ML23283A026
| ML23283A026 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/09/2023 |
| From: | DTE Electric Company |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML23283A021 | List: |
| References | |
| NRC-23-0063 | |
| Download: ML23283A026 (13) | |
Text
Total Page Count (13 Pages)
FERMI 2 IN"SERVICE -TESTIN"G PROGRAM FOR PUMPS AND VALVES FERMI 2 FOURTH 10 YEAR INTERVAL - START DATE 02/17/2020 PART 4: 1ST Valve Testing Program (Revision 3)
Revision Summary:
- 1. Revised per LCR 19-036-ISI to support the IST Program 4th Interval Update. Due to the extensive changes, no revision bars are used.
QUAL Date: 2 .. /z -2.b Date: ~ - Is~ ;;lo PE-03 J?
Reviewed: -/J14!3wL(tl1Ul-/<J~tJtJI//) Date: ~-/ 7" .:?tJ:?O NIA Supervisor, Performance Engineering Date: 7 "17 - "2 NIA INFORMATION AND PROCEDURES DSN: 1ST Valve Testing Program Rev: 3 Date: _ _ _ _ _ __
DTC: TMPLAN File: 1715.04 Recipient: _ _ _ _ __
Date Approved: _ _~ - - - - - Release authorized by:._ _ _ _ _ _ _ _ _ __
1ST Program Plan Part 4 Page 1 2/17/2020
1.0 INSERVICE TESTING PLAN FOR VALVES 1.1 Valve Inservice Testing Plan Description This testing program for valves meets the requirements of ASME OM Code 2012 Edition, Section ISTC "Inservice Testing of Valves in Light-Water Reactor Nuclear Power Plants",
Mandatory Appendix II "Jnservice Testing a/Valves in Light-Water Reactor Nuclear Power Plants" Check Valve Condition Monitoring Plan", Mandatory Appendix III "Inservice Testing of Valves in Light-Water Reactor Nuclear Power Plants" 1.2 Valve Plan Table Description The valves included in the Fermi 2 IST Program scope are listed in Pait 5 (IST Valve Scope Tables) of the IST Program Plan. The information contained within this table identifies those valves which are to be tested to the requirements of Subsection ISTC of the ASME OM Code 2012 Edition, the testing parameters and frequencies, and any associated relief requests. The key headings for the valve tables are delineated below.
- VALVE ID The valve identification number. A Plant Identification System (PIS)
Number is identified.
- FUNCTION: The standard nomenclature name given for the valve.
- DRAWING/ COORDINATE: Related drawing and coordinate.
- VALVE CATEGORY: The category(s) assigned to the valve is based on the definitions ofISTC-1300. Four (4) sepai*ate 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 rnpture disks or explosively actuated valves.
- ACTIVE/PASSIVE: Requirement for obturator movement to fulfill its safety function as defined in ISTA-2000 for Valves - Active and Valves - Passive.
1ST Program Plan Pait 4 Page2
- 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.)
NOTE: Motor Operated Valves have the following actuator types:
MO: Passive MOV MOL: MOV Low Risk (LSSC)
MOL-C: MOV Low Risk with Close Stroke Time MOL-O: MOV Low Risk with Open Stroke Time MOL-OC: MOV Low Risk with Open and Close Stmke Time MOH: MOV High Risk (HSSC)
MOH-C: MOV High Risk with Close Stroke Time MOH-O: MOV High Risk with Open Stroke Time MOH-OC: MOV High Risk with Open and Close Stroke Time MO I SA: Self-actuated MOV
- NORMAL POSITION: The normal position of the valve during typical plant operation.
- 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.
- TEST REQIDREMENT: The test(s) which will be pe1formed to fulfill the requirements of ISTC. The exam definitions and abbreviations used are identified in Section 2.0.
- TEST FREQUENCY: 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.
- NOTES: Identifies any related Relief Requests, Cold Shutdown Justifications, Refueling Outage Justifications, historical testing codes, and Technical Positions.
