ML23283A028

Inservice Testing Program for Pumps and Valves - Part 6: IST Check Valve Condition Monitoring Plans Rev. 3

ML23283A028
Person / Time
Site:	Fermi
Issue date:	10/09/2023
From:	DTE Electric Company
To:	Office of Nuclear Reactor Regulation
Shared Package
ML23283A021	List: ML23283A022 ML23283A023 ML23283A024 ML23283A025 ML23283A026 ML23283A027 ML23283A028 ML23283A029 ML23283A030 ML23283A031 ML23283A032 ML23283A034 NRC-23-0063, Inservice Testing Program for Pumps and Valves - Part 12: IST Program Pump Basis Revision 1
References
NRC-23-0063
Download: ML23283A028 (1)

Text

Total Page Count (194 Pages)

FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES F RMI 2 FOURTH 10 YEAR INTERVAL-START DATE 02/17/2020 PART 6: 1ST CHECK VALVE CONDITION MONITORING PLANS REVISION3 Revision Summary:

1. Complete revision per 4th Interval 1ST Update Prepared:9 u,Q Date: 9-2t~ 21

~

p

~zu/21 Reviewed: Ill

.,. Date:

PE-03 )Q Reviewed:

Date: 7/411~~~1 NIA Approved:

Superv~formance Engineering 4~

Manager, Performance Engineering Date:

9/30/21 NIA INFORMATION AND PROCEDURES DSN: 1ST CVCM Plans DTC: TMPLAN Rev:

3 Date:

Transmittal 1/14/22 File:

1715.04 Recipient:. _____

Date Approved:........;;..;..

9/.;;_;

30'-'/2'-'-1 ____

Release authorized by:. _________ _

PLAN#

CMJ-01 CMJ-02 CMJ-03 CMJ-04 CMJ-05 CMJ-06 CMJ-07 CMJ-08 CMJ-09 CMJ-10 CMJ-11 CMJ-12 CMJ-13 CMJ-14 CMJ-15 CMJ-16 CMJ-17 CMJ-18 IST PROGRAM PLAN PART 6 CVCMPLANS INDEX DESCRIPTION RHR Service Water Return Checks Standby Liquid Control CIV Checks RHR Min Flow Checks Core Spray Pump Discharge Checks Core Spray Pump Min Flow Checks HPCI Booster Pump Suction Checks EECW Return Checks EECW Pump Discharge Checks HPCI Turbine Check Valves HPCI Turbine Exhaust Check Valve EECW Nozzle Style Check Valves Nitrogen Inerting Check Valves LPCI Injection Check Valves RBCCW & CCHV AC Check Valves EESW Minimum Flow Valves RCIC Pump Discharge Check Valve Core Spray Injection Check Valves EDG Starting Air Receiver Tank Check Valves Total Page Count (194 Pages)

VALVES E1100F020A & B C4100F006 &

F007 E1100F046A-D E2100F003A-D E2100F038A-D E4100F019 E4100F045 E5100F030 P4400F051 P4400Fl l 6A&B P4400Fl65 P4400F274 P4400F003A&B P4400F077 A&B E4100F040 E4100F048 E4100F057 E5100F021 E4100F049 E5100F040 P4400F038 P4400F111A&B P4400F182 P4400F246 T4901F001, F006, F0lO, and F012 Ell 00F0S0A&B P4200F037 &

F049, T4100F352A

&B P45F400 & F401 E5100F014 E2100F006A&B R3000F031A-D &

R3000F032A-D

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-1 : RHR Service Water Return Checks 1.0 GROUP INFORMATION 1.1 Valve List 1.2 1.3 1.4 E1100F020A RHR DIV 1 HX "A" SERVICE WATER RETURN CHECK VLV E1100F020B RHR DIV 2 HX "B" SERVICE WATER RETURN CHECK VLV Manufacturing Data Manufacturer:

Valve Type:

Model:

Size:

Valve Body Material:

Disc Material:

Design Feature:

Service Conditions Service Duty:

System Flow:

System Pressure:

System Temperature:

Grouping Bases Powell Swing 1561AWE 24 SA216 HF SS CA15 BODY SEAT HF COCR Bolted bonnet Water 9000 gpm 175 155 These valves are grouped together based on having the same manufacturer, model, and service application. The following were considered in group determination:

121Same Mfg 121Like Orientation

~ Service Conditions

!21 Like Design

~ Identical Application Maximum Flow Unachievable

~ Identical Test Methodology S i milar Upstream Downstream Flow Turbulence IZ!Frequency of Operation Othe r 1.5 Safety Function Discussion

Total Page Count (194 Pages)

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 1ST Evaluation 99-071.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience 1ST Testing results have been very good overall. The valves were open exercise tested each quarter by pass 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 - Dissimilar Metals in Swing Check Valves Experience Corrosion, is based on events at Fermi U2 on 1 O 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 relevant Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevant Generic Letters were found.

All information Notices available from the NRCs reading room were reviewed. No relevant 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 CMJ-01 are not containment isolation valves and have no closed safety function. The valves are not required to meet any seat leakage

Total Page Count (194 Pages) requirements.

LER 87-009-01 (Hatch U1) reports the LLRT failure of the HPCI turbine 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 CMJ-01 are not containment isolation valves and have no closed safety function. The valves are not required to meet any seat leakage requirements.

OE18668-Dissimilar 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 meals. The disc is carbon steel (A216 GR WCB) and the nut (and swing arm) stainless steel (SA217 GR CA 15). 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.

Applicability: Applicable. This failure occurred at Fermi in valves similar to those in Group CMJ-01.

As a result of the OE review; the carbon steel discs in the valves in this Group were replace 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 identified, 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 the 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 failures 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

Total Page Count (194 Pages) this Group. The discs were replaced in 2001 and periodic maintenance is performed to address this known 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 erosion/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 CMJ-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.

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 LER/OE Notices NIC Database Review EPIX Review Vendor Input Industry Template 2.3 Valve History Information None LER 87-001-00 (Fitzpatrick), LER 87-009-01 (Hatch U1), and OE18668.

Failure Record Numbers FRN 88-021,88-019, 88-001,89-086, 99-149 and 99-123.

FN-155 and FN-101 None None Prior to the implementation of Condition Monitoring, the valves in Group CMJ-01, were open

Total Page Count (194 Pages) exercise tested each quarter under 24.205:05 (E11 00F020A) and 24.205.06 (E11 00F0208) by passing a minimum of 9000 gpm through the valves. No failures have occurred since 2001.

Although not a requirement of the 1ST 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 known corrosion issues and ensures preventive maintenance is performed prior to degradation to the point of potential failu e. It is not recommended that the frequency be decreased due to the history with finding corrosion products and the fact that the DI for E1100F020A was found poor in 2001.

E1100F020A Work Order Date Complete Examination Results 039D900609 4/16/1991 DI - Expected aged conditions.

Corrosion excessive - decided to replace disc and clean.

E115950216 10/25/1996 DI - Good condition. Minor corrosion / scale 0002002597 11/13/2001 DI - Poor/ Unsat condition (this was an expected condition due to the known galvanic corrosion issue). Si,gnificant corrosion on disc - replaced disc and holder arm (carbon stell disc replace with stainless steel disc to address galvanic corrosion issue of OE 18668.

A 111070100 4/4/2006 DI - Good condition. Minor corrosion throughout.

A111120100 4/5/2012 DI - Sat with corrosion noted.

Hinge pin could not be removed.

34445238 10/10/2018 DI - Sat with corrosion noted.

Hinge pin could not be removed.

Total Page Count (194 Pages)

E1100F020B Work Order 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.

Cleaned seat surfaces.

0002002598 11/3/2001 DI-Expected aged condition.

Disc corroded/ degraded, disc pin to nut corrosion. Disc replaced ( carbon steel disc replaced with stainless steel disc to address galvanic 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 enable inspection. Minor corrosion/MIC.

25971603 3/8/2014 DI-Sat. Disc holder bolts replaced. Very dirty around seating area. Some pitting and corrosion.

52180196 4/17/20 DI-Sat.

3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open {FTO)

Failure to Close {FTC) 181 Internal Leakage (IL)

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM) 181 Broken/Detached Pars (BOP) 181

3.2 Total Page Count (194 Pages)

Failure Causes Normal Wear 18!

Maintenance Error Abnormal Wear Manufacturing Error Design Corrosion 18!

Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation 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.

Total Page Count (194 Pages) 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure Detect Degradation Detected High Low FTO, RM NA NA NA NA NA NA NA NA High High All NA NA NA NA NA NA NA NA NA NA NA NA NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but > 25%

Low -

probability of detection < 25%

NIA -

test method not available

Total Page Count (194 Pages) 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ) PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation Prior to the implementation of Condition Monitoring, the valves in Group CMJ-01 were open exercise tested each quarter under 24.205.05 (E11 00F020A) and 24.205.06 (E11 00F020B) by passing a minimum of 9000 gpm through the valves. No failures have occurred since 2001.

Although not a requirement of the 1ST 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 IX!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 pass required flow.

Frequency:

Quarterly Tasks:

24.205.05 (E1100F020A) 24.205.06 (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.

Total Page Count (194 Pages)

2. Plan Activity: Disassembly & inspection Demonstrate 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 intervals.

Frequency:

Each valve in the Group will be inspected once every 4 refuel cycles.

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 abili y 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. 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 and inspection under the SOER 86-03 program has demonstrated the bidirectional functionality of these valves, and supports placing the Group in a Final Condition Monitoring 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.

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-2: Standby Liquid Control CIV Checks 1.0 GROUP INFORMATION 1.1 Valve List C41 00F006 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:

NICRAND 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.

IZISame Mfg 181Like Orientation IZIService Conditions 181Like Design Identical Application Maximum Flow Unachievable 18i ldentical Test Methodology Similar Upstream Downstream Flow Turbulence 181Frequency of Operation Other

Total Page Count (194 Pages) 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.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience 1ST 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 relevant Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevant Generic Letters were found.

All information Notices available from the NRCs reading room were reviewed. No relevant 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 co denser. 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

Total Page Count (194 Pages) 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 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 identified, 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 folllowing 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 the other RHR service water pump discharge checks in FRNs88-019, 88-001 Applicability: Applicable. Although the valves in Group CMJ-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. The 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 failures 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 replaced in 2001 and periodic maintenance is performed to address this known issue.

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.

Total Page Count (194 Pages)

Vendor Input There was no vendor input or Part 21 Reports associated with 1.5" Anchor Darling swing check valves 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 CMJ-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 CMJ-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 CMJ-02. The possibility of this occurrence is directly related to the service environment and usage. It is unlikely the valves in Group CMJ-02 would experience any of the other failures reflected in, 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

Total Page Count (194 Pages) 2.3 Valve History Information As CIVs, the valves in Group CMJ-02 have been subject to Appendix J Type C seat leakage testing, which was also credited to satisfy 1ST 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 d al 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 WO#

Date Examination Results Complete 0002922529 10/26/1992 Failed LLRT - would not stroke closed. Repacked and tested successfully 0002931844 7/12/1994 Failed LLRT - replaced disc and reworked seats 8427040100 11/16/2004 Disassembly Inspection - Good condition 000X043678 11/26/2004 Packing leak - retorqued and did stroke test verification 1424071006 10/6/2007 CTC I LLRT SAT Dual indication during 24.139.03 - finally identified cause of 25892091 10/18/2007 recurring "dual indication" problems.24-139.03 revised to provide adequate back pressure.

