ML19322A006

NRR E-mail Capture - Fermi 2: Request for Additional Information- Relief Request VRR-006, Proposed Alternative for Preservice Testing of Butterfly Valves

ML19322A006
Person / Time
Site:	FitzPatrick
Issue date:	11/15/2019
From:	Booma Venkataraman NRC/NRR/DORL/LPL3
To:	Jonathan Haas Exelon Generation Co
References
L-2019-LLR-0057
Download: ML19322A006 (5)

Text

From: Venkataraman, Booma Sent: Friday, November 15, 2019 3:12 PM To: Jason R Haas; Margaret M Offerle

Subject:

Fermi 2: Request for Additional Information- Relief Request VRR-006, Proposed Alternative for preservice testing of butterfly valves (EPID: L-2019-LLR-0057)

Attachments: RAI_Fermi 2_VR006.docx Expires: Tuesday, January 14, 2020 12:00 AM Mr. Haas and Ms. Offerle, By application dated June 14, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19165A134), DTE Electric Company, (DTE, the licensee) submitted Request for Alternative Relief VRR-06 for Fermi 2. VRR-06 proposes an alternative for preservice testing of butterfly valves, and pursuant to Title 10 Code of Federal Regulations (10 CFR) Section 50.55a, Codes and Standards, paragraph (z)(1), relief is requested to deviate from certain American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code requirements, which requires each valve to be tested in accordance with the requirements prior to implementation of inservice testing (IST). The basis of the relief request is that the proposed alternative will provide an acceptable level of quality and safety.

A draft request for information (RAI) was sent to you on November 12, 2019. A clarification call was held on November 15, 2019. The final RAI version after the clarification is attached to this e-mail. It was agreed that DTE will respond to the attached RAI with a supplement by December 6, 2019.

Please treat this e-mail as transmittal of formal RAIs. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-2934 or via email at Booma.Venkataraman@nrc.gov.

Sincerely, Booma Booma Venkataraman Project Manager, NRR/DORL/LPL3 Office of Nuclear Reactor Regulation Booma.Venkataraman@nrc.gov 301.415.2934

Hearing Identifier: NRR_DRMA Email Number: 315 Mail Envelope Properties (MN2PR09MB4000EAE37E27C8AC0DC713DB86700)

Subject:

Fermi 2: Request for Additional Information- Relief Request VRR-006, Proposed Alternative for preservice testing of butterfly valves (EPID: L-2019-LLR-0057)

Sent Date: 11/15/2019 3:12:09 PM Received Date: 11/15/2019 3:12:00 PM From: Venkataraman, Booma Created By: Booma.Venkataraman@nrc.gov Recipients:

"Jason R Haas" <jason.haas@dteenergy.com>

Tracking Status: None "Margaret M Offerle" <margaret.offerle@dteenergy.com>

Tracking Status: None Post Office: MN2PR09MB4000.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1562 11/15/2019 3:12:00 PM RAI_Fermi 2_VR006.docx 33960 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: 1/14/2020

REQUEST FOR ADDITIONAL INFORMATION REQUEST FOR PROPOSED ALTERNATIVE RELIEF REQUEST VRR-006 FERMI-2 DTE ELECTRIC COMPANY DOCKET NO. 50-341 By application dated June 14, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19165A134), DTE Electric Company, (DTE, the licensee) submitted Request for Alternative Relief VRR-006 for Fermi 21. VRR-06 proposes an alternative for preservice testing of butterfly valves, and pursuant to Title 10 Code of Federal Regulations (10 CFR) Section 50.55a, Codes and Standards, paragraph (z)(1), relief is requested to deviate from certain American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code requirements, which requires each valve to be tested in accordance with the requirements prior to implementation of inservice testing (IST). The basis of the relief request is that the proposed alternative will provide an acceptable level of quality and safety.

The U. S. Nuclear Regulatory Commission (NRC) staff is reviewing the submittal and has determined that the additional information below is needed to complete its review.

Applicable Regulations:

10 CFR 50.55a, Codes and Standards lists all the (ASME) Codes that have incorporated by reference including ASME Code for Operation and Maintenance of Nuclear Power Plants with conditions, that the NRC has approved for use. 10 CFR 50.55a defines the requirements for applying industry codes and standards to nuclear power facilities. Each of these facilities is subject to the conditions in paragraphs (a), (b), and (f) of 10 CFR 50.55a, as they relate to IST.

