '10 psig with the flow rate measured and compared to its reference value.

All instrumentation will meet the accuracy for comprehensive tests as listed in Table ISTB 3510-1 (an accuracy improvement from +/-2 percent to +/- 1/2 percent for pressure instrumentation): The acceptable range for flow rate would be 0.95 to .1.06 of the reference value, the alert range would be 0.93 to less than 0.95 of the reference value, and the required action range would be less than 0.93 of the reference value or greater than 1.06 of the reference value. The licensee will evaluate all ranges against the design conditions to ensure that all procedural limits bound 'the more-conservative of the design or ASME OM Code ranges.

The biennial comprehensive test would not be performed. The SLC pumps listed in Table 4-1 are currently classified as Group B pumps and would be re-classified as Group A pumps.

The pumps, normally categorized as Group B pumps but re-categorized as Group A pumps, will be tested according to the provisions of this alternative. As a result of this re-categorization from Group B to Group A, per Table ISTB-3000-1, additional data must be obtained quarterly rather than once every two years on the test parameters of vibration for these pumps. The acceptance criteria for vibration tests would be the same as for Group,A tests shown in Table ISTB-5321-2 for the Group A test. Corrective actions will be taken in accordance with ISTB-6200.

Use of this alternative provides for consistent acceptance criteria for pump tests. The licensee would consistently utilize the modified Group A test acceptance criteria (discussed above) for pump IST rather than having to utilize the comprehensive test criterion for one biennial test.

Diesel Fuel Oil Transfer Pumps The licensee proposes that in lieu of the requirements of ISTB-5322 and ISTB-5323, modified Group A tests will be performed quarterly with the pumps operating at reference discharge pressures of between 9.50 psig (pump R3000C010) and 9.93 psig (pump R3000C004) with the allowable discharge pressure variation for each pump at +/- 0.05 psig. Pump flow rate is then measured and compared to its reference value. All instrumentation will meet the accuracy for comprehensive tests as listed in Table ISTB-3510-1 (an accuracy improvement from +/-2 percent to +/- 1/2 percent for pressure instrumentation). The acceptable range for flow rate

-21 -

would be 0.95 to 1.06 of the reference value, the alert range would be 0.93 to less than 0.95 of the reference value, and the required action range would be less than 0.93 of the reference value or greater than 1.06 of the reference value. The licensee will evaluate all ranges against the design conditions to ensure that all procedural limits bound the more conservative of the design or ASME OM Code ranges; The biennial comprehensive test would not be performed.

The DGFOT pumps listed inTable 4-1 are currently classified as Group B pumps and would be re-classified as Group A pumps.

The pumps, normally categorized as Group B pumps but re-categorized as Group A pumps, will be tested according to the provisions of this alternative. As a result of this re-categorization from Group Bto Group A, per Table ISTB-3000-1, additional data must be obtained quarterly rather than once every two years on the test parameters of vibration for these pumps. The acceptance criteria'for vibration tests would be the same as for Group A tests shown in Table ISTB-5321-2 for the Group A test. Corrective actions will be taken inaccordance with ISTB-6200.

Use of this alternative provides for consistent acceptance criteria for pump tests. The licensee would consistently utilize the modified Group A test acceptance criteria (discussed above) for pump IST rather than having to utilize the comprehensive test criterion for one biennial test.

3.4.2 NRC Staff Evaluation The licensee is proposing to re-classify the Group B pumps listed inTable 4-1 as Group A pumps, and perform IST for all the pumps listed inTable 4-1 inaccordance with a modified Group A test procedure.

The ASME OM Code requires that for Group B pumps, a Group B test is performed every quarter, and a comprehensive test is performed biennially. The Group Btest isperformed within +/-20 percent of the pump design flow rate (if practicable), the pressure and flow instrument accuracy is +/-2 percent, and the upper limit for the acceptable range for flow is 110 percent of the reference value. The comprehensive test is performed within t 20 percent of the pump design flow rate, the pressure instrument accuracy is 1/2 percent, and the upper limit of the acceptable range for flow is 103 percent of the reference value.. Vibration monitoring isonly performed during the comprehensive test.

The licensee proposes that for the pumps listed inTable 4-1 (all will be classified as Group A pumps), a modified quarterly test be performed every quarter, and the biennial. comprehensive test is not required. The modified Group A quarterly test would be performed within t 20 percent of the pump design flow rate, using the more accurate-pressure instrumentation that is required for a comprehensive test (+/- 1/2 percent versus - 2 percent). This modified quarterly test would replace the comprehensive test. The acceptable range for flow rate for the modified Group A quarterly test istighter than the range for the Group A quarterly test.

The licensee is proposing to perform a modified Group A pump test every quarter and not perform a comprehensive test. The licensee will use a more limiting upper bound of 106 percent for the Acceptable Range for flow rate inlieu of 110 percent that isrequired by the OM Code for Group A tests. This proposed upper bound of 106 percent isgreater than the upper bound of 103 percent for the biennial comprehensive test. The licensee will evaluate all

__35

-22 -

ranges against the design conditions to ensure that all procedural limits bound the more conservative of the design or ASME OM Code ranges. The pumps that will be reclassified from Group B to Group A will now have vibration monitoring performed quarterly. The OM Code does not require vibration monitoring for Group B pump tests. All of the pump tests will be performed with pressure gauges with +/- 1/2 percent accuracy. The elimination of the comprehensive test is compensated for by using a tighter Acceptable Range on the quarterly tests, by using more accurate pressure gauges on every quarterly test, and by performing vibration monitoring on every quarterly test. This will provide for better trending of pump performance. Instead of performing seven tests with pressure gauges with +/- 2 percent accuracy, with no vibration monitoring, and then performing the eighth test with pressure gauges with +/- 1/2 percent accuracy and vibration monitoring, all eight tests will be performed with pressure gauges with the same +/- 1/2 percent'accuracy, all eight tests will include vibration monitoring, and seven of the eight tests will have a tighter Acceptable Range for flow rate. The proposed alternative would provide reasonable assurance of the operational readiness of the pumps listed in Section 3.1.

3.4.3 Conclusion As set forth above, the NRC staff finds that the proposed alternative in Request,PRR-010 provides reasonable assurance that pumps. listed in Table 4-1 are operationally ready.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i), and is in compliance.with the ASME OM Code's requirements. Therefore, the NRC staff authorizes the alternative'in Request PRR-010 for the third 10-year Inservice testing interval, which began-on-February 17, 2010 and ends on February 16, 2020.

4.0 CONCLUSION

As-set forth above, the NRC staff determines that proposed alternative PRR-004 provides reasonable assurance that the pumps are operationally ready, and proposed alternatives PRR-005, PRR-007, and PRR-010 provide an acceptable level of quality and safety. The NRC staff authorizes proposed alternatives PRR-004, PRR-005, PRR-007, and PRR-010 for the Fermi 2 third 10-year inservice testing interval, which began on February 17,, 2010 and ends on February 16, 2020. All. other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable.

Principal Contributors Gurjendra Bedi - PRR-004, PRR-005 Robert Wolfgang - PRR-007, PRR-010 Dated: July 6, 2010 c l

J. Davis All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable.

Sincerely, IRA/ Peter Tam for Robert J. Pascarelli, Branch Chief Plant Licensing Branch Ill-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341.

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ DISTRIBUTION:

PUBLIC LPL3-1 R/F RidsRgn3MailCenter Resource RidsAcrsAcnw_MaiICTR Resource RidsNrrDorlDpr Resource RidsNrrDirsltsb Resource RidsNrrPMFermi2 Resource RidsNrrDorlLpl3-1 Resource RidsOgcRp Resource RidsNrrLABTully Resource RWolfgang, NRR GBedi, NRR Accession Number: ML101670372 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA DCI/CPTB/BC NRR/LPL3-1/BC NAM MChawla BTully AMcMurtray RPascarelli /PTam for DATE 07/02/10 07/01/10 07/02/10 07/06/10 OFFICIAL RECORD COPY 31

C

p RECog . UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 5, 2010 Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - RELIEF REQUEST NO. PRR-09, RELIEF FROM FIXED REFERENCE VALUE TESTING FOR THE THIRD 10-YEAR INSERVICE TESTING PROGRAM INTERVAL (TAC NO. ME2555)

Dear Mr. Davis:

By letter dated November 3, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093140302), as supplemented by letters dated February 19 and August 20, 2010 (ADAMS Accession Nos. ML100540147 and ML102320577, respectively),

Detroit Edison Company (DECo, the licensee) submitted 11 requests for relief from certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Fermi, Unit 2 (Fermi-2) for the third 10-year inservice testing (IST) program interval. The Fermi-2 third 10-year IST program interval began on February 17, 2010, and ends on February 16, 2020.

This letter and the enclosed safety evaluation (SE) address Relief Request No. PRR-009 for relief from fixed reference value testing for the third 10-year IST program interval. Specifically, pursuant to paragraph 50.55a(a)(3)(i) of Title 10 of the Code of Federal Regulations (10 CFR),

the licensee requested to use the proposed alternative described in PRR-009, on the basis that the alternative provides an acceptable level of quality and safety.

The NRC staff has reviewed the subject request and determined that the proposed alternative provides reasonable assurance that the Residual Heat Removal Service Water, Emergency Equipment Cooling Water Makeup, and Control Center Heating, Ventilation, and Air Conditioning chilled water pumps are operationally ready. Accordingly, the staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth.in 10 CFR 50.55a(3)(ii), and is in compliance with the ASME OM Code's requirements. Therefore, the NRC staff authorizes PRR-09 for the remainder of the third 10-year IST program interval at Fermi-2.

All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request remain applicable.

J. Davis If you have any questions, please contact the Project Manager, Mahesh Chawla, at (301) 415-8371.

Sincerely, Robert J. Pascarelli, Chief Plant Licensing Branch Il1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ 1+0

AUNITED RE a STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST NO. PRR-009 FOR FIXED REFERENCE VALUE TESTING THIRD 10-YEAR INSERVICE TESTING PROGRAM INTERVAL DETROIT EDISON COMPANY FERMI, UNIT 2 DOCKET NO. 50-341

1.0 INTRODUCTION

By letter dated November 3, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093140302), Detroit Edison Company (DECo, the licensee) submitted 11. requests for relief from certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Fermi, Unit 2 (Fermi-2) for the third 10-year inservice testing (IST) program interval. The Fermi-2 third 10-year IST program interval began on February 17, 2010, and ends on February 16, 2020. This safety evaluation (SE) addresses Relief Request No. PRR-009 (PRR-09) for fixed reference value testing.-

In its submittal, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i), the licensee requested Nuclear Regulatory Commission (NRC) approval to use the proposed alternative described in PRR-009, on the basis that the alternative provides an acceptable level of quality and safety. Specifically, the licensee requested approval to use an instrument inaccuracy band for measuring certain Residual.Heat Removal Service Water (RHRSW), Emergency Equipment Cooling Water (EECW) Makeup, and Control Center Heating, Ventilation, and Air Conditioning (CCHVAC) chilled water pump flow rates in lieu of using set reference values required by the ASME OM Code. By an e-mail dated January 7, 2010 (ADAMS Accession No. ML101760333), the NRC staff requested the licensee to submit additional information to support request PRR-009, and by letter dated February 19,-2010 (ADAMS Accession No. ML100540147), the licensee submitted this additional information.

During a conference call on July 27, 2010, the NRC staff requested additional clarification from the licensee, which the licensee provided by letter dated August 20, 2010 (ADAMS Accession No. ML102320577).

2.0 REGULATORY EVALUATION

The regulations in 10 CFR 50.55a(f), "Inservice testing requirements," require, in part, that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year) program intervals in accordance with the specified ASME Code and applicable Enclosure

addenda incorporated by reference inthe regulations. Exceptions are allowed where alternatives have been authorized or relief has been requested by the licensee and granted by the NRC pursuant to paragraphs (a)(3)(i), (a)(3)(ii); or(f)(6)(i) of 10 CFR 50.55a. Inproposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety (10 CFR 50.55a(a)(3)(i));

(2) compliance would result inhardship or unusual difficulty without a compensating increase in the level of quality and safety (10 CFR 50.55a(a)(3)(ii)); or (3)conformance is impractical for the facility (10 CFR 50.55a(f)(6)(i)). Section 50.55a allows the NRC to authorize alternatives and to grant relief from ASME OM Code requirements upon making necessary findings.

In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month IST program interval. The regulations in 10 CFR 50.55a(f)(4)(iv), state that IST of pumps and valves may meet the requirements set forth insubsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met. The guidance contained in NRC Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," dated April 3, 1989, provides alternatives to ASME Code requirements which are acceptable. Further guidance isgiven in NRC GL 89-04, Supplement 1, dated April 4, 1995, and NUREG-1482; Revision 1, "Guidelines for Inservice Testing at Nuclear Power Plants," dated January 2005. ASME OM Code cases that are approved for use by the NRC are listed inNRC Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," dated June 2003. The Code of record for the Fermi-2 third 10-year IST program interval is the ASME OM Code, 2004 Edition and No Addenda, as required by 10 CFR 50.55a(f)(4)(ii).

The NRC's findings with respect to approving alternatives associated with Fermi-2 relief request PRR-009 are given below

3.0 TECHNICAL EVALUATION

3.1 Alternative Request PRR-009 The requirements inISTB-5121(b), ISTB-5123(b), ISTB-5221(b) and ISTB-5223(b) of the ASME OM Code state that, The resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined ard compared to its reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value.

The ASME OM Code requires that for subsequent IST, after the establishment of reference values, the flow rate or differential pressure (DP) shall be set to the exact reference value. The Code does not acknowledge the possibility that there may be limitations inthe ability to set to an 4Z7

exact reference value. This issue is discussed in NUREG-1482, Revision 1, Section 5.3, "Allowable Variance from Reference Points and Fixed-Resistance Systems."

The licensee has evaluated the ability'to test the pumps in the IST program and determined that several cases exist where compliance with the ASME OM Code and NUREG-1482, Revision 1 recommendations cannot be achieved. .The characteristics of the affected piping system designs do not allow flow to be adjusted to an exact value.

The licensee noted that the RHRSW pumps are tested at a flow rate of 5,400 gallons per minute (gpm) and are throttled to reference flow using a 24-inch motor-operated globe valve (MOV).

These globe valves are in high-radiation areas which preclude manual operation. Experience with throttling these valves has shown that the most rapid operation of the MOV controls yields changes in flow rate from 30-60 gpm.. The ECCW Makeup pumps are tested at a flow rate of 15 gpm and are throttled to reference flow using 1-inch manual globe valves. These globe valves provide some throttling capability but small changes in valve position result in relatively significant changes in flow. Finally, the CCHVAC chilled water pumps are tested at a flow rate of 233 gpm and are throttled to reference flow using a 4-inch manual gate valve. Because gate valves are not designed for throttling purposes, a flow tolerance of +3 gpm, or 1.3 percent, has been determined by the licensee to be the best achievable. The licensee has also stated that precision flow measurement instruments cannot be used in these tests due to accessibility issues.

In PRR-009, the licensee proposed an alternative to perform the quarterly Group A pump testing for the centrifugal pumps listed in Table 1, using the following "set parameter" reference value bands:

- For RHRSW pumps, a total tolerance inclusive of instrument inaccuracy of 12:78 percent

• For EECW Makeup pumps, a total tolerance inclusive of instrument inaccuracy of

+3.0 percent

- For CCHVAC chilled water pumps, a total tolerance inclusive of instrument inaccuracy of +3.5 percent Table 1 Code Pump Description Class OM Group E1151C001A RHRSW PumpA 3 A E1151CO001B RHRSW Pump B 3 A E1151C001C RHRSW Pump C 3 A E1151C001D RHRSW Pump D 3 A P4400C002A EECW Makeup Pump A 3 . B*

P4400C002B EECW Makeup Pump B 3 B*

T4100C040 South CCHVAC Chilled Water Pump 3 A T4100C041 North CCHVAC Chilled Water Pump 3 A

• Per alternative request PRR-007, these pumps are to be reclassified and tested as Group A purmps.

43

Additionally, for the CCHVAC chilled water pumps, the licensee will utilize a more conservative DP acceptance criteria range of -8.0 percent to 6 percent for the quarterly Group A test in lieu of the +10 percent required by the ASME OM Code.  ;

On January 7, 2010, the NRC staff requested that the.licensee provide justification for the tolerance of the reference value bands being greater than +2.0 percent.fdreach group of pumps listed in.Table 1. In its letter dated February 19, 2010, the licensee stated that the additional tolerance would still allow for pump performance to be accurately monitored. The larger flow test band results in increased scatter in the DP data.

The licensee routinely uses a flow normalization method to analyze short-term trerds in purnp performance. In its letter dated February 19, 2010, the licensee provided the following excerpts from the Fermi=2 IST Program Technical Position; TP-12, which describes this method DATA NORMALIZATION:

For pump testing where areference band is allowed, there will be some scatter associated with the measured variable data. This guidance will allow the evaluator to normalize the variable data in.order to properly assess trends.. An example is a centrifugal pump where flow is set to an established reference value but.allowance is given within the procedure for test flow to be plus or minus a.

given range around the reference value. Discharge and suction pressures are then measured at some measured flow value within the allowed test flow range.

The evaluator-needs to establish a known linear pressure-flow relationship, either from baseline data or from an assessment of a large quantity of pressure to flow.

data accumulated over several years. Using MS Excel, this linear relationship will need to be expressed as a table with at least 4 rows of data relating pressure to flow. One set.of.values will be at or below the minimum end of the allowable test flow band, another set at or above the maximum end and the remaining data at or very close to the middle (reference flow). The evaluator shall then use the Excel Forecast function to input an actual measured test flow and derive what the DP should be. The numerical difference between the derived DP and the DP at the center of the flow range shall then be subtracted from or added to (as applicable) the actual measured DP for that test flow. This should done for all .

measured data to be used in the trend analysis.

Following this excerpt, the licensee continued in the supplement by stating:

DP analysis performed in-this manner is accurate regardless of the degree of scatter caused by variation in test flow. In addition, long term pump performance analysis is done using a moving average technique that eliminates the effects of scatter in DP data. The [recorded flow values for the RHRSW pumps .

demonstrate] that there is no discernible bias in the historic flow variance for these pumps. The number and amplitude of points with test flow,below reference flow is roughly equal to those above reference flow. Averaging of the DP within the data scatter produces an accurate plot for pump performance.

qq I

On July 27, 2010, during a conference call with the licensee, the NRC staff requested the licensee to submit additional information to support request PRR-009. Specifically, the NRC staff requested additional clarification of the operating margin for the pumps affected by the request, and an explanation of how the data normalization technique will be used by the licensee. By letter dated August 20, 2010, the licensee submitted this additional information.

The licensee stated that Table 2 (provided below) shows the available margin between the average of the last three test values and the IST Required Action Low criteria, except for RHRSW Pump C. Because this pump has been recently replaced, the available margin is based on the average of only two available test values.

Table 2

.. Pumnp _______ ;Desariptio__________Margm ,

E1151C001A RHRSW Pump A 8.43% -

E1151C001B RHRSW Pump B 7.89%

E1151C001C RHRSW Pump C 8.29%

El151C001D RHRSW Pump D 6.09%

P4400C002A EECW Makeup Pump A 4.23%

P4400C002B EECW Makeup Pump B 5.00%

T4100C040 South CCHVAC Chilled Water Pump 8.41%

T4100C041 North CCHVAC Chilled Water Pump 8.3%

For all pumps listed in Table 2, the initial acceptance criteria for minimum and maximum DP are calculated per ASME 2004 OM Code, Section ISTB, as a function of the existing single-point reference DP values. The criteria are then conservatively truncated. A pump is declared inoperable if any test falls outside the minimum and the minimum and maximum DP acceptance criteria, which are contained in the pump surveillance test procedures.

The IST program manager uses the data normalization technique for long-term and short-term trend analysis. Data normalization is completed separately from surveillance testing, after testing is performed.

3.2 NRC Staff Evaluation As stated above, Section ISTB of the ASME OM Code does not allow for variance from a fixed reference value for pump testing. However, NUREG-1482, Revision 1, Section 5.3, acknowledges that certain pump system designs do.not allow for the licensee to set the flow at an exact value because of limitations in the instruments and controls for maintaining steady flow. The licensee has presented a case that each of the pumps listed in Table 1 falls into this category.

NUREG-1482, Revision 1, Section 5.3 states that "[t]he allowed tolerance for setting the fixed parameter must be established for each case individually, including the accuracy of the instrument and the precision of its display." It also states that for a flow measurement, a total tolerance of +2 percent of the reference value is allowed without prior NRC approval. This Lf5

agrees with Table ISTB-3510-1, which states that the required instrument accuracy for flow rate is +2 percent. NUREG-1482, Revision 1 also states that "[f]or a tolerance greater than the allowed percent (which may be necessary depending on the precision of the instrument), the licensee may make a corresponding adjustment to acceptance criteria to compensate for the uncertainty, or may perform and document an evaluation to justify a greater tolerance."

