NRC-19-0047, Submittal of Valve Relief Requests for the Inservice Testing Program Fourth 10-Year Interval

Submittal of Valve Relief Requests for the Inservice Testing Program Fourth 10-Year Interval

ML19165A134
Person / Time
Site:	Fermi
Issue date:	06/14/2019
From:	Fessler P DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-19-0047
Download: ML19165A134 (33)

Text

Paul Fessler Senior Vice President and Chief Nuclear Officer DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4153 Fax: 734.586.1431 Email: paul.fessler@dteenergy.com June 14, 2019 10 CFR 50.55a NRC-19-0047 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Submittal of Valve Relief Requests for the Inservice Testing Program Fourth 10-Year Interval Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z), DTE Electric Company (DTE) hereby requests NRC approval of the following relief requests for the Fermi 2 Inservice Testing (IST) Program fourth 10-year interval, which begins on February 17, 2020 and ends on February 16, 2030.

VRR-004, Relief to Utilize Diagnostic Testing to Confirm Obturator Verification

VRR-006, Alternative for Preservice Testing of Butterfly Valves

VRR-007, Relief from Conducting Obturator Verification for Certain Power Operated Valves

VRR-009, Alternative for Motor Operated Valve Preservice/Inservice Testing The enclosures to this letter provide details of each of the individual relief requests.

Relief requests VRR-004, VRR-006, VRR-007, and VRR-009 are new relief requests for Fermi 2.

DTE requests NRC approval of relief requests VRR-004, VRR-007, and VRR-009 by March 16, 2020 to support planned testing during the next refuel outage scheduled in the spring of 2020.

DTE requests NRC approval of relief request VRR-006 by February 16, 2020 such that the request is approved prior to beginning the fourth 10-year interval.

No new commitments are being made in this submittal.

USNRC NRC-19-0047 Page 2 Should you have any questions or require additional information, please contact Mr. Jason R. Haas, Manager -Nuclear Licensing, at (734) 586-1769.

Sincerely, Paul Fessler Senior Vice President and CNO

Enclosures:

1. Relief Request VRR-004 for the IST Fourth 10-Year Interval

2. Relief Request VRR-006 for the IST Fourth 10-Year Interval

3. Relief Request VRR-007 for the IST Fourth 10-Year Interval

4. Relief Request VRR-009 for the IST Fourth 10-Year Interval cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

to NRC-19-0047 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request VRR-004 for the IST Fourth 10-Year Interval to NRC-19-0047 Page 1 10 CFR 50.55a Relief Request VRR-004 Relief to Utilize Diagnostic Testing to Confirm Obturator Verification Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

Alternative Results in Hardship Without a Compensating Increase in Quality and Safety

1. ASME Code Component(s) Affected The ASME code components affected by this relief request are listed in Attachment 1 to this Enclosure.

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda 10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication.

3. Applicable Code Requirement

ASME OM Code, 2012 Edition, Subsection ISTC-3700, Position Verification Testing, states that valves with remote position indicators shall be observed locally at least once every two years to verify that valve operation is accurately indicated. In addition, ISTC-3700 states that, where practicable, this local position indication observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position.

10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication, states that when implementing ASME Code, 2012 Edition, Subsection ISTC-3700, Position Verification Testing, licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation, to provide assurance of proper obturator position.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(2), relief is requested from the requirement of ASME OM Code ISTC-3700 and 10 CFR 50.55a(b)(3)(xi), for the subject valves. The basis of the relief request is that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

DTE is requesting to align the performance of obturator verification as required by 10 CFR 50.55a(b)(3)(xi) with the air operated valve (AOV) diagnostic test frequency of 10 years or less rather than with the position indication test frequency of ISTC-3700. Position indication testing will still be performed every two years in accordance with ISTC-3700.

to NRC-19-0047 Page 2 10 CFR 50.55a Relief Request VRR-004 Relief to Utilize Diagnostic Testing to Confirm Obturator Verification NRC Information Notice (IN) 2012-14, Motor-Operated Valve Inoperable Due to Stem-Disc Separation, (Reference 1) highlighted the need to supplement valve position indicating lights with other indications to provide assurance of proper obturator position. ASME Code, 2012 Edition, included requirements for the use of other indications to supplement position indicating lights in Subsection ISTC-3700 as practicable. For the purpose of this relief request, obturator verification is used to describe stem-to-disc attachment or integrity.

Techniques considered for obturator verification included flow testing, seat leakage testing, observation of pressure decay following unseating, and diagnostics.

In some cases, verification of obturator position through other indications would require establishment of complex testing schemes that would increase radiation dose exposure and potentially increase the risk to various systems and equipment. For other cases, diagnostics provides the only reliable means of obturator verification. An example is where the existing leakage test or process flow is unreliable because the valve orientation is flow under the seat (FUS). In the case of FUS, the plug/disc could lift and allow flow even when the stem and disc are not attached due to system or testing pressure. For other cases, use of diagnostics results in less plant/component impact than other potential methods while providing at least an equivalent level of quality and safety. An example is where an existing test would need to be created or significantly modified, such as when the existing leakage test boundary currently includes a group of valves.