25850051 4/3/09 CTC I LLRT SAT 31910166 2/15/14 CTC I LLRT SAT LLRT failure / CARD 15-27558 I Indicator shaft binding. Also G427130100 11/4/15 See CARD 15-28377. System Engineer recommends frequency change to 6 years for F006 and F007.

44254636 3/31/17 CTC I LLRT SAT 47406520 10/2/2018 CTC I LLRT SAT

Total Page Count (194 Pages)

C4100F007 WO#

Date Examination Results Complete 3145070920 10/6/2007 CTC I LLRT SAT 25850045 4/3/2009 CTC I LLRT SAT 29684417 4/112009 CTC I LLRT SAT 34436231 2/15/14 LLRT failure/ Valve seating surface/ CARD 14-21258 38051009 3/7/14 CTC I LLRT SAT 44227889 10/7/15 LLRT fail / CARD 15-27558 38131877 10/28/15 CTC I LLRT SAT 44152499 3/30/17 CTC I LLRT SAT 47402470 10/6/18 CTC I LLRT SAT 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO)

Failure to Close (FTC)

Internal Leakage (IL) lg]

External Leakage (EL)

Disk Separation (DS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM)

Broken/Detached Pars (BOP)

3.2 Total Page Count (194 Pages)

Failure Causes Normal Wear IZI Maintenance Error Abnormal Wear Manufacturing Error Design Corrosion Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Other Remarks:

Leakage has been an occasional problem with each valve in the group failing once since 1993.

The valves in Group CMJ-02 are maintained in the closed position and are opened only during surveillance testing. Therefore, wear is minimal.

Total Page Count (194 Pages) 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT TesUlnspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure Detect Degradation Detected Medium Low FTO, RM NA NA NA NA NA NA High High IL, FTC, RM NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but > 25%

Low -

probability of detection < 25%

NIA -

test method not available

Total Page Count (194 Pages) 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ) PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation The valves in CMJ-02 have been subjected to the following tests and inspections as required by the lnservice Testing Program.

-The valve was exercised open as part of the 1ST 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 1ST 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 6 years for both valves per CARD 15-27558 / AIM 20-22227 under the site PM program. This frequency is not driven by IST,but does have a formal process. Any change in frequency requires adequate justification and documentation, as well as joint concurrence of the 1ST 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:

Interim Plan IZ!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 CMJ-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.

Total Page Count (194 Pages)

2. Plan Activity: Leak Test The valves in CMJ-02 shall be lealk 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.

5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMJ 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.

Total Page Count (194 Pages)

Failure Modes Industry Template NIC Check Valve Performance Database A/D Swing Total Swing Checks Failure Mode Check Valve in Failure Percent Description Failures Population of Total Part Other Than Disk Broken 22 135 16.30%

Stuck Closed 8

19 42.10%

Stuck Open 47 303 15.50%

Restricted Motion 19 159 11.90%

Improper Seating 87 424 20.50%

Unknow 6

59 10.20%

Free/Loose Internals.

7 57 12.30%

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-3: RHR Min-Flow Check Valves 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:

Borated water System Flow:

42 gpm System Pressure:

1400 System Temperature:

150

Total Page Count (194 Pages) 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.

~ Same Mfg

~ Service Conditions Identical Application IZI Identical Test Methodology

~ Frequency of Operation 1.5 Safety Function Discussion Like Orientation

~ Like Design Maximum Flow Unachievable Similar Upstream Downstream Flow Turbulence Other 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.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience 1ST 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 cannot 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 ta present.

A review of the inspection results was performed for each of the valves in the group.

The focus of the review was to determine if normal wear or hinge pin wear experienced a negative trend over time. These two parameters are listed as the

Total Page Count (194 Pages) failure modes in this plan. It was found by a trending analysis that these valves have not experienced normal wear including the hinge pin. The jobs used for this analysis are identified in the table using an asterisk(*). The ASME OM code (Appendix II) allows an interval extension of one cycle for a good performing group.

Therefore, the total interval allowed to perform all four valves in this group has been increased from four cycles to five cycles.

2.2 Industry Service Experience Generic Notices All Generic Notices available from the NRCs reading room were reviewed. No relevant Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevant Generic Letters were found.

All information Notices available from the NRCs reading room were reviewed. No relevant 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 CMJ 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 a d 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 CMJ-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 94-14 7 reported the restricted motion of a check valve (failed to initially close)

Total Page Count (194 Pages) due to normal wear of internal components.

Applicability: Not Applicable. The valves in Group CMJ-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 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 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 minimum flow line.

The use of the RHR flow meter to record a flow difference with the minimum flow

Total Page Count (194 Pages) valve open has been determined una,cceptable 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.

1ST 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 WO#

Date Examination Results Complete E101911008 12/15/1991 DI - Good condition, minor corrosion only E101971107 9/21/1998 DI - Good condition E101040100 11/16/2004 DI - Good condition (*)

E101100100 11/10/2010 DI - Good condition (*)

E1100F0468 WO#

Date Examination Results Complete E100911008 9/21/1992 DI - Good condition Other failure/ rework, DI found nothing abnormal -

0002920239 7/15/1994 scotchbrite cleaning only. No reason for suspected high seat leakage.

0002991538 4/28/2000 DI - Good condition A244060100 4/22/2006 DI - Good condition (*)

A244120100 4/13/2012 DI - Good condition (*)

35831776 5/18/20 DI - Good condition

Total Page Count (194 Pages)

E1100F046C WO#

Date Examination Results Complete 026D900609 4/8/1991 DI - Good condition DI - Good condition E543950216 10/19/1996 Light corrosion - scotchbrite cleaning only A350030100 4/1/2003 DI - Good condition (*)

A350090100 3/31/2009 DI - Good condition (*)

35831598 10/17/2015 DI - Good condition E1100F046D WO#

Date Examination Results Complete DI - Good condition E551930414 7/16/1994 Light rust - scotchbrite cleaning only A098010100 11/2/2001 DI - Good condition A098070100 10/5/2007 DI - Good condition (*)

25981938 3/1/2014 DI - Good condition (*)

52178700 4/14/20 DI - Good condition

Total Page Count (194 Pages) 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 3.2 Failure Modes Failure to Open (FTO)

Internal Leakage (IL)

Disk Separation (OS)

Not Applicable Failure Causes Normal Wear

~

Abnormal Wear Design Human Error Procedure Erosion/Corrosion Other Remarks:

Failure to Close (FTC)

External Leakage {EL)

Hinge Pin Wear (HPW)

Restricted Motion (RM)

Broken/Detached Pars (BOP)

Maintenance Error Manufacturing Error Corrosion Foreign Material Stress Corrosion Cracking Improper Installation

~

A review of 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 potential failure mode. Leakage was a common industry failure, but the valves in this group are not Cat A valves.

Total Page Count (194 Pages) 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure I Detect Degradation Detected NA NA Low Low FTO Medium Low FTC, RM, HPW NA NA NA NA High High All NA NA NA NA NA NA NA NA NA NA NA NA NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but > 25%

Low -

probability of detection < 25%

N/A -

test method not available

Total Page Count (194 Pages) 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation The valves in CMJ-03 have been subjected to the following tests and inspections as required by the lnservice 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 1ST 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 1ST program by the performance of a backflow test per 24.204.01.

Disassembly Inspection was performed to satisfy full open requirements.

5.2 Condi ion Monitoring Program Plan Status:

Interim Plan IZ!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:

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

Total Page Count (194 Pages) 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, hus preventing flow diversion. Trending is a 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:

All four valves are disassembled and inspected over a six 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 CMJ 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

Total Page Count (194 Pages) 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.

Total Page Count (194 Pages)

Fermi Nuclear Station (CMJ-4) Core Spray Pump Discharge Checks 1.0 GROUP INFORMATION 1.1 Valve List E2100F003A CS Pump A Discharge Check Valve E2100F003B 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

Total Page Count (194 Pages) 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:

IZ!Same Mfg IZ!Service Conditions IZI Identical Application IZl Identical Test Methodology IZl Frequent Operation 1.5 Safety Function Discussion Like Orientation lZI Like Design Maximum Flow Unachievable Similar Upstream Downstream Flow Turbulence Other 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 quarterly. Thus, Division 1 pumps, E21010001A and E2101 C001 C (Check Valves E21 00F003A and E21 00F003C respectively), are tested in parallel; and Division 2 pumps, E2101 C001 B and E2101 C001 D (Check Valves E21 00F003B and E21 00F003D, 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 direction.

Because of the operating restriction imposed, testing for full stroke capability of these check valves is to be accomplished every two years during the Comprehensive Pump Test.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience 1ST Testing results have been very good overall. Numerous disassembly

Total Page Count (194 Pages) inspections have been performed from 1991 to 2008 with no failures. The PM events for dissasembly inspections are referenced to provide a basis for health of these check valves only and are not part of the recommended monitoring plan activities. The Check Valve Program will continue to monitor the dissassembly and inspection results outside this monitoring plan.

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 relevant Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevant Generic Letters were found.

All information Notices available from the NRCs reading room were reviewed. No relevant 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 CMJ 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 CMJ-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.

Total Page Count (194 Pages)

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 CMJ-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 There was no Powell Swing Check Valve Industry Template available on the Nuclear Industry Check (NIC) Valve Group's website.

Total Page Count (194 Pages) 2.2.1 References Generic Notices None LER/OE Notices None NIC Database Review Failure Record Numbers FRN 87-66 and EPIX Review None Vendor Input None Industry Template None 2.3 Valve History Information 1ST Testing results have been very good overall. Numerous disassembly inspections have been performed from 1991 to 2008 with no failures. As noted above, the dissembly inspections performed during the past support this plan by verifying the good health of these valves; the D&I is no longer used for this monitoring plan since the combination of partial open tests (quarterly) and full flow open tests (With 2 Year Comprehensive Pump Tests) are adequate to track degradation. The Check Valve Program will continue to monitor the dissassembly inspections.

Total Page Count (194 Pages)

E2100F003A Date Examination Results WO#

Complete DI Expected aged condition 000Z99159 4/7/2000 AF DI SAT w/e minor pitting on disc face. Cleaned up and 3

restored.