The RHRSW pumps are throttled to reference flow using a 24-inch motor-operated globe valve (MOV). These globe valves are in high radiation areas which preclude manual operation. 'The most rapid operation of the MOV controls yields changes in flow rate from 30-60 gpm. Based on this information and the analysis of previous pump tests, an optimum flow tolerance of

+/-100 gpm or 1.85 percent is achievable. Combining this tolerance with an instrument accuracy tolerance of 0.8 percent and rounding up for readability yields a reference value tolerance of 2.78 percent. Also, per NRC-authorized request PRR-007 dated July 6, 2010 (ADAMS Accession No. ML101670372), the Acceptable Range for the Group A tests for these pumps will be 0.95 to 1.060Pr. The Required Action High will be >1.06APr.

The EECW Makeup pumps, per the NRC-authorized request PRR-007, will be reclassified and tested as Group A pumps. The pumps are throttled to reference flow using 1-inch manual globe valves. The valves provide some throttling capability, but small changes in valve position result in relatively significant changes in flow. Experience with throttling these globe valves shows that the optimum flow tolerance achievable is +/-0.3 gpm or 2.0 percent of the reference value.

Combining this tolerance with the stated instrument accuracy tolerance of 0.8 percent and rounding up for readability yields a reference value tolerance of 3.0 percent. Also, per NRC-authorized request PRR-007, the Acceptable Range for the Group A tests for these pumps will be 0.90 to 1.06APr. The Required Action High will be >1.06APr.

The NRC staff concludes that this slight increase in reference value tolerance from +/-2 to

+/-2.78 percent for the RHRSW pumps and from +/-2 to +/-3 percent for the EECW Makeup pumps is acceptable for the following reasons. The intent of this ASME OM Code testing is to assess the hydraulic and mechanical condition of a pump and monitor for degradation. The licensee continues to perform ASME OM Code Group A pump tests using the reference point acceptance criteria given in ASME OM Code, 2004 Edition, Tables ISTB-5121-1 and ISTB-5221-1. The larger flow tolerance will yield increased scatter in the differential pressure data. However, the licensee performs analysis of the-results using a data normalization methodology to minimize the effect of the scatter in assessing pump degradation. In addition, any small increases in undetected degradation will not affect pump operability as the RHRSW pumps are tested at a 6.09 to 8.43 percent margin above the IST Required Action Low criteria and the EECW pumps are tested at a 4;23 to 5.0 percent margin above the IST Required Action Low criteria. Furthermore,, the licensee has observed that the RHRSW pumps degrade uniformly over a 12- to 15-year period, and the EECW Makeup pumps show no hydraulic degradation, which gives adequate time to detect and correct degrading trends in performance.

The CCHVAC chilled water pumps are throttled to reference flow using a 4-inch'manual gate valve. Because gate valves are hot designed for throttling purposes, a flow tolerance of +/-3 gpm or 1.3 percent is the best achievable flow tolerance. Also, precision flow measurement instruments cannot be used in these tests due to accessibility issues. The installed analog instrumentation used for testing these pumps has an accuracy of 2.0 percent. Combining this

tolerance with the flow tolerance of 1.3 percent and rounding up for readability yields a

-reference value tolerance of 3.5 percent. Because of the increased reference value tolerance, the licensee has proposed a corresponding adjustment to the acceptance criteria to compensate for the uncertainty as presented in NUREG-1482, Revision 1, Section 5.3.

Specifically, the allowable DP acceptance range will be reduced for Group A tests from the ASME OM Code Table ISTB-5121-1 required range of 0.90 to 1.10APr to 0.92 to 1.06APr (NRC-authorized request PRR-007 changed the upper end of the Acceptable Range from 1.10APr to 1.06APr). The Required Action Low will be <0.92APr and the Required Action High will be >1.06APr.

The NRC staff concludes that this increase inreference value tolerance from +2 to +/-3.5 percent for the CCHVAC chilled water pumps with a corresponding adjustment to the acceptance criteria, as stated, acceptable for the following reasons. As stated by the licensee, the 2 percent change inthe minimum DP acceptance criteria would increase the test criteria DP by 0.5 pounds per square inch differential (psid), based on a reference value of 24.55 psid. The 3.5 percent test flow tolerance is equivalent to 8 gpm (233 gpm x 0.035 = 8 gpm). Inthe range of the test flow on the pump curves, the relationship between flow and discharge pressure is approximately 2.2 pounds per square inch (psi) per 40 gpm. Therefore, an 8-gpm flow uncertainty yields a 0.44 psi DP uncertainty. Increasing the minimum DP acceptance criteria by 2 percent (or 0.5 psid) is greater than the 0.44 psid expected uncertainty and is,therefore, conservative. In addition, any small increases inundetected degradation will not affect pump operability since the pumps are tested at an 8.3-8.41 percent margin above the IST Required Action Low criteria.

The licensee also stated that the data normalization technique is used by the IST program manager for long term and short term trend analysis. Data normalization is completed separately from surveillance testing, after testing iscomplete. For all pumps listed inTable 1, the initial acceptance criteria for minimum and maximum DP are calculated per ISTB, as a function of the existing single point reference DP values. The criteria are then conservatively truncated. A pump is declared inoperable if any test falls outside the minimum and the minimum and maximum DP acceptance criteria, which are contained inthe pump surveillance test procedures..

Based on the above information, the NRC staff concludes that requiring the licensee to perform Group A tests for the pumps listed inTable 1, at a flow rate reference point, as required by the OM Code, and within +/-2 percent of the test flow tolerance would cause hardship or unusual difficulty without a compensating increase inthe level of quality and safety: The inability to perform the testing, as required, isdue to the poor throttling capabilities of the valves inthe discharge lines of the pumps. The licensee's ability to accurately trend performance of these pumps using flow reference value bands, inlieu of fixed reference points, and flow normalization methodology, despite increased data scatter during testing, due to higher.flow tolerance bands around the flow rate reference points, is an acceptable alternative to the ASME OM Code requirements. This alternative provides reasonable assurance that the pumps listed inTable 1 are operationally ready.

LA1

-8

4.0 CONCLUSION

As set forth above, the NRC staff determines, that the proposed alternative as specified in request PRR-009 provides reasonable assurance that the RHRSW, EECW Makeup and CCHVAC chilled water pumps listed in,Table 1 are operationally ready. Accordingly, the staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(3)(ii), and is incompliance with the ASME OM Code's requirements.

Therefore, the NRC staff authorizes the alternative noted above, at Fermi 2, for the remainder of the third 10-year IST program interval, which began on February 17, 2010, and ends on February 16, 2020.

All other ASME OM Code requirements for which relief was not specifically requested and.

approved inthe subject request remain applicable.

Principal Contributors: Russell Lake Robert Wolfgang Date: October 5, 2010

ML102720160 *SE memo (ML102660232 & ML102660240) dated OFFICE DORL/LPL4/PM DORU/LPL3-1/PM DORUILPL3-1/LA DCI/CPTB/BC DORUJLPL3-1/1BC NAME LGibson MChawla BTully (JBurkhardt for) AMcMurtray* RPascarelli DATE 09/29/10 09/30/10 09/29/10 09/21/10 10/05/10 rJ ll,

'v s

RREG UNITED STATES NUCLEAR REGULATORY COMMISSION

$ n WASHINGTON, D.C. 20555-0001

. September 28, 2010 Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - EVALUATION OF IN-SERVICE TESTING PROGRAM RELIEF REQUESTS VRR-011, VRR-012, AND VRR-013 (TAC NO. ME2558, ME2557, AND ME2556)

Dear Mr. Davis:

By letter dated November 3, 2009, as supplemented by letter dated May 19, 2010, Detroit Edison Company, the licensee for Fermi 2, submitted eleven requests for the third 10-year inservice testing (IST) program interval. This safety evaluation addresses three of eleven requests, VRR-011, VRR-012, and VRR-013. The licensee requested proposed alternatives from certain IST requirements of the 2004 Edition of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code).

The Detroit Edison Company third 10-year IST interval for Fermi 2 commenced on February 17, 2010.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a(a)(3)(i), the licensee requested to use proposed alternative in VRR-011 on the basis that the alternative provides an acceptable level of quality and safety. Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee requested to use proposed alternatives in VRR-012 and VRR-013 since complying with the current ASME OM Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality.and safety.

The NRC staff finds that the proposed alternative in request VRR-011 provides an acceptable level of quality and safety. The NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i), and is in compliance with the ASME OM Code requirements. All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.

The NRC staff finds that the proposed alternatives in requests VRR-012 and VRR-013, provide reasonable assurance that the 32 solenoid operated valves'noted in paragraph 3.2.2 and the 15 pressure isolation valves noted in paragraph 3.3.2 are operationally ready. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request for relief remain applicable. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the ASME OM Code requirements.

c.9

Jack M. Davis Therefore, the NRC staff authorizes the alternatives in requests VRR-011, VRR-012, and VRR-013 for the remainder of the Detroit Edison Company third 10-year IST interval for Fermi 2 which commenced on February 17, 2010. The NRC staff review and evaluation iscontained in the enclosed safety evaluation.

Sincerely, 6

Robert J. Pascarelli, Branch Chief Plant Licensing Branch IlIl-1 Y Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ

GR REG& UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ALTERNATIVE REQUEST NOS. VRR-011, VRR-012, AND VRR-013 RELATED TO THE INSERVICE TESTING PROGRAM, THIRD 10-YEAR INTERVAL DETROIT EDISON COMPANY FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION

By letter dated November 3, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093140302), as supplemented by letter dated May 19, 2010 (ADAMS Accession No. ML101400550), Detroit Edison Company (the licensee), submitted eleven requests for the third 10-year inservice testing (IST) program interval. This safety evaluation addresses three of eleven requests, VRR-011, VRR-012, and VRR-013. The licensee requested proposed alternatives from certain IST requirements of the 2004 Edition of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code). The Detroit Edison Company third 10-year IST interval for Fermi 2 commenced on February 17, 2010.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a(a)(3)(i), the licensee requested to use proposed alternative in VRR-011 on the basis that the alternative provides an acceptable level of quality and safety.

Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee requested to use proposed alternatives in VRR-012 and VRR-013 since complying with the current ASME OM Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

In an e-mail dated March 3, 2010 (ADAMS Accession No. ML100630051), the U.S. Nuclear Regulatory Commission (NRC) requested additional information for Relief Request VRR-012.

The licensee provided the additional information response in letter dated May 19, 2010.

2.0 REGULATORY EVALUATION

Pursuant to 10 CFR 50.55a(f), "Inservice Testing Requirements," requires, in part, that ASME Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii).

In proposing alternatives, a licensee must demonstrate that the proposed alternatives provide an acceptable level of quality and safety, or compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Section 50.55a allows the NRC to authorize alternatives to ASME OM Code requirements upon making necessary findings. NRC guidance contained in NUREG-1482 Revision 1, "Guidance for Inservice Testing at Nuclear Power Plants," provides alternatives to ASME Code requirements which are acceptable.

The NRC's findings with respect to authorizing the alternative to the ASME OM Code are given below.

3.0 TECHNICAL EVALUATION

3.1 Request VR-011 3.1.1 ASME OM Code requirements:

ISTC-3522(c) (Category C Check Valves) states that if exercising is not practicable during operation at power and cold shutdowns, it shall be performed during refueling outages.

ISTC-3700 (Position Verification Testing) states that valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated.

3.1.2 Licensee's Basis For Requesting Alternative Testing Alternative testing was requested for the following 93 excess flow check valves:

B21F501A B21F501B B21F501C B21F501D B21F502A B21F502B B21F502C B21F502D B21F503A B21F503B B21F503C B21F503D B21F504A B211F504B B21F504C B21F504D B21 F506 B21 F507 B21F508 B21F509 B21F510 B21F511 B21F512 B21F513A B21F513B B21F513C B21F513D B21F514A B21F514B B21F514C B21F514D B21F515A B21F515B B21F515C B21F515D B21F515E B21F515F B21F515G B21F515H B21F515L B21F515M B21F515N B21F515P B21F515R B21F515S B21F515T B21F515U B21F516A B21F516B B21F516C B21F517A B21F517B B21F517C B21F517D B31F501A B31F501B B31F501C B31F501D B31F502A B31F502B B31F502C B31F502D B31F503A B31F503B B31F504A B31F504B B31F505A B31F505B B31F506A B31F506B B31F510A B31F510B B31F511A B31F511B B31F512A B31F512B B31F515A B31F515B B31F516A B31F516B E21F500A E21F500B E41F500 E41F501 E41 F502 E41 F503 E51 F503 E51 F504 E51 F505 E51 F506 G33F583, N21F539A N21F539B The licensee states:

Excess flow check valves (EFCV) are provided in each instrument process line that is part of the reactor coolant pressure boundary. The excess flow

check valve is designed so that itwill not close accidentally during normal ,

operation, will close if a rupture of the instrument line occurs downstream of the valve, and can be reopened, when appropriate, after closure from a local panel. These valves have both local position indication and position indication inthe control room.

The design and installation of the excess flow check-valves at Fermi 2 follow the guidance of Regulatory Guide [(RG) 1.11, "Instrument Lines Penetrating Primary Reactor Containment" (ADAMS Accession No. ML100250396)]. As detailed inthe Fermi 2 [Update Final Safety Analysis Report] UFSAR, Detroit Edison has incorporated into the design of each excess flow check valve source line the equivalent of a 0.25-inch restricting orifice. This was done by either the installation of a 0.25-inch orifice, the tap size of the source line being 0.25-inch or.in the case of the Feedwater pressure-sensing lines, taking credit for an inboard containment isolation valve. Additionally, the design of each excess flow check valve contains an internal 0.25-inch main body orifice. The restrictions inthe source lines of the excess flow check valves limit leakage, in case of a failure to close, to a level where the integrity and functional performance of secondary containment and associated safety systems are maintained. The coolant loss iswell within the capabilities of the reactor coolant makeup system, and the potential offsite exposure is substantially below the guidelines of 10 CFR 100.

Excess flow check valves are required to be tested inaccordance with ISTC-3522, which requires exercising check valves nominally every three months to the positions required to perform their safety functions. ISTC-3522(c) permits deferral of this requirement to every reactor refueling outage. Excess flow check valves are also required to be tested inaccordance with ISTC-3700, which requires remote position indication verification at least once every 2 years.

The EFCVs are classified as ASME Code Category A/C and are also containment isolation valves. However, these valves are excluded from 10 CFR 50 Appendix J Type C leak rate testing, due to the size of the instrument lines and upstream orificing.

The excess flow check valve isa simple and reliable device. The major components are a poppet and spring. The spring holds the poppet open under static conditions. The valve will close upon sufficient differential pressure across the poppet. Functional testing of the valve is accomplished by venting the instrument side of the valve. The resultant increase inflow imposes a differential pressure across the poppet, which compresses the spring and decreases flow through the valve. Systen design does not include.test taps upstream of the EFCV. For this reason, the EFCVs cannot be isolated and tested using a pressure source other than reactor pressure.

Industry experience as documented inGE Nuclear Energy topical report NEDO-32977-A, "Excess Flow Check Valve Testing Relaxation," [ADAMS Accession No. ML003729011] indicates the EFCVs have a very low failure

rate. The report indicates similarly that many reported test failures at other plants were related to test methodologies and not actual EFCV failures. The technology for testing these valves is simple and has been demonstrated effectively during the operating history of Fermi 2. Test history at Fermi 2 shows a very low failure rate and no evidence of common mode failure, which is consistent with the findings of NEDO-32977-A. The EFCVs at Fermi 2, consistent with the industry,:have exhibited a high degree of reliab,ility, availability, and provide an acceptable level of quality and safety.

3.1.3 Licensee's Proposed Alternative Testing (as stated)

Functional testing with verification that flow is checked will be performed per Technical Specification 3.6.1.3.9 during refueline outages. Surveillance Requirement 3.6.1.3.9 allows a "representative sample" of Excess Flow Check Valves (EFCVs) to be tested every 18 months, such that each EFCV will be tested at least once every ten years (nominal). The six sample groups contain approximately 15 EFCVs each and are selected from different plant locations and operating conditions. The basis for this alternative is that testing a sample of EFCVs each refueling outage provides a level of safety and quality equivalent to that of the Code-required testing.

-The EFCVs have position indication in the control room. Check valve remote position indication is excluded from RG 1.97 ["Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants" ADAMS Accession' No. ML061580448] as a required parameter for evaluating containment isolation. The remote position indication will be verified accurate at the same frequency as the exercise test prescribed in Technical Specification Surveillance Requirement 3.6.1.3.9. Although inadvertent actuation of an EFCV during operation is highly unlikely due to the spring poppet design, Fermi 2 checks the EFCVs indications on a daily basis as part of the Operations Routines Checklist #26. Corrective Action documents are initiated for; any EFCVs with abnormal position indication displays and repairs are scheduled for the next refueling outage.

3.1.4 Staff Evaluation The licensee is in its third 10-year IST program interval which commenced on February 17, 2010. The licensee has proposed an.alternative test in lieu of the requirements found in 2004 Edition of the ASME OM Code Section ISTC-3522(c) and ISTC-3700 for 93 instrument process line excess flow check valves. Specifically, the licensee's proposal to functionally test and verify the 93 EFCVs per Technical Specification (TS) Surveillance Requirement (SR) 3.6.1.3.9.

SR 3.6.1.3.9 allows a representative sample of EFCVs to be tested every 18 months, such that each EFCV will be tested at least once every ten years.

EFCVs in reactor instrumentation lines are used to limit the release of fluid from the reactor coolant system in the event of an instrument line break. EFCVs are not required to close in response to a containment isolation signal and are not postulated to operate under post loss of coolant accident (LOCA) conditions. The 93 EFCVs were installed following the guidance of .

RG 1.11 which states in part that the instrumentation lines penetrating the primary containment

that are part of the reactor coolant boundary should be sized or orificed in such a manner as to ensure that, inthe event of any breach, the leakage is reduced to the maximum extent practical and that the rate and extent of coolant loss are within the capability of the normal reactor coolant makeup system. Inaddition, the design of each EFCV contains an internal .25 inch main body orifice and has remote position indication.

TS SR 3.6.1.3.9 was initially proposed and changed during the licensee's second 10-year IST program interval (see ADAMS Accession No. ML993610163 and safety evaluation ADAMS Accession No. ML003691487). The proposal included a request for adopting the test interval of TS SR 3.6.1.3.9 inlieu of the requirements of 1987 Edition with 1988/1989 Addenda of ASME OM Code Part 10, Section 4.3.2.1 which states that Category C check valves shall be exercised nominally every 3 months. The 1987 Edition with 1988/1989 Addenda of ASME OM Code Part 10, Section 4.3.2.1 isequivalent to the 2004 Edition ASME OM Code Section ISTC-3522.

Inthe previous safety evaluation, the NRC staff concluded that the impact of the increase in EFCV surveillance test intervals to 10 years would result in an increase inthe release frequency of about 7.66E-5/year from the current release frequency estimate (for an 18 month surveillance test interval) of about 1.36E-5/year. The NRC staff considered this estimate to be sufficiently low. The NRC staff also noted that the consequence of such an accident isunlikely to lead to core damage. The NRC staff concluded that the consequences of the steam release from the depicted events isbounded by an existing UFSAR analysis and that the increase inrisk associated with the licensee's request for relaxation of EFCV surveillance testing islow. A review of today's measures and standards yields no changes to the previous conclusions.

The licensee also requested to use TS SR 3.6.1.3.9 test interval inlieu of the requirements of 2004 Edition of the ASME OM Code Section ISTC-3700 which states that valves with-remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated. As noted inthe discussion above, EFCVs are not required to close inresponse to a containment isolation signal and are not postulated to operate under post loss LOCA conditions. Also, check valve remote position indication is excluded from RG 1.97.

The check valve position indications are monitored on a daily basis. Abnormal position indications are addressed via the Corrective Action system. The overall performance of the 93 EFCVs has been consistent with industry data yielding very low failure rates, no evidence of common mode failure, and have exhibited a high degree of reliability and availability. Testing and,remote position verification of a representative sample of EFCVs every 18 months, such that each EFCV will be tested at least once every 10 years, per TS SR 3.6.1.3.9 provides reasonable assurance that the EFCVs will perform their design function when called upon. The proposed alternative provides an acceptable level of quality and safety.

3.2 Request VR-012 3.2.1 ASME OM Code Requirements ISTC-3700 (Position Verification Testing) states that valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated.