Regardless of the specific case, obturator verification of each of the valves in Attachment 1 to this Enclosure presents hardship or difficulty without an increased level of quality and safety when compared to AOV diagnostic testing.

5. Proposed Alternative and Basis for Use

The proposed alternative is to supplement valve position indication with AOV diagnostic testing at a frequency of 10 years or less.

A maximum frequency of 10 years is based on the frequency currently recommended in the OM Code (2017 Edition, Reference 2), Appendix IV for high safety significant valves. This is conservative since the valves associated with this relief request have been ranked by the Fermi 2 probabilistic safety assessment (PSA) as low safety significant valves. Mandatory Appendix III of the OM Code (2012 Edition) also includes a maximum frequency of 10 years for obturator verification.

The testing capability for each of the valves subject to this relief request were reviewed by the AOV Engineer using past AOV diagnostic data. It was determined that the unseating event can be monitored with gate valves in the open direction. Similarly, the back-seating event for globe valves can be detected in the open direction using AOV diagnostics.

to NRC-19-0047 Page 3 10 CFR 50.55a Relief Request VRR-004 Relief to Utilize Diagnostic Testing to Confirm Obturator Verification Use of AOV diagnostics is the only practical method to perform obturator verification either because of the current valve and piping configuration is not designed to support the use of a seat leakage test or process observations or because of the complexity of revising an existing leakage test. Attachment 1 provides a description of the various bases for the cases and identifies the basis that applies for each valve of this relief request. In all cases, the AOV diagnostics method will ensure obturator verification without increasing risk to the equipment and dose to personnel.

6. Duration of Proposed Alternative

This proposed alternative will be utilized for the entire fourth 10-year interval. The fourth interval begins on February 17, 2020 and ends on February 16, 2030.

7. Precedent No precedent was identified for this relief request.

8. References

1. NRC Information Notice (IN) 2012-14, Motor-Operated Valve Inoperable Due to Stem-Disc Separation, dated July 24, 2012 (ML12150A046).

2. Division 1, Mandatory Appendix IV Preservice and Inservice Testing of Active Pneumatically Operated Valve Assemblies in Nuclear Reactor Power Plants (ASME OM-2017).

9. Attachments (1) Affected Components and Bases for Using AOV Diagnostics for Obturator Position Verification [6 pages]

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Page 1 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Type1 Valve Manu-facturer Valve Model Flow Direction2 Leak Test Basis B3100F014A Reactor Recirculation (RR)

Control Rod Drive (CRD) Supply to Division 1 Inboard Seal Cavity Inboard Containment Isolation AOV 2

A GL Rockwell 3624F316MMT FUS Individual A revision of the current leakage testing procedure would be complex and increase testing risk and dose to test operators.

B3100F014B RR CRD Supply to Division 2 Inboard Seal Cavity Inboard Containment Isolation AOV 2

A GL Rockwell 3624F316MMT FUS Individual Same as B3100F014A E4100F025 High Pressure Coolant Injection (HPCI) Barometric Condenser Condensate Outlet to Floor Drain (FD)

Outboard Isolation AOV 2

B GL Rockwell 3624GRIIMMT FOS None The local drain is not visible for operators to view flow. The drain line is in a congested /

high dose area next the turbine. There is no practical method to use a leakage test to perform obturator verification.

E4100F026 HPCI Barometric Condenser Condensate Outlet to FD Inboard Isolation AOV 2

B GL Rockwell 3624GRIIMMT FOS None Same as E4100F025

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Page 2 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Type1 Valve Manu-facturer Valve Model Flow Direction2 Leak Test Basis E4100F053 HPCI Turbine Exhaust Drain Pot Condensate Drain AOV 2

B GL Rockwell 3624MMLT2 FUS None A test using the process flow will not validate stem to disc integrity since flow is under the seat. No test connections exist in the piping system to develop a leakage test.

E5150F005 Reactor Core Isolation Cooling (RCIC) Division 2 Barometric Condenser Condensate Pump to Clean Radwaste Outboard Drain Isolation AOV 2

B GL Rockwell 3624GRIIMMT FUS None A test using the process flow will not validate stem to disc integrity since flow is under the seat. The existing piping configuration is not suitable to develop a leakage test to pressurize air over the seat.

E5150F025 RCIC Division 1 Steam Header Drain Pot to Condenser Inboard Drain Isolation AOV 2

B GL Flowserve D36124FJMMT2 FUS None A test using the process flow will not validate stem to disc integrity since flow is under the seat. The test connection needed to perform a leakage test to pressurize air over the seat is blocked by a piping support.

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Page 3 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Type1 Valve Manu-facturer Valve Model Flow Direction2 Leak Test Basis E5150F026 RCIC Division 2 Steam Header Drain Pot to Condenser Outboard Drain Isolation AOV 2

B GL Rockwell 3624GRIIMMT FUS None A test using the process flow will not validate stem to disc integrity since flow is under the seat. The current piping configuration does not have adequate isolation valves and test connections to develop a leakage test to allow flow over the seat.