2.0 IST Exam Definitions The Inservice Test descriptions are given below along with con-esponding test abbreviations and a description of the test being performed.
1ST Program Plan Part 4 Page 3
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 contaimnent in the drywell or torus airspace (except lines which te1minate 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. NOTE:
An exam code of AT-1 S is also used in the IST database for valves that have specific stem leakage tests. Note:
The Fenni surveillances have historically used test codes AT-1 and AT-1S. The valve tables which are generated using Iddeal Software use and equivalent code LTJ.
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 contaimnent" designation. Note: The Fermi surveillances have historically used the test code AT-2. The valve tables which are generated using Iddeal Software use the equivalent code LTJ.
AT-3 Seat Leakage scfm A leakage test perfom1ed on non-Appendix J valves to Test ensure the valve can perform its intended safety function.
Note: The Fe1mi surveillances have historically used the test code AT-3. The valve tables which are generated using Iddeal Software use the equivalent code LT.
1ST Program Plan Part 4 Page4
IST Exam Definition Table TEST TEST UNITS TEST DESCRIPTION NAME 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. For further information on bypass leakage valves, see UFSAR Section 6.2.1.2.2.3. Note: The Fermi surveillances have historically used test the test code AT-4. The valve tables which are generated using Iddeal Software use the equivalent code LTJ.
AT-8 PurgeNent scfh In addition to Type C tests for the purge/vent isolation Isolation valves, leakage integrity tests are performed as required Valve Leak by Technical Specifications.
Test NOTE: An exam code of AT-8S is also used in the 1ST database for valves that have specific stem leakage tests.
Note: The Fermi surveillances have historically used test the test codes AT-8 and AT-8S. The valve tables which are generated using Iddeal Software use the equivalent code LT.
AT-9 MSIV Leak scfh The MSIVs are Type C tested at a reduced pressure. NRC Test SSER 5 granted Fenni exemption from the full pressure-testing requirement of 10CFR50 Appendix J. The MSIV leakage is excluded from the summation of the measured local lealc rate tests. The allowable combined leak rate for all four main steam lines shall be in accordance with the Technical Specifications. Note: The Fermi surveillances have historically used the test code AT-9. The valve tables which are generated using Iddeal Software use the equivalent code LTJ.
AT-10 Pressure gpm Pressure isolation valves (PIVs) will receive pedodic Isolation leakage tests in accordance with Technical Specifications Valve Leak requirements. Note: The Fermi surveillances have Test historically used the test code AT-10. The valve tables which are generated using Iddeal Software use the equivalent code LT.
IST Program Plan Part 4 Page 5
1ST Exam Definition Table TEST TEST UNITS TEST DESCRIPTION NAME AT-11 Drywell to inches Drywell to Torus Vacuum Breakers will receive periodic Suppression drop leakage tests in accordance with Technical Specifications Chamber requirements. Note: The Fe1mi surveillances have Bypass Leak historically used the test code AT-3. The valve tables Test which are generated using Iddeal Software use the equivalent code LT.
STe Full Stroke sec Exercise testing, verified by stroke time measurements, TIMED will be performed to confom the full stroke capability of Exercise Test each valve. The stroke dh-ection 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 exerc1smg.
STO Full Stroke sec Exercise testing, verified by stroke time measurements, TIMED will be performed to confirm the full stroke capability of
- f.
Exercise Test each valve. The stroke direction timed for this exam is 1 to the OPEN full closed to full open I~
position ;i l
- 1 ETO Full Stroke P/F Exercise test for a manual valve which vedfies*that the :I
'.l ETF 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 i valve. either the back seat or other mechanical stop and closing the valve to its seated position.
PSe Partial Stroke P/F Partial stroke exercise test pe1formed on MSIVs during Exercise Test normal operation. This testing is required to meet Technical Specifications. For IST Program purposes, this testing implements the open and closed obturator verification requirements for the MSIVs.
eve 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. The code BDC implements position this same test for a non-safety direction.