S,

3.2.2 Licensee's Basis For Requesting Alternative Testing Alternative testing was requested for the following components:

C5100F002A - TIP Channel A Ball Valve C5100F002B - TIP Channel.B Ball Valve C5100F002C- TIP Channel C Ball Valve C5100F002D - TIP Channel D Ball Valve C5100F002E - TIP Channel E Ball Valve E11 F412 - RHR Div. II Primary Containment Monitoring Isolation Valve E11 F413 - RHR Div. II Primary Containment Monitoring Isolation Valve E11F414 - RHR Div. I Primary Containment Monitoring Isolation Valve E11F415 - RHR Div. I Primary Containment Monitoring Isolation Valve E41 F400 - Primary Containment Monitoring (PCM) - Suppression Pool E41 F401 - Primary Containment Monitoring (PCM) - Suppression Pool E41 F402 - Primary Containment Monitoring (PCM) - Suppression Pool E41 F403 - Primary Containment Monitoring (PCM) - Suppression Pool P34F401A - Post Accident Sampling (PAS) Vi3-7360 P34F401B - Post Accident Sampling (PAS) Vi3-7361 P34F403A - Post Accident Sampling (PAS) Vi3-7364 P34F403B - Post Accident Sampling (PAS) Vi3-7365 P34F404A - Post Accident Sampling (PAS) V13-7374 P34F404B - Post Accident Sampling (PAS) V13-7375 P34F405A - Post Accident Sampling (PAS) Vi3-7366 P34F405B - Post Accident Sampling (PAS) Vi3-7367 P34F406A- Post Accident Sampling (PAS) V3-7376 P34F406B,- Post Accident Sampling (PAS) V3-7377 P34F407- Post Accident Sampling (PAS) Vi3-7368 P34F408 - Post Accident Sampling (PAS) V13-7369 P34F409 - Post Accident Sampling (PAS) Vi.3-7378 P34F410 - Post Accident Sampling (PAS) V13-7379 T50F41.2A - Primary Containment Torus Level Monitoring Div. 1 T50F412B - Primary Containment Torus Level Monitoring Div. 2 T50F450 - Primary Containment Radiation Monitoring System Inlet Isolation Valve T50F451 - Primary Containment Radiation Monitoring System Outlet Isolation Valve T50F458 - Primary.Containment Primry Atmospheric Mnitrin Monitoring ontinmnt (PM) (PCAM) Division 2

-SupresionPoo Penetration X-27F Remote Manual Solenoid Valve The licensee states:

The subject valves are all categorized as A and are all containment isolation valves per the plant safety analysis. All of the subject valves have a safety function to close in order to isolate containment during a Loss of Coolant Accident (LOCA) when required.

Since these valves are containment isolation valves, they are each individually seat leakage tested inaccordance with 10 CFR 50 Appendix- i

In 1996, Fermi 2 received a Safety Evaluation (Technical Specification Amendment 108) with approval to implement Option Bof the 10 CFR 50 Appendix J Program. This program permits the extension of the Appendix J seat leakage testing to a frequency corresponding to the specific valve performance. Valves whose leakage test results indicate good performance may have their interval of testing increased based on these test results. The Fermi 2 program which implements Appendix J, Option B requires individual containment isolation valves to pass two successful seat leakage tests before it can be placed on extended seat leakage testing frequency. The majority of the listed valves are ingood performer status, requiring a seat leakage test every 3 refueling outages.

Each of the subject valves is a solenoid operated valve design such that the position of the valve is not locally observable. The design of these valves issuch that the coil position isinternal to the valve body and not observable in either the energized or de-energized state.

In accordance with ISTC-3700, where local observation isnot possible, other indications shall be used to verify valve position. The method used at Fermi 2 isa pressure test using the local leakage rate testing equipment. This method involves pressurizing the containment penetration volume to approximately 55 psig [pounds per square inch gauge] and verifying the penetration remains pressurized while the valve is indicating closed on the main. control room board. The valve isthen opened using the control switch inthe main control room. A decrease in pressure isthen verified along with valve position indicating open inthe main control room. This method satisfies the requirement for position indication verification and ensures that the indicating system accurately reflects the.valve position.

Since each. of these valves is seat leakage tested using local leakage rate testing equipment, the current leakage rate tests have been modified to also perform the position indication verification test at the same time., The individual valve being tested must have its system properly drained, vented, and aligned correctly prior to performing the seat leakage test or the position indication verification. This must be done every two years.. Radiation exposure and Operations./ Test personnel time /

labor involved will be significantly reduced by performing the position indication verification test at the same interval as the Appendix J seat leakage test.

Each of the subject valves isexercised on a quarterly or refueling frequency and their stroke times measured and compared to the ASME OM Code acceptance criteria. Inaddition, stroke time data is-entered into a database where an automatic '

check for a deviation of more than 12% from the mean of the last 10 years of recorded values is performed. A 12% or greater deviation alerts the IST Engineer of the need to perform a more detailed analysis of the stroke time data. Out of a total of 3119 stroke time tests recorded inthe IST database for these 32 SOVs, there have been 23 failures, 15 of which were attributed to limit switch assembly adjustments.

The remaining 8 failures were related to SOV sticking problems.

These solenoid-operated valves are also subject to Preventive Maintenance program coverage. Many of these SOVs are periodically replaced to satisfy EQ

[environmental qualification) Program criteria. Any maintenance that isperformed on

these valves which might affect position indication will be followed by applicable PMT

[post maintenance test] including position PIT [position indication verification test].

3.2.3 Licensee's Proposed Alternative Testing (as stated)

For the subject valves, Fermi 2 will perform the position indication verification in conjunction with the seat leakage test at a frequency in accordance with 10 CFR 50 Appendix J Option B. This interval may be adjusted to a frequency of testing commensurate with Option B"of 10 CFR.50 Appendix J Type C leakage testing based on valve seat leakage perforiance.

The proposed alternative will provide an acceptable level of quality and safety.

Reducing the number of tests involving set-up of Leak Rate Monitors, tubing, etc. every two years will reduce overall dose. Based on actual.dose data,from past testing it is estimated that alternative testing performed at a 3-cycle interval would result in dose savings of about 600 mRem over three operating cycles..

3.2.4 Staff Evaluation The licensee has proposed an alternative test in lieu of the requirements found in 2004 Edition of the ASME OM Code Section ISTC-3700 for 32 SOVs: Specifically,.the licensee's proposal to functionally test and verify valve operation is accurately indicated on a 10 CFR 50 Appendix J Option B schedule. Valves would initially be tested at the required interval schedule which is currently every refueling outage (RFO) or 2 years as specified by ASME'OM Code Section ISTC-3700. Valves that have demonstrated good performance for two consecutive cycles. may, have their test interval extended to every 3 RFO, not to exceed 60 months. Any position indication verification test failure would require the component to return to the initial, interval of every RFO or 2 years until good performance can again be established.

The 32 SOVs are category A containment isolation valves with a leakage rate test requirement specified in ASME OM Code Section ISTC-3620. They are also required to be leak tested in accordance with 10 CFR 50 Appendix J program. The licensee has implemented Option B of 10 CFR 50 Appendix J program. This places the 32 SOV's leakage testing requirements into a performance based program. Valves that have demonstrated a history of good performance may have their leakage test interval extended beyond the normal 2 year test interval requirement. Extension intervals shall not exceed 60 months. The licensee proposes to synchronize the position indication verification test requirements of ISTC-3700 with the leakage rate test requirements of ISTC-3620: Both tests will be performed together on a.10 CFR 50 Appendix J Option B-perforrance based schedule.

Performance data compiled from the IST and maintenance programs for the 32 solenoid valves show that the valves have been relatively maintenance free. Less than 1% of the test population has exhibited failure over the course of 3119 IST tests. Maintaining the current 2 year position indication verification test interval which results in additional personnel radiation exposure represents a hardship-or'unusual difficulty without increase in the level of quality and safety. Quarterly valve exercise coupled with a 10 CFR 50 Appendix J Option B performance based program to test for leakage and verify valve position indication provides reasonable assurance that the components or systems are operationally ready.

The licensee is authorized to perform position indication verification for the stated 32 SOV's in conjunction with the seat leakage test at a frequency in accordance with 10 CFR 50 Appendix J Option B. This interval may be adjusted to a frequency of testing commensurate with Option B of 10 CFR 50 Appendix J Type C leakage testing based on valve seat leakage performance.

The performance based program interval shall not exceed 60 months.

3.3 Request VR-013 3.3.1 ASME OM Code Requirements ISTC-3630 (Leakage Rate for Other Than Containment Isolation Valves) states that category A valves with a leakage requirement not based on an Owner's 10 CFR 50, Appendix J program, shall be tested to verify their seat leakages are within acceptable limits. Valve closure before seat leakage testing shall be by using the valve operator with no additional closing force applied.

ISTC-3630(a) (Frequency) Tests shall be conducted at least once every 2 years.

3.3.2 Licensee's Basis For Requesting Alternative Testing Alternative testing was requested for the following components:

E1100F050A -RHR Div. 1 Inboard Isolation Testable Check Valve El10OF050B -RHR Div. 2 Inboard Isolation Testable Check Valve El 150F008 - RHR Div. 1 & 2 Shutdown Cooling Outboard Containment Isolation Valve E1150F009 - RHR Div. 1 & 2 Shutdown Cooling Inboard Containment Isolation Valve El150F015A -RHR Div. 1 Low Pressure Coolant Injection (LPCI) Inboard Isolation Valve E1150F015B'-RHR Div. 2 Low Pressure Coolant Injection (LPCI) Inboard Isolation Valve E1150F608 - RHR Shutdown Cooling Inboard Inlet Isolation Bypass Valve E210OF006A -Core Spray (CS) Div. 1 Inboard Primary Containment (PC) Check Valve E2100F006B -Core Spray (CS) Div. 2 Inboard Primary Containment (PC) Check Valve E2150F005A -Core Spray (CS) Div. 1 Inboard Isolation Valve E2150F005B -Core Spray (CS) Div. 2 Inboard Isolation Valve E4150F006 - HPCI Main Pump Outlet to Feedwater Isolation Valve E4150F007 - HPCI Main Pump Discharge Isolation Valve E5150F012 - Reactor Core Isolation Cooling (RCIC) Pump Supply To Feedwater Header Isolation Valve E5150F013 - Reactor Core Isolation Cooling (RCIC) Pump Supply To Feedwater Header Isolation Valve The licensee states:

ASME OM Code ISTC-3630(a) requires that leakage rate testing (water) for pressure isolation valves (PIVs) be performed at least once every 2 years.

Recent historical data was used to identify that PIV testing alone each refuel outage incurs a total dose of approximately 400 mRem. The reason for this relief request is to reduce outage dose.

At Fermi 2, the functional tests for PIVs are performed only at a Cold Shutdown or Refuel Outage frequency. Such testing is not performed online in order to prevent any possibility of an inadvertent Interfacing System Loss of Coolant Accident (ISLOCA) condition. The 18 month functional testing of the PIVs is adequate to identify any abnormal condition that might affect closure capability. Performance of the separate 18 month PIV leak rate testing does not contribute any additional assurance of functional capability, it only verifies the seat tightness of the closed valves.

The primary basis for this relief request is the historically good performance of the PIVs. The only recorded PIV test failures at Fermi 2 were in fact determined to be a result of the test methodology and not due to seating surface condition of the valves. These failures occurred many years ago and, following test procedure enhancements, have not recurred.

NUREG/CR-5928; "Final Report of the NRC-sponsored ISLOCA Research Program" (ADAMS Accession No. ML072430731), evaluated-the likelihood and potential severity-of ISLOCA events in Boiling Water Reactors (BWR) and Pressurized Water Reactors (PWR). The BWR design used as a reference for this analysis was a BWR-4 with a Mark 1 containment. Fermi 2 was listed as one of the applicable plants. The BWR systems were individually analyzed and in each case the report concluded that the system was "...judged to not be an important consideration with respect to-ISLOCA risk." Section 4.3 of the report concluded the BWR portion of the analysis by saying "ISLOCA is not a risk concern for the BWR plant examined here."

The following statement iscontained in the Fermi 2 PSA [Probabilistic Safety Analysis]:

...initiators related to the ECCS [Emergency Core Cooling System] valve test and maintenance activities are the dominant contributors to the interfacing LOCA frequency, while hardware failure induced valve leakage accounted for only 0.3% of the overall interfacing system LOCA frequency.

The mean values of frequencies associated with test and maintenance activities and hardware failures are 6.2E-7/year and 2.0E-9/year respectively."

This means that the actual act of testing these valves is a far higher ISLOCA initiation risk than actual valve leakage. Reducing the test frequency would actually reduce the likelihood of an ISLOCA.

The intent of this relief request is simply to allow for a performance-based approach to the scheduling of PIV leakage testing. It has been shown that ISLOCA rep'esents a small risk impact to BWRs such as Fermi-2. Fermi 2 PIVs have an excellent performance history in terms of seat leakage testing.

The risks associated with extending the leakage test interval to a maximum of 3 refueling outages are extremely low. This relief will provide significant reductions in radiation dose.

'I 3.3.3 .Licensee's Proposed Alternative Testing (as stated)

Fermi 2 proposes to. perform PIV testing at intervals ranging from every refuel to every third refuel. The specific interval for each valve would be a function of its performance and would be established ina manner consistent with the Containment Isolation Valve (CIV) process under 10 CFR 50 Appendix J Option B. Nine of the 15 valves listed are also classified as CIVs and are leak rate tested with air at intervals determined by 10 CFR 50 Appendix J Option B. ISI Leak Rate Program guidance will be established such that if any of those 9 valves fail either the CIV test or their PIV test, the interval for both tests will be reduced to every RFO until they can be re-classified as good performers per the Appendix J, Option B requirements.

The test intervals for the valves with a PIV-only function will be determined inthe same manner as isdone for CIV testing under Option B. That is,the test interval may be extended to every 3 RFO (not to exceed 6 years) upon completion of two consecutive periodic PIV tests with results within prescribed acceptance criteria. Any PIV test failure will require a return to the initial (every RFO) interval until good performance can again be established.

3.3.4 Staff Evaluation The licensee has proposed an alternative test inlieu of the requirements found in2004 Edition of the ASME OM Code Section ISTC-3630(a) for 15 PIVs. Nine of the 15 valves also function as CIV. Specifically, the licensee proposes to functionally test and verify the leakage rate of 15 PIVs using 10 CFR 50 Appendix J Option B performance based schedule. Valves would initially be tested at the required interval schedule which is currently every RFO or 2 years as specified by ASME OM Code Section ISTC-3630(a). Valves that have demonstrated good performance for two consecutive cycles may have their test interval extended to every 3 RFO not to exceed 6 years. Any PIV leakage test failure would require the component to return to the initial interval of every RFO or 2 years until good performance can again be established.

Pressure isolation valves are defined as two valves inseries within the reactor coolant pressure boundary which separate the high pressure reactor coolant system from an attached lower pressure system. Failure of a PIV.could result inan.over-pressurization event which could lead to a system rupture and possible release of fission products to the environment. This type of failure event was analyzed under NUREG/CR-5928 Inter System Loss of Coolant Accident (ISLOCA) Research Program (ADAMS Accession No. ML072430731). The purpose of NUREG/CR-5928 was to quantify the risk associated with an ISLOCA event. NUREG/CR-5928 analyzed BWR and PWR designs. Specifically, NUREG/CR-5928 reviewed BWR-4 design which included Fermi 2. The conclusion of the analysis resulted in ISLOCA not being a risk .

concern for BWR-4 design.

The licensee proposes to initiate a performance based program consistent with 10 CFR 50 Appendix J Option B. The licensee stated that the 15 PIVs would be placed into a performance based program where the component would have to complete two consecutive leakage tests within the acceptance criteria. Upon completion of two successful tests, the component leakage test interval can be extended to 3 RFO intervals not to exceed 6 years. The NRC staff is in agreement with the licensee's proposal of a performance based program, except for extending the leakage test interval to 6 years. Title 10 of CFR 50 Appendix J, Option B notes that specific guidance concerning a performance based leakage test program, acceptable leakage rate test G13

methods, procedures, and analyses that may be used to implement these requirements and criteria-are provided in RG 1.163, "Performance-Based Containment Leak-Test Program" (ADAMS Accession No. ML003740058). RG 1.163 endorses Nuclear Energy Institute (NEI)

Topical Report 94-01, Revision 0, "Industry Guideline For Implementing Performance-Based Option of 10 CFR Part 50, Appendix J" dated July 26, 1995 with the limitation that Type C components test interval cannot.extend greater than 60 months. In addition, NEI 94-01 Revision 2 was recently reviewed by NRC staff on June 25, 2008 (see safety evaluation ADAMS Accession No. ML0811401050) and addressed the limitation of allowing 25% extension of Type C test intervals due to standard scheduling practices. The NRC staff concluded that intervals up to 60 months for Type C tests may be extended by up to 25% of the test interval, not to exceed 9 months.

The 15 PIVs are currently being leak tested every RFO or 2 years. Performance of the leakage test of the 15 PIVs places a burden on test personnel being exposed to radiation. Overall completion of leak test requirements averages a dose of 400 mRem. The valves have maintained a history of good performance. Extending the leakage test interval based on good performance and the low risk factor as noted in NUREG/CR-5928 is a logical progression to a performance based program. To maintain the current RFO or 2 year leakage test interval would represent an undue hardship without an increase in the level of quality and safety. Testing low risk valves on a performance based schedule provides reasonable assurance that the component is operationally ready.

The licensee is authorized to,implement a performance based program for the 15 PIVs. The performance based program interval shall not exceed 60 months. Standard scheduling practice may extend the program interval by 25%, not to exceed 9 months.

4.0 Conclusion As set forth above, the NRC staff finds that the proposed alternative in request VRR-011 provides an acceptable level of quality and safety. The NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i),

and is in compliance with the ASME OM Code requirements. All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.

The NRC staff finds that the proposed alternatives in requests VRR-012 and VRR-013, provide reasonable assurance that the 32 solenoid operated valves noted in paragraph 3.2.2 and the 15 pressure isolation valves noted in paragraph 3.3.2 are operationally ready. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request for relief remain applicable. Accordingly, the NRC staff concludes that the ,

licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the ASME OM Code requirements.

Therefore, the NRC staff authorizes the alternatives in requests VRR-011, VRR-012, and VRR-13 for the remainder of the Detroit Edison Company third 10-year IST interval for Fermi 2 which commenced on February 17, 2010.

Principal Contributor: M. Farnan, NRR Dated: September 28, 2010

FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES FERMI 2 THIRD 10 YEAR INTERVAL - START DATE 02/15/20 10 PART 8: IST PROGRAM COLD SHUTDOWN JUSTIFICATIONS REVISION 0 Revision Summary:

1. Complete rewrite for start of 3rd ten year interval U~AL Prepared: '~~.Date: 3.173 I!1 PE-03 .'

IST gram NQiager Reviewed: 'ij~),-r Date: - PE-03 ISI/PEP Ei ineer Reviewed:__________ Date: ~ N/A Supervisor, Perfonrmanc Engineering Approved: EIl-Date: ____ N/A Mana r, Perform ance Engineering INFORMATION AND PROCEDURES DSN: 1ST Program CSJ Rev: 0 Date: i '--~

DTC: TM PLAN File: 1715.04 Recipient:_______

Date Aprvd U gaz Release authorized by: s/,bl

IST PROGRAM PLAN PART 8 COLD SHUTDOWN JUSTIFICATIONS (CSJ)

INDEX SCold Shutdown Description Justification No. ___________________________________

CSJ-001 fNot used

~CSJ-002 [Feedwater Check Valves Open Direction Testing, B21 CGSJ-003 LECRD Pump Cooling Water Isolation Valves, P44 CSJ-004_____ j Pressure Isolation Valves Stroke Time Testing, E2 1, E4 1, E5 1 CSJ-005 Not used ICSJ-006 ~ jMSIVs Stroke Time Testing, B21 CSJ-007 [Recirculation Pump Seal Water Supply Containment Isolation Valves Strokce Tinie Testing, B3 I Testing, CS-008 Reactor Recirculation Pump Discharge Valves Stroke Time CSJ-009 ]RPS istrument Isolation Valves Stroke Time Testing, El 1.

CSJ-010 ][Inboard Containmient Isolation Valves Stroke Time Testing, E41, G1i CSJ-011 to 014 ]Not usedI fCSJ-015 j[EECW Drywell Isolation Valves Stroke Time Testing

[CSJ7016 Not Used CSJ-017 jT4803F601 and T4803F602 Stroke Time Testing C~SJ-018 ]IB2103FO16 and B2103FO19 Stroke Time Testing FCSJ-019 HPCI Keep Fill E410OF220 and E410OF221 Check Valve Testing C~SJ-020 HPCI Vac Breaker E410OF076 and E410OF077 Check Valve Testing IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 2

COLD SHUTDOWN JUSTIFICATION - CSJ-002 Revision 0 SYSTEM: FEEDWATER VALVES:

Valve PIS No. Code Class Category ISI Drawing B2100F010A 1 A/C 6M721-5821 B2100FO1OB 1 A/C 6M721-5821 B2100F076A 1 A/C 6M721-5821 B2100F076B 1 A/C 6M721-5821 FUNCTIONS:

. These check valves open to permit Feedwater flow to the vessel during plant operations and o Valve B2100F010A opens to permit HPCI injection to the reactor vessel via the "A" Feedwater Line.

o Valve B2100F010B opens to permit RCIC injection to the reactor vessel via the "B" Feedwater Line.