A35206010 4/5/2006 DI - Good condition 0

E2100F003B Date Examination Results WO#

Complete E18691100 9/16/1992 DI - Good condition 8

A14001010 10/31/2001 DI - Good condition 0

A14007010 10/5/2007 DI - Good condition 0

E2100F003C Date Examination Results WO#

Complete E55895021 10/15/1996 DI _ Very good condition 6

A35303010 4/10/2003 DI _ Very good condition 0

Total Page Count (194 Pages)

E2100F003D WO#

Date Examination Results Complete E55995021 9/8/1998 DI - Very good condition 6

E55904010 11/10/2004 DI - Very good condition 0

3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO)

Fail re to Close (FTC) 181 Internal Leakage (IL)

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW) 181 Not Applicable Restricted Motion {RM)

Broken/Detached Pars (BOP) 3.2 Failure Causes Normal Wear 181 Maintenance Error Abnormal Wear Manufacturing Error Design Corrosion Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Other

Total Page Count (194 Pages)

Remarks:

A review of 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.

4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Effectiveness of Activity to Failure Modes Test/Inspection Activity Detect Failure I Detect Degradation Detected Full Open Stroke w/Flow NA NA FTO Partial Open Stroke Low Low FTO w/Flow Back Flow/Reverse Flow Medium Low FTC Manual Exercise NA NA Leak Test NA NA Disassembly & Inspection High High Temperat re 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

Total Page Count (194 Pages)

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 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation

- The original purpose of this CMJ was to use a quarterly partial open stroke and a dissassembly and inspections to credit the full open exercise which was not possible when testing two pumps in parallel. The plan also included, and continues to include a quarterly exercise in the closed direction as described below. The historical Dissassembly & Inspection results will continue to be displayed in this plan for historical reference only.

- Recently (RF17), a modification was performed on E2150F015A&B to allow individual pump testing at a two year frequency. During this two-year comprehensive pump testing, a full flow exercise was found to be possible and is described below. Therefore, the plan was revised to replace the Dissassembly &

Inspection with a two-year full flow exercise.

5.2 Condition Monitoring Program Plan Status:

Interim Plan IZI Fi al 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 F003O)

Notes:

Total Page Count (194 Pages)

There is no way to verify quarterly 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 in conjunction with pump testing.

Tasks:

24.203.02 (E21 00-F003A and F003C)24-203.03 (E21 00-F003B and F003D)

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: Full open stroke Demonstrates the valve opens to meet intended safety function per ISTC-5211 (a)(1) by achieving a flow rate of 3175 GPM per pump during the Comprehensive Pump Test Frequency:

Once per two years.

Tasks:

24.203.02 (E2100-F003A and F003C) 24.203.03 (E2100-F003B and F003D)

Notes:

Total Page Count (194 Pages)

None 5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of co dition monitoring activities, the CMJ tests identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance.

Partial open and closu re testing performed quarterly in addition full open exercise testing during the comprehensive pump test 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.

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-5: Core Spray 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

Total Page Count (194 Pages) 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:

[8JSame Mfg

[8JService Conditions

[8J Identical Application

[8J Identical Test Methodology Frequency of Operation 1.5 Safety Function Discussion Like Orientation IZ!Like Design Maximum Flow Unachievable Similar Upstream Downstream Flow Turbulence Other 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 pump.

The Core Spray Pumps in each Division are tested in parallel. Thus, Division 1 pumps, E2101C001A and E2101 C001 C (Check Valves E2100F038A and E21 00F038C respectively), are tested in parallel; and Division 2 pumps, E2101C0018 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.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience 1ST Testing results have been very good overall. Numerous disassembly inspections have been performed from 1991 to 2020 with no failures.

These valves are very likely seeing full flow each quarter, however, there is no way to co firm that and satisfy Code requirements for a full or partial open test. Two

Total Page Count (194 Pages) valves see flow and one could mask the performance of the other.

A review of the inspection results was performed for each of the valves in the group.

The focus of the review was to determine if normal wear or hinge pin wear experienced a negative trend over time. These two parameters are listed as the failure modes in this plan. It was found by a trending analysis that these valves have not experienced normal wear including the hinge pin. The jobs used for this analysis are identified in the table using an asterisk (*). The ASME OM code (Appendix II) allows an interval extension of one cycle for a good performing group.

The total interval allowed to perform all four valves in this group has been increased to six cycles.

2.2 Industry Service Experience Generic Notices All Generic Notices available from the NRCs reading room were reviewed. No relevant Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevant Generic Letters were found.

All information Notices available from the NRCs reading room were reviewed. No relevant 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 NRG 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. The OE was also searched in INPO IRIS database using the search term "3061A WE".

Two additional OE were found after 2008. These included OE 229693 which discussed a check valve exercise failure due to debris in the related test line. In addition, OE 307594 was found discussed the failure of a valve to fully close due to the inappropriate deferral of preventative maintenance. It should be noted that the valve subject to this OE was used in the heater drain system which is a harsh environment compared to Core Spray. Finally, the NRC website was searched for "3061A WE" and no relevant OE was found.

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 CMJ 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

Total Page Count (194 Pages) 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 CMJ-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 CMJ-05 are in a clean water system and would only see flow during testing or an emergency event requiring CS to run at a 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 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 LER/OE Notices NIC Database Review None None Failure Record Numbers FRN 87-66 and 94-147 EPIX Review None Vendor Input None Industry Template None

Total Page Count (194 Pages) 2.3 Valve History Information Beca se 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.

Numerous disassembly inspections have been performed from 1991 to 2020 with no failures.

Total Page Count (194 Pages)

E2100F038A WO#

Date Examination Results Complete ES44950216 10/14/1996 DI - Good condition E544970307 4/9/2003 DI - Good condition (*)

E544090100 4/2/2009 DI - Good condition (*)

35850780 10/14/2015 DI - Good condition E2100F038B WO#

Date Examination Results Complete E224911008 9/16/1992 DI - Very good condition 0002991541 4/21/2000 DI - Good condition A351060100 4/13/2006 DI - Good condition (*)

32434559 4/9/2012 DI - Good condition (*)

35831608 4/19/20 DI - Good condition E2100F038C WO#

Date Examination Results Complete Other failure / rework 0002910478 4/18/1991 Minor leak from cover gasket area - reworked and SAT 029D900609 4/21/1191 DI - Very good condition E545971107 9/21/1998 DI - Very good condition E545040100 11/10/2004 DI - Good condition (*)

E545100100 11/8/2010 DI - Good condition (*)

Total Page Count (194 Pages)

E2100F038D WO#

Date Examination Results Complete E549930414 7/1/1994 DI - Very good condition A125010100 10/30/2001 DI - Good condition A125070100 10/4/2007 DI - Very good condition (*)

25977166 12/2014 DI - Very good condition (*)

54294470 4/20/20 DI - Good condition 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO)

Failure to Close (FTC)

Internal Leakage (IL)

External Leakage (EL)

Disk Separation (DS)

Hinge Pin Wear (HPW)

~

Not Applicable Restricted Motion (RM)

Broken/Detached Pars (BOP) 3.2 Failure Causes Normal Wear

~

Maintenance Error Abnormal Wear Man facturing Error Design Corrosion Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Other

Total Page Count (194 Pages)

Remarks:

A review of 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.

4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Effectiveness of Activity to Failure Modes Test/Inspection Activity Detect Failure Detect Degradation Detected 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:

Total Page Count (194 Pages)

High -

Probability of detection > 75%

Medi m -

< 75% probability of detection but > 25%

Low -

Probability of detection < 25%

N/A -

Test method not available 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation Disassembly inspection. All valves disassembled and inspected over six cycles.

The Core Spray Pumps in each Division are tested in parallel. Thus, Division 1 pumps, E2101C001A and E2101C001C (Check Valves E2100F038A and E21 00F038C respectively), are tested in parallel; and Division 2 pumps, E2101'. 0001 B and E2110C001 D (Check Valves E2100F0388 and E21 00F038D, 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 i!s 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.

Total Page Count (194 Pages) 5.2 Condition Monitoring Program Plan Status:

Interim Plan

~ 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:

All four valves are disassembled and inspected over a six 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.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Fermi Nuclear Station CMJ-6: HPCI Booster Pump Suction Checks 1.0 GROUP INFORMATION 1.1 Valve List Total Page Count (1 94 Pages)

E4100F019 HPCI Booster Pump CST Suction Check Valve E4100F045 HPCI Booster Pump Supp Pool Suction Check Valve 1.2 Manufacturing Data Manufacturer:

Valve Type:

Model:

Size:

Valve Body Material:

Disc Material:

Design Feature:

1.3 Service Conditions Service Duty:

System Flow:

System Pressure:

System Temperature:

1.4 Grouping Bases Powell Swing 3061A WE 16 SA216 HF SS410 BODY SEAT HF COCR Bolted Water 125 140 AND 170 These valves are grouped together based on having the same manufacturer, model, and similar service application. The E4100F019 CST suction valve is opened every quarter during pump testing. The E4100F045 torus suction would see almost no service and would not be subject to wear-induced degradation. The following were considered in group determination:

0 Same Mfg Like Orientation 0 Service Conditions Identical Application Identical Test Methodology Frequency of Operation 0 Like Design Maximum Flow Unachievable Similar Upstream Downstream Flow Turbulence Other

Total Page Count (194 Pages) 1.5 Safety Function Discussion Both valves have a safety related open stroke function. E41 00F019 must open to allow flow from the Condensate Storage Tank to the High Pressure Coolant Injection (HPCI) Booster Pump and E41 00F045 must open to allow flow from the Torus to the HPCI Booster Pump. Additionally, E4100F019 has a safety related function to close to prevent gross movement of water from the Torus to the CST during HPCI suction swap, if the HPCI CST suction isolation MOV fails to close. E41 00F045 has no closed safety function.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience 1ST Testing results have been very good overall. An open test with full flow has been performed each quarter on the F019 valve with zero failures.

2.2 Industry Service Experience Generic Notices All Generic Notices available from the NRCs reading room were reviewed. No relevant Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevant Generic Letters were found.

All information Notices available from the NRCs reading room were reviewed. No relevant information Notices were found.

LER/OE Notices Reviewed INPOs Nuclear Network for OE Notices pertaining to 16" 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 16 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-06 are in a

Total Page Count (1 94 Pages) clean water system and would only see flow during testing or an emergency event requiring HPCI 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-06 are in a clean water system and would only see flow during testing or an emergency event requiring HPCI 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 16" 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 LER/OE Notices NIC Database Review EPIX Review Vendor Input Industry Template 2.3 Valve History Information None None Failure Record Numbers FRN 87-66 and None None None 1ST Testing results have been very good overall. An open test with full flow has been performed each quarter on the F019 valve with zero failures.

The F019 valve has only been disassemble inspected once, but the results were good.

The F045 valve has several inspections from 1991 to present with no failures. This valve seldom sees flow and has limited failure mechanisms.

Total Page Count (1 94 Pages)

E4100F019 WO#

Date Examination Results Complete A341060100 4/6/2006 DI - Very good condition A341090100 4/3/2009 DI - Satisfactory condition; some wear on disc stop.

Corrosion on bolting and wear on related washer.