P5000F403 Non-Interruptable Control Air Supply (NIAS) Isolation AOV 3

B GL Rockwell 3624F316MMT FUS None A complex leakage test would need to be developed. This test would increase risk to equipment and dose to test operators.

P5000F440 NIAS Station Air to Control Air Isolation AOV 3

A GA Powell 3003 WE FOS/Gate Group A revision of the current leakage testing procedure would be complex and potentially increase testing risk and dose exposure to test operators.

P5000F441 NIAS Station Air to Control Air Isolation AOV 3

A GA Powell 3003 WE FOS/Gate Group Same as P5000F440

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Page 4 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Type1 Valve Manu-facturer Valve Model Flow Direction2 Leak Test Basis T4800F416 Containment Atmospheric Control (CAC) N2 Inerting to Vacuum Breaker Valve T23-F400A N2 Supply Isolation AOV 2

A GL Rockwell 3624MMT FUS Individual Use of the process flow or revision to the existing leakage test is not practical to perform obturator verification since the current flow direction is under the seat.

T4800F417 CAC N2 Inerting to Vacuum Breaker Valve T23-F400B N2 Supply Isolation AOV 2

A GL Rockwell 3624MMLT2 FUS Individual Same as T4800F416 T4800F418 CAC N2 Inerting to Vacuum Breaker Valve T23-F400C N2 Supply Isolation AOV 2

A GL Rockwell 3624MMLT2 FUS Individual Same as T4800F416 T4800F419 CAC N2 Inerting to Vacuum Breaker Valve T23-F400D N2 Supply Isolation AOV 2

A GL Rockwell 3624MMLT2 FUS Individual Same as T4800F416 T4800F420 CAC N2 Inerting to Vacuum Breaker Valve T23-F400E N2 Supply Isolation AOV 2

A GL Rockwell 3624MMLT2 FUS Individual Same as T4800F416

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Page 5 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Type1 Valve Manu-facturer Valve Model Flow Direction2 Leak Test Basis T4800F421 CAC N2 Inerting to Vacuum Breaker Valve T23-F400F N2 Supply Isolation AOV 2

A GL Rockwell 3624MMLT2 FUS Individual Same as T4800F416 T4800F455 CAC N2 Inerting Drywell N2 Makeup Inboard Isolation AOV 2

A GL Rockwell 3624MMT FOS/FUS Group A revision of the current leakage testing procedure would be complex and increase testing risk and dose to test operators.

T4800F456 CAC N2 Inerting to Standby Gas Treatment System (SGTS) N2 Supply Bypass Isolation AOV 2

A GL Rockwell 3624MMT FOS Group Same as T4800F455 T4800F457 CAC N2 Inerting to SGTS N2 Supply Bypass AOV 2

A GL Rockwell 3624MMT FOS/FUS Group Same as T4800F455 T4800F458 CAC N2 Inerting to SGTS N2 Supply Bypass AOV 2

A GL Rockwell 3624MMT FUS Group Same as T4800F455 T4901F467 Primary Containment (PC)

Pneumatic Division 1 NIAS Isolation AOV 3

B GL Rockwell 3624MMT FUS None A complex leakage test would need to be developed. This test would increase risk to equipment and dose to test operators.

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Page 6 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Type1 Valve Manu-facturer Valve Model Flow Direction2 Leak Test Basis T4901F468 PC Pneumatic Division 2 Supply Outboard PC Isolation AOV 2

A GL Rockwell 3624MMLT2 FUS Group A revision of the current leakage testing procedure would be complex and increase testing risk and dose to test operators.

Table Footnotes:

1: Valve types - GL = globe, GA = gate 2: Flow direction - FOS = flow over seat, FUS = flow under seat

to NRC-19-0047 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request VRR-006 for the IST Fourth 10-Year Interval to NRC-19-0047 Page 1 10 CFR 50.55a Relief Request VRR-006 Alternative for Preservice Testing of Butterfly Valves Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Plant Drawing T4803F601 Containment Atmospheric Control (CAC) N2 Inerting Drywell Air Purge Inlet Supply Valve 2

A M-5739-1 T4803F602 CAC N2 Inerting Drywell Inboard Exhaust Isolation Valve 2

A M-5737

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda

3. Applicable Code Requirement

ASME OM Code Mandatory Appendix III, Preservice and Inservice Testing of Active Electric Motor Operated Valve Assemblies in Light-Water Reactor Power Plants, Section III-3200, Preservice Test, states that each Motor Operated Valve (MOV) shall be tested during the preservice test period or before implementing inservice testing. Section III-6100, Acceptance Criteria, states that [t]hrust, torque, or other measured engineering parameters correlated to thrust or torque consistent with [Paragraphs] III-6100 through III-6500, may be used to establish the acceptance criteria. Motor control center testing is acceptable if correlation with testing at the MOV has been established.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(1), relief is requested to deviate from OM-2012 Appendix III, Paragraph III-3200, which requires each MOV to be tested in accordance with the requirements of Appendix Paragraph III-6100 prior to implementation of inservice testing. The basis of the relief request is that the proposed alternative will provide an acceptable level of quality and safety.