QUARTERLY TEST REQUIREMENTS: Open (CT-0) Exercising (ISTC-3510)

JUSTIFICATION:

Isolating a feedwater line to full stroke (CT-O) open a feedwater check valve from the closed position would necessitate feedwater flow being reduced by 50% from 1.00% feedwater flow during plant operations. The feedwater lines cannot be isolated during reactor operation to facilitate testing. If a feedwater isolation valve was closed during operation, the feedwater nozzle and spargers would undergo a severe thennal shock when feedwater was restored. This thermal shock could cause cracking and possible failure of the spargers and nozzles. The open stroke of the Feedwater check valves is verified during plant startup after cold shutdown by verification of flow to the reactor vessel.

COLD SHUTDOWN TESTING:

These valves will be exercised open (CT-O) during startup from cold shutdowns when system configuration permits in accordance with ISTC-3521(c).

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 3

COLD SHUTDOWN JUSTIFICATION - CSJ-003 Revision 0 SYSTEM: EMERGENCY EQUIPMENT COOLING WATER VALVES:

Valve PIS No. Code Class Category ISI Drawing P4400F182 3 C 6M721-5825-2 P4400F604 . 3 B 6M721-5825-2 FUNCTIONS:

These valves close to isolate the non-safety related, non-seismic piping supplying cooling water to the CRD drive pumps from the EECW system.

QUARTERLY TEST REQUIREMENTS: CT-C and BTC exercising (ISTC-3510)

JUSTIFICATION:

During power operation the RBCCW system supplies cooling water to the CRD Pumps. Upon auto initiation of the EECW system, isolation valve P4400F604 receives a signal to close which results in check valve P4400F182 closing, isolating the non-class portion of piping. During quarterly testing following the initiation of EECW, Operations immediately re-opens the P4400F604 to restore cooling to the CRD pumps.

Closing the subject valves interrupts cooling water flow to the CRD pumps. The CRD pumps cannot have their cooling water isolated for more than a short time during operation. These valves-should not be exercise tested (CT-C, BTC respectively) during nonral operation because interruption of the cooling water flow would cause damage to the pumps.

COLD SHUTDOWN TESTING:

These tests:

P4400F182 CT-C P4400F604 BTC will be performed during cold shutdowns when the CRD pumps can be secured and cooling water isolated.

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 4

COLD SHUTDOWN JUSTIFICATION- CSJ-004 Revision 0 SYSTEM: CORE SPRAY, HIGH PRESSURE COOLANT INJECTION, AND REACTOR CORE ISOLATION COOLING VALVES:

Valve PIS No. Code Class Category ISI Drawing E2150F005A 1 A 6M721-5814 E2150F005B 1 A 6M721-5814 E4150F006 1 A 6M721-5815 E5150F013 1 A 6M721-5816 FUNCTIONS:

These valves are designated as pressure isolation valves (PIVs). Pressure isolation valves are defined as valves which isolate the portions of a system designed for low pressure service from the portions of a system connected to the Reactor Coolant Pressure Boundary (RCPB) which are designed for high pressure service. (Reference NUREG-0677 and ongoing RACTs commitment 94175)

QUARTERLY TEST REQUIREMENTS: BTO and BTC exercising (ISTC-3510)

JUSTIFICATION:

Inadvertent opening of these valves is prevented by various system controls and interlocks. In accordance with guidance presented in NRC Information Notice 84-74 and previous NRC concerns regarding intersystem LOCAs, cycling these valves every quarter during power operation increases the probability of exposing the downstream low pressure piping to reactor coolant pressure (since only one valve would have to be ruptured or stuck open to expose the low pressure system to reactor coolant pressure).

Interfacing system LOCAs produce consequences that are very difficult to mitigate. The best defense is to minimize the probability,of occurrence. An important contribution to such minimization is to test pressure boundary valves only at conditions of low reactor vessel pressure. Also, maintenance history on these valves has shown that excessive cycling at pressure will reduce the leak tightness of the valves COLD SHUTDOWN TESTING:

Exercise and stroke time testing (BTO and/or BTC) of these valves will be performed during cold shutdowns.

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 5

COLD SHUTDOWN JUSTIFICATION- CSJ-006 Revision 0 SYSTEM: NUCLEAR BOILER VALVES:

Valve PIS No. Code Class Category ISI Drawing B2103F022A 1 A 6M721-5808-1 B2103F022B 1 A 6M721-5808-1 B2103F022C 1 A 6M721-5808-1 B2103F022D 1 A 6M721-5808-1 B2103F028A 1 A 6M721-5808-1 B2103F028B 1 A 6M721-5808-1 B2103F028C 1 A 6M721-5808-1 B2103F028D 1 A 6M721-5808-1 FUNCTIONS:

These valves are the inboard and outboard Main Steam Line Isolation Valves (MSIV's) and serve as primary containment isolation valves for the main steam line penetrations.

QUARTERLY TEST REQUIREMENTS: BTC exercising (ISTC-3510)

JUSTIFICATION:

Full stroke closed (BTC) testing of these valves during normal reactor operation requires isolating one of the four main steam lines. Isolation of these lines results in primary system pressure spikes, reactor power fluctuation, and increased flow in the unisolated steam lines.

These unstable conditions can lead to reactor scrams. In addition, pressure transients resulting from stroke testing MSIVs increase the chances of inadvertent actuation of primary system safety relief valves (SRVs). These valves are partial stroke tested (BTP) every three months as required per System Engineering evaluation.

This deferral also contributes to a reduction of the Main Steam Safety Relief Valves challenge rate as recommended in NUREG-0626.

COLD SHUTDOWN TESTING:

These valves will be full stroke exercised and stroke timed closed (BTC) during cold shutdowns.

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 6

COLD SHUTDOWN JUSTIFICATION - CSJ-007 Revision 0 SYSTEM: REACTOR RECIRCULATION, REACTOR RECIRCULATION PUMP SEAL WATER SUPPLY VALVES VALVES:

Valve PIS No. Code Class Category ISI Drawing B3100F014A 2 A 6M721-5809 B3100F014B 2 A 6M721-5809 B3100F016A 2 A 6M721-5809 B3100F016B 2 A 6M721-5809 FUNCTIONS:

These valves are primary containment isolation valves on the CRD supply to the Reactor Recirculation pumps seals. Their safety function is to close for primary containment isolation.

QUARTERLY TEST REQUIREMENTS: BTC exercising (ISTC-3510)

JUSTIFICATION:

It is not practical to verify the closure function of these valves on a quarterly basis. Exercising these valves during normal operation would result in the isolation of seal water flow to the Reactor Recirculation pump seals.. The isolation of the seal water flow to the recirculation pumps coild potentially damage the seals and result in a plant shutdown and extensive mnaintenance.

COLD SHUTDOWN TESTING:

These valves will be full stroke exercised and stroke timed closed (BTC) and timed during cold shutdowns when the reactor recirculation pumps are secured.

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 7

COLD SHUTDOWN JUSTIFICATION - CSJ-008 Revision 0 SYSTEM: REACTOR RECIRCULATION VALVES:

Valve PIS No. Code Class Category ISI Drawing B3105F031A 1 B 6M721-5809 B3105F031B 1 B 6M721-5809 FUNCTIONS:

The safety function of these valves is to go closed. During a reactor recirculation loop pipe break loss of coolant accident, one of these valves will close depending on the location of the pipe break. Low Pressure Coolant Injection (LPCI) loop selection logic deternines which valve must close.

QUARTERLY TEST REQUIREMENTS: BTC exercising (ISTC-3510)

JUSTIFICATION:

These valves cannot be full stroke tested during normal operation since the isolation of a recirculation loop would cause a running recirculation pump to trip, resulting in single loop operation. Single loop operation is permitted by Fermi 2's Technical Specifications but is not prudent. Single loop operation requires a reduction in power-and creates power to flow instability. This would be an undue hardship on operations personnel.

COLD SHUTDOWN TESTING:

These valves will be full stroke exercised and stroke timed closed (BTC) during cold shutdowns.

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 8

COLD SHUTDOWN JUSTIFICATION- CSJ-009 Revision 0 SYSTEM: RESIDUAL HEAT REMOVAL VALVES:

Valve PIS No. Code Class Category ISI Drawing E11F412 2 A 6M721-5813-1 El 1F413 2 A 6M721-5813-1 E11F414 2 A 6M721-5813-2 E11F415 2 A 6M721-5813-2 FUNCTIONS:

These valves act as primary containment isolation valves to isolate the Reactor Protection System instrumentation from the Primary Containment atmosphere.

QUARTERLY TEST REQUIREMENTS: BTC exercising (ISTC-3510)

JUSTIFICATION:

These normally open valves cannot be stroked during plant operation since these valves isolate the Reactor Protection System instrumentation. The closing of the isolation valves can cause a pressure spike that would result in an ESF actuation and a reactor scram.

COLD SHUTDOWN TESTING:

These valves will be full stroke exercised and stroke timed closed (BTC) during cold shutdowns:

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 9

COLD SHUTDOWN JUSTIFICATION- CSJ-01O Revision 0 SYSTEM: HIGH PRESSURE COOLANT INJECTION (E41)

SUMP PUMP (G11)

VALVES:

Valve PIS No. Code Class Category IST Drawing E4150F002 1 A 6M721-5815 G1154F018 2 A 6M721-5817 G1154F600 2 A 6M721-5817 FUNCTIONS:

E4150F002, G1 154F018, and GI 154F600 are all inboard containment isolation valves and isolate the primary containment when required.

QUARTERLY TEST REQUIREMENTS: BTO and BTC Exercising (ISTC-3510)

JUSTIFICATION:

These valves are located inside the primary containment. E4150F002 is the inboard containment isolation valve on the steam supply to the HPCI turbine. Closing this valve isolates the steam supply and renders the HPCI system inoperable. G1154F600 and G1154F018 are the inboard containment isolation valves for the Drywell floor and equipment drain pumps discharge lines, respectively. Closing these valves inhibits the ability to pump down the respective sump. All of these valves are normally open. Frequent operation can be a contributor to actuator and/or valve degradation. The failure of any of these valves, if stroked time tested at power, would result in a portion or the entire system becoming inoperable. 'Since the valves are inaccessible during operations a plant shutdown to correct the problem would be required.

COLD SHUTDOWN TESTING:

These valves will be full stroke exercised and stroke timed [closed (BTC) and/or open (BTO)],

as applicable, during cold shutdowns.

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 10

COLD SHUTDOWN JUSTIFICATION - CSJ-015 Revision 0 SYSTEM: EMERGENCY EQUIPMENT COOLING WATER VALVES:

Valve PIS No. Code Class Category ISI Drawing P4400F606A 2 A 6M721-5825-1 P4400F606B 2 A 6M721-5825-2 P4400F607A 2 A 6M721-5825-1 P4400F607B 2 A 6M721-5825-2 P4400F615 2 A 6M721-5825-2 P4400F616. 2 A 6M721-5825-1 FUNCTIONS:

These valves are primary containment isolation valves for the four EECW containment penetrations.

QUARTERLY TEST REQUIREMENTS: BTC Exercising (ISTC-3510)

JUSTIFICATION:

During power operation the RBCCW/EECW system supplies cooling water to the components inside the drywell, including the reactor recirculation pumps and motors and Drywell coolers.

Full stroke testing of these motor operated valves would interrupt cooling water flow to the reactor recirculation pumps and motors, potentially causing damage to these components. It would also interrupt cooling water to the DW coolers which may cause localized temperature spikes with adverse component impacts.

ALTERNATE TESTING:

These valves will be exercised and stroke time tested (BTO and BTC) during cold shutdown.

conditions.

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE))

COLD SHUTDOWN JUSTIFICA TION - CSJ-0] 7 Revision 0 SYSTEM: NITROGEN INERTING-PURGE SYSTEM VALVES:

Valve PIS No. Code Class Category ISI Drawing T4803F601 2 A 6M721-5830-1 T4803F602 2 A 6M721-5829 FUNCTIONS:

T4803F601, Nitrogen Inerting Drywell Air Purge Inlet Supply Valve (MO), and T4803F602, Nitrogen Inerting Drywell Inboard Exhaust Isolation Valve (MO), are both 24 inch diameter butterfly valves with motor actuators. They close to isolate the primary containment when required.

QUARTERLY TEST REQUIREMENTS: BTC Exercising (ISTC-3510)

JUSTIFICATION:

Both of these valves are located inside containment. These valves have very fast nominal closing times of approximately 3.5 seconds. The extremely high actuator rotational speeds could result in fairly rapid degradation rates for certain critical actuator parts, resulting in an increased potential of certain failure modes, e.g., failure of the MOV clutch mechanism. Lower stroke test frequencies combined with the diagnostic testing completed per the GL 96-05 Program on these valves will continue to ensure that degradation is detected in a tirnely manner.

COLD SHUTDOWN TESTING:

These valves will be exercise and stroke time tested (BTC) during cold shutdown conditions.

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 12

COLD SHUTDOWN JUSTIFICATION - CSJ-018 Revision 0 SYSTEM: NUCLEAR BOILER SYSTEM VALVES:

Valve PIS No. Code Class Category ISI Drawing B2103F016 1 A 6M721-5808-1 B2103F019 1 A 6M721-5808-1 FUNCTIONS:

These valves are the inboard and outboard containment isolation valves (CIV) for the main steam lines drains penetration. These valves are opened as required during plant startup to drain condensate from the main steam lines. During power operations these valves remain closed to isolate the penetration. During plant shut downs these valves are again opened and closed as necessary to drain the lines.

QUARTERLY TEST REQUIREMENTS: BTC Exercising (ISTC-3510)

JUSTIFICATION:

The safety position for these valves is the closed position, and they are in the safety position at all times during normal power operations. During power operations these valves could be considered as passive valves.

These valves are located in inaccessible areas, and if they were to fail in the open position during stroke time testing at power, they would not be repairable until the plant was shut down.

Plant LLRT data and inspection results indicate that stroking these valves at power results in premature valve wear and degradation of the valve's seat leakage performance. It has been determin'ed through investigation that this testing at power operating conditions causes increased wearing of the disc and in-body disc guides. During this testing the valve is opened at high differential pressure conditions, which can cause excessive wear on the valves in-body disc guides and the disc wedge guides. This results in accelerated degradation of the valve which could then prevent the valve froni performing its safety function of containment isolation.

Therefore, the conditions under which the valve could be tested at power are impractical in that they,place additional stress on the valve and unnecessarily reduce its life expectancy.

If the. valve stroke time testing were conducted only under cold conditions, this degradation would not occur.

COLD SHUTDOWN. TESTING:

These valves will be exercise and stroke time tested (BTC) under cold shutdown conditions.

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 13

COLD SHUTDOWN JUSTIFICATION - CSJ-019 Revision 0 SYSTEM: HIGH PRESSURE COOLANT INJECTION SYSTEM VALVES:

Valve PIS No. Code Class Category ISI Drawing E4100F220 2 C 6M721-5815 E4100F221 2 C 6M721-5815 FUNCTIONS:

A High Pressure Coolant Injection (HPCI) keep-fill system using condensate system water as an additional pressurization source was installed per EDP-29446. This modification was necessary because CST pressure (10-12 psig) alone was insufficient to prevent voiding upstream of the HPCI Injection Valve, E4150F006. Check valves E4100F220 and E4100F221 protect the lower pressure condensate system fiom HPCI discharge pressure when HPCI is operating.

These check valves are the class boundary isolation valves between the Class 2 HPCI injection piping and the Class D keep fill (condensate) piping. These check valves open to supply keep-fill water/pressure to the HPCI system and have a safety function to close on the initiation of the HPCI system so as to direct all HPCI flow into the vessel and to protect the keep-fill piping from over pressurization.

QUARTERLY TEST REQUIREMENTS: CT-C Exercising (ISTC-3510)

JUSTIFICATION:

These check valves tie into the HPCI system pump discharge piping downstream of the E4150F007 and are therefore potentially subject to pressures of greater than 1100 psig. The check valve testing methodology requires the installation of bypass hoses within the Class 2 boundaries and bypassing the inboard check valve. In this configuration the test lineup could subject the low pressure condensate piping to pressures in excess of their design pressure.

The installation. of the bypass hoses within the Class boundary results in HPCI being declared inoperable. Not only would the testing result in additional inoperable time for HPCI, but also would require additional fills and vents after the check valve testing. Additionally, testing during reactor operation has the potential to expose test personnel to HPCI pump discharge pressure, if the system were to auto-initiate, which is a personnel safety concern.

Under Cold Shutdown conditions, the HPCI auto start is inhibited and thus the personnel safety concern is eliminated. Also, no additional out of service time for HPCI will be incurred.

Plant operators observe the Keep Fill supply relief valve during HPCI system runs and regularly scheduled surveillance tests. No discharge from the relief valve indicates that the two check valves (as a pair) are closed and holding against HPCI pump discharge pressure.

COLD SHUTDOWN TESTING:

Check valve closed exercise testing (CT-C) will be conducted during cold shtitdown conditions.

IST PROGRAM PLAN PART 8 - COLD SHUTDOWN JUSTIFICATIONS PAGE 14

COLD SHUTDOWN JUSTIFICATION - CSJ-020 Revision 0 SYSTEM: HIGH PRESSURE COOLANT INJECTION SYSTEM VALVES:

Valve PIS No. Code Class Category ISI Drawing E4100F076 2 C 6M721-5815 E4100F077 2 C 6M721-5815 FUNCTIONS:

These two in-series check valves function to:

" Open to break vacuum in the HPCI Turbine Steam Exhaust Line resulting from condensing steam.

" Close to prevent HPCI Turbine exhaust steam from entering the Torus air space.

QUARTERLY TEST REQUIREMENTS: CT-O and CT-C Exercising (ISTC-3510)

JUSTIFICATION:

The open (CT-C) and closed (CT-C) exercise tests present a personnel safety concern when performed on a quarterly basis. The valves are above the torus, which is a, difficult and hazardous place to work. The testing is time-consuming and involves connecting and disconnecting hoses from multiple piping connections. The dose considerations and handling /

draining of radioactive fluid make this test impractical to perform every 92 days.

These tests were completed quarterly in the past and there has been no evidence of any problems or degradation of these valves. Consideration of bypassing containment isolation valves, HPCI out of service time, and the personnel safety and radiological concerns outweigh any safety benefit provided by more frequent IST examinations. An extended test frequency of Cold Shutdown will continue to provide reasonable assurance of continued acceptability of these check valves.

COLD SHUTDOWN TESTING:

The open (CT-0) and closed (CT-C) exercise tests for these check valves will be performed during cold shutdowns.

IST PROGRAM PLAN PART COLD SHUTDOWN JUSTIFICATIONS PAGE 15

FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES FERMI 2 THIRD 10 YEAR INTERVAL - START DATE 02/15/2010 PART 9:1IST PROGRAM REFUELING OUTAGE JUSTIFICATIONS REVISION 0 Revision Summary:

1. Complete rewrite for start of 3rd ten year interval ULAL Prepared: Date: 120____ PE-03 1 Program iager Reviewed: QL Date:iJ§% PE-03 L ISI/PEP Enginr Reviewed: 120 - 2X 6Jk-Super visor, Performance Eii ineering Date: S~7N/A Approved: -' l' >? . Date: ______"_ N/A anager, Performance Engineering INFORMATION AND PROCEDURES DSN: IST Programn ROJ Rev: 0 Date: 5- ~-

~

DTC: TM PLAN File: 1715.04 Recipient:_______

Date Approved: 4IV/R Qho-7 Release authorized by: N1/

~i

IST PROGRAM PLAN PART 9 REFUELING OUTAGE JUSTIFICATIONS (ROJ)

INDEX Refueling Outage Description Justification No.