35831589 10/15/2015 DI - Satisfactory E4100F045 WO#

Date Examination Results Complete 030D900609 4/17/1991 DI - Good condition E110911006 9/25/1992 DI - Very good condition E110930614 7/26/1994 DI - Very good condition E110941011 10/3/1996 DI - Very good condition 0002967322 11/18/1996 Other failure / rework Bonnet leak - installed new thicker gasket and tested SAT E110961025 9/17/1998 DI - Very good condition 0002991542 4/10/2000 DI - Good condition E110010100 11/4/2001 DI - Good condition E110030100 4/6/2003 DI - Good condition E110070100 11/16/2004 DI - Very good condition E110060100 10/7/2007 DI - Good condition 25971635 4/8/2012 DI - Satisfactory 35840445 10/13/2018 DI - Good condition

3.0 Total Page Count (1 94 Pages)

FAILURE MODES AND CAUSES ANALYSIS 3.1 3.2 Failure Modes Failure to Open (FTO)

Failure to Close (FTC)

Internal Leakage (IL)

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW)

IZJ Not Applicable Restricted Motion (RM)

Broken/Detached Pars (BOP)

Failure Causes Normal Wear IZJ Maintenance Error Abnormal Wear Manufacturing Error Design Corrosion Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Other Remarks:

A review of maintenance history and surveillance history for valves in this group found one failure from 1991-2008. P4400F051 had a hinge pin replaced in 1994.

Leakage was a common industry failure, but the valves in this group are not Cat A valves.

Total Page Count (194 Pages) 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure I Detect Degradation Detected High Low FTO, RM NA NA NA NA NA NA NA NA High High All NA NA NA NA NA NA NA NA NA NA NA NA NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but > 25%

Low -

probability of detection < 25%

N/A -

test method not available 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation The valves in CMJ-06 have been subjected to the following tests and inspections as required by the lnservice 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 E41 00F019 valve was exercised open as part of the 1ST program per 24.202.01 &.08. During this test the valve was verified to open by demonstrating capability to pass accident flow.

Total Page Count (1 94 Pages)

- Disassembly inspection was performed to satisfy closure requirements for both valves, and open for E41 00F045.

5.2 Condition Monitoring Program Plan Status:

Interim Plan 12JFinal 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 E4100F019.

Frequency:

Quarterly Tasks:

24.202.01/08 Notes:

Flowrate through the valves is recorded and provides 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:

Both valves are disassembled and inspected over a five 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 reli.able check valve performance 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

Total Page Count (194 Pages) and. provides further assurance of operational readiness during the entire interval.

Open testing of E41 00F019 is performed quarterly and further verifies the ability of the valve to perform its function.

Closure test of E41 00F019 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 is justified 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.

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-7 EECW Return/ RCIC Suction Checks 1.0 GROUP INFORMATION 1.1 Valve List P4400F051 EECW Return Check Valve P4400F116A EECW Return Header Check Valve P4400F1168 EECW Return Header Check Valve P4400F165 EECW Coolers Return Check Valve P4400F274 EECW Div 2 OW Sump Hx RTRN CHECK VLV E5100F030 RCIC Pump Suctioin From Suppression Pool Check Valve 1.2 Manufacturing Data Manufacturer:

Powell Valve Type:

Swing Model:

3061A WE Size:

2.5, 6, and 8 Valve Body Material:

A-216 Gr. WCB Disc Material:

A-515-69 Gr. 70 or A-216 Gr. WCB Design Feature:

Bolted 1.3 Service Conditions Service Duty:

Water System Flow:

173 to 1500 gpm System Pressure:

125-150 PSIG (Design)

System Temperature:

150~1 ?0F (Design)

Total Page Count (194 Pages) 1.4 Grouping Bases The valve sizes for this group range between 2.5" and 8" from the same manufacturer/ model number. The difference in size is not considered to have much affect on valve performance and does not warrant placing any one of these valves in a group by itself. Each valve in the group is exposed to clean EECW or RCIC water at approximately the same temperature. All of the valves are installed horizontally and experience flow continuously.

These valves are grouped together based on having the same manufacturer, model, and service application. The following were considered in group determination:

IZ!Sa e Mfg IZ!Service Conditions Identical Application Identical Test Methodology IZ! Frequent Operation 1.5 Safety Function Discussion P4400 Checks IZ!Like Orientation IZ!Like Design Maximum Flow Unachievable Similar Upstream Downstream Flow Turbulence Other These check valves have a safety function to open 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 exception is P4400F274 which only has a safety function to close to prevent inventory loss at the class to non-class piping boundary.

Total Page Count (194 Pages)

E5100F030A This check valve has a safety function in the OPEN position to provide a suction flow path from the suppression pool to the Reactor Core Isolation Cooling (RCIC) pump when suction is transferred to the Suppression pool on low Condensate Storage Tank (CST) level. This check valve has a safety function in *he CLOSED position. This check valve closes on reverse flow to isolate the Reactor Core Isolation Cooling (RCIC) system piping from the suppression pool to prevent water from t e Condensate Storage Tank (CST) draining into the suppression pool when RCIC pump suction is transferred to the suppression pool on low level in the CST.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience 1ST Testing results have been very good overall. An open test has been performed each quarter with zero failures for the* P4400 Checks.

All valves in the group have been disassemble inspected except P4400F274.

Results from 1991 to 2018 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 relevant Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevant Generic Letters were found.

All information Notices available from the NRCs reading room were reviewed. No relevant 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 CMJ group is not

Total Page Count (194 Pages) 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 CMJ-07 are also in a raw water application and in frequent use. Normal wear will occur in this application.

CMJ 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 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.

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 LER/OE Notices NIC Database Review EPIX Review Vendor Input Industry Template None None Failure Record Numbers 87-66 and 94-147 None None None

Total Page Count (194 Pages) 2.3 Valve History Information 1ST Testing results have been very good overall. Valve exercising for all of the EECVV valves has been performed satisfactory.

The valves have been disassemble inspected except P4400F27 4 which is added to this plan per this revision. Results from 1991 to 2018 have always been good. In 1994, the hinge pin was replaced on P4400F051.

P4400F051 (P353}

WO#

Date Examination Results Complete 032D900609 4/10/1991 DI - Good condition Other failure / rework 0002910423 11/17/1991 Leaking from cover-replaced gasket and SAT P353911008 10/2/1992 DI - Good condition DI - Good condition P353930223 6/4/1994 Minor indications on pin - replaced pin and disc holder P353940630 4/9/2000 DI - Good condition P353060100 3/27/2006 DI - Good condition P353120100 3/31/2012 DI - Good condition 35831685 9/28/2018 DI - Good condition

Total Page Count (194 Pages)

P4400F116A (P549)

WO#

Date Examination Results Complete P549911212 10/3/1992 DI - Good condition P549930223 9/20/1998 DI - Good condition P549040100 4/1/2003 DI - Good condition E110941011 10/3/1996 DI - Very good condition P549100100 4/2/2009 DI - Good condition 35831710 10/21/2015 DI - Good condition P4400F116B (P356)

WO#

Date Examination Results Complete 0340900609 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 P356100100 10/29/2010 DI - Good condition 35850842 4/5/2017 DI - Good condition

Total Page Count (194 Pages)

P4400F165 (P360)

WO#

Date Examination Results Complete 035D900609 4/27/1991 DI - Good condition P36091108 9/20/1992 DI - Good condition P360930223 10/6/1996 DI - Good condition P360961025 11/1/2001 DI - Good condition P360070100 10/3/2007 DI - Good condition 25975799 3/9/2014 DI - Good condition 52178232 4/23/20 DI - Good condition P4400F27 4 (G323)

WO#

Date Examination Results Complete N/A N/A No disassembly & inspection history E51 00F030 (C559)

WO#

Date Examination Results Complete E006930223 4/12/94 DI - Good condition 0002991544 4/12/00 DI - Good condition C559040100 3/2/04 DI - Good condition C559090100 8/17/11 DI - Good condition

Total Page Count (194 Pages) 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO) 0 Failure to Close (FTC) jgJ Internal Leakage (IL)

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW) 0 Not Applicable Restricted Motion (RM)

Broken/Detached Pars (BOP) 3.2 Failure Causes Normal Wear 0

Maintenance Error Abnormal Wear Manufacturing Error Design Corrosion Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion lmpmper Installation Other

Total Page Count (194 Pages) 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure Detect Degradation Detected NA NA Low Low FTO NA NA FTC NA NA NA NA High High All NA NA NA NA NA NA NA NA NA NA NA NA NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but > 25%

Low -

probability of detection < 25%t NIA -

est method not available

Total Page Count (194 Pages) 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Condition Monitoring Program Plan Status:

Interim Plan IZ!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: Exercise with flow Frequency: Quarterly I Refuel: All except ES 1 00F030 Tasks:

24.207.08 Open exercise (P4400F051, P4400F116A) 24.207.09 Open exercise (P4400F116B, P4400F165) 24.207.11 Closed exercise (P4400F27 4)

Notes:

Trending is on a pass/fail basis.

2. Plan Activity: Disassembly & Inspection Frequency:

A minimum of one valve in the group per cycle will be disassembled and inspected.

Tasks:

43.000.010 (ISi/PEP inspection) with 35.000.232 (Maintenance)

The D&I verifies E5100F030 (CVO & CVC), P4400F051, F116A&B, F165 (BOC), & P4400F274 (BOO)

Total Page Count (194 Pages)

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 CMJ 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.

Open/ closed 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.

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-8: 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 C001 B Discharge Check Valve P4400F077A EECW Div. I Pump A Supply to Essential Equipment Check Valve P4400F077B EECW Div. II Pump C001 B Supply to Essential Equipment Check Valve 1.2 Manufacturing Data Manufacturer:

Powell Swing 3061A WE 8

1.3 1.4 Valve Type:

Model:

Size:

Valve Body Material:

Disc Material:

Design Feature:

Service Conditions Service Duty:

System Flow:

System Pressure:

System Temperature:

Grouping Bases SA216 HF SS410 BODY SEAT HF COCR Bolted bonnet Water 1650 gpm 150 150 These valves are grouped together based on having the same man facturer, model, and service application. The following were considered in group determination:

IZ!Same Mfg IZJService Conditions IZl Identical Application IZI Identical Test Methodology IZ! lnfrequent Operation Like Orientation

!Zllike Design Maximum Flow Unachievable Similar Upstream Downstream Flow Turbulence Other 1.5 Safety Function Discussion These check valves 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 assodated EECW pump is not opera ing. This function is not required for safe

Total Page Count (194 Pages) shutdown or accident mitigation since this function is only required when the EECW pumps are in the standby mode.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience 1ST 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 disassembl,e inspected every 6th refuel outage (9 years) under 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 relevant Generic Notices were found.

All Generic Letters available from the NRCs reading room were reviewed. No relevant Generic Letters were found.

All information Notices available from the NRCs reading room were reviewed. No relevant 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 CMJ 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 replaced.

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 failure to close of a service water supply c eek valve. The hinge arm, hinge pin and disc stud were worn to the point that the disc could catch under the tip 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 CMJ-08 are in a raw water application, however are only open when the EECW pumps are in

Total Page Count (194 Pages) 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.