1ST Program Plan Pait 4 Page6
1ST Exam Definition Table TEST TEST UNITS TEST DESCRIPTION NAME D&I Check Valve P IF Check valves will be disassembled and intemals 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 .
cvo 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. The test code BDO implements this same test in the non-safety direction.
CVP 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 occmTed as evidenced by an observed change in a parameter such as flow, temperature, etc.
RV Relief Valve Set lbs Relief and safety/relief valve set points will be verified in Point accordance with ASME OM 2004 Appendix I.
DIAG MOV Diagnostic NIA MOV will be diagnostically tested in accordance with Test Appendix III RD& Rupture Disk P/F Explosive valves will be tested in accordance with ASME EXP and Explosive OM Code ISTC-5260 (EXP). Rupture disks will be Valve Test replaced on a periodic cycle in accordance with manufacturer's instructions and per ASME OM Code ISTC-5250 (RD).
FSO/C Fail-Safe Test PIP All valves with fail-safe actuators will be tested to verify proper fail-safe operation upon loss of actuator power.
FSO/C is typically accomplished by perf01mance of STO/STC exams on AOVs in the safety direction. For MSIV s, the FSC is perfonned using a special "springs-only11 stroke time test.
1ST Program Plan Part 4 Page7
1ST Exam Definition Table TEST TEST UNITS TEST DESCRIPTION NAME ovo Obturator PIF All valves with RPI requirements per ASME OM Code ovc Verification ISTC-3700 will verify valve operation is accurately Open I Close indicated by supplementing valve position indicating lights with other indications, such as flow or other suitable instrumentation to provide assurance of proper obturator position (10CFR50.55a(b)(3)(xi)).
RPI Position PIF 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 RPI exam should be supplemented with other indications capable of verifying proper valve obturator movement.
FV SRV Functional NIA Per Technical Specification Amendment 190, the Test following tests are performed on SRVs:
- 1. A solenoid valve (SOV) functional test will be perf01med in-situ for each SRV solenoid valve once per operating cycle (18 months).
- 2. An SRV actuator functional test will be perfo1med at an offsite test facility as patt of certification testing for each SRV pilot assembly. The cmrent practice of replacing all 15 SRV pilot assemblies each operating cycle (18 months) will be maintained.
- 3. SRV setpoint testing is perf01med using steam at the offsite test facility as part of ce1tification testing for each SRV pilot assembly, at intervals determined in accordance with the IST Program.
- 4. SRV main stage certification testing will be perf01med using steam at the offsite test facility at intervals dete1mined in accordance with the Inservice Testing Program.
1ST Program Plan Part 4 Page 8
VBSP Vac. Breaker Set (lbs) Force measurement made with a push/ pull gauge to Point detennine force needed to push disc from seat. This test was historically labeled CT-F.
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 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 cmTent at pump reference flows. Inclusion Pump Cunent of these exam codes in the Valve Tables is infonnational; these exams are not ASME In-Service Tests.
PIT-RS Position PIF 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.
3.0 MOV Program ASME OM 2012 included Mandatory Appendix III, Preservice and Inservice Testing of Active Electric Motor Operated Valve Assemblies in Light Water Reactor Power Plants. This section descdbes implementation of Appendix III at Penni.
This section also describes requirements ofMOVs determined to be Passive.
An Appendix III implementation review was conducted by Kalsi Engineering and reviewed by Fe1mi personnel (DSN: IST Appendix III Reviews/ Edison File Number Pl-19243). Recommendations were addressed during Appendix III program development.
1ST Program Plan Part 4 Page9
3.1 Active vs. Passive The definition for active and passive valves from ISTA-2000 is as follows:
valves, active: valves that are required to change obturator position to accomplish a specific function in shutting down a reactor to the safe shutdown condition, maintaining the safe shutdown condition, or mitigating the consequences of an accident.
valves, passive: valves that maintain obtw:ator position and are not required to change obturator position to accomplish the required function(s) in shutting down a reactor to the safe shutdown condition, maintaining the safe shutdown condition, or mitigating the consequences of an accident.