ROJ-001 Feedwater Check Valves Closure Testing ROJ-002 EECW Check Valves Closure Testing ROJ-003 SRV/MSIV Accumulator Check Valves Functional Testing ROJ-004 Core Spray Injection Check Valves Functional Testing ROJ-005 Not used ROJ-006 RWCU Isolation Valves Stroke Time Testing ROJ-007 Not used ROJ-008 Not used ROJ-009 EECW Non-essential Load Return Check Valve Closnre Testing ROJ-010 CRD Check Valves Closure Testing ROJ-011 Not used ROJ-012 RHR SDC Thermal Relief Check Valves Functional Testing ROJ-013 RPV Level Backfill Check Valves Closure Testing ROJ-014 Not used ROJ-015 RHRSW/EDGSW Min Flow Valves Stroke Time Testing ROJ-016 Not used ROJ-017 Not used ROJ-018 SLC Pump Discharge Check Valves Closure Testing ROJ-019 SRV Vacuum Breaker Valves Functional Testing ROJ-020 Not used ROJ-021 Not used ROJ-022 RHR Shutdown Cooling Valves Stroke Time Testing ROJ-023 RHR Injection Check Valves Functional Testing IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 2

REFUELING OUTAGE JUSTIFICATION - ROJ-001 Revision 0 SYSTEM: FEEDWATER VALVES:

Valve PIS No. Code Class Category ISI Drawing B2100FOOA 1 A/C 6M721-5821 B2100F010B 1 A/C 6M721-5821 B2100F076A 1 A/C 6M721-5821 B2100F076B 1 A/C 6M721-5821 FUNCTIONS:

These check valves must close to isolate Primary Containment and to limit leakage to a specific amount. Valve B2100F076A must also close to ensure HPCI injection flow to the Reactor Vessel. Valve B2100F076B must also close to ensure RCIC injection flow to the Reactor.

Vessel.

QUARTERLY TEST REQUIREMENTS: CT-C Exercising (ISTC-3510)

JUSTIFICATION:

These check valves cannot be exercised to the closed (CT-C) position during reactor operation because the. feedwater system is needed to maintain primary coolant inventory and these valves can only close with the cessation of feedwater flow. The air operators on feedwater check valves B2100F076A and B2100F076B cannot close the valves against feedwater flow. Closure verification is perfonied via a leak test which requires system draining and test equipment setup.

This test evolution is not practical during cold shutdowns.

ALTERNATE TESTING:

These valves will be exercise tested in the closed direction (CT-C) during the Appendix J leak rate test (AT-1) of the feedwater penetrations during reactor refueling outages.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 3

REFUELING OUTAGE JUSTIFICATION- - ROJ-002 Revision 0 SYSTEM: EMERGENCY EQUIPMENT COOLING WATER VALVES:

Valve PIS No. Code Class Category ISI Drawing P4400F282A 3 A/C 6M721-5825-1 P4400F282B 3 A/C 6M721-5825-2 FUNCTIONS:

These check valves are primary containment isolation valves which isolate the Emergency Equipment Cooling Water (EECW) drywell return containment penetrations.

QUARTERLY TEST REQUIREMENTS: CT-C Exercising (ISTC-3510)

JUSTIFICATION:

During power operation the RBCCW/EECW system supplies cooling water to the components inside the drywell, including the Reactor Recirculation pumps and motors. Exercising check valves P4400F282A/B in the closed direction (CT-C) would require isolation of cooling water flow to the drywell, including flow to the reactor recirculation pumps and motors bearings, potentially causing damage to these components. Open functional testing is performed during normal power operation with flow.

It is not practical to test these valves Quarterly or during Cold Shutdowns as a drywell entry is required and the drywell.is inerted during operations and most cold shutdowns. Closure testing these valves also requires the reactor recirculation pumps to be shutdown. Shutting down and restarting these purips causes unnecessary wear and tear on the pumps, motors and seals as well as significant changes in reactor power level during operations. Starting and stopping the reactor recirculation pumps and de-inerting during cold shutdowns solely to allow inservice testing is not practical (Ref. NUREG 1482 Rev. 1, Sections 3.1.1.3 and 3.1.1.4).

ALTERNATE TESTING:

These valves will be exercised closed (CT-C) during reactor refueling outages.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 4

REFUELING OUTAGE JUSTIFICATION- ROJ-003 Revision 0 SYSTEM: NUCLEAR BOILER AND PRIMARY CONTAINMENT PNEUMATIC SUPPLY VALVES:

Valve PIS No. Code Class Category ISI Drawing B2100F029A 3 A/C 6M721-5808-1 B2100F029B 3 A/C 6M721-5808-1 B2100F029C 3 A/C 6M721-5808-1 B2100F029D 3 A/C 6M721-5808-1 T4901F019' 3 A/C 6M721-5856 T4901F022 3 A/C 6M721-5856 T4901F025 3 A/C 6M721-5856 T4901F028 3 A/C 6M721-5856 T4901F031 3 A/C 6M721-5856 T4901F034A 3 A/C 6M721-5856 T4901F034B 3 A/C 6M721-5856 T4901F034C 3 A/C 6M721-5856 T4901F034D 3 A/C 6M721-5856 T4901F039 3 A/C 6M721-5856 T4901F040 3 A/C 6M721-5856 FUNCTIONS:

These check valves must close upon loss of air / nitrogen supply to isolate their corresponding accumulator. These check valves isolate the accumulators for the SRVs with LLS / ADS function and MSIVs. These check valves must also open to supply air / nitrogen to the accumulators.

QUARTERLY TEST REQUIREMENTS: CT-O / CT-C Exercising (ISTC-3510)

JUSTIFICATION:

The change in obturator position of these simple check valves cannot be verified during normal plant operation or cold shutdown, as there are no external or control room indications. To verify the disk position requires special testing which requires access to these valves which are located in the drywell and main steam tunnel. De-inerting during cold shutdowns solely to allow inservice testing is not practical (Ref. NUREG 1482 Rev. 1, Section 3.1.1.3). Additionally, a portion of the testing to verify change in obturator position requires isolating the supply air to the accumulators. Test setup and valve access restrictions prevent testing these valves during power operations and cold shutdowns.

ALTERNATE TESTING:

These valves will be exercised open (CT-Q) and closed (CT-C) during reactor refueling outages.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 5

REFUELING OUTA GE JUSTIFICATION - ROJ-004 Revision 0 SYSTEM: CORE SPRAY VALVES:

Valve PIS No. Code Class Category ISI Drawing E2100F006A 1 A 6M721-5814 E2100F006B 1 A 6M721-5814 FUNCTIONS:

These valves are designated as pressure isolation valves (PIVs). Pressure isolation valves are defined as valves which isolate the portions of a system designed for low pressure service from the portions of a system connected to the Reactor Coolant Pressure Boundary (RCPB) which are designed for high pressure service. (Reference NUREG-0677)

QUARTERLY TEST REQUIREMENTS: CT-O / CT-C Exercising (ISTC-3510)

JUSTIFICATION:

Full flow injection testing of these valves is impractical and undesirable due to dead legs of water in the Core Spray piping, which would be flushed into the reactor vessel and seriously impact reactor water chemistry and clarity. During power operation these valves experience a 1000 psig pressure differential across their disks. The installed actuators are not designed to overcome this high pressure differential. If these valves could be stroked, routinely stroking during power operation would place the plant in an unsafe condition by potentially exposing low pressure piping to reactor coolant pressure. These valves are partially stroked open (CT-OP) and then stroked closed (CT-C) during Cold Shutdown conditions.

The full stroke functional testing cannot be done during Cold Shutdown conditions due to the need to access the valves which are located high up in the drywell. De-inerting during cold shutdowns solely to allow inservice testing is not practical (Ref. NUREG 1482 Rev. 1; Section 3.1.1.3).

ALTERNATE TESTING:

These valves will be exercised open (CT-O) and closed (CT-C) using a mechanical exerciser (torque wrench) during reactor refueling outages. This torque wrench exam is identified as exam code CT-F.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 6

REFUELING OUTAGE JUSTIFICATION - ROJ-006 Revision 0 SYSTEM: REACTOR WATER CLEANUP VALVES:

Valve PIS No. Code Class ISI Drawing Category G3352F001 1 A 6M721-5818 G3352F004 1 A 6M721-5818 G3352F220 1 A 6M721-5818 FUNCTIONS:

These valves provide isolation of the Reactor Water Cleanup System from the Primary Containment.

QUARTERLY TEST REQUIREMENTS: BTC Exercising (ISTC-3510)

JUSTIFICATION:

The Reactor Water Cleanup System (RWCU) is inservice during normal plant operations to maintain water purity, and provides a backup function during post accident cleanup. This system ensures that reactor chemistry is maintained within specified limits and process fluid radioactivity is minimized. These system functions are necessary to prevent the likelihood of exceeding 10CFR100 release limits and to maintain water purity to minimize the occurrence of stress corrosion cracking of the vessel and attached stainless steel piping systems.

Closing of the containment isolation valves to perform a full stroke test requires the removal of the RWCU system from service. Quarterly performance of this activity would also accelerate degradation of the RWCU pump seals due to stopping and starting the RWCU pumps with the reactor at operating pressure. This leads to increases in the frequency of RWCU pump seal failure. Replacing a pump seal causes water purity to degrade, and exposes Fermi personnel to approximately 2 to 3 man-rem of dose (per occurrence).

Cold shutdown stroke testing is not practical since it is more critical during a forced shutdown to have RWCU in-service to mitigate the effects of a chemistry transient as a result of the shutdown. Failure of these valves in the closed position, as a result of testing, during a cold shutdown outage would result in loss of the RWCU system and could inhibit the ability to recover from the chemistry transient. This could lead to a delay, in the plant startup, which impacts unit availability.

ALTERNATE TESTING:

These valves will be stroke time tested in the closed direction (BTC) at a Refueling Outage frequency.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 7

REFUELING OUTAGE JUSTIFICATION- ROJ-009 Revision 0 SYSTEM: CONTROL ROD DRIVE VALVES:

Valve PIS No. Code Class Category ISI Drawing P4400F246 3 C 6M721-5825-1 P4400F274 3 C 6M721-5825-2 FUNCTIONS:

These check valves isolate the non-essential Emergency Equipment Cooling Water return piping upon the initiation of the Emergency Equipment Cooling Water System. P4400F246 isolates the penetration cooling jackets and P4400F274 isolates the drywell sump heat exchanger, from the balance of the system.

QUARTERLY TEST REQUIREMENTS: CT-C Exercising (ISTC-3510)

JUSTIFICATION:

These valves cannot be exercised to the closed position during reactor refueling to satisfy the closed test (CT-C) requirement. They are located inside the drywell and are not accessible during the plant operation. Additionally these valves are simple check valves and cannot be tested remotely.

This testing is not practical during non-refueling Cold Shutdown conditions due to the need for drywell access and the duration/dose involved. De-inerting during cold shutdowns solely to allow inservice testing is not practical (Ref. NUREG 1482 Rev. 1, Section 3.1.1.3).

ALTERNATE TESTING:

These valves will be exercised closed (CT-C) during reactor refueling outages as required by Technical Specifications.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 8

REFUELING OUTAGE JUSTIFICATION - ROJ-010 Revision 0 SYSTEM: CONTROL ROD DRIVE VALVES:

Valve PIS No. Code Class Category ISI Drawing C1103F115 2 C 6M721-5810-1 FUNCTIONS:

For a scram to occur, the normally open C1103F115 must go closed in, order to direct flow into the Control Rod Drive and prevent back flow into the charging water header. There are a total of 185 Cl 103F115 valves, one for each of the 185 Hydraulic Control Units.

QUARTERLY TEST REQUIREMENTS: CT-C Exercising (ISTC-3510)

JUSTIFICATION:

The C1103F 15 will be tested in the closed direction (CT-C) during refuel outages as required by the UFSAR and Technical Specifications. During normal plant operation, the CRD pumps supply charging water through C1103F115 to the CRDs. The charging water also is used to cool the contiol rod drives. In order to test the Cl 103F1 15 in the closed direction, the CRD pumps must be shut down, thus interrupting the cooling water supply to all the control rod drives. The interruption of the cooling water to the control rod drive mechanisms would result in excessive temperatures in the drives with possible damage to the drive seals.

This testing is not practical to be performed during non-refueling Cold Shutdown conditions because of the duration and complexity of the testing and impact on the normal scheduling parameters for a forced outage scenario. In addition, this testing is specifically prescribed for refueling outage conditions by the UFSAR and Technical Specifications.

ALTERNATE TESTING:

These valves will be exercised closed (CT-C) during reactor refueling outages as required by Technical Specifications.

1ST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 9

REFUELING OUTAGE JUSTIFICATION- ROJ-012 Revision 0 SYSTEM: RESIDUAL HEAT REMOVAL VALVES:

Valve PIS No. Code Class Category ISI Drawing E1100F408 1 A/C 6M721-5813-1 E1100F409 1 C 6M721-5813-1 FUNCTIONS:

The safety function of these valves is to open to provide thermal relief protection between valves El 150F009, El 150F608, and E 1150F008. Additionally, valve El100F408 is required to close to satisfy its containment isolation function.

QUARTERLY TEST REQUIREMENTS: CT-O Exercising (ISTC-3510)

CT-C Exercising (ISTC-3510)

JUSTIFICATION:

Both of these valves are non-testable check valves located inside the primary-containment and .

have no remote flow or position indication. Testing of these valves inside the containment during power operation and when the drywell is inerted is unacceptable from both the ALARA

-and personnel safety perspectives. De-inerting during cold shutdowns solely to allow inservice testing is not practical (Ref. NUREG 1482 Rev. 1, Section 3.1.1.3). Additional problems associated with testing these valves during power operation involve the potential exposure of test personnel to reactor pressure during valve manipulations.

These valves serve as a thermal relief path and as such have no design flow. All that is required is that they open to relieve the hydraulic pressure between El.] 50F009, El 150F608, and El 150F008 produced by the thermal expansion of water in an isolated volume.

Since these valves are designed such that they begin to unseat at approximately I psid and are fully open at 4 psid, they will be tested by the applicatioi of pressure/flow across the valves at approximately 50 psig. This will assure that the valves are exercised (CT-0) to the full open position and are capable of performing their safety function to open.

The closing function of these valves will be verified by a back flow leakage test through the valve with an open vent downstream and sufficient pressure applied upstream. This reverse exercise testing is not practical during non-refueling Cold Shutdown conditions due to the need to secure RHR Shutdown Cooling while the reactor is in a short time to boil condition.

ALTERNATE TESTING:

El 100F408 and El 100F409 will be full stroked exercised open (CT-O) and closed (CT-C) during reactor refueling outages.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 10

REFUELING OUTAGE JUSTIFICATION - ROJ-013 Revision 0 SYSTEM: NUCLEAR BOILER, RPV WATER LEVEL INSTRUMENTATION BACKFILL VALVES VALVES:

Valve PIS No. Code Class Category ISI Drawing B2100F248A D A/C 6M721-5808-2 B2100F248B D A/C 6M721-5808-2 B2100F249A D A/C 6M721-5808-2 B2100F249B D A/C 6M721-5808-2 FUNCTIONS:

These backfill check valves function to provide continuous flow to the Reactor Pressure Vessel (RPV) Water Level Instrumentation from the Control'Rod Drive (CRD) System. This cross connect provides a path from Primary Containment through Secondary Containment, a Bypass Leakage path. These check valves serve as Bypass Leakage Valves and must close (CT-C) to perform their safety function.

QUARTERLY TEST REQUIREMENTS: CT-C Exercising (ISTC-3510)

JUSTIFICATION:

These check valves cannot be tested during reactor power operation, as the isolation of flow is required to perform the test. The instrument backfill flow is needed to prevent reactor water level indication errors during plant depressurization transients; Valve manipulations required to perform these tests, during system operation, could result in. a reactor scram. The back flow check valves will be verified to 1perform their safety function .to close during their seat leakage' test.

This testing is not practical during non-refueling Cold Shutdown conditions because of the time /

dose required to set up the leak rate testing equipment for the performance of the tests.

Bi-directional open testing is completed on a continuing basis while the plant is online based on.

satisfactory operation of the Reactor Water Level instrumentation.

ALTERNATE TESTING:

These check valves will be exercise tested in the close (CT-C) direction during reactor refueling outages.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 11

REFUELING OUTAGE JUSTIFICATION- ROJ-015 Revision 0 SYSTEM: RESIDUAL HEAT REMOVAL SERVICE WATER (RHRSW)

EMERGENCY DIESEL GENERATOR SERVICE WATER (EDGSW)

VALVES:

Valve PIS No. Code Class Category ISI Drawing El1F400A 3 B 6M721-5813-3 El1F400B 3 B 6M721-5813-3 E11F400C 3 B 6M721-5813-3 El1F400D 3 B 6M721-5813-3 R30F400 3 B 6M721-5813-3 R30F401 3 B 6M721-5813-3 R30F402 3 B 6M721-5813-3 R30F403 3 B 6M721-5813-3 FUNCTIONS:

Minimum flow valves assure minimum pump flow requirements are maintained for the RHRSW and EDGSW systems and thus assure the pumps are not damaged should the normal flow path be isolated or restricted. The subject valves are air-to-open and spring-to-close valves that fail closed on loss of air. These valves are normally closed and their safety function is to close which assures system flow is not diverted through the minimum flow lines back to the RHR reservoir. These systems are normally aligned for startup with open flow paths so that the minimum flow valve function to open is not required when the pumps are started.

QUARTERLY TEST REQUIREMENTS:. BTC Exercising (ISTC-3510)

JUSTIFICATION:

All 8 minimum flow valves have a control logic that does not provide the capability for stroke time testing. These valves automatically open when the pump discharge pressure is high and close when pressure decreases. There are no manual override switches or controls. High discharge pressure indicates that the normal pump flow path is either closed or severely restricted. Nonnal pressure indicates a viable flow path is available.

Current fail-safe testing (FST) of these valves is accomplished by manipulating service water flowrate and observing automatic operation. This testing is accomplished on a quarterly basis.

These valves have no remote position indicating devices and are only equipped with a local pointer on the stem which, at best, is a gross measure of position. From this indicator there is no way of knowing the exact starting open position of the valve or the exact travel distance from open to close. Also, the exact open starting position would vary from test to test, as the exact position would be a result of varying pressure within the system. This would make test repeatability difficult without significant modifications to the valve and its control logic.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 12

ROJ-015 (cont.)

In order to accurately and precisely stroke time these valves, it would be necessary to modify the control circuitry to allow for manual override operation. However, the installation of such controls would not improve system operation or contribute to system reliability. It would instead make operation more complicated by adding additional hardware whose only function is to allow stroke time testing of the valve.

It is possible to full stroke and time these valves on a less frequent basis using a temporary test rig. This requires the breaking of normal control air connections rendering the system to be inoperable. Because of the time limitations placed on the unavailability of safety systems and the potential damage to the connections after frequent disconnecting and reconnecting, conformance to the quarterly requirements would result in unusual hardship and difficulty without a compensating increase in the level of safety and quality (reference NUREG-1482 Rev.

1 Section 4.1.6).

This testing is not practical during non-refueling Cold Shutdown conditions because of its duration and safety system operability impact. The systems involved are relied upon for reactor safety during both operating and shutdown conditions. This testing is not within the normal scheduling parameters for a forced outage scenario and would create challenges for Operations

-to control and protect the operability of the opposite divisions during such testing.

ALTERNATE TESTING:

These valves will be stroked timed closed (BTC) at a Refueling Outage frequency. If necessary, these tests may be performed online (with specific IST concurrence) as PMT for emergent maintenance or as part of a long interval scheduled maintenance activity.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 13

REFUELING OUTAGE JUSTIFICATION - ROJ-018 Revision 0 SYSTEM: STANDBY LIQUID CONTROL (SBLC)

VALVES:

Valve PIS No. Code Class Category ISI Drawing C4100F033A 2 C 6M721-5811 C4100F033B 2 C 6M721-5811 FUNCTIONS:

The safety function of these check valves is to open upon Standby Liquid Control (SLC) system initiation and injection and to close to prevent back-flow through the non-running pump. The valves are normally closed lift check valves with internal springs to assist in closing.

QUARTERLY TEST REQUIREMENTS: CT-C Exercising (ISTC-3510)

JUSTIFICATION:

The open test, CT-O, for both valves is performed during the quarterly SLC pump and valve operability test.

Both of these valves are simple lift check valves and have no external arm or position indication.

The piping configuration upstream of each pumps discharge check valve is welded, so it is not possible to test the check valve in the closed direction by verifying that no back-flow is present with the opposite pump running without removing / disassembling the individual pump relief valves. Removal of these relief valves online would significantly increase system unavailability and is a level of intrusive maintenance.which is not justified against the benefits of a quarterly check valve test. Open functional testing (CT-O). for both valves is performed during the quarterly SLC pump and valve operability test.

The closure (CT-C) testing is not appropriate for non-refueling Cold Shutdown conditions due to the duration and intrusive nature of the testing. SLC pump discharge relief valves must be temporarily removed from the system to provide the vent path to perform the closing tests for these check valves. This testing is not within the normal scheduling parameters for a forced outage scenario and would require maintenance resources which would likely be devoted to critical forced outage recovery activities.