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 LER/OE Notices NIC Database Review 060 None None Failure Record Numbers91-117 and 90-EPIX Review None Vendor Input None Industry Template None 2.3 Valve History Information 1ST 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 ou age (9 years) under the SOER 86-03 Program. Results from 1991 to 2018 have always been good.

Total Page Count (194 Pages)

P4400F003A WO#

Date Examination Results Complete 0460900609 4/9/1991 DI - Good condition A121010100 11/11/2001 DI - Good condition A121100100 3/31/2009 DI - Good condition 35831742 10/8/18 DI - Good condition P4400F003B WO#

Date Examination Results Complete P364971107 9/12/1998 DI - Very good condition P364040100 4/12/2009 DI - Valve was found SAT - in very good condition. Only general light cleaning of internal surfaces was prescribed.

P4400F077A WO#

Date Examination Results Complete 0470900609 4/10/1991 DI - Good condition A36001010 11/12/2001 DI - Good condition 0

A360100100 3/31/2009 DI - Good condition 35831631 10/23/15 DI - Good condition P4400F077B WO#

Date Examination Results Complete P365971107 9/11/1998 DI - Very good condition P365040100 10/3/2007 DI - Good condition 25975808 4/17/12 DI - Good condition 35831705 4/21/20 DI - SAT. CARD 20-24845 Discussed minor service wear

3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO)

Failure to Close (FTC)

Internal Leakage (IL)

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM)

Broken/Detached Pars (BOP) 3.2 Failure Causes Normal Wear IZI Maintenance Error Abnormal Wear Manufacturing Error Desig Corrosion Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Other Remarks:

Total Page Count (194 Pages)

IZI 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.

4 0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT TesUlnspection Activity Effectiveness of Activity to Failure Modes Detect Failure I Detect Degradation Detected 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

Total Page Count (194 Pages)

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 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation The valves in Group CMJ-08 were exercised full open each quarter as part of the 1ST 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 IST-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:

Inter i m Plan IZIFinal 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 P4400F077 A)

24.207.09 (P4400F003B and P4400F077B)

Notes:

Total Page Count (194 Pages)

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:

All 4 valves are inspected within 12 years.

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 CMJ 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 1ST 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 CMJ 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.

Total Page Count (194 Pages)

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.

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-9: HPCI Turbine/ RCIC Min Flow 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 E5100F021 RCIC Pump Min Flow/ Recirc Bypass Check VLV 1.2 Manufacturing Data Manufacturer:

Valve Type:

Model:

Size:

Valve Body Material:

Disc Material:

Design Feature:

1.3 Service Conditions Rockwell Lift Y-Globe 838YT / A838YT2 2

CARBON STEEL SA 105 SA182GR.F11, STELLITED / A565 GR. 616HT Bolted Bonnet, Spring Loaded Service Duty:

Clean Water System Flow:

70 gpm, F040 as required System Pressure:

Design~ 1280 PSIG System Temperature:

Design ~ 298 F

Total Page Count (194 Pages) 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:

IZISame Mfg Service Conditions Identical Application Identical Test Methodology

!Zllnfrequent Operation 1.5 Safety Function Discussion For E41 00F040:

~ Like Orientation

~ Like Design Maximum Flow Unachievable Similar Upstream Downstream Flow Turbulence Other This c eek 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 This c eek valve has a safety function in the open position to provide a return flowpath for the HPCI lube oil cooling water. This check valve has a safety function in the closed direction to isolate barometric condenser condensate pump discharge return piping.

E4100F057 This check valve has an open safety function to provide a return flowpath for the HPCI lube oil cooling water. This valve does not have a closed safety function.

E5100F021 This check valve opens to provide a inimum flow path for the RCIC pump to prevent overheating during low flow conditions.

This check valve closes to isolate RCIC from the suppression pool.

Total Page Count (194 Pages) 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 inspection failure. During performance of a Disassembly & Inspection PM on valve E4100F040, the valve plug /disc 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 in bore based on measurements as recorded in Fermi Repair Replacement Plan 09-022. The valve was cleaned, proven functional, and then returned to service. During RF15, this valve was replaced per ERE 36285.

ERE 36285 (Equivalent Replacement Evaluation) changed the plug/ disc from SA182 Gr. F11 to A565 Gr.616 to eliminate cobalt. The valve body material did not change and is considered to be equivalent. It is also noted that the period of time for this issue to occur was approximately 6 years. Finally, it should also be noted that plug / disc material change is not considered to be a change that would impact the grouping. The valves are exercised every quarter during the pump and valve surveillance. There have been no 1ST 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 followjng 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 failure*s of Rockwell Edwards lift check valves with similar model number, size, and application. Seat

Total Page Count (194 Pages) 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 CMJ-09 do not have a specified credited closed safety functi'on, 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 CMJ-09. Failures of valves in air/nitrogen systems were not considered 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 CMJ-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 CMJ-09 do not have a specified credited closed safety function, Restricted Motion (failure to fully open or

Total Page Count (194 Pages) 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 CMJ-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 CMJ-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 CMJ-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 was reviewed:

Failure Number FN-514 reported the failure to meet seat leakage criteria of a 1 inch Edwards Model 838Y piston check valve.

Total Page Count (194 Pages)

Applicability: Not Applicable. The valves in Group CMJ-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 on the Nuclear Industry Check (NIC) Valve Group's website.

2.2.1 References Generic Notices LER/OE Notices IOM ReviewNone NIC Database Review Information Notice 97-31 LER 05-002-00 and OE21402 (LaSalle)

Failure Record Numbers FRN 85-089,92-384, 93-079,93-297 & 04-051 EPIX Review None Vendor Input None Industry Template None 2.3 Valve History Information The valves have been open exercise tested by the 1ST Program each quarter with the exception of E51 00F021. However, E51 00F021 is exercised during the pump and valve surveillance when the RCIC pump is on minimum flow. T e historical test result review covered the time period from 1992 to the present; there was only one report,ed disassembly and inspection (D&I) failure of the valves in Group CMJ-09.

During performance of D&I 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.

Total Page Count (194 Pages)

E4100F040 WO#

Date Complete Examination Results E404911008 9/23/1992 D&I results - Good condition E404950216 10/5/1996 D&I results - Good condition C561020100 3/12/2002 D&I results - Good condition Unsat condition - Found stuck open - see CARD 08-23654 C561080100 6/2/2008 file. The valve was cleaned, proven functional, and then returned to service.

32859188 4/11/2012 Replace valve per ERE 36285 based on CARD 08-23654 findings.

38569642 8/22/17 D&I results - Good condition E41 00F048 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&I results - Good condition P523110100 5/31/2011 D&I results - Good condition 36679693 2/23/16 D&I results - Good condition

Total Page Count (194 Pages)

E4100F057 WO#

Date Complete Examination Results E407911008 10/6/1992 D&I results - Good condition 0002991545 1/12/2000 D&I results - Good condition C564050100 5/12/2005 D&I results - Good condition C564080100 12/1/2009 D&I results - Very good condition 34653136 10/28/2014 D&I results - Good condition 431105178 2/23/16 D&I results - Good condition E5100F021 WO#

Date Complete Examination Results E563951003 10/3/96 D&I results - Good condition E563970218 9/19/98 D&I results - Good condition E563010100 12/5/02 D&I results - Good condition E563070100 3/1/07 D&I results - Very good condition 26004301 7/19/16 D&I results - Good condition 3.0 FAILURE MODES AND CAUSES ANAL YS.IS 3.1 Failure Modes Failure to Open (FTO)

IZI Failure to Close (FTC) 181 Internal Leakage (IL)

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM)

IZI Broken/Detached Pars (BOP)

3.2 Total Page Count (194 Pages)

Failure Causes Normal Wear

~

Maintenance Error Abnormal Wear Manufacturing Error Design Corrosion

~

Human Error Foreign Material

~

Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Other 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.

Total Page Count (194 Pages) 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure I Detect Degradation Detected NA NA Medium Low FTO, RM NA NA NA NA NA NA High High All NA NA NA NA NA NA NA NA NA NA NA NA NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but> 25%

Low -

probability of detection < 25%

N/A -

test method not available

Total Page Count (194 Pages) 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation Prior to the implementation of Condition Monitoring, the valves in Group CMJ-09 were open exercise tested each quarter per the 1ST Program under surveillance procedure 24.202.01. While closure testing was not a requirement of the 1ST Program, the valves have been periodically disassembled and inspected at a frequency established by the former Site SOER 86-03 Program.

There are no different or additional testing requirements imposed prior to CMJ implementation.

5.2 Condition Monitoring Program Plan Status:

Interim Plan

~ Fi11al 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: Open Stroke w/Flow Demonstrate the functionality of the valves in the group, except E51 00F021, to open and pass flow to meet the normal operating requirements.

Frequency:

The valves in the group are tested each quarter during the associated HPCI pump test.

Tasks:

24.202.01/08 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.

Total Page Count (194 Pages)

2. Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from full closed to full open and back to full closed position, with no evidence of binding of the internals. These D&ls demonstrate the open function for E41 00F040, F048, and F057, and open/closed function for E5100F021.

Frequency:

All valves in this group shall be disassembled and inpspected 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 CMJ tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance. The historical quarterly open exercise testing under the 1ST Program / Surveillances and disassembly & inspections supports placing this Group in a Final CMJ plan.

Of the historical inspections, there was only one reported disassembly and inspection (D&I) failure of the valves in Group CMJ-09. For valve E41 00F040, 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 safe y function. During RF15, this valve was replaced per ERE-36285; only the plug material changed to reduce cobalt.

Based on records, the corrosion products increased over the period between 2002 and 2008; approximately a 6 year period. This means the seven year frequency evaluated in Revision 0 of this plan should not change until more data is collected in the future.

Total Page Count (194 Pages)

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. The open exercise performed during the pump and valve surveillances further verifies 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.

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-10: HPCI Turbine Exhaust Check Valve 1.0 GROUP INFORMATION 1.1 Valve List E41 00F049 HPCI TURB Exhaust Check Valve E5100F040 RCIC Turbine Exhaust Check Valve 1.2 Manufacturing Data Manufacturer:

Anchor Darling Valve Type:

Lift Y-Globe Model:

W8221576 Size:

1 0" (E51 00F040), 20" (E41 00F049)

Valve Body Material:

SA216-WCB Disc Material:

Disc/Skirt (SA515-70, SA 106-B with COCR-A)

Design Feature:

Bolted bonnet; No spring; Equalizer line 1.3 Service Conditions Service Duty:

Wet Steam System Flow:

154.5: M-5860 I 26.. 6: M-5859 (x 1000 LB/hr)

System Pressure:

Design 150 PSIG System Temperature:

DESIGN 267F - 360F 1.4 Grouping Bases This is a single valve group.