Preservice testing that meets the requirements of Paragraph III-6100 has not yet been performed for these valves. This testing requires plant cold conditions. The next testing opportunity is the next refueling outage, which is scheduled for the spring of 2020 (vs. an Appendix III required implementation date of 2/17/2020).

to NRC-19-0047 Page 2 10 CFR 50.55a Relief Request VRR-006 Alternative for Preservice Testing of Butterfly Valves

5. Proposed Alternative and Basis for Use

The proposed alternative is to measure torque during a static diagnostic test during the first refueling outage after Appendix III implementation for each valve. The first refueling outage is planned for the spring of 2020. This test will serve as the preservice test for each valve.

T4803F601 and T4803F602 are butterfly valves. T4803F601 and T4803F602 are not practicable to test under dynamic conditions. The valves are all Class A under the Joint Owners Group (JOG) Periodic Verification approach. Bearing degradation was addressed by applying the JOG threshold Coefficient of Friction (COF) to these valves.

Design basis testing for each valve to meet Generic Letter (GL) 89-10 requirements consisted of a diagnostic test conducted under static conditions. During GL 89-10 implementation, valve travel in both directions was interrupted by a limit switch. A torque switch was included in the control circuit. Torque measured at torque switch trip was corrected and compared to the minimum required torque under design basis conditions to demonstrate margin was available.

Subsequent to GL 89-10 testing, a plant modification was implemented to remove the torque switch from the valve control circuit for the listed valves. Thus, the original testing methodology of measuring torque at torque switch trip was no longer possible. Since the valves have significant margin between actuator capability and valve operating requirements, a combination of condition monitoring from periodic motor control center testing and local leak rate testing is used to monitor for valve / actuator degradation. While this practice provides acceptable monitoring of valve / actuator condition, it does not meet Appendix III Section 6100 requirements for acceptance criteria.

Motor control center testing, preventive maintenance activities, stroke timing and periodic exercising and leak rate testing have been conducted for these valves. No anomalies or adverse trends have been identified from the motor control center testing. Stroke times have been consistent. No adverse findings have been identified in the preventive maintenance activities. While some local leak rate results have necessitated corrective actions, the causes of the leakage were not related to actuator capability or valve operational capability. This provides confidence that these valves and actuators will remain capable of meeting design basis requirements until the preservice test is performed.

6. Duration of Proposed Alternative

This proposed alternative will be utilized from the beginning of the fourth 10-year interval on February 17, 2020 until the end of the refueling outage in the spring of 2020. The testing to NRC-19-0047 Page 3 10 CFR 50.55a Relief Request VRR-006 Alternative for Preservice Testing of Butterfly Valves during the refueling outage in the spring of 2020 will then be used as the preservice testing for the duration of the fourth interval, which ends on February 16, 2030.

7. Precedent No precedent was identified for this relief request.

to NRC-19-0047 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request VRR-007 for the IST Fourth 10-Year Interval to NRC-19-0047 Page 1 10 CFR 50.55a Relief Request VRR-007 Relief from Conducting Obturator Verification for Certain Power Operated Valves Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

Alternative Results in Hardship Without a Compensating Increase in Quality and Safety

1. ASME Code Component(s) Affected The ASME code components affected by this relief request are listed in Attachment 1 to this Enclosure.

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda 10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication.

3. Applicable Code Requirement

ASME OM Code, 2012 Edition, Subsection ISTC-3700, Position Verification Testing, states that valves with remote position indicators shall be observed locally at least once every two years to verify that valve operation is accurately indicated. In addition, ISTC-3700 states that, where practicable, this local position indication observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position.

10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication, states that when implementing ASME Code, 2012 Edition, Subsection ISTC-3700, Position Verification Testing, licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation, to provide assurance of proper obturator position.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(2), relief is requested from 10CFR50.55a(b)(3)(xi), for the subject valves. The basis of the relief request is that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

NRC Information Notice (IN) 2012-14, Motor-Operated Valve Inoperable Due to Stem-Disc Separation, (Reference 1) highlighted the need to supplement valve position indicating lights with other indications to provide assurance of proper obturator position. ASME Code, 2012 Edition, included requirements for the use of other indications to supplement position to NRC-19-0047 Page 2 10 CFR 50.55a Relief Request VRR-007 Relief from Conducting Obturator Verification for Certain Power Operated Valves indicating lights in Subsection ISTC-3700 as practicable. 10CFR50.55a(b)(3)(xi) does not allow for exceptions for the use of other indications to supplement position indicating lights.

For the purpose of this relief request, obturator verification is used to describe stem-to-disc attachment or integrity. In addition, position indication testing in accordance will still be performed every two years in accordance with ISTC-3700.