ALTERNATE TESTING:

These check valves will be exercise tested in the close (CT-C) direction during reactor refueling outages.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 14

REFUELING OUTAGE JUSTIFICATION- R OJ-019 Revision 0 SYSTEM: NUCLEAR BOILER, SRV VACUUM BREAKER VALVES VALVES:

Valve PIS No. Code Class Category ISI Drawing B2100F037A 3 C 6M721-5808-1 B2100F037B 3 C 6M721-5808-1 B2100F037C 3 C 6M721-5808-1 B2100F037D. 3 C 6M721-5808-1 B2100F037E .3 C 6M721-5808-1 B2100F037F 3 C 6M721-5808-1 B2100F037G 3 C 6M721-5808-1 B2100F037H 3 C 6M721-5808-1 B2100F037J 3 C 6M721-5808-1 B2100F037K 3 C 6M721-5808-1 B2100F037L 3 C 6M721-5808-1.

B2100F037M 3 C 6M721-5808-1 B2100F037N 3 C 6M721-5808-1 B2100F037P 3 C 6M721-5808-1 B2100F037R 3 C 6M721-5808-1 FUNCTIONS:

During an SRV discharge, these valves (SRV Vacuum Breakers) must be closed to direct the steam into the torus water. After an SRV discharge, the steam remaining in the SRV discharge line will condense and try to draw a vacuum in the line. These check valves (vacuum breakers) will open and permit the containment atmosphere to enter the line, thus relieving the vacuum condition.

QUARTERLY TEST REQUIREMENTS: CT-O / CT-C Exercising (ISTC-351.0)

JUSTIFICATION:

The only practical method for exercising these valves open and closed is by measuring opening force with a push-pull gage pushing the disk from its seat and visually verifying that the valve reseats manually. This type of exercise test (CT-F) verifies both open and close direction. Since this requires access to the valves, which are located in the drywell, the test will be deferred to refuel outage when the plant is shutdown and the drywell is de-inerted.

This testing is not practical during non-refueling Cold Shutdown conditions due. to the need for high drywell access and the duration/dose involved.

ALTERNATE TESTING:

These check valves will be full stroke exercise tested (CT-F) during reactor refueling outages.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 15

REFUELING OUTAGE JUSTIFICATION- ROJ-022 Revision 0 SYSTEM: RESIDUAL HEAT REMOVAL VALVES:

Valve PIS No. Code Class Category ISI Drawing E1150F008 1 A 6M721-5813-1 E1150F009 1 A 6M721-5813-1 El 150F015A 1 A 6M721-5813-2 E1150F015B 1 A 6M721-5813-1 E1150F608 1 A 6M721-5813-1 FUNCTIONS:

These valves are designated as pressure isolation valves (PIVs). Pressure isolation valves are defined as valves which isolate the portions of a system designed for low pressure service from the portions of a system connected to the Reactor Coolant Pressure Boundary (RCPB) which are designed for high pressure service. (Reference NUREG-0677 and ongoing RACTs commitment 94175). These valves also provide the flow-path for Shutdown Cooling operation.

QUARTERLY TEST REQUIREMENTS: BTO / BTC Exercising (ISTC-3510)

JUSTIFICATION:

Inadvertent opening of these valves is prevented by system interlocks that require the primary.

system pressure to be below the secondary design pressure prior to opening. Routinely stroking these valves open and closed (BTO and BTC) during power operation would place the plant in an unsafe condition by potentially exposing low pressure piping to reactor coolant pressure, which could result in inter-systenm LOCAs.

Interfacing system LOCAs produce consequences that are very difficult to mitigate. The best .

defense is to minimize the probability of occurrence. An important contribution to such minimization is to test pressure boundary valves only at conditions of low reactor vessel pressure..

Testing of these valves in a non-refueling Cold Shutdown condition can incur risk to reactor safety. During refueling conditions the reactor head is removed and the vessel is flooded up.

This greatly increases time to boil because of the large additional water volume as compared to a Cold Shutdown non-refueling situation. There are also more redundant decay heat removal options available during the refueling conditions than in cold shutdown condition. Testing of these valves involves interruption and/or reconfiguration of Shutdown Cooling. With reduced time to boil any interruptions of Shutdown Cooling incur additional risk. [Reference IST Evaluation 09-037 for detailed basis for this deferral to refueling outage interval]

ALTERNATE TESTING:

These valves will be stroke time tested (BTO and BTC) at a Refueling Outage frequency.

IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 16

REFUELING OUTAGE JUSTIFICATION- ROJ-023 Revision 0 SYSTEM: RESIDUAL HEAT REMOVAL VALVES:

Valve PIS No. Code Class Category ISI Drawing E1100F050A 1 A/C 6M721-5813-1 E1100F050B 1 A/C 6M721-5813-1 FUNCTIONS:

These valves are designated as pressure isolation valves (PIVs). Pressure isolation valves are defined as valves which isolate the portions of a system designed for low pressure service fi-om the portions of a system connected to the Reactor Coolant Pressure Boundary (RCPB) which are designed for high pressure service. (Reference NUREG-0677). These valves also provide the flow-path for Shutdown Cooling operation.

QUARTERLY TEST REQUIREMENTS: CT-O / CT-C Exercising (ISTC-3510)

JUSTIFICATION:

Full flow injection testing of these valves is not possible during power operation as there would be a pressure differential across these valves of approximately 1000 psid. The actuators on these valves are, by design, incapable of overcoming this high-pressure differential. Additionally, if these valves could be routinely, stroked during power operation, it would place the plant in an unsafe condition by potentially exposing low pressure piping to reactor coolant pressure.

Testing of these valves in a non-refueling Cold Shutdown condition can incur risk to reactor safety. During refueling conditions the reactor head is removed and the vessel is flooded up.

This greatly increases time to boil because of the large additional water volume as compared to a Cold Shutdown non-refueling situation. There are. also more redundant decay heat removal options available during the refueling conditions than in cold shutdown condition. Testing of these valves adversely impacts the redundancy of Shutdown Cooling. With reduced time to boil any adverse impact to Shutdown Cooling incurs additional risk. [Reference IST Evaluation 09-037 for detailed basis for this deferral to refueling outage interval]

Establishing a testing interval of every Refueling Outage eliminates the risks associated with inter-system LOCA and the risks associated with Shutdown Cooling manipulations during a non-refueling Cold Shutdown condition.

ALTERNATE TESTING:

El l 0OF05OA/B will be functionally tested (CT-O and CT-C), using the full stroke actuator, at a Refueling Outage frequency IST PROGRAM PLAN PART 9 - REFUELING OUTAGE JUSTIFICATIONS PAGE 17

1ST Program Plan Fermi 2 FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES FERMI 2 THIRD 10 YEAR INTERVAL - START DATE 02/15/2010 PART 10: IST PROGRAM TECHNICAL POSITIONS REVISION 0 Revision Sunmnary:

1. New documnent within the IST Program Plan beginning with 3rd ten year interval ULIAL Prepared: 1 4J Date: (__)_tD___k PE-12 L Reviewed: :12 Date: L-16-0( PE-12 OISI/PEP Engineer Reviewed____________ Date: 1/1 N/A SerisRr,Perfor:mance Eni eeriing Approved: Date _____ N/A Mar er, Perfoirmance Engineering INFORMATION AND PROCEDURES DSN: 1ST Program Tech Positions Rev: 0 Date: .(~I DTC: TM PLAN File: 1715.04 Recyent:

Date Approved: 6)JA- Jr'L~t Release authorized by:_f:S1,-

Revision Date: 061/62011 Page 116

IST Program Plan Fermi 2 IST PROGRAM PLAN PART 10 IST PROGRAM TECHNICAL POSITIONS INDEX Technical Position Description No.

TP-01 Bi-directional Testing of Check Valves TP-02 Preconditioning TP-03 Passive Valves without Test Requirements TP-04 Fail Safe Testing of Valves TP-05 Classification of Skid Mounted Components TP-06 Manual Valve Exercise Frequency TP-07 Outside Design Basis TP-08 Categorization of IST Pumps (Group A or B)

TP-09 Reference Value testing ranges TP-10 Stroke Timing of ADS Safety Relief Valves TP-1 1 Scheduling of exams with CSJ or ROJ applicability TP-12 Use of Linear'Regression for Pump Curves and Data Normalization of Test Results TP-13 Flow measurement accuracy using M&TE - Rosemount model 3051 /

Decade Box 25wohu / Digital Voltmeter TP-14 CRD valve testing per Technical Specifications Revision Date: 06162011 Page 2

- IST Program Plan Fermi 2 Technical Position TP-01 (Page 1 of 3)

Bi-directional Testing of Check Valves with Non-Safety Positions Purpose The purpose of this Technical Position is to establish the station position for the verification of the non-safety direction exercise testing of check valves by normal plant operations.

Applicability This Technical Position is applicable to those valves which are included in the Inservice Testing Program that are required to be exercised tested in their non-safety related direction of flow. This position applies to those check valves required to be tested in accordance with Subsection ISTC (ASME OM Code 2004 Edition through 2006 Addenda) and Appendix II.

This Technical Position does not apply .to testing of the safety function (direction) of check valves included in the Inservice Testing Program.

Background.

The ASME OM Code 2004 through 2006 Addenda section ISTC-3550, "Valves in Regular Use", states:

"Valves that operate in the course of plant operation at a frequency that would satisfy the exercising requirements' of this Subsection need not be additionally exercised, provided that the observations otherwise required for testing are made and analyzed during such operation and recorded in the plant record at intervals no greater than specified in ISTC-3510."

Section ISTC-3510 requires that check valves shall be exercised nominally every 3 months with exceptions for extended periods referenced.

Section ISTC-5221(a)(2) states:

"Check valves thaf have a safety function in only the open direction shall be exercised by initiating flow and observing that the obturator has traveled to either the full open position or to the position required to perform its intended function(s) (see ISTC-1 100),

and verify closure."

Section ISTC-5221(a)(3) states:

"Check valves that have a safety function in only the close direction shall be exercised by initiating flow and observing that the obturator has traveled [to] at least the partially Revision Date: 06162011 Page 3

IST Program Plan Fermi 2 Technical Position TP-01 (Page 2 of 3) open position, and verify that on cessation or reversal of flow, the obturator has traveled to the seat."

"The partially open position should correspond to the normal or expected system flow."

Normal and/or expected system flow may vary with plant configuration and alignment. Fermi Plant Operations staff is trained in recognizing normal plant conditions, For check valves that have a non-safety function in the open position, Operator judgment has been deemed acceptable in determining whether or not the normal or expected flow rates for plant'operation has been obtained. For check valves that have a non-safety related function in the closed -

position, Operator judgment is also deemed acceptable in determining whether or not flow has stopped relative to a normal or expected flow rate, in order to verify appropriate obturator travel.

Position Where feasible; an additional test will be established which provides direct quantifiable measurement of the check valve operation in the non-safety direction. Where plant design or system configuration does not support such a dedicated test, the following alternate verifications may be performed as follows:

1: An appropriate means shall be deternined which establishes the method for determining the open/closed non-safety function of the check valve during normal operations. The position detennination may be by direct indicator, or by other positive means such as changes in system pressure, flow rate, level, temperature, seat leakage, etc. This determinriation shall be documented in the respective Condition Monitoring Plan for the specific check valve group. For check valves included in the Inservice Testing Program and not included in the Condition Monitoring Plan, this determination shall be documented in the IST Bases Document for the specific check valve.

2. Observation and analysis of plant processes may be used to detennine that a check valve is satisfying its non-safety direction function. For an example, consider a check valve that has a safety function only in the closed direction but is normally open to provide a flow path to maintain plant operations. If this check valve does not open to pass sufficient flow when required, an alarm or indication would identify a problem to the operator. The operator would respond by taking the appropriate actions. A CARD would then be generated for the abnormal plant condition which would identify the check valve failure.

3. Observation and analysis of plant logs and other records may be an acceptable method for verifying 'a check valves non-safety direction function verification during normal plant operations.

Revision Date: 06162011 Page 4

IST Program Plan Fermi 2 Technical Position TP-01 (Page 3 of 3)

The open/closed non-safety function shall be recorded at a frequency required by ISTC-3510, nominally every 3 months, (with exceptions as allowed), in plant records such as Fermi Nuclear Operating Logs, Electronic Rounds, chart recorders, automated data loggers, etc. The safety function direction testing requires a Quality Record in the form of a surveillance test.

Records as indicated above in 1 through 3 are satisfactory for the non-safety direction testing.

A CARD shall be generated for any issues regarding check valve'operability.

Evaluations of applicability to this Technical Position are provided in the Basis Working Note section of the IST Basis for individual valves. These evaluations provide details on the methods by which the open / close function is being monitored on a continual basis during nonnal operations.

Justification This Technical Position establishes the acceptability of the methods used in determining the ability of a valve to satisfy its non-safety function. Through normal plant system operation and Operator actions, a valves non-safety function is verified through either observation or analysis of plant records and logs. Additionally, the recording of parameters which demonstrate. valve position is satisfied at a frequency in accordance with ISTC-3510. These actions collectively demonstrate the non-safety position of Inservice Testing Program check valves in regular use as required by ISTC-3550.

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IST Program Plan Fermi 2 Technical Position TP-02 (Page 1 of5)

Preconditioning Purpose The purpose of this Technical Position is to establish the Fermi IST Program position on preconditioning.

Applicability This Technical Position is applicable to IST Program pumps and valves.

Background

There are no ASME Code requirements regarding preconditioning or the necessity to perform as-found testing, with the exception of setpoint testing of relief valves and some guidance-in 10CFR50 Appendix J regarding leak rate testing of valves on extended frequencies.

Nevertheless, there has been significant concern raised by the NRC, and documented in numerous publications, over this issue. It is the intent of this Technical Position to provide a unified, consistent approach to the issue of preconditioning as it applies to the Fermi IST Program.

The purpose of IST is to confirm the operational readiness of pumps and valves within the .

scope of the IST Program to perform their intended safety functions whenever called upon.

This is generally accomplished by testing using quantifiable parameters which provide an indication of degradation in the performance of the component. Preconditioning can diminish or eradicate the ability to obtain any meaningful measurement of component degradation; thus -

defeating the purpose of the testing.

Preconditioning is defined as the alteration, variation, manipulation, or adjustment of the physical condition of a system, structure, or component before Technical Specification surveillance or ASME Code testing. Since IST is a component-level program, this Technical Position will address preconditioning on a component-level basis. Preconditioning may be acceptable or unacceptable.

Acceptable preconditioning is defined as preconditioning which is necessary for the protection of personnel or equipment, which has been evaluated as having insufficient impact to invalidate the results of the surveillance test, or which provides performance data or information which is equivalent or superior to that which would be provided by the surveillance test.

- Unacceptable preconditioning is preconditioning that could potentially mask degradation of a component and allow it to be returned to or remain in service in a degraded condition.

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IST Program Plan Fermi 2 Technical Position TP-02 (Page 2 of 5)

In most cases, the best means to eliminate preconditioning concerns is to perform testing in the as-found condition, prior to scheduled maintenance activities. When this is not practical, an evaluation must be performed to determine if the preconditioning is acceptable, unless the specific activity is already listed as acceptable in MOP03 Enclosure F or this Technical Position. Appendix I to this Technical Position may be used to document a preconditioning evaluation.

The acceptability or unacceptability of preconditioning should be evaluated on a case-by-case basis due to the extensive variability in component design, operation, and performance requirements. Preconditioning of pumps may include filling and venting of pump casings, venting of discharge piping, speed adjustments, lubrication, adjustment of seals or packing, etc.

Preconditioning of valves may include stem lubrication, cycling of the valve prior to the "test" stroke, charging of accumulators, attachment of electrical leads or jumpers, etc.

Factors to be considered in the evaluation of preconditioning acceptability include component size and type, actuator or driver type, design requirements, required safety functions, safety significance, the nature, benefit, and consequences of the preconditioning activity, the.

frequencies of the test and preconditioning activities, applicable service and environmental conditions, previous performance data and trends, etc. A general rule is that if an IST exam interval is at least four times shorter than the applicable periodic maintenance interval then that maintenance would not be considered as unacceptable preconditioning.. Example: A motor-operated valve (MOV) is stroke timed quarterly and has a PM event performed every 24:

months. The PM includes activities such as stem and gearing lubrication. That MOV has been stroke time tested seven times in a true as found condition prior to the PM. The PM is performed and the PMT stroke timing is counted as the eighth quarterly test. It is unreasonable to assume that significant degradation could have only occurred between the 7th test stroke and the PM.

Lubrication of a valve stem provides a good example of the variability of whether or not a preconditioning activity is acceptable. For example, lubrication of the valve stem of an MOV would have no beneficial impact on its stroke time measurements (see Conduct Manual MOPO3 Enclosure G). Lubrication of a valve stem for an air-operated valve (AOV) prior to exercise testing is likely to be unacceptable, unless it can be documented that the preconditioning (i.e., maintenance or diagnostic testing) can provide equal or better information regarding the as-found condition of the valve. Manipulation of a check valve or a vacuum breaker that uses a mechanical exerciser to measure breakaway force prior to surveillance testing would typically be unacceptable preconditioning. Additional information regarding preconditioning may be found in Fenni Conduct Manual MOP03 Enclosure F.

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IST Program Plan Fermi 2 Technical Position TP-02 (Page 3 of 5)

Definitions

" Preconditioning The alteration, variation, manipulation, or adjustment of the physical condition of an SSC before ASME Code surveillance testing. The scope of this requirement is limited to components tested in accordance with the ASME OM Code and 10CFR50 Appendix J for inservice testing (IST).

" Acceptable Preconditioning The alteration, variation, manipulation, or adjustment of the physical condition of an SSC before ASME Code surveillance testing:

- For the purpose of protecting personnel or equipment or to meet the manufacturer's recommendations.

. Which has been evaluated to have no adverse impact on the ability to detect degradation.

- Which is a scheduled activity being performed at an interval at least four times

- longer than the IST test interval.

" . Unacceptable Preconditioning Performance of a maintenance activity or an equipment manipulation activity which is consistently performed prior to each surveillance test and where the activity could mask an unacceptable condition that may have been detected during the surveillance test.

Position Preconditioning shall be avoided tinless a specific policy applies or an evaluation has been performed to determine that the preconditioning is acceptable. Appendix I to this Technical Position may be used as an aid within an IST Evaluation to document the preconditioning determination. In cases where the same information applies to more than one component, a single acceptability evaluation may be performed and documented.

The evaluations should be prepared, reviewed and approved by persons with the appropriate level of knowledge and responsibility. The evaluation should be approved by an Engineering Manager or designee.

If it is determined that an instance of preconditioning has occurred without prior evaluation, the evaluation should be performed as soon as practical following discovery. If the evaluation concludes that the preconditioning is unacceptable, a CARD shall be written to evaluate the condition and identify corrective actions.

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IST Program Plan Fermi 2 Technical Position TP-02 (Page 4 of5)

One example of acceptable preconditioning is the procedural allowance for a second stroke of an AOV or certain hydraulically-operated valves (HOV) when the initial stroke time is outside IST limits but within Owner Specified Limits (OSL). -This is a process specifically described in ASME OM Code Section ISTC. The purpose is to identify if actual degradation may have occurred or if some other factor caused the abnormal reading, such as how the stopwatch was. operated. Since the operability criteria (OSL) is not involved, this second stroke allowance does not constitute-unacceptable preconditioning.

10 CFR5O Appendix J-leak-rate tested valves follow the requirements as identified in this Technical Position. Appendix J valves will be as-found tested before any scheduled maintenance activities which could affect the valve's seat condition or closing force. If possible, the valve will be leak-rate tested prior to any stroking of the valve. If the required test conditions cannot be achieved (for example, to accommodate system draining) without stroking of the applicable valve, it is acceptable to cycle the affected valve as needed to achieve required test conditions.

Examples Acceptable Preconditioning:

1. Stroking of an MOV as part of a system starting sequence prior to the timed stroke of that MOV.

2. Lubrication of an MOV stem prior to a stroke timing exam. This applies to both AC and DC MOVs.

3. Operation of a pre-lube system prior to a start of a large pump or EDG.

4. Pump venting directly prior to testing, provided that the venting operation has proper controls with a technical evaluation to establish that the amount of gas vented would not adversely affect pump operation.

5. Running a pump (e.g. for PMT) prior to a surveillance test that only measures the differential pressure and flow is acceptable because the starting, stopping, or running of a pump prior to the test is not expected to improve the pump's performance during the test.

6. Stroking of an Appendix J valve prior to it's leak rate testing if necessary to establish required test conditions.

Unacceptable Preconditioning:

1. Lubrication of an AOV stem on a regular basis prior to surveillance testing of that AOV.

2. Lubrication of an AOV or MOV stem just prior to performance of an LLRT.

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IST Program Plan Fermi 2 Technical Position TP-02 (Page 5 of 5)

3. Routine calibration/adjustment of indicators prior to surveillance testing where the indication without adjustment might provide measurements outside surveillance acceptance criteria.

4, Maintenance on a leak-rate tested (LLRT) valve which improves the condition of the valve seats prior to the LLRT test.