181Same Mfg

~ Like Orientation Service Conditions 181Like Design 1811dentical Application Maximum Flow Unachievable Identical Tesst Methodology Similar Upstream Downstream Flow Turbulence 181 Infrequent Operation Other

Total Page Count (194 Pages) 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 HPCI or RCIC pump turbine to the suppression pool.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience Plant service experience for the valves in this group has been good. These valves are normally closed and see limited service. All Disassembly & Inspection PMs have found the valve in good condition. The valves are open exercise tested every quarter under the 1ST program. There have been no 1ST failures.

2.2 Industry Service Experience Generic Notices The NRG 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 11ft 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 valves in Group CMJ-1 O are not seat leakage tested & do not use a resilient.

IOM Review None NIC Database Review The NIC Check 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.

Total Page Count (194 Pages)

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 exhaust 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 sin Group CMJ-10 do not have a soft seat and have 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.

Applicability: Not applicable. The valves in Group CMJ-10 do not have a soft seats and have 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 valves in Group CMJ-1 O are not seat leakage tested & do not use a resilient seat.

Vendor Input No Part 21 Reports were identified that were applicable to the valve in Group CMJ-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 servic~ 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 CMJ-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.

Total Page Count (194 Pages)

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 CMJ-1 O valve.

2.2.1 References Generic Notices LER/OE Notices IOM Review None None None NIC Database Review EPIX Review Failure Record #s FRN 99-095,92-012, 98-114,93-262 Failure Number FN-1 94 Vendor Input Industry Template 2.3 Valve History Information None Industry Review Template for Anchor Darling Piston/Lift Check Valves, Revision A, 1/5/01 The valves have been open exercise tested by the 1ST Program each quarter. The results for the disassembly and inspection are shown below.

E4100F049 WO#

Date Complete Examination Results E412930223 10/14/1996 D&I results - Good condition E412961116 4/6/2004 D&I results - Good condition E412080100 3/14/2014 D&I results - Good condition 47799909 5/21/20 D&I results - Good condition E5100F040 WO#

Date Complete Examination Results E501930223 10/16/96 D&I results - Good condition E501961116 3/2/04 D&I results - Good condition E501080100 6/23/08 D&I results - Good condition 31151074 7/19/16 D&I results - Good condition

3.0 Total Page Count (194 Pages)

FAILURE MODES AND CAUSES ANALYSIS 3.1 3.2 Failure Modes Failure to Open (FTO)

Failure to Close (FTC)

Internal Leakage (IL)

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM)

IZl Broken/Detached Pars (BDP)

Failure Causes Normal Wear lZl Maintenance Error Abnormal Wear Manufacturing Error Design Corrosion Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Other Remarks:

Based on a review of the Performance Analysis, the valve in CMJ-1 O is potentially subject to restricted motion due to normal wear.

Total Page Count (194 Pages) 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure I

NA Medium NA NA NA High NA NA NA NA NA NA NA High -

Medium -

Low -

N/A-Detect Degradation Detected NA Low FTO, RM NA NA NA High All NA NA NA NA NA NA NA probability of detection > 75%

< 75% probability of detection but > 25%

probability of detection < 25%

test method not available

Total Page Count (194 Pages) 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ) PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation Prior to the implementation of Condition Monitoring, the valves in Group CMJ-10 were open exercise tested each quarter per the 1ST Program under surveillance procedure 24.202.01.

While closure testing was not a requirement of the 1ST Program, the valves were periodically disassembled and inspected, including open & close exercising, at a frequency established by the Site SOER 86-03 / IST Program.

There are no different or additional testing requirements imposed prior to CMJ implementation.

5.2 Condition Monitoring Program Plan Status:

Interim Plan C8l 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: Open Stroke w/Flow Demonstrate the functionality of the valve to open and pass flow to meet the normal operating conditions.

Frequency:

The valves in this group are tested each quarter during the associated HPCI pump test.

Tasks:

24.202.01 & 08 - E4100F049 24.206.01-E51 00F040 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.

Total Page Count (194 Pages)

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:

These valves shall be disassembled & inspected at least once every 8.0 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 CMJ 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 1ST Program, and periodic internal inspections have demonstrated the valve is performing its function with no evidence of wear or degradation. This supports placing this Group in a Final CMJ plan.

The periodic performance of a disassembly and inspection demonstrates the bi-directional functionality of the valve a d 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 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.

Total Page Count (194 Pages)

ATTACHMENT 1 Failure Mode Industry Template NIC Check Valve Performance Database Failure Mode Anchor Darling Lift CV Total Lift Failure

% of Total Description Failures Population Part Other Than Disck 2

17 11.80 Broken Stuck Closed 0

65 0

Stuck Open 7

154 4.50 Restricted Motion 0

30 0

Improper Seating 20 514 3.90 Unknown 1

34 2.90 Free/Loose Internals 1

3 33.30

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-11: EECW Nozzle Style Check Valves 1.0 GROUP INFORMATION 1.1 Valve List P4400F038 EECW Div. I Battery Room Space Cooler T4100B033 Return Check Valve P4400F111 B EECW Div. II RB Equipment Sump Hx G1100B002 Return Check Valve P4400F111A EECW Div. I RB Equipment Sump G1101B002A Hx Return Check Valve P4400F182 EECW Div. II CRD Pump Coolers Return Check Valve P4400F246 EECW Div. I DW Penetration Coolers Return Check Valve 1.2 Manufacturing Data Manufacturer:

Enertech Valve Type:

Nozzle Check Model:

DRV-Z Size:

1.5 and 2" Valve Body Material:

SA 105 Disc Material:

SA 479 TP316 Design Feature:

Bolted 1.3 Service Conditions Service Duty:

Water System Flow:

28 - 57 gpm System Pressure:

150 psig System Temperature:

150 F 1.4 Grouping Bases P4400F038 and F111 B are 1.5" valves. P4400F111A, F182 and F246 are 2" valves.

The difference in size is not considered to have much effect on valve performance and does not warrant splitting the two valve sizes into two different groups. All five 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:

IZ!Same Mfg IZILike Orientation IZIService Conditions

!Zllike Design Identical Application Maximum Flow Unachievable Identical Test Methodology S i milar Upstream Downstream Flow Turbulence IZIFrequency of Operation Other

Total Page Count (194 Pages) 1.5 Safety Function Discussion These return check valves have a safety function in the closed position in order to isolate non-essential equipment from the cooling path of the EECW system.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience Fermi 2 internal OE points to corrosion products buildup on valve internals as the main failure mechanism. This conclusion is based on a single instance of P4400F111A failure, which was attributed to gray/black oxide interfering with valve internals operation (see CARD 09-27321 ).

Reference Section 2.3 for all Corrective Action numbers associated with check valves in this Group.

2.2 Industry Service Experience LER/OE Notices Based on ICES database OE available on ENERTECH DRV-Z check valves, the most common failure cause has been determined to be excessive cycling. Other less frequently encountered failure causes were abnormal wear, incorrect gasket installation, seat ring damage, and foreign material. It should be noted that the service conditions of the nozzle check valves in the ICES reports were different that the conditions of the valves in this Group. The valves in the ICES report were all exposed to raw (service) water, as opposed to the clean (closed cooling) water inside the valves in this Group.

2.2.1 References LER/OE Notices ICES Reports:

146313, 164376, 179144, 192141, 192142, 203158, 206316, 218340, 218341,

229796, 308547 2.3 Valve History Information Check valves in this group have been exercised closed (safety direction) on a quarterly basis per the 1ST program. Open exercises (non-safety direction) were historically not part of 1ST testing plan, due to 1ST code rules prior to the third interval. However, all of the valves in this group have history of disassembly and inspection, which provides evidence of valve capability to open. Additionally equipment associated with check valves in this group will not function properly without the check valves being capable to open sufficiently to allow for required flow

Total Page Count (194 Pages) rates. In the event that any of these check valves fails to open sufficiently, operators will be alerted by equipment alarms.

Closed Position Test History Overall valve performance based on quarterly surveillances is satisfactory with the following exceptions:

- P4400F111A discovered stuck open in 2009. The cause was determined to be corrosion buildup on internals, which is a common failure mode for nozzle check valves. The internals were replaced and subsequent surveillances have been satisfactory.

- P4400F246 did not reseat closed following disassembly and inspection.

Subsequent internal inspection did not uncover any abnormalities. Valve was reassembled without any work done and passed PMT and subsequent 1ST surveillances.

Open Position Test History There is no recorded history of the valves in this Group failing to open.

P4400F038 WO#

Date Complete Examination Results 0002980851 9/27/1992 Valve replace with nozzle type check per EDP 28988.

P429960219 10/18/2007 D&I - Good condition 25975783 10/2/18 D&I - Good condition P4400F111A WO#

Date Complete Examination Results 0002980845 10/1/1998 Valve replaced with nozzle type per EDP 28988.

P420960109 was closed to this WO.

P420010100 11/15/2001 D&I - Good condition P420040100 3/26/2009 D&I - Good condition Repair resulting from failed surveillance 24.207.08 (CARD 09-27321). The valve was discovered stuck open, due to 30381047 11/3/2009 corrosion products accumulation and stem deformation.

The repair consisted of replacement of valve internals, such as disk, stem and spring. PMT was SAT 43001083 12/5/16 D&I - Good condition

Total Page Count (194 Pages)

P4400F1118 WO#

Date Complete Examination Results 0002980847 9/18/1998 Valve replaced with nozzle type per EDP 28988.

P421960109 was closed to this WO.

P421010100 9/7/2005 D&I - Good condition P421130100 7/9/2013 Cannot locate work package / documentation 49705777 10/21/19 D&I - Good condition P4400F182 WO#

Date Complete Examination Results 0002980849 9/18/1998 Valve replaced with nozzle type per EDP 28988.

P424960109 was closed to this WO.

P424010100 11/13/2004 D&I - Good condition P424120100 3/10/2014 D&I - Good condition P4400F246 WO#

Date Complete Examination Results 0002980850 9/30/1998 Valve replaced with nozzle type per EDP 28988. was closed to this WO.

P423960219 4/15/2000 D&I - Good condition P423030100 4/10/2003 D&I - Good condition Valve internals SAT during disassembly. However, valve failed to close during PMT surveillance 24.207.04 (CARD P423100100 4/3/2012 12-22910). WO 34290900 was performed to investigate by valve disassembly. No issues were noted with valve internals. Valve was then closed and passed PMT.

34290900 4/19/2012 D&I - Good condition. (see P4231 00100).

48162254 10/9/2018 D&I - Good condition.

3.0 Total Page Count (194 Pages)

FAILURE MODES AND CAUSES ANALYSIS 3.1 3.2 Failure Modes Failure to Open (FTO)

~

Failure to Close (FTC)

~

Internal Leakage (IL)

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM)

~

Broken/Detached Pars (BDP)

Failure Causes Normal Wear lZI Maintenance Error Abnormal Wear lZI Manufacturing Error Design Corrosion

~

Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Remarks:

Since the nozzle check valves were installed in 1998 (in place of lift checks previously used) there have been two failures. In 2009 a failure of P4400F111A was attributed to corrosion product buildup on the valve internals. In 2012, P4400F246 failed a PMT following a satisfactory D&I. Subsequent investigation could not determine a cause for failure and the valve was reassembled and passed PMT.