Obturator verification of each of the valves in Attachment 1 to this Enclosure presents hardship or difficulty without an increased level of quality and safety. The specific hardship or difficult for each valve is provided in Attachment 1 to this Enclosure.

5. Proposed Alternative and Basis for Use

The proposed alternative is to supplement valve position indication with other indications to provide assurance of proper obturator position except for those cases identified in this relief request where obturator verification is not necessary or results in a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Techniques considered for obturator verification included flow testing, seat leakage testing, observation of pressure decay following unseating, and diagnostic testing. In some cases, verification of obturator position through other indications would require establishment of complex testing schemes or valve disassembly. For these situations, the licensee reviewed each power-operated valve individually to determine if the verification process would provide a compensating increase in quality and safety.

Establishment of a complex testing scheme or performance of valve disassembly to confirm obturator position can require safety system outages and can result in significant dose and system upsets. In most cases, the potential for a stem to disc separation is very low. In addition, there are a few stop check valves for which the stem is not attached to the disc by design, so that obturator verification is not necessary.

provides a description of the various bases for each valve of this relief request to exclude obturator position verification through other indications as required by 10CFR50.55a(b)(3)(xi). For each valve, obturator position verification is not practicable per ASME OM Code, 2012 Edition, Subsection ISTC-3700.

6. Duration of Proposed Alternative

This proposed alternative will be utilized for the entire fourth 10-year interval. The fourth interval begins on February 17, 2020 and ends on February 16, 2030.

to NRC-19-0047 Page 3 10 CFR 50.55a Relief Request VRR-007 Relief from Conducting Obturator Verification for Certain Power Operated Valves

7. Precedent No precedent was identified for this relief request.

8. References

1. NRC Information Notice (IN) 2012-14, Motor-Operated Valve Inoperable Due to Stem-Disc Separation, dated July 24, 2012 (ML12150A046).

9. Attachments (1) Affected Components and Bases for Exclusion of Obturator Position Verification

[9 pages]

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Page 1 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Typea Actuator Typeb Flow Directionc Leak Test Basis C1100F011 Control Rod Drive (CRD)

Scram Discharge Headers Clean Radwwaste Drain AOV 2

A GL AO FUS Individual NOTE 1 C1100F181 CRD Scram Discharge Volume to Torus Room Sump G1101D065 Drain AOV 2

A GL AO FUS Individual NOTE 1 E1100F078 Residual Heat Removal (RHR) Reactor Vessel Emergency Injection Line Check AOV 2

C CK AO FOS No This valve is an interface between service water and RHR for emergency reactor vessel injection of service water. This configuration prevents using process flow.

The valve is exercised with an actuator as there is no way to perform mechanical exercise and measure torque.

The valve has a periodic maintenance (PM) activity to disassemble and inspect internals, but the PM frequency (i.e. every 8 refueling outages) is much less frequent than would be necessary to meet 10 CFR 50.55a(b)(3)(xi).

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Page 2 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Typea Actuator Typeb Flow Directionc Leak Test Basis E1150F017A RHR Division 1 Low Pressure Coolant Injection (LPCI) MOV 2

B GL MO FUS No NOTE 1.

In addition, the risk of stem/disc separation would be minimal since the valve is normally cycled under near-static conditions.

E1150F048B RHR Division 2 Heat Exchanger "B" Bypass MOV 2

B GL MO FUS No NOTE 1.

In addition, the risk of stem/disc separation would be minimal since the valve is normally cycled under near-static conditions.

E4100F028 HPCI Turbine Supply Drain Pot to Main Condenser Drain Line Isolation AOV 2

B GL AO FUS No NOTE 1 E4100F029 HPCI Turbine Supply Drain Pot to Main Condenser Drain Line Isolation AOV 2

B GL AO FUS No NOTE 1 E4100F054 HPCI Turbine Steam Line Drain Pot Steam Trap Bypass AOV 2

B GL AO FUS No NOTE 1 E4150F012 High Pressure Coolant Injection (HPCI) Main Pump E4101C001A Minimum Flow to Suppression Chamber Isolation MOV 2

B GL MO FUS No NOTE 1 E4150F021 HPCI Turbine Exhaust Stop Globe MOV 2

B/C SCK MO FUS No NOTE 2

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Page 3 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Typea Actuator Typeb Flow Directionc Leak Test Basis E4150F022 HPCI Turbine Exhaust Condensate Drain to Suppression Pool Stop Check MOV 2

B/C SCK MO FUS No NOTE 2 E4150F059 HPCI Lube Oil Cooling Water Supply Isolation MOV 2

B GL MO FUS No NOTE 1 E4150F600 HPCI Turbine Steam Supply Line E4150F003 Bypass MOV 1

A GL MO FUS Group NOTE 1 E5150F001 Reactor Core Isolation Cooling (RCIC) Turbine Exhaust Line Isolation MOV 2

B/C SCK MO FUS No NOTE 2 E5150F002 RCIC Barometric Condenser Vacuum Pump Discharge Stop Check MOV 2