5. Maintenance and adjustments which increase the seating force of an LLRT valve prior to performance of an LLRT.

Summary CARD 98-10548 documents Fermrui compliance to NRC Information Notice. 97-18 and evaluated site policies / processes for preconditioning. The policies contained in this IST Program Technical Position are in accordance with site policies as described in CARD 98-10548 and MOP03 Enclosure F. The intent of IST is to identify component degradation as early as possible and to ensure restoration of component capability prior to inability to perform its safety function. Testing in the as-found condition is the preferable way to perform IST, however there are situations where this is not feasible. Adherence to this Technical Position will ensure the intent of IST is met even in those situations.

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IST Program Plan Fermi 2 Technical Position TP-02 Appendix I EVALUATION OF PRECONDITIONING ACCEPTABILITY I. NRC Inspection Manual Part 9900 Review Answer the following questions to determine the acceptability of the preconditioning activity.

NOT YES NO DETERMINED

1. Does the alteration, variation, manipulation, or o o o adjustment ensure that the component will meet the surveillance test acceptance criteria?

2. Would the component have failed the surveillance Q o without the alteration, variation, manipulation, or, adjustment?

3. Does the practice bypass or mask the as-found o Q o condition?

4. Is the alteration, variation, manipulation, or o Qo adjustment routinely performed just before the testing?

5. Is the alteration, variation, manipulation, or o Q o adjustment performed only for scheduling convenience?

If all answers to Questions 1 through 5 are "No", the activity is acceptable. Otherwise, continue with Section II II. Additional Evaluation The following questions may be used to determine if preconditioning activities that do not meet the screening criteria of Section I are acceptable.

YES NO

6. Is the alteration, variation, manipulation, or adjustment required Q Q to prevent personnel injury or equipment damage? If yes, provide explanation.

7. Does the alteration, variation, manipulation, or adjustment .

provide performance data or information that is equivalent or superior to that provided by the surveillance test? If yes, provide explanation.

8. Is the alteration, variation, manipulation, or adjustment being Q Q performed to repair, replace, inspect, or test a component that.is .

inoperable or is otherwise unable to meet the surveillance test acceptance criteria? If yes, provide explanation.

9. Is there other justification to support classification of the Q Q alteration, variation, manipulation, or adjustment as acceptable preconditioning? If yes, provide explanation and references.

Provide sufficient details in the IST Evaluation to validate the answers to these questions.

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IST Program Plan Fermi 2 Technical Position TP-03 (Page 1 of 1)

Passive Valves without Test Requirements Purpose The purpose of this Technical Position is to establish the Fermi IST Program position for valves which perform a passive safety function. However, no testing is required in accordance with ISTC.

Applicability This Technical Position is applicable to valves that perform a passive function in accordance with ISTA-2000 and do not have inservice testing-requirements per Table ISTA-3500-1. This position is typical of Category B, passive valves that do not have position indication.

'An example is a manual valve which must remain in its normal position during an accident, to perform its intended function.'

Typically, manual valves that perform a safety function are locked in their safety position and administratively controlled by Fermi plant procedures. These valves would be considered passive.

If they do not have remote position indicating systems and categorized as B, they would not be subjected to any test requirements in accordance with Table ISTC-3500-1.

Justification Valves that meet.this position will not be listed in the IST Valve Scope Tables, however, the basis for categorization and consideration of active/passive functions shall be documented in the IST Program Basis Document.

Position-The Fermi Inservice Testing Program Part 5 - Valve Scope Tables, will not list valves that meet ALL of the following criteria.

• The valve is categorized B (seat leakage in the closed position is inconsequential for fulfillment of the valves' required function(s)) in accordance with ISTC-1300.

• The valve is considered passive (valve maintains obturator position and is not required to change obturatpr position to accomplish the required function(s)) in accordance with ISTA-2000.

• The valve does not have a remote position indicating system which detects and indicates valve position.

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IST Program Plan Fermi 2 Technical Position TP-04 (Page 1 of 1)

Fail Safe Testing of Valves Purpose e The purpose of this Technical Position is to establish the Fermi IST Program position for fail safe testing of valves in conjunction with stroke time exercising or position indication testing.

Applicability This Technical Position is applicable to valves with fail-safe actuators required to be tested in accordance with ISTC-3560.

Background

The ASME OM Code 2004 through 2006 Addenda section ISTC-3560 requires; .

"Valves with fail-safe actuators shall be tested by observing the operation of the actuator upon loss of valve actuating power in accordance. with the exercising frequency of ISTC-3510."

Justification Fail Safe Testing tests the ability of the fail safe mechanism of the valves to go to its fail safe condition. Whether or not the actuation of this fail safe mechanism is due to Operator Action or failure of the valves air / electric power source, the resultant action of the valve will be the same. Therefore, the verification of a valve fail safe ability can be taken credit for with the performance of either a stroke time exercising or full stroke position indication test Position In cases where the valve operator moves the valve to the open or closed position following de-energizing the operator electrically, by venting air, or both, the resultant valve exercise will satisfy the fail safe test requirements and an additional test specific for fail safe testing will not be performed.

Fermi will also use remote position indication as applicable to verify proper fail-safe operation, provided that the indication system for the valve is periodically verified in accordance with ISTC-3700.

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IST ProgramPlan Fermi 2 Technical Position TP-05 (Page 1 of 6)

Classification of Skid Mounted Components Purpose The purpose of this technical position is to clarify requirements for classification of various skid mounted components, and to clarify the testing requirements of these components.

Background

The ASME Code allows classification of some components as skid mounted when their satisfactory operation is demonstrated by the satisfactory performance of the associated major components. Testing of the major component is sufficient to satisfy Inservice Testing requirements for skid mounted components. In section 3.4 of NUREG 1482 Rev 1, the NRC supports the designation of components as skid mounted:

"The staff has determined that the testing of the major component is an acceptable means for verifying the operational readiness of the skid-mounted and component subassemblies if the licensee documents this approach in the IST Program. This is acceptable for both Code class components and non-Code class components tested and tracked by the IST Program."

In the 1996a addenda to the ASME OM Code (endorsed by IOCFR50.55(a) in October 2000),

the term skid-mounted was clarified by the addition of ISTA paragraph 1.7:

ISTA 1.7 Definitions Skid mounted components and component sub assemblies - components integral to or that support operation of major components, even though these components may not,be located directly on the skid. In general, these components are supplied by the manufactuier of the major component. Examples include: diesel skid-mounted fuel oil pumps and valves, steam admission and trip throttle valves for high-pressure coolant injection or Auxiliary Feedwater turbine-driven pumps, and solenoid-operated valve provided to control the air-operated valve.

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IST ProgramPlan Fermi 2 Technical Position TP-05 (Page 2 of 6)

This definition was further clarified in the 1998 and 2001 Editions of the ASME Code:

ISTA-2000 DEFINITIONS Skid mounted pumps and valves - pumps and valves integral to or that support operation of major components, even though these components may not be located directly on the skid. In general, these pumps and valves are supplied by the manufacturer of the major component. Examples include:

(a) diesel fuel oil pumps and valves; (b) steam admission and trip throttle valves for high-pressure coolant injection pumps; (c) steam admission and trip throttle valves for Auxiliary Feedwater turbine driven pumps; (d) solenoid-operated valves provided to control an air-operated valve.

Additionally the Subsections pertaining to pumps. (ISTB) and valves (ISTC) includes exclusions/exemptions for skid mounted components; ISTB-1200(c) Exclusions Skid-mounted pumps that are tested as part of the major component and are justified by the Owner to be adequately tested.

ISTC-1200 Exemptions Skid-mounted valves are excluded fromn this Subsection provided they are tested as part of the major component and are justified by the Owner to be adequately tested.

Position The 2004/2005a ASME OM Code definition of skid mounted will be used for.classification of components in the Fernn Inservice Testing Program. In addition, for a component to be considered skid mounted:

• The major component associated with the skid mounted component must be surveillance tested at a frequency sufficient to meet ASME Code test frequency for the skid mounted component.

" Satisfactory operation of the skid mounted component must be demonstrated by satisfactory operation of the major component.

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IST Program Plan Fermi 2 Technical Position TP-05 (Page 3 of 6)

" The IST Bases Document should describe the bases for classifying a component as skid mounted, and the IST Program Plan should reference this technical position for the component.

Recognition and classification of components as skid mounted eliminates the need for.the redundant testing of the sub componeit(s) as the testing of major (parent) component satisfactorily demonstrates operation of the "skid mounted" component(s).

The components designated as skid-mounted are identified as such in the IST Bases. These include auxiliary pumps for the Emergency Diesel Generators and the HPCI system. Also several valves mounted on the EDG skids which are part of the lube oil, fuel oil and cooling water sub-systems.

EDG-related Skid Mounted Pumps In addition to the component level justifications in the IST Bases, the following provides an overall description of the exclusion basis for several EDG-related pumps.

The following EDG support system pumps are designated as skid-mounted:-

Fuel Oil subsystem -

Motor-driven fuel oil pumps (R3001C021, C022, C023 and C024)

Engine-driven fuel oil pumps Engine Cooling subsystem -

Motor-driven standby jacket cooling pumps (R3001C025, C026, C027 and C028)

Engine-driven jacket coolant pumps Engine-driven air coolant pumps Engine Lube Oil subsystem -

Motor-driven standby lube oil pumps (R3001C017, C018, C019 and C020)

Motor-driven lube oil pre-lube pumps (R3001C013, C014, C015 and- C016)

Engine-driven lube oil pumps Justification Classification of components as skid-mounted eliminates the need for testing of sub components that are redundant with testing of major components. Testing of the major components demonstrates satisfactory operation of the "skid-mounted" components.

The following is a description of the system monitoring done for the EDG support systems skid-mounted pumps:

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IST Program Plan Fermi 2 Technical Position TP-05 (Page 4 of 6)

1. EDG motor driven fuel oil pump: This pump is a backup to the engine driven pump and has no safety function. It is used for Post Maintenance Testing and discharge fuel oil pressure is verified. Reliability is assured through periodic maintenance per 34.307.001.

2. EDG Engine-driven fuel oil pump: This pump is monitored by trending of fuel oil pressure. The capability of the pump is also checked via the 5 minute high load run (3150

- 3250 KW) contained in 24.307.45-48. The system engineers EDG system monitoring plan contains additional details on data collection and analysis.

3. EDG motor-driven standby jacket cooling pump: This pump is verified to work by jacket coolant temperature being maintained in standby. If the pump is not working, standby jacket coolant temperature will drop. Low jacket coolant temperature is alarmed. Standby jacket coolant temperature is recorded daily in Operator rounds. Standby jacket coolant temperature is trended by System Engineering. The system engineers EDG system monitoring plan contains additional details on data collection and analysis.

4. EDG engine driven jacket cooling pump: This pump is monitored by trending of jacket coolant pressure, jacket coolant pressure fluctuations and jacket coolant temperature in to and out of the engine. The system engineers EDG system monitoring plan contains additional details on data collection and analysis.

5.. EDG engine driven air coolant pump: water pressure in the air coolant loop is not monitored (no instrument).; Performance of the entire cooling loop (including the pump) is verified by trending of scavenge air temperature: The system engineers EDG system monitoring plan contains additional details on data collection and analysis.

6. EDG motor-driven standby lube oil pump: This pump is verified to work by lube oil temperature being maintained in standby. If the pump is not working, standby lube oil temperature will drop. Low lube oil temperature is alarmed. Standby lube oil temperature is recorded daily in Operator rounds. Standby lube oil temperature is trended by System Engineering. Reliability is assured through periodic maintenance per 34.307.001. The system engineers EDG system monitoring plan contains additional details on data collection and analysis.

7. EDG motor-driven Pre-lube pump: Reliability is assured through periodic maintenance per 34.307.001. Bearing checks done in 34.307.001 would indicate bearing damage if this pump were not working properly. System Engineers also check for proper operation of this pump when they observe surveillance testing. of the EDGs (verify slight increase in upper header lube oil pressure):

8. EDG engine driven lube oil pump: This pump is monitored by trending of lube oil pressure (at filter, strainer and upper lube oil header) and temperature into and out of the engine.

The system engineers EDG system monitoring plan contains additional details on data collection and analysis.

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IST Program Plan Fermi 2 Technical Position TP-05 (Page 5 of 6)

Additional skid-mounted components at Fermi:

Diesel GeneratorAir Starting System Control Valves are located on the engine skid. They perform the active safety function of opening to provide starting air to the diesel engine.

They also close to isolate starting air following an engine start or start failure to prevent bleeding the remaining compressed air from the air receiver. These valves will be tested as part of the monthly Diesel Generator testing subject to Technical Specification Surveillance Requirement 3.8.1.3 and 3.8.1.7 Control Rod Drive Valves are located on the hydraulic control units for the 185 control rod drives. They perform the active safety function of rapidly inserting the control rods into the reactor core, upon receipt of a reactor scram signal from the reactor protection system.

These valves will be tested as part of the control rod insertion times subject to the conservative limitations of Technical Specification Surveillance Requirements 3.1.4.1, 3.1.4.2, 3.1.4.3 and 3.1.4.4.

The High Pressure Coolantii ection (HPCI) Turbine Stop Valve has a design closure stroke time of 0.5 seconds. This rapid closure is accomplished by spring force. As a rapid acting valve, closure of this valve cannot be timed accurately nor trended from test-to-test.

In contrast, opening is accomplished hydraulically by oil pressure working against spring force. The valve has no independent manual control, but rather is controlled only by HPCI turbine oil pressure. The turbine stop valve.is a skid-mounted component of the HPCI turbine and structurally integrated with the turbine.

The HPCI Booster Pump, E4101C001B, ensures adequate NPSH is available to the Main Pump to prevent cavitations. The Booster Pump is a single stage centrifugal pump with a capacity of 5,100 gpm. Its normal speed range is between.1,000 rpm and 2,000 rpm. The pump is designed to pump water with a temperature range of 40 to 140degF. Booster Pump discharge pressure into the Main Pump is 290 psig at 2,000 rpm. The 12 inch piping connection between the booster pump and the main pump does include a 2 inch outlet which provides cooling water flow to the HPCI Lube Oil cooler and the barometric condenser. The flow in this line is controlled by design to 70 gpm (see HPCI Design Spec DSN: 22A1362AR). This flow control is established by the setpoint operation of the E41F035 valve as well as by restricting orifices E4150D008 and E4150D009. This flow path is not monitored during HPCI Pump IST, however due to its fixed value and the consistency of the testing methodology since the inception of IST there is no adverse impact. Performance testing of the Main pump adequately monitors the performance of the booster pump.

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IST Program Plan Fermi 2 Technical Position TP-05 (Page 6 of 6)

The HPCI Main and Auxiliary Oil Pumps provide pressurized oil for lubrication and control oil functions. The capacity of each pump is approximately 30 gpm. The DC motor-driven Aux Oil Pump supplies lubrication and control oil pressure at 90-100 psig to the turbine during startup, shutdown, and whenever the turbine speed is too low for the turbine driven Main Oil Pump to deliver operating pressure. A pressure switch in the Main Oil Pump discharge line controls automatic operation of the Aux Oil Pump. The Aux Oil Pump will start when HPCI receives an initiation signal and low oil pressure is sensed. The Main Oil Pump is driven by the HPCI Turbine shaft and delivers oil at 105-115 psig to the system once the turbine reaches a'speed of 1,450-1,650 rpm on start up. If turbine speed falls below 1,200-1,500 rpn during operation, the Mail Oil Pump can no longer maintain proper. operating oil pressure, and the Auxiliary Oil Pump will automatically start. Proper operation of the HPCI pump during testing and monitoring of several turbine/pump parameters ensures adequate performance of these oil pumps.

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IST Program Plan Fermi 2

-Technical Position TP-06 (Page 1 of 1)

Manual Valve Exercise Frequency Purpose The purpose of this Technical Position is to establish the Fermi IST Program position for the frequency of exercising those manual valves which are required to be exercised.

Applicability This Technical Position is applicable to the manual valves included in the Inservice Testing Program.

Background

The ASME OM Code 2004 through 2006 Addenda section ISTC-3540 states; "Manual valves shall be full-stroke exercised at least once every 5 years, except where adverse conditions' may require the valve to be tested more frequently to ensure operational readiness."

'Harsh service environment, lubricant hardening, corrosive or sediment laden process fluid, or degraded valve components are some examples of adverse conditions.

However, 10CFR50.55a(b)(3)(vi) states: " Exercise intervalfor manual valves. Manual valves must be exercised on a 2-year interval rather that the 5-year interval specified in paragraph ISTC-3540 of the 1999 Addenda through the latest edition and addenda incorporated by reference in paragraph (b)(3) of this section, provided that adverse conditions do not require more frequent testing."

Justification The NRC stipulates a frequency of exercising manual valves at least once every 2 years. This interval is more frequent than required by ASME OM Code 2004 through 2006 Addenda section ISTC-3540, therefore no other justification is required.

Position Fermi will perform exercising of manual valves within the scope of the IST Program at a frequency not to exceed 2 years. NOTE: At the present time there are no manual valves within the scope of the Fermi IST Program.

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IST ProgramPlan Fermi 2 Technical Position TP-07 (Page 1 of 2)

Outside Design Basis Purpose The purpose of this Technical' Position is to establish the Fernni IST Program position for scoping decisions on components which may be functionally credited within the Appendix R program but are not considered in the scope of the IST Program.

Applicability This Technical Position is applicable to components outside the scope of UFSAR Chapter 15 accident mitigation or which have no specific functional requirement to. achieve or maintain cold shutdown.

Background

The ASME OM Code 2004 through 2006 Addenda section ISTA-1100, "Scope", states that Inservice Testing requirements pertain to:

"Pumps and Valves that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident."

The Appendix R Program examines accident scenarios triggered predominantly by fires in various plant locations. An Appendix R scenario may verify the ability of operators to travel to a specific plant location and to manually manipulate a valve in a BOP system which would be operated as part of an orderly plant shutdown. The ASME IST scoping process looks at safety-related equipment - for example, the need to provide adequate makeup water to the reactor must be fulfilled by our ECCS systems with an underlying assumption that all non-ASME systems are unavailable. We would provide for testing of those ECCS systems to ensure they can meet their design basis capabilities. This is only one example of the differences between ASME IST pump and valve scoping and Appendix R scoping. Another example is the components installed in the T49 system under EDP 33934. This mod installed a sub-system of N2 bottles / piping / valves which would provide a backup to the Interruptible Air System for supplying air/N2 to the Division II SRVs. The Div II SRVs have an active opening. safety function within the IST Program to protect primary piping from over pressurization. This safety function is met by the ability of those SRVs to open as a relief valve against a spring-setpoint pressure. The air/N2 supply to these SRVs is only to allow for remote opening by Operations for testing or if Operations deems it necessary. There is no accident scenario within Chapter 15 which would require the capability for remote-manual operation of those SRVs. However, a specific Appendix R scenario based on certain fire-damage conditions Revision Date: 06162011 Page 21

IST Program Plan Fermi 2 Technical Position TP-07 (Page 2 of 2) determined that Operator ability to remotely open those SRVs needed to be assured. The components installed per EDP 33934 were not ASME Class 1,2 or 3.

Those components are not credited with an active safety function as defined by the ASME IST scoping definitions, and will not be tested under the auspices of the Fermi IST Program.

Justification Components credited in Appendix R or other outside design basis evaluations may or may not be safety-related. Testing of these components may be accomplished through the plant PM Program or other test scheduling processes. The expertise of the ISI/IST qualified personnel may be utilized to develop and even perform such testing. The IST Program involves a significant administrative burden and the scope of components within the program needs to be limited and in line with standard industry norms.

Position Consistent-with industry practice, components required solely to mitigate the consequences of 10CFR50 Appendix R fires and station blackout events are outside the scope of the IST Program since these events are beyond the facility design basis.

Beyond design basis events are initiated by multiple (and sometimes complete) failures of safety-related components and systems. The facility desigi is based on requirement that each safety system be capable of performing its safety-related functions given a failure of the most limiting active component. Although regulations have been imposed that require.the capability to cope with, or to mitigate these events, they are outside the scope of the facility accident analyses. Components whose sole safety functions are to mitigate these "outside design basis" events are not required by regulations to be classified as safety-related, nor would they meet the ASME OM Code scoping definitions.

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IST Program Plan Fermi 2 Technical Position TP-08 (Page 1 of 3)

Cate2orization of IST Pumps (Group A or B)

Position Fermi has categorized the pumps required to be included in the Inservice Testing Program as either Group A or B in accordance with the requirements of ISTB=2004/2006a.