10 CFR 50.55a(f)(4)(ii) requires that an IST activity conducted during each 120-month interval following the initial interval must be conducted in compliance with the requirements of the latest edition and addenda of the OM Code incorporated by reference in the version of 10 CFR 50.55a(a) that is in effect 12 months before the start of the interval and subject to the conditions listed in 10 CFR 50.55a(b). This Code Edition is called the Code of Record.

Therefore, the applicable Code of Record for the Fermi 2 fourth 10-year IST interval is 2012 Edition of the OM Code.

10 CFR Part 50, Appendices A and B require that licensees provide confidence that safety-related equipment (including motor operated valves (MOVs)) is capable of performing its safety functions under design-basis conditions.

Pursuant to 10 CFR 50.55a(z)(1) and (2), the Commission may authorize the licensee to implement an alternative to the OM Code requirements, provided that the alternative ensures an 1

The application also listed 3 other proposed alternative relief requests (VRR-004, VRR-007 and VRR-009) 1

acceptable level of quality and safety or the OM Code requirement presents a hardship without a compensating increase in the level of quality and safety.

RAI VRR-006-1

Background:

Enclosure 2 of the application, Page 2, Relief Request Section 5, Proposes Alternative and Basis for Use, second paragraph, states that the valves are 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.

Issue: The JOG program was a 5-year study on a variety of valves with a scope to determine how a valve degrades over time. The JOG data examined friction factors of valves operating under dynamic conditions. The JOG final program plan classified valves based on their type, material makeup, and system operating conditions. The butterfly valve matrix noted that for certain valves under specified conditions that no threshold COF value is required for developing a qualifying basis. All other valves required individual dynamic testing or group dynamic testing of similar valves to obtain the qualifying basis.

Request: The JOG threshold value was never intended to be a bounding number to use when developing a qualifying basis. Please explain why applying the JOG threshold friction value is acceptable.

RAI VRR-006-2

Background:

Enclosure 2 of the application, Page 2, Section 5, Proposed Alternative and Basis for Use, of the application, fourth paragraph, states 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 the 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, Paragraph III- 6100 requirements for acceptance criteria.

Issue: The licensee did not provide information that addresses how the valves significant margin between actuator capability and valve operating requirements is acceptable while using, a combination of condition monitoring from periodic motor control center testing and local leak rate testing is used to monitor for valve/actuator degradation. Further, licensee states that while this practice provides acceptable monitoring of valve/actuator condition, it does not meet Appendix III Section 6100 requirements for acceptance criteria.

Request: Please discuss how condition monitoring and MCC testing will be acceptable when valves have significant margin between actuator capability and valve operating requirements and used this to monitor for valve/actuator degradation. Also, explain how this practice provides acceptable monitoring of valve/actuator condition, when it does not meet the Appendix III, Section 6100 requirements for acceptance criteria for the operational readiness of the MOVs.

RAI-VRR-006-3

Background:

Enclosure 2 of the application, Page 2, Section 5, Proposed Alternative and Basis for Use, fifth paragraph states, in part, while some local leak rate results have 2

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.

Issue: The licensee did not address the reason how the cause of the leakage were not related to actuator capability or valve operational capability.

Request: Please explain how situations where local leak rate results (asserted to be unrelated to actuator capability or valve operational capability) that necessitated corrective actions did not challenge confidence in the operational readiness of the valves.

RAI-VRR-006-4

Background:

ASME OM Code, Mandatory Appendix III, Paragraph III-3100, Design Basis Verification Test, states, in part, that a one-time test is to be conducted to verify capability of each MOV to meet its safety-related design- basis requirements. Paragraph III-3100 also states that where design-basis testing of the specific MOV being evaluated is impracticable, or not meaningful (provides no additional useful data), data from other MOVs may be used if justified by engineering evaluation.

Issue: Enclosure 2 of the application, Page 2, Section 5, Proposed Alternative and Basis for Use, second paragraph, states, in part, that butterfly valves T4803F601 an T4803F602 are not practicable to test under dynamic conditions.

Request: Please explain the engineering evaluation that justifies that these butterfly valves will meet their design-basis capability requirements.

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