Active MOVs are addressed per Mandatory Appendix III. Passive MOVs are addressed per ISTC requirements.
3.2 Testing Requirements Passive MOVs: passive MOVs with remote indication require remote position indication (RPI) testing at least once every two years in accordance with ISTC-3700. They also require obturator verification in accordance with 10CFR50.55a(b)(3)(xi). They do not require periodic exercising (Table ISTC-3500-1).
Leakage Testing: leakage testing for active and passive MOVs is governed by the valve category as defined in ISTC-1300 and Table ISTC-3500-1.
Exercising: Appendix III MOV s are exercised at least once per refueling cycle with the maximum time between exercises of24 months. Those high safety significance (HSSC) MOVs that can be stroked during plant operation are exercised quarterly.
Stroke time testing: MOV stroke time testing is not required by Appendix III. However, in accordance with 10CFR50.55a(b)(3)(ii)(D), the licensee must verify that the stroke time ofMOVs specified in plant technical specifications satisfy the assumptions in the plant's safety analysis. In these cases, stroke timing is performed at the MOV Exercising frequency.
Diagnostic Testing: In accordance with Appendix III, each active MOV must have a current design basis verification test (III-3100), a current preservice test (III-3200) and a periodic inservice test (III-3300).
These tests are identified in accordance with MOV Program requirements and the results are archived in the appropriate Work Order(s).
Remote Position Indication (RPI) and Obturator Verification (OV): Passive MOVs with remote position indicators require verification that valve operation is accurately indicated at least once every two years, and this local operation shall be supplemented by other indications as practicable to verify obturator position (ISTC-3700). Remote position indication and OV is required fo1* all Appendix III MOVs. RPI and OV are conducted during inservice testing and during maintenance or modification activities that require performance of the inservice test (III-3300(e)). OV is not required to be concurrent with RPI (ISTC-3700) but is conducted at a frequency that provides reasonable assurance of valve operation. The IST Valve Scope Table lists the procedure(s) and frequency for RPI and OV.
IST Program Plan Part 4 Page 10
3.2.1 Design basis verification testing (DBVT): Design basis verification testing (DBVT) was performed for each MOV to meet Generic Letter 89-10 / Generic 96-05 test requirements where the testing was practicable and would provide meaningful results. Where DBVT was not practicable/meaningful, results of testing from other MO Vs (grouping) or testing results from industry test programs (JOG PV, EPRI PPM, special individual valve analyses) were justified and applied to verify design-basis capability using results from preservice (static) diagnostic tests. In addition, testing perfonned at conditions other than design basis conditions were analyzed and the results used to justify design-basis capability.
III -3100 allows the use of design basis verification tests that were conducted prior to implementation of Appendix III to be used as long as they met the requirements of Appendix III. GL 96-05 tests were used for all MOVs except for four, which were added to the IST Program for the 4th Interval. These will be tested as described in VRR-011.
Plant processes address review of MOV changes, MOV modifications or system modifications that would invalidate the DBVT. The DBVT is repeated if a change would invalidate the DBVT unless the test would not be practicable or provide meaningful results. In this case, and when the test is conducted at conditions other than design-basis conditions, an analysis is performed to justify the use of the alternate technique to verify MOV design-basis capability.
3.2.2 Preservice Testing: Static diagnostic tests were conducted in conjunction with a DBVT for each Appendix III MOV for which a DBVT was performed under GL 89-10. For those cases that a DBVT was not practicable or would not provide meaningful results, a diagnostic test was conducted under conditions like those expected during subsequent diagnostic tests. The preservice test is considered the most recent test prior to implementation of Appendix III. In cases where MOV changes could invalidate the DBVT and it is practicable and meaningful to perform it, the preservice test is conducted in conjunction with the DBVT. Otherwise the preservice test is considered the diagnostic test perfonned to confinn MOV design-basis capability.
3.2.3 Inservice Testing: Periodic Inservice testing is conducted in accordance with the Preventive Maintenance (PM) Program. Each Appendix III MOV has a PM assigned to it that contains technical requirements for the test and specifies the test interval. Inservice testing is also performed following activities that could impact inservice test criteria but will not impact DBVT criteria.