Group A pumps are pumps that are operated continuously or routinely during normal operation, cold shutdown, or refueling operations. The following pumps are categorized as Group A:

Pump CIC Class Group Type Function El 1020002A 2 A Centrifugal Residual Heat Removal Pump A E1102C002B 2 A Centrifugal Residual Heat Removal Pump B E1102C002C 2 A Centrifugal Residual Heat Removal Pump C El 102C002D 2 A Centrifugal Residual Heat Removal Pump D El 15100IA 3 A Centrifugal RHR Service Water Pump A El 151C00IB 3 A Centrifugal RHR Service Water Pump B E11510001C 3 A Centrifugal RHR Service Water Pump C El 151C001D 3 A Centrifugal RHR Service Water Pump D T41000O40 3 A Centrifugal South CCHVAC Chilled Water Pump T41,00C041 3 A Centrifugal North CCHVAC.Chilled Water Pump Group B pumps are those pumps in standby systems that are not operated routinely except for testing. The following pumps are categorized as Group B (2):

Pump Number Class Group Type Function C4103C001A 2 B Pos. Displ. North Standby Liquid Control Pump C41030001B 2 B Pos. Displ. South Standby Liquid Control Pump E2101C001A 2 B Centrifugal Core Spray Pump A E2101C001B 2 B Centrifugal Core Spray Pump B E2101COOIC 2 B Centrifugal Core Spray Pump C E2101C001D 2 B Centrifugal Core Spray Pump D E410C00IA 2 B Centrifugal HPCI - Main Pump E4101C001B 2 B Centrifugal HPCI - Booster Pump P4400COOIA 3 B- Centrifugal Emergency Equip Cooling Water Div 1 Pump P4400CO01B 3 B Centrifugal Emergency Equip Cooling Water Div 2 Pump P4400C002A 3 B Centrifugal EECW Makeup Div 1 Pump Revision Date: 06162011 Page 23

IST Program Plan Fermi 2 Technical Position TP-08 (Page 2 of 3)

Pump Number Class Group Type Function P4400C002B 3 B Centrifugal EECW Makeup Div 2 Pump P4500C002A -3 B Centrifugal Emergency Equip Servine Water South Pump P4500C002B 3 B Centrifugal Emergency Equip Service Water North Pump R3000C001 - 3 B Pos. Displ. EDG 11 Diesel Fuel Oil Xfer Pump A R3000C002 3 B Pos. Displ. EDG 12 Diesel Fuel Oil Xfer Pump A R3000C003 3 B Pos. Displ. EDG 11 Diesel Fuel Oil Xfer Pump B R3000C004 3 B Pos. Displ. EDG 12 Diesel Fuel Oil Xfer Pump B R3000C009 3 B Pos. Displ. EDG 13 Diesel Fuel Oil Xfer Pump A R3000CO10 3 B Pos. Displ. EDG 14 Diesel Fuel Oil Xfer Pump A R3000COl - 3 B Pos. Displ. EDG 13 Diesel Fuel Oil Xfer Pump B R3000C012 3 B Pos. Displ. EDG 14 Diesel Fuel Oil Xfer Pump B R3001C005 3 B Centrifugal EDG 11 DG Service Water Pump R3001C006 3 B Centrifugal EDG 12 DG Service Water Pump R30010007 3 B Centrifugal EDG 13 DG Service Water Pump R3001C008 3 B Centrifugal EDG 14 DG Service Water Pump The following summarizes the Group A, B, and Comprehensive Pump Test requirements as specified by the ASME OM Code Subsection ISTB.

Group A Pump Tests - Group A tests are performed quarterly for each pump categorized as A.

The following inservice test parameters are measured for each Group A pump test:

- Speed (if pump is variable speed) e Differential Pressure e Discharge Pressure, (for positive displacement pumps) e Flow Rate

• Vibration Group B Pump Tests - Group B tests are performed quarterly for each pump categorized as B.

The following inservice test parameters are measured for each Group B pump test.

• Speed (if pump is-variable speed) e Differential PressureM e Flow RateM Note 1: For positive displacement pumps, flow rate shall be measured or determined, for all other pumps, differential pressure or flow rate shall be measured or determined.

Revision Date: 06162011 Page 24

IST Program Plan Fermi 2 Technical Position TP-08 (Page 3 of 3)

Comprehensive Pump Tests - Comprehensive pump tests (CPT) are performed biennially for all(') pumps in the Inservice Testing Program. The following inservice test parameters are measured for each Comprehensive pump test:

. Speed (if pump is variable speed)

• Differential Pressure

• Discharge Pressure, (for positive displacement pumps)

• Flow Rate - The ISTB Design Flow for the comprehensive pump test is the System's Accident Condition Flow for a single pump

• Vibration The following instrument accuracy requirements apply to each test type:

Parameter Group A' Group B Comprehensive Pressure .+/-2.0% .+/-2.0% +/-0.5%

Fidw Rate +/-2.0% +/- 2.0% +/-2.0%

Speed +/-2.0% +1-2.0% +/-2.0%

Vibration +/- 5.0% +/- 5.0% +/- 5.0%

Differential Pressure '+/- 2.0% +/- 2.0% +/- 0.5%

Note 2: For pumps covered under Relief Requests PRR-007 and PRR-008, the quarterly testing accomplishes the requirements for biennial CPT and no separate CPT testing shall be necessary.

As a reiuirement imposed by the NRC for approval of PRR-007 and PRR-008 Fernm has re-

- classified all of the applicable pumps as Group A. Quarterly testing of these pumps is and will be performed in a manner which meets the ISTB Group A testing requirements. In addition, Fermi is required to use pressure instrumentation accurate to CPT requirements (+/- 0.5%) and a.-

maximum DP criteria basis of 106% of reference DP. These requirements match the stipulations found in ASME Code Case OMN-18.

Note 3: For those pumps classified as Group A which are covered under Relief Requests PRR-07 and PRR-08, the'instrumentation used for quarterly testing shall meet the requirements for Comprehensive Pump Testing in ISTB-3510-I.

Revision Date: 061620 I1 Page 25

IST ProgramPlan Fermi 2 Technical Position TP-09 (Page 1 of 2)

Reference Value Testing Ranges Purpose The purpose of this Technical Position is to establish the station position for controlling pump testing reference value ranges.

Applicability This Technical Position is applicable to all pumps in the IST Program scope Justification The intent of Inservice Testing of pumps is to identify long or short term degradation. The method of accomplishing that objective is to create a repeatable hydraulic perfonnance test for each pump. This involves operation of the system and adjustment of a parameter such as flow to a specific fixed value and then recording the variable parameter(s) such as DP. A lowering-of the DP value. over time at a consistent test flow point is indicative of pump degradation. The problem lies with the ability of Operations to adjust the system consistently to a fixed reference.parameter.

Some systems contain throttling controls which allow for very precise increments of adjustment, while other systems have much coarser throttling capability.

The OM Code requires during subsequent inservice testing, after the establishment of reference values, that the flow rate or differential pressure be set to the exact reference value. The Code does not acknowledge the possibility that there may beliimitations in the ability to do this. This issue is discussed in NUREG 1482 Revision 1, Section 5.3, "Allowable Variance from Reference Points and Fixed-Resistance Systems. -

The NUREG discussion acknowledges that the Code does not allow for variance around a fixed reference value. It states: "The OM Code does not address the likelihood that it may not be possible to control a flow rate or differential pressure to an exact value." The NUREG conchides that when the Code specifies that the system resistance must be varied until the "set parameter" equals the corresponding reference value, it does not intend the "set parameter" to have an acceptable range as stated in the ISTB test acceptance criteria tables. The acceptance criteria ranges in these tables apply only to the parameter being determined after the resistance is varied.

The NUREG discussion stipulates that the reference value of the "set parameter" for certain pumps can only be achieved within a specified tolerance. It states: "...the allowed tolerance for setting the fixed parameter must be established for each case individually, including the accuracy of the instrument and the precision of its display." The "set parameter" may be adjusted "...as close as possible to the reference value during each test, rather than treating any variance in the value with a pump curve."

Revision Date: 06162011 . Page 26

IST Program Plan Fermi 2 Technical Position TP-09 (Page 2 of 2)

In NUREG-1482, the NRC recommendation section states: "The staff has determined that, if the design does not allow for establishing and maintaining flow at an exact value, achieving a steady flow rate or differential pressure at approximately the set value does not require relief for establishing pump curves." It further states that for Group A, Group B and Comprehensive tests, a total tolerance of +/-2 percent of the reference value for flow is allowed without prior NRC approval.

The IST Owners group (ISTOG) recently published a position paper with implementation guidance related to this issue. The ISTOG position is that an allowance of +1% / -2% for test to test control of the reference value, exclusive of instrument accuracy, is an acceptable method for meeting the intent of OM Code pump testing. This guidance paper has been provided to the NRC as a recommendation for inclusion in a planned revision to NUREG 1482.

The ASME OM Code committee for Pump Testing has recently prepared an OM Code revision which also provides for.a +1%/-2% acceptable range for reference values during testing.

Position Fermi will ensure procedural controls provide for reference value ranges not to exceed +1% / -2%

.nless specific NRC relief has been granted. Relief Request PRR-009 does provide such relief for the RHRSW, CCHVAC and EECW pumps.

Revision Date: 06162011 Page 27

1ST Program Plan Fermi 2 Technical Position TP-10 (Page 1 of 1)

Stroke Timing of ADS Safety Relief Valves Purpose The purpose of this Technical Position is to establish the IST Program position for stroke timing of selected SRVs.

Applicability This Technical Position is applicable to the following SRVs'which are aligned to the ECCS ADS function:

Valve PIS No. Code Class Category ISI Drawing B2104F013E 1 B/C 6M721-5808-1 B2104F013H 1 B/C 6M721-5808-1 B2104F013J 1 B/C 6M721-5808-1 B2104F013P 1 B/C 6M721-5808-1 B2104F013R 1 B/C 6M721-5808-1' Justification The functions of these five Safety Relief Valves (SRVs) are: 1) act as a primary system safety relief valve which actuates on high pressure; 2) open upon receipt of an ECCS auto depressurization signal to reduce reactor pressure and; 3) act as a primary system relief valve which can be manually actuated from the control room.

It is impractical to measure the stroke times for an SRV since the actual stem movement times are on the order of 100 msec. Steam flow measurements and/or turbine valve position will be used to verify that the SRVs have performed their function in less than or equal to 2 seconds. Time "zero" for this stroke time measurement corresponds to the instant the SRV pushbutton is depressed.

Position These valves will be tested normally during a plant start-up after the replacement of the SRVs/pilots and with the reactor at sufficient power and pressure to be able to verify a change in either steam line flow or turbine bypass valve position. The change in turbine bypass valve position or in steam line flow will be equal to the quantity of steam discharge by the open SRV.

Stroke timing of the valves will be done in the same manner with the stroke time being the time from when the open pushbutton is pushed till a change in steam line flow or turbine bypass valve position is noted.

No direct stroke time measurements will be performed. An abrupt change in turbine bypass valve position or steam line flow within 2 seconds will demonstrate valve operability.

Revision Date: 0616201/ Page 28

IST Program Plan Fermi 2 Technical Position TP-11 (Page .1of 1)

Work involving Cold Shutdown Justifications (CSJs) and Refueling Outage Justifications (ROJs)

Purpose The purpose of this Technical Position is to establish the IST Program position for scheduling of jobs involving components with CSJ or ROJ affected PMT.

Applicability This Technical Position is applicable to any components which have exams associated with a CSJ or ROJ.

Position Cold Shutdown Justification (CSJ) - An IST exam which has been evaluated and found to require cold shutdown plant conditions as a prerequisite for performance. These are exams for which issues such as access to test location, danger to personnel or equipment, system lineup requirements, etc. have led to determination that plant shutdown and cooldown below 200deg would be necessary for. their performance. An example of a CSJ exam would be a stroke time test on a Pressure Isolation Valve (PIV). PIVs provide a boundary between high pressure and low pressure portions of systems. Inadvertent-opening of a PIV could lead to over-pressurization and damage to the lower pressure rated portion of.a system.

Elective work shall not be scheduled online for components which would require a CSJ-coded exam as PMT.

Refueling Outage Justification (ROJ) --An IST exam which has been evaluated and found to involve sufficient difficulty and hardship to justify changing the test interval from quarterly to every refueling (18 months). ROJ coded exams will be performed during refueling outages. On a case-by-case basis (as approved specifically by the IST Engineer) a supplemental ROJ exam may be performed online. An example is the stroke time testing of EDG Service Water Min Flow valves. The difficulty and duration involved in setting up for this testing would make it a significant hardship to perform every 92 days as stipulated in ASME OM Code. An ROJ covers this testing and allows for extending the required interval from 92 days to every RFO. If an intrusive work order needed to be performed on any of these valves online the exam would have to be completed as PMT. However, a long interval (6 years or more) PM event could be scheduled and performed online with the'ROJ exam done as PMT. Performing an ROJ-coded exam online does not create a safety concern as would a CSJ exam. Frequent performance online of ROJ-coded exams would not be appropriate and would compromise the original ROJ evaluation.

Elective work, including long interval (>6 years) PMs, may be performed online using ROJ-coded .exams as PMT.

Revision Date: 06162011 Page 29

IST Program Plan Fermi 2 Technical Position TP-12 (Page 1 of 2)

Requirements for use of Linear Regression and Data Normalization related to Pump Curves Purpose The purpose of this Technical Position is to establish the IST Program position on developing a linear regression for portions of pump curves and for normalizing pressure data within a specific flow band.

Applicability This Technical Position is applicable to all IST program pumps.

Position USE OF LINEAR REGRESSION (reference IST Evaluation 87-053):

There are situations where a portion of a pump curve needs to be quantified with a pressure to flow relationship such that a derivation of one paranmeter can be made given a single value of the other parameter. Most pump curves have a non-linear pressure (head) to flow relationship over the entire curve; however, for specific portions of the curve the pressure to flow relationship may be proportional enough to use linear regression as the derivation technique. The following are guidelines and requirements to be used in establishing a linear regression for a pump curve:

GUIDELINE 1: It is recommended that at least 6 points be measured for actual flow. and pressure within the bounds of the linear regression region. -

REQUIREMENT 1: It is required that at least 4 points be measured for actual flow and pressure within the bounds of the linear regression region.

GUIDELINE 2: It is recommended that the correlation coefficient (R) for the linear relationship be greater than 0.960 [abs]. This provides high confidence and accuracy for deriving values using the regression equation.

REQUIREMENT 2: It is required that the correlation coefficient (R) for the linear relationship be greater than 0.920 [abs]. This provides sufficient confidence and accuracy for deriving values using the regression equation.

GUIDELINE 3: It is recommended that the valid range of "x", typically flow, be no lower than the lowest measured flow data point and no higher than the highest measured flow data point.

REQUIREMENT 3: It is required that the valid range of "x", typically flow, be no lower than 90% of the lowest measured flow data point and no higher than 110% of the highest measured flow data point.

Revision Date: 06162011 Page 30

IST Program Plan Ferimi 2 Technical Position TP-12 (Page 2 of 2)

DATA NORMALIZATION:

For pump testing where a reference band is allowed, there will be some scatter associated with the measured variable data. This guidance will allow the evaluator a method. to normalize that variable data in order to properly assess trends. The example used will be for a centrifugal pump where flow is set to an established reference value but allowance is given within the procedure for test flow to be plus or minus a given range about the reference value. Discharge and suction pressures are then measured at some measured flow value within the allowed test flow range.

The evaluator shall need to establish a known linear pressure-flow relationship, either from baseline data or from an assessment of a large quantity of pressure to flow data accumulated over several years. Using MS Excel, this linear relationship will need to be expressed as a table with at least 4 rows of data relating pressure to flow. One set~of values should be at or below the minimum end of the allowable test flow band, another set at or above the maximum end and the remaining data at or very close to the middle (reference flow). The evaluator shall then use the Excel Forecast function to input an actual measured test flow and derive what the DP should be.

The numerical difference between the derived DP and the DP at the center of the flow range-shall then be subtracted from or added to (as applicable) the actual measured DP for that test flow.

This should be done for all measured data to be used in the trend analysis. Below is an example:

RI-IRSW Pump B Baseline data table Test Derived values for Point Flow DP allowed test range of 4 4768 75.2 5300 - 5500 gpm 5 5410 59 5300 61.53947 6 6040 41.5 5400 58.89056 7 5407 59.2 5500 56.24165 Assume actual test measurements of 5362gpm / 60.3psid and 5465gpm / 56.6psid are being evaluated. The forecast DP at 5362 gpm is 59.73221 and the forecast DP at 5465 gpm is 57.16877.

For the 5362 gpm reading: 60.3 - (59.73221- 58.89056)= 59.46 For the 5465 gpm reading: 56.6 + (58.89056 - 57.16877) = 58.32 For the purposes of trending, the corrected values of 59.46 and 58.32 would be used for these two data points. Normalizing the DP in this manner eliminates the scatter that would be introduced by tests performed at flow values well above or below the reference flow.

Revision Date: 06162011 Page 31

IST ProgramPlan Fermi 2 Technical Position TP-13 (Page 1 of 1)

Flow measurement accuracy using M&TE - Rosemount model 3051 / Decade Box 250ohm / Digital Voltmeter Purpose The purpose of this Technical Position is to establish the IST Program position on the accuracy of flow readings taken using the standard M&TE setup connected to system.flow elements.

Applicability This Technical Position is applicable to all IST program pumps which are tested using this M&TE setup.

Justification Several surveillanne procedures stipulate-the use of the following temporary M&TE equipment

-for flow measurement

.- Rosemount model 3051Smart Pressure Transmitter

" Decade Box or dedicated 250 ohm test resistor

• Digital Voltmeter equipped for averaging function The Rosemount transmitter is connected directly to the flow element upstream (HP) and downstream (LP) pressure connections. The transmitter output is connected to a simple series circuit supplied with 24 VDC. The current through the 250 ohm resistor is a linear 0-20 mA directly proportional to the differential pressure (inH20) produced by the flow element. The -

voltmeter reads the voltage drop across the 250 ohm resistor. The procedures provide a data tablethat relates the Vdc (or inH2O) to system flow in gpm based on the flow element design data.

The accuracy of the Rosemount transmitter is 0.1% of full scale (0.7 iriH20 @ 700 inH20).

The precise accuracy at readings of interest is determined as follows:

Div 1.RHR Flow minimum = 10,000 gpm = 1.565 Vdc = 6.26 mA Div 1 RHRSW Flow minimum = 5300 gpm = 1.751 Vdc = 7.0 mA Div 1 EESW Flow minimum = 1660 gpm = 155.6 inH20 = 7.556 mA The 6.26mA minimum reading for RHR is the most limiting in terms of accuracy. The 6.26mA corresponds to 98.919 inH20. The specified accuracy is +/- 0.7 inH20 therefore the limiting accuracy for the Rosemount 3051 is 0.7 / 98.91.9 = 0.708%.

The individual accuracies of the digital voltmeter and decade box/resistor are both better than 0.01%. Conservative straight addition yields an overall accuracy of 0.708 + .01 + .01 =

0.728%.

Position A conservative value of +/- 0.8% total accuracy will be assumed for any flow readings taken using this typical M&TE setup.

Revision Date: 06162011 Page 32

IST Program Plan Fermi 2 Technical Position TP-14 (Page 1 of 1)

Testing of Control Rod Drive (CRD) mechanism valves per the Fermi Technical Specifications Purpose The purpose of this Technical Position is to establish the IST Program position on the testing intervals for CRD valves.

Applicability This Technical Position is applicable to. all IST program valves associated with the CRD units. A set of valves C1 103F114, C1103F126, and C1103F127 are located on each CRD hydraulic control unit Valve PIS No. Code Class Category ISI Drawing C1103F114 2 C 6M721-5810-1 C1103F126 2 B 6M721-5810-1.

CI103F127 2 B 6M721-5810-1 Justification For a scram to occur check valve C1103F1 14 must open (CT-0) and air operated valves Cl 103F126 and Cl 103F127 must open (BT-0).

ISTC requires that Category C check valves be exercised every 3 months to verify they fulfill their safety function.

OM-10 Paragraph 4.2.1.4(a), limiting value(s) of full stroke times shall be specified by the owner.

OM-10, Paragraph 4.2.1.8, test results shall be compared to the initial reference values established in accordance with paragraph 3.4 and 3.5.

Position The proper operation of each of these valves will be demonstrated during scram time testing. During scram time testing, each drive's scram insertion time is measured and a fail-safe actuator test is performed. Fermi 2's Technical Specifications provide a specific time for individual CRD scram insertion. If a particular CRD's scram insertion time is less than the specified time, the above valves are functioning properly.

Revision Date: 06162011 Page 33

JST Program Plan Fermi 2 Technical Position TP-14 (Page 2 of 2)

This testing will be performed at intervals specified by Fermi 2 Technical Specifications (TS). The applicable TS Surveillance Requirements (SR) are:

• SR 3.1.4.1 e SR 3.1.4.2 0 SR 3.1.4.3

. SR 3.1.4.4 Revision Date: 061620/1 Page 34