B/C SCK MO FUS No NOTE 2 E5150F004 RCIC Division 1 Barometric Condenser Condensate Pump to Clean Radwaste (CRW) Inboard Drain Isolation AOV 2

B GL AO FUS No NOTE 1 E5150F022 RCIC Supply to Condensate Storage Tank (CST) Test Isolation MOV 2

B GL MO FUS No NOTE 1 E5150F046 RCIC Lube Oil Cooler Cooling Water Supply Isolation MOV 2

B GL MO FUS No NOTE 1

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Page 4 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Typea Actuator Typeb Flow Directionc Leak Test Basis P4400F604 EECW Division 2 Supply to CRD Pumps Isolation MOV 3

B GL MO FUS No NOTE 1 P4400F605A EECW Division 1 Supply to Reactor Building (RB)

Equipment Sump Heat Exchanger G1101B002A Isolation MOV 3

B GL MO FUS No NOTE 1 P4400F605B EECW Division 2 Supply to RB Equipment Sump Heat Exchanger G1101B002B Isolation MOV 3

B GL MO FUS No NOTE 1 P4400F613 EECW Division 1 Supply to Battery Room Space Cooler T4100B033 Isolation MOV 3

B GL MO FUS No NOTE 1 P4400F614 EECW Division 1 Supply to Drywell (DW)

Penetration Coolers Isolation MOV 2

B GL MO FUS No NOTE 1 T4600F407 Standby Gas Treatment System (SGTS) from RB Exhaust System Isolation AOV Aug. B NC BF AO FOS No NOTE 3 T4600F408 SGTS Secondary Containment (SC) to Division 2 SGTS Isolation AOV Aug. B NC BF AO FOS No NOTE 3 T4600F409 SGTS SC to Division 1 SGTS Isolation AOV Aug. B NC BF AO FOS No NOTE 3

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Page 5 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Typea Actuator Typeb Flow Directionc Leak Test Basis T4600F410 SGTS from Air Inlet Refueling Area Isolation AOV Aug. B NC BF AO FOS No NOTE 3 T4600F420 SGTS Division 1 Torus Hardened Vent SC Inboard Isolation AOV Aug. B NC BF AO FOS No NOTE 3 T4600F421 SGTS Division 2 Torus Hardened Vent SC Outboard Isolation AOV Aug. B NC BF AO FOS No NOTE 3 T4800F422 Containment Atmospheric Control (CAC) N2 Inerting to Vacuum Breaker Valve T23-F400G N2 Supply Isolation AOV 2

A GL AO FUS Individual NOTE 1 T4800F423 CAC N2 Inerting to Vacuum Breaker Valve T23-F400H N2 Supply Isolation AOV 2

A GL AO FUS Individual NOTE 1 T4800F424 CAC N2 Inerting to Vacuum Breaker Valve T23-F400J N2 Supply Isolation AOV 2

A GL AO FUS Individual NOTE 1 T4800F425 CAC N2 Inerting to Vacuum Breaker Valve T23-F400K N2 Supply Isolation AOV 2

A GL AO FUS Individual NOTE 1 T4800F426 CAC N2 Inerting to Vacuum Breaker Valve T23-F400L N2 Supply Isolation AOV 2

A GL AO FUS Individual NOTE 1

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Page 6 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Typea Actuator Typeb Flow Directionc Leak Test Basis T4800F427 CAC N2 Inerting to Vacuum Breaker Valve T23-F400M N2 Supply Isolation AOV 2

A GL AO FUS Individual NOTE 1 T4800F453 CAC N2 Inerting DW Pressure Control Vent AOV 2

A GL AO FOS/FUS Group NOTE 1 T4800F454 CAC N2 Inerting DW N2 Makeup Outboard Isolation AOV 2

A GL AO FOS/FUS Group NOTE 1 T4901F465 PC Pneumatic Division 1 Supply Outboard PC Isolation AOV 2

A GL AO FUS Group NOTE 1 T4901F466 PC Pneumatic Division 1 N2 Supply Isolation AOV 3

B GL AO FUS No NOTE 1 T4901F469 PC Pneumatic Division 2 N2 Supply Isolation AOV 3

B GL AO FUS No NOTE 1 T4901F601 Primary Containment (PC)

Pneumatic Division 1 Instrument N2 Inerting Supply Inboard PC Isolation MOV 2

A GL MO FUS Group NOTE 1.

In addition, risk of stem/disc separation would be minimal since the valve is normally cycled under near-static conditions.

T4901F602 Compressor Air PC Pneumatic Division 2 Instrument N2 Inerting Supply Inboard PC Isolation MOV 2

A GL MO FUS Group NOTE 1.

In addition, risk of stem/disc separation would be minimal since the valve is normally cycled under near-static conditions.