Test intervals: Fermi adopted the Joint Owners Group MOV Periodic Verification Program (JOG PV).
The JOG PV Program established maximum periodic test intervals based on valve degradation only. The maximum periodic test intervals were based on risk insights, margin and valve category. The following table summarizes the maximum test interval established by the JOG PV Program:
Risk Rank Mantin Low (<5%) Medium (5 to <l 0%) High (>10%)
High 2 years 4 years 6 years Medium 4 years 8 years 10 years Low 6 years 10 years 10 years 1ST Program Plan Part 4 Page 11
In accordance with the JOG PV Program, each MOV has been categorized as Category A (valve not susceptible to degradation) or B (valve not susceptible to degradation extended by analysis or engineering judgment), Those valves that are outside the scope of the JOG PV Program (Category D) were evaluated separately to establish the maximum test frequency, DSN: Pl-17745, MOV JOG Classification summarizes the JOG Classification for each GL 96-05 MOV and the basis for the maximum test intervals for Category D MOVs.
The maximum test intervals for Category A MOV s are established using risk and the "High" margin column in the above table. The maximum test intervals for Category B MOVs are established using all columns in the table, Risk ranking is established using the BWR Owner's Group methodology for risk ranking (RefNEDC-32264-A), grouping each MOV as High, Medium or Low risk. Margin is based on the limiting thrust margin for rising stem valves and limiting torque margin for quarter turn valves. Since Appendix III employs only two risk ranking levels, HSSC (high safety significance) and LSSC (low safety significance), any valves that are determined to have Medium risk per the risk ranking methodology are considered HSSC at Fermi. Updates to risk ranking (reference TE-ANL-10-035) are finalized following review by a Plant Expe1t Panel. Maximum inservice test intervals and exercising frequency are then adjusted as necessary based on any risk ranking changes.
In addition to the maximum test intervals established per the JOG PV Program, degradation of the actuator and valve/ actuator interface are considered in establishing the test interval. Functional margin is calculated for each MOV as the difference between the available actuator output and valve operating requirements. Prior to retuming the MOV to service following testing, a review is conducted by qualified individuals to ensure functional margin is positive and that there are no anomalous conditions present that could impact valve functionality. If these conditions are not met, corrective actions are identified and addressed as appropriate prior to returning the MOV to service. A follow-up test review is conducted by qualified individuals to determine the test interval based on consideration of functional margin, performance degradation and anomalous behavior or adverse trends. The test interval is adjusted if this review indicates test interval modification is necessary.
As-found testing and as-left testing is perfonned for each periodic inservice test and typically for maintenance activities conducted within the inservice test interval that requires diagnostic testing to be performed. Justification is provided in the testing evaluation if as-found testing is not perfo1med. If as-found testing is not performed, the test interval is set at two cycles or three years for HSSC MOVs (whichever is longer) or three cycles or five years for LSSC MOVs (whichever is longer) unless sufficient data is available to justify a longer test interval.
All Appendix III MOV Inservice Testing is conducted and documented using plant Work Orders.
Pertinent test infonnation and documentation of data analysis and evaluation is archived with the Work Order.
1ST Program Plan Part 4 Page 12
4.0 Applicable Code Cases Code Case OMN-8 For control valves which only have a fail-safe design, valve stroke timing is not required. This code case is used for the following control valves which have a fail-safe design function:
El 1F400A-D (RHRSW Pump Minimum Flow Valves)
P44F400A&B (EECW Heat Exchanger Service Water Outlet Temperature Control Valves)
R30F400-F403 (EDGSW Pump Minimum Flow Valves)
Code Case OMN-17 Extends the frequency of removal and testing of SRV s to six years. This code case was used in the Third Interval under Relief Request VRR-014. *This code case is used for the following valves:
B2104F013A-R (Main Steam Safety Relief Valves)
IST Program Plan Part 4 Page 13