Both valves have performed satisfactory in surveillances following these events. For more detail see section 2.3.

Total Page Count (194 Pages) 4 0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure I Detect Degradation Detected NA NA NA NA Medium Low RM, FTC NA NA Medium Low RM, FTC High High All NA NA NA NA NA NA NA NA NA NA NA NA NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but > 25%

Low -

probability of detection < 25%

N/A -

test method not available 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements Prior to CMJ implementation The valves in Group CMJ-11 were exercised closed as part of the 1ST program per 24.207.04 (F246), 24.207.08 (F038, F111A), 24.207.09 (F111 8), and 24.207.11 (F182). No failures have occurred since 2018.

Although open exercise testing was not previously required by the 1ST Program, disassembly inspection was performed on each valve on periodic basis. This is a visual and functional inspection to identify evidence of wear, corrosion, damaged or missing internals, and the condition of locking devices. All of the valves in the group have at least two D&l's performed since 1998.

Total Page Count (194 Pages) 5.2 Condition Monitoring Program Plan Status:

Inter i m Plan IZI 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: Back Flow/Reverse Flow Demonstrated the ability of the valve to prevent backflow and isolate non-essential equipment cooling during EECW operation.

Frequency:

P4400F038, F111A and F111 Bare tested quarterly.

P4400F182 is tested at a refueling outage frequency.

P4400F246 is tested at a refueling outage frequency.

Tasks:

24.207.04 (F246) 24.207.08 (F038, F111A) 24.207.09 (F111B) 24.207.11 (F182)

Notes:

Each return check is verified closed by monitoring for lack of leakage through upstream drains. Trending is on 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:

P4400F038 - P422 - 2750 days P4400F111A-P420 - 2730 days P4400F111 B - P421 - 2730 days P4400F182 - P424 - 2750 days P4400F246 - P423 - 2750 days Tasks:

43.000.010 (ISi) 35.000.232 (Maintenance)

Notes:

The inspection results from disassembly and inspection shall be trended

Total Page Count (194 Pages) 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.

Given the current frequency of the existing D&I PMs, each valve in this Group will be disassembled and inspected within eight years. This inspection period is justified for the following reasons:

1. Per the OM Code (11 -3000), a group of this size is allowed a maximum inspection interval of 16 years. The actual interval used in half of the maximum allowed.

2. Previous disassembly and inspection results, which are available for all valves in this Group, suggest overall good valve performance.

5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMJ tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance. Closed exercise (backflow and total water leakage monitoring) testing under the 1ST Program and periodic internal inspections of the valves have demonstrated the valves are performing their function satisfactorily. This supports placing this Group in a Final CMJ plan.

The periodic performance of a disassemble inspection test was selected for this group for the following reasons:

1. It demonstrates the bi-directional functionality of the valve (I.e. allows for assessment of the open functionality of the check valves.

2. It is highly effective in detecting all failure modes for nozzle check valves.

3. It is a good identifier that the internals are intact with o abnormal wear, provides trending data to monitor for degradation and provides further assurance of operational readiness during the entire interval.

4. It is the only plausible solution for trending internal conditions, since this type of check valve does not have external means for open/close mechanical exercise a d does not allow for access to its internals, unless the valve is removed from the line.

5. It allows for cleaning of debris (e.g. corrosion products) from valve internals. Corrosion product buildup is one of the primary failure causes in nozzle checlk valves.

Closed direction verification testing (backflow testing) further verifies the ability of the valve to perform its function.

Total Page Count (194 Pages)

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-12: Nitrogen lnerting Check Valves 1.0 GROUP INFORMATION 1.1 Valve List T4901F001 PC Pneu DIV1 Inst N2 lnerting Sply To OTBD (PC) ISO VLV V4-2079 Check VLV T4901F006 PC Pneu DIV1 N2 lnerting Bottle SPLY Check VLV T4901F010 PC Pneu DIV2 Inst N2 lnerting Sply Tb OTBD (PC) ISO VLV V4-2187 Check VLV T4901F012 PC Pneu DIV2 N2 lnerting Bottle SPLY Check VLV 1.2 Manufacturing Data Manufacturer:

Rockwell Valve Type:

Model:

Size:

Valve Body Material:

Disc Material:

Desig Feature:

Lift Y-Globe 838YT (T 4901 F006 and F0 12) 838YFRT (T4901 F001 and F010) 1.0" and 1.5".

CARBON STEEL SA 105 SA182GR.F11, STELLITED (T4901F001 and F010)

A479T41 0NUC (T4901 F006 and F012)

Bolted Bonnet, Spring Loaded

1.3 1.4 Total Page Count (194 Pages)

Service Conditions Service Duty:

Nitrogen System Flow:

Intermittent System Pressure:

150 PSIG System Temperature:

150°F Grouping Bases These valves are grouped together based on having the same man facturer, model, and service application. The following were considered in group determination:

IX!Same Mfg Service Conditions Identical Application Identical Test Methodology IZ! lnfrequent Operation IZI Like Orientation 0 Like Design Maximum Flow Unachievable Simila r Upstream Downstream Flow Turbulence Other 1.5 Safety Function Discussion ForT4901F001 Open Position - Non-safety This check valve is located in the NIS supply line to the PCPS system Div 1 control air header. The valve opens to allow N2 from the nitrogen inerting system to provide control pneumatic pressure to the satiety related components supplied by the PCPS Div 1 control air header inside the drywell. This is not a safety function since the NIS is not safety related and a safety related source (NIAS) is available to perform this function if the NIS is lost.

Closed Position - Safety This valve closes on reverse flow to isolate the NIS system from the PCPS system if the NIS to PCPS system isolation valve should fail to close. This valve has a safety function in the closed position.

Total Page Count (194 Pages)

ForT4901F006 Open Position - Safety This check valve is located in the N2 emergency backup bottled supply line to the PCPS system Div 1 control air header. The valve opens to allow N2 from the emergency backup bottles to provide control pneumatic pressure to the safety related components supplied by the PCPS Div 1 control air header inside the drywell. This valve has a safety function in the open position.

Closed Position - Safety This valve closes on reverse flow to isolate the NIS system from the N2 emergency backup bottled supply when the NIS or NIAS is supplying N2 to PCPS system to isolate a potential leak path and provide the class 3 boundary between the PCPS system and the emergency backup N2 bottles. This valve has a safety function in the closed position.

ForT4901F010 Open Position - Non-safety This check valve is located in the NIS supply line to the PCPS system Div 2 control air header. The valve opens to allow N2 from the nitrogen inerting system to provide control pneumatic pressure to the safety related components supplied by the PCPS Div 2 control air header inside the drywell. This is not a safety function since the NIS is not safety related and a safety related source (N2 emergency backup bottles) is available to perform this function if the NIS is lost.

Closed Position - Safety This valve closes on reverse flow to isolate the NIS system from the PCPS system if the NIIS to PCPS system isolation valve should fail to close. This valve has a safety function in the closed position.

Total Page Count (194 Pages)

ForT4901F012 Open Position - Safety This check valve is located in the N2 emergency backup bottled supply line to the PCPS system Div 2 control air header. The valve opens to allow N2 from the emergency backup bottles to provide control pneumatic pressure to the safety related components supplied by the PCPS Div 2 control air header inside the drywell. This is considered a safety function since this supply is considered safety related and the normal N2 supply form the NIS is not safety related and this is the only safety related source (N2 emergency backup bottles) available to perform this function if the NIS is lost.

Closed Position - Safety This valve closes on reverse flow to isolate the NIS system from the N2 emergency backup bottled supply when the NIS is supplying N2 to PCPS system. This valve has a safety function in the closed position.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience Plant service experience for the valves in this group has been good overall. No failures of significant degradation has been identified during performance of past disassembly and inspection activities.

2.2 Industry Service Experience Generic Notices The RC 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

Total Page Count (194 Pages) susceptible to corrosion products buildup.

Applicability: Applicable. Corrosion products are present in the Fermi 2 nitrogen inerting lines, but to a much lesser extent than any water system. Therefore, the probability of valve function failure due to corrosion deposits in the disc/seat area is very low for the nitrogen inerting system.

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. Corrosion products are present in the Fermi 2 nitrogen inerting lines, but to a much lesser extent than any water system. Additionally, corrosion and binding of valve internals are much less likely in the inert nitrogen environment, compared to the stagnant water conditions of water systems.

Therefore, the probability of valve function failure due to corrosion deposits in the disc/seat area or internal corrosion related binding is very low for the nitrogen inerting system.

IOM Review None.

Total Page Count (194 Pages)

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 CMJ-09. Failures of valves in air/nitrogen systems were not considered 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. Corrosion products are present in the Fermi' 2 nitrogen inerting lines, but to a much lesser extent than any water system. Additionally, corrosion and binding of valve internals are much less likely in the inert nitrogen environment, compared to the stagnant water conditions of water systems.

Therefore, the probability of valve function failure due to corrosion deposits in the disc/seat area or internal corrosion related binding is very low for the nitrogen inerting system.

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. Corrosion products are present in the Fermi 2 nitrogen inerting lines, but to a much lesser extent than any water system. Additionally, corrosion and binding of valve internals are much less likely in the inert nitrogen environment, compared to the stagnant water conditions of water systems.

Therefore, the probability of valve function failure due to corrosion deposits in the disc/seat area or internal corrosion related binding is very low for the nitrogen inerting system.

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. Based on historical experience with these valves, the likely cause for this event was valve internals binding due to corrosion. Manual agitation of the valve resulted in dislodging of the

Total Page Count (194 Pages) crud layer responsible for the binding.

Applicability: Applicable. Corrosion products are present in the Fermi 2 nitrogen inerting lines, but to a much lesser extent than any water system. Additionally, corrosion and binding of valve internals are much less likely in the inert nitrogen environment, compared to the stagnant water conditions of water systems.

Therefore, the probability of valve function failure due to corrosion deposits in the disc/seat area or internal corrosion related binding is very low for the nitrogen inerting system.

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. Corrosion products are present in the Fermi 2 nitrogen inerting lines, but to a much lesser extent than any water system or systems subject to traceable amounts of moisture (i.e. condensation). Additionally, corrosion and binding of valve internals are much less likely in the inert nitrogen environment, compared to the systems with water exposure conditions. Therefore, the probability of valve function failure due to corrosion deposits in the disc/seat area or internal corrosion related binding is very low for the nitrogen inerting system.

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. Corrosion products are present in the Fermi 2 nitrogen inerti g lines, but to a much lesser extent than any water system or systems subject to traceable amounts of moisture (i.e. condensation). Additionally, corrosion and binding of valve internals are much less likely in the inert nitrogen environment, compared to the systems with water exposure conditions. Therefore, the probability of valve function failure due to corrosion deposits in the disc/seat area or internal corrosion related binding is very low for the nitrogen inerting system.