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Page 7 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Typea Actuator Typeb Flow Directionc Leak Test Basis T5000F401A Primary Containment Monitoring (PCAM)

T50L400A CT Outboard Sample AOV 2

A BA AO FOS Group NOTE 4 T5000F401B PCAM T50L400B CT Outboard Sample AOV 2

A BA AO FOS Group NOTE 4 T5000F402A PCAM T50L401A CT Outboard Sample AOV 2

A BA AO FOS Group NOTE 4 T5000F402B PCAM T50L401B CT Outboard Sample AOV 2

A BA AO FOS Group NOTE 4 T5000F403A PCAM T50L402A CT Outboard Sample AOV 2

A BA AO FOS Group NOTE 4 T5000F403B PCAM T50L402B CT Outboard Sample AOV 2

A BA AO FOS Group NOTE 4 T5000F404A PCAM T50L403A CT Outboard Sample AOV 2

A BA AO FOS Group NOTE 4 T5000F404B PCAM T50L403B CT Outboard Sample AOV 2

A BA AO FOS Group NOTE 4 T5000F405A PCAM T50L404A CT Outboard Sample AOV 2

A BA AO FOS Group NOTE 4 T5000F405B PCAM T50L404B CT Outboard Sample AOV 2

A BA AO FOS Group NOTE 4 T5000F407A PCAM T50L410A CT Outboard Sample AOV 2

A BA AO FOS Individual NOTE 4 T5000F407B PCAM T50L410B CT Outboard Sample AOV 2

A BA AO FOS Individual NOTE 4 T5000F408A PCAM T50L411A CT Outboard Sample Return AOV 2

A BA AO FOS Individual NOTE 4

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Page 8 Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Valve Typea Actuator Typeb Flow Directionc Leak Test Basis T5000F408B PCAM T50L411B CT Outboard Sample Return AOV 2

A BA AO FOS Individual NOTE 4 T5000F420A PCAM PC Pressure Monitor T50L406A PT Outboard Sample AOV 2

A BA AO FOS Individual NOTE 4 T5000F420B PCAM PC Pressure Monitor T50L406B PT Outboard Sample AOV 2

A BA AO FOS Individual NOTE 4 T5000F421A PCAM PC Torus Water Level Monitor Division 1 Torus Level Instrument Line Isolation AOV 2

B BA AO FOS No NOTE 4 T5000F421B PCAM PC Torus Water Level Monitor Division 2 Torus Level Instrument Line Isolation AOV 2

B BA AO FOS No NOTE 4 T5000F422A PCAM PC Torus Water Level Monitor Division 1 Torus Level Instrument Line Isolation AOV 2

B BA AO FOS No NOTE 4 T5000F455 PCAM PC Radiation Monitor Rack H21P284 Outlet Secondary Isolation AOV Division 2 2

A BA AO FOS Individual NOTE 4 T5000F456 PCAM PC Radiation Monitor Rack H21P284 Inlet Secondary Isolation AOV 2

A BA AO FOS Individual NOTE 4

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Page 9 Table Footnotes:

a: Valve types - BA = ball, BF = butterfly, CK = check, SCK = stop check, GL = globe, GA = gate b: Actuator type - AO = air operated, MO = motor operated c: Flow direction - FOS = flow over seat, FUS = flow under seat Note 1 - Globe valve with flow under the seat:

Flow presence or isolation does not prove indication of stem and disc connection. Since flow is under the seat, flow could occur with the stem in the open position even if the stem and disc are not attached. Flow isolation also does not prove the stem and disc are connected because a detached stem could seat the disc. For diagnostics, there is no unseating event or other indications that would provide conclusive indication the stem and disc are connected. Creating or revising an existing leakage test to validate stem to disc integrity is not practical and would result in additional dose to personnel. Valve disassembly is the only method to positively confirm stem to disc integrity.

Note 2 - Stop check valve:

The stem and disc are not attached by design; the stem moves independently of the disc. Thus, alternate indications to supplement valve position indication is not necessary. Presence of flow with the stem in the open position merely verifies the disc is not stuck in the seat as for any other check valve. Flow isolation also does not confirm obturator position because the detached stem will seat the disc by design. Diagnostic testing does not provide any indication of stem and disc attachment.

Note 3 - Butterfly valve in gas service:

The stem and disc on these butterfly valves are connected by taper pins. There is no reasonable mechanism for the pins to shear or become detached in gas service. Diagnostic testing does not provide any indication of stem and disc attachment.

Note 4 - Ball valve in gas service:

The stem fits into a cavity on the ball. There is no reasonable mechanism that would result in failure of the stem/disc connection, particularly in gas service. Diagnostic testing does not provide any indication of stem and disc attachment.

to NRC-19-0047 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request VRR-009 for the IST Fourth 10-Year Interval to NRC-19-0047 Page 1 10 CFR 50.55a Relief Request VRR-009 Alternative for Motor Operated Valve Preservice/Inservice Testing Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected Valve Identification (PIS) No.

Noun Description ASME Code Class OM Valve Category Plant Drawing T4804F601A Containment Atmospheric Control (CAC) H2 Recombiner to Torus Division 1 H2 Control Return Isolation Valve 2

A M-5739-2 T4804F601B CAC H2 Recombiner to Torus Division 2 H2 Control Return Isolation Valve 2

A M-5739-2 T4804F602A CAC H2 Recombiner Division 1 H2 Control Torus Suction Isolation Valve 2

A M-5739-2 T4804F602B CAC H2 Recombiner Division 2 H2 Control Torus Suction Isolation Valve 2

A M-5739-2 T4804F603A CAC H2 Recombiner Division 1 H2 Control Drywell Suction Isolation Valve 2

A M-5739-2 T4804F603B CAC H2 Recombiner Division 2 H2 Control Drywell Suction Isolation Valve 2

A M-5739-2 T4804F604A CAC H2 Recombiner Division 1 H2 Control Return Outboard Isolation Valve 2

A M-5739-2 T4804F604B CAC H2 Recombiner Division 2 H2 Control Return Outboard Isolation Valve 2

A M-5739-2 T4804F605A CAC H2 Recombiner Division 1 Drywell Outboard Suction Isolation Valve 2

A M-5739-2 T4804F605B CAC H2 Recombiner Division 2 Drywell Outboard Suction Isolation Valve 2

A M-5739-2 T4804F606A CAC H2 Recombiner Division 1 Torus Outboard Suction Isolation Valve 2

A M-5739-2 T4804F606B CAC H2 Recombiner Division 2 Torus Outboard Suction Isolation Valve 2

A M-5739-2

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda to NRC-19-0047 Page 2 10 CFR 50.55a Relief Request VRR-009 Alternative for Motor Operated Valve Preservice/Inservice Testing

3. Applicable Code Requirement

ASME OM Code Mandatory Appendix III Preservice and Inservice Testing of Active Electric Motor Operated Valve Assemblies in Light-Water Reactor Power Plants, Section III-3200 Preservice Test states that each motor operated valve (MOV) shall be tested during the preservice test period or before implementing inservice testing. It also states that testing that meets the requirements of this Mandatory Appendix but conducted before implementation of this Mandatory Appendix may be used.

Section III-6100 Acceptance Criteria states that thrust, torque, or other measured engineering parameters correlated to thrust or torque consistent with paragraphs III-6100 through III-6500, may be used to establish the acceptance criteria. It also states that motor control center (MCC) testing is acceptable if correlation with testing at the MOV has been established.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(1), relief is requested from the requirements of ASME OM Code Appendix III, Paragraph III-6100. The basis of the relief request is that the proposed alternative will provide an acceptable level of quality and safety.

MCC testing is utilized for the subject valves. Appendix III, Paragraph III-6100 allows MCC testing to be used if correlation with testing at the MOV has been established. Correlation with thrust or torque has not been performed for the subject valves. Relief from Appendix III, Paragraph III-6100 is needed to utilize MCC testing for the subject valves without prior correlation with thrust or torque.

5. Proposed Alternative and Basis for Use

The proposed alternative is to conduct periodic MCC testing for these valves to demonstrate operational readiness without prior correlation with thrust or torque. Margin will be expressed in terms of calculated actuator output capability and calculated valve operating requirements. MCC testing will identify any performance-related degradation and analysis of this data will ensure the inservice test interval is appropriate.

The listed valves are all butterfly valves. The valves have high margin between calculated actuator capability and valve operating requirements. The valves are only required to operate under static conditions to meet their design basis function. The valves are classified as Class A under the MOV Joint Owners Group Periodic Verification (JOG PV) approach since they are only required to operate under static conditions and have bearing and shaft materials that were covered by the JOG PV. Thus, per the JOG PV, these valves are not susceptible to to NRC-19-0047 Page 3 10 CFR 50.55a Relief Request VRR-009 Alternative for Motor Operated Valve Preservice/Inservice Testing degradation. The valves are low risk per the JOG PV, corresponding to a low safety significant component (LSSC) per III-3720.

The valves are controlled by a limit switch in both directions; the torque switch is removed from the control circuit. Thus, actuator output capability is calculated vs. being determined from torque measurement taken at the torque switch trip event.

Since these valves are only required to operate under static conditions, each static stroke demonstrates their capability to operate under design basis conditions. Only that portion of the closing stroke beyond cessation of motor power (valve seating) would not be monitored by MCC testing as compared to torque measurement at the valve. However, MCC testing includes monitoring during valve unseating. MCC testing can identify newly developed anomalies as well as small changes in valve and actuator performance. Significant changes in valve and/or actuator performance would be necessary to compromise operational capability since margin is high. These anomalies and adverse trends can be detected and assessed without the need for torque measurement.

Fermi 2 has and will continue to conduct numerous MCC tests on each of these valves as well as other plant MOVs. The testing has provided Fermi 2 with the historical data and experience necessary to identify anomalies and/or adverse conditions.

Thus, periodic MCC testing will provide assurance that the valves remain capable of performing under design basis conditions throughout each testing interval.

6. Duration of Proposed Alternative

This proposed alternative will be utilized for the entire fourth 10-year interval. The fourth interval begins on February 17, 2020 and ends on February 16, 2030.

7. Precedent No precedent was identified for this relief request.