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 was reviewed:

Total Page Count (194 Pages)

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. Valves in Group CMP-13 are category C valves (open/close check valves) and do not have a seat leakage criteria associated with them.

Vendor Input There was no vendor input or Part 21 Reports associated with 1" and 1.5" Rockwell-Edward piston (lift) check valves.

Industry Template There was no Rockwell-Edward Piston (Lift) Check Valve Industry Template on the Nuclear Industry Check (NIC) Valve Group's website.

2.2.1 References Generic Notices LER/OE Notices IOM Review None NIC Database Review EPIX Review Vendor Input Industry Template 2.3 Valve History Information Information Notice 97-31 LER 05-002-00 and OE21402 (LaSalle)

Failure Record Numbers FRN 85-089.

None None None Each valve in Group CMP-13 has at least one disassembly and inspection (D&I) performed since 9/28/1998. All D&l's resulted in satisfactory results, which is an expected outcome, given the inert nitrogen environment these valves are continuously subjected to.

Total Page Count (194 Pages)

T4901F001 WO#

Date Complete Examination Results H335040100 11 /18/04 S.atisfactory condition.

H335130100 10/13/18 S.atisfactory condition.

T4901F006 WO#

Date Complete Examination Results P4279705012 9/28/98 Satisfactory condition.

P427070100 11/11/07 Satisfactory condition.

25975766 10/14/18 Satisfactory condition.

T4901F010 WO#

Date Complete Examination Results H337060100 4/24/06 Satisfactory condition.

H337150100 4/6/20 Satisfactory condition T4901F012 WO#

Date Complete Examination Results H338060100 4/11/06 Satisfactory condition.

H338150100 4/5/20 Satisfactory condition. Some rust / pitting outside of sealing surface.

3.0 Total Page Count (194 Pages)

FAILURE MODES AND CAUSES ANALYSIS 3.1 3.2 Failure Modes Failure to Open (FTO)

IZI Failure to Close (FTC)

IZI Internal Leakage (IL)

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM) 181 Broken/Detached Pars (BOP)

Failure Causes Normal Wear IZI Maintenance Error Abnormal Wear Manufacturing Error Design Corrosion 181 Human Error Foreign Material

[g]

Procedure Stress Corrosion Cracking Eros ion/Co rrosion Improper Installation Other 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.

Total Page Count (194 Pages) 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT TesUlnspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure I

Detect Degradation Detected NA NA NA NA NA NA NA NA NA NA High High All NA NA NA NA NA NA NA NA NA NA NA NA NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but > 25%

Low -

probability of detection < 25%

N/A -

test method not available

Total Page Count (194 Pages) 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation The valves in this Group 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 CMJ implementation.

5.2 Condition Monitoring Program Plan Status:

Interim Plan 181Final 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 position, with no evidence of binding of the internals.

Frequency:

Each valve in group will be inspected at a frequency of 6R.

Tasks:

43.000.010 Notes:

Procedure inspection / measurement results shall be trended to monitor for evidence of degradation.

Total Page Count (194 Pages) 5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMJ tests and inspections identified in Section 5.2.1 have been selected to ensure continued acceptable and reliable check valve performance. Of the five past inspections, there was no failure of the valves in Group CMJ-12. This supports placing this Group in a Final CMJ plan.

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 condiHon. 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 verifies 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.

Group IP CMJ-13 Valve List:

E1100F050A, E1100F0508 Pescrjptjon:

Condition Monitoring Plan CVCM Group CMJ-13 Total Page Count (194 Pages)

This Check Valve Condition Monitoring evaluation follows the requirements of ASME OM Code Mandatory Appendix II Check Valve Condition Monitoring (CVCM) Program.

Manytactyrjng Pata:

Manufacturer - Anchor Darling Model Number - 2229-3 Valve Type - Stop Check Size - 24 inch Valve Body Material - SA 352 LCB Valve Internal Material - Disc SA-105, Hinge A216-WCB, Bushing 8139, Shaft A276-410T service conditions:

Service Duty - low duty cycle, severe service condition (pressure >1000 psig)

System Flow - 23352 gpm two pumps LPCI, 9250 gpm min. RHR Heat Hx Removal System Pressure - design pressure 1500 PSIG System Temperature - design temperature 575° F Service Media - water Valve Orientation - horizontal Safety Class.:

These check valves are Class 1

pressure isolatio:n valves.

Page 1 of 22

Safety f ynct;on Pescrjptjon:

Condition Monitoring Plan CVCM Group CMJ-13 Total Page Count (194 Pages)

These valves have a safety function in the open position. These air-operated testable check valves are required to open to permit LPCI flow to the reactor vessel for the LPCI mode of operation during a postulated LOCA The air operator for this valve is for test purposes only and is used to test the valve in the open direction only. The air operator is not required for the valve to open and meet its safety function. Testing of the operator is exempt from 1ST requirements based on ISTC-1200. [UFSAR 5.5.7, Table 6.2-2 & Note 36, Table 6.3-9] [DBD E11-00 Section 4.1.3.3, Data Sheet 4.2.3.22]

These valves have a safety function in the close position. These valves are normally closed to prevent reactor coolant leakage and are required to automatically close upon cessation of flow to maintain reactor coolant pressure boundary. These valves are designated pressure isolation valves required to protect high to low pressure interface and are the inboard isolation valves for penetrations X-13A (E1100F050B) or X-138 (E1100F050A). Reference T.S. SR 3.4.5.1 and UFSAR Table 6.3-9. TS Amendment 98 determined valves not subject to APP J testing due to water seal inside CTMT. (Note 36 UFSAR Table 6.2-2).

The valves are equipped with air operators for two reasons (non-safety):

allows full stroke testing to satisfy operability requirements; and can be opened to allow reverse flow through the LPCI lines to prewarm and flush these lines prior to entry into shutdown cooling.

A review of the Fermi AP-913 Maintenance Strategies indicates these valves are categorized as Risk Significant. This evaluation also documented that a failure of one of these valves would result in a loss of a High Safety Significant (Risk Significant)

Maintenance Rule (MR) Function. It lists the following applicable MR Risk Significant functions:

E1100-02 Remove reactor decay heat in the Torus Cooling Mode (TC) to the RHRSW system via one of the two divisional heat exchangers.

E 1100-04 Isolate containment in conjunction with other Containment isolation systems to provide protection against the release of radioactivity to the environment as a result of a postulated accident. (See A7100)

E1100-15 Remove reactor decay heat in the Shutdown Cooling Mode (SD) to the RHRSW system via one of two divisional heat exchangers.

E1151 -01 Remove heat in the Torus Cooling Mode (TC) from the RHR heat exchangers and transfer it to the environment through the Ultimate Heat Sink.

E1156-01 Dissipate the heat which has been transferred to the Ultimate Heat Sink, (RHR Reservoir).

Grouping Bases; These valves have been grouped together based on their similar design and service conditions. Both valves are located in the RHR system and have similar functions. Each valve has a full open Cv of 17916 and are tested as pressure isolation valves.

Page 2 of 22

Condition Monitoring Plan CVCM Group CMJ-13 Performance Anatysjs Reyjew Total Page Count (194 Pages)

The following trend graphs represent the results of seat leakage during he pressure isolation valve testing.

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Test Method Is ue SAT Test unsat Test Test Method Issue SAT Test Un t Test Note: Test Method Issues were not considered failures; only a testing problem. Once test methodology problem was addressed, subsequent satisfactory test results were obtained.

Page 3 of 22

Station Service Experience:

Condition Monitoring Plan CVCM Group CMJ-13 Total Page Count (194 Pages)

Upon review of both Fermi CARDs and Corrective Work Orders, Attachment 3 contains a summarized listing of pertinent documents.

Collectively, there have been eleven (11) valve position indication problems. The operation of the air operator is required only for testing the operability of the check valve when the differential pressure across the valve is approximately O psi and when operating properly does not impact the overall function of th_e check valve itself. There has been one event related to the actuator impacting the check valves' function. CARD 17-22684 identified an actuator issue where all attempts to free E1100F050B were unsuccessful, and WO 47381211 was initiated to perform disassembly and internal rework. The valve was disassembled, and found to be mechanically bound. The actuator and indicator shafts were found mechanically bound together, and the brass indicator shaft bushing was found mechanically bound to the valve body, with evidence of brass shavings within the valve body. With this binding present, the valve disc was being held at approximately half stroke, and also enslaving the actuator to the hinge arm. The force of binding was more than the actuator could overcome. As both the actuator and indicator stuffing boxes were loosened, the binding lessened and the valve disc was free to fall closed. Following RF17, procedure 35.205.009 was extensively revised to capture lessons learned and provide instructions for obtaining proper clearance between components. 35.205.009 Section 5.5 was rewritten to obtain the necessary 0.060-0.070" clearance between the spur gear and locating spacers prior to installing the actuator housing cover. Had this revision been available in RF17, the housing cover would not have been installed with interference. Consequently, this issue affecting overall valve function is considered corrected to the extent it will not impact these valves' entry into the CVCM Program.

The internals of E1100F050B have been reworked twice (2014 and 2015). In 2014, due to LLRT failure, the valve was disassembled. The disc was not inspected but replaced, soft seat was worn and flat, disc moved freely, pin to disc looked slightly oblong to disc yet disc appeared to be in full closed position with 360 degree contact. The soft seat was replaced. In 2015, following an indication problem and subsequent disassembly, during a manual full stroke, the valve opened but showed signs of drag at full open and hung up at full open and would not close without assistance As documented in CARD 15-28948, several problems were positively identified regarding the mechanical assembly of the valve's internal actuator shaft components and external actuator shaft gearing components, in addition to some parts found damaged during disassembly.

CARD 15-28948 concluded the valve procedure did not contain any guidance or instruction to verify the necessary clearances were present between components to allow the valve to function as designed, nor did it contain detailed instructions to stroke the valve prior to bonnet installation to verify all modes of valve stroking are functional.

This CARD concluded that the work in 2014 (CARD 14-21704) contributed to this failure condition. The 2015 event compounded by the maintenance activity in 2014 when looking at the overall valve test history indicates this event is not indicative of valve degradation. These two events are considered isolated events related to procedural deficiencies and would not impact the valves' entry into the CVCM Program.

Collectively, there have been four (4) seat replacements attributed to degradation all of which occurred between plant startup and the year 2000. No failures have been identified since 2000. Card 00-13873 states in 1994, the CIV test requirements were removed and thus air testing was no longer required. Therefore, the function for which Page 4 of 22

Condition Monitoring Plan CVCM Group CMJ-13 Total Page Count (194 Pages) the elastomer O-ring was installed no longer exists. However, the O-ring does provide assistance in performing the required water test. The O-ring helps because the water test configuration cannot fully duplicate operating and accident conditions due to system constraints. As documented in CARD 00~13873, to pass the low pressure air test for LLRT, the elastomer seal must work. However, at high pressure conditions the O-ring is compressed so that stellite to stellite contact is made, thus sealing is achieved by metal to metal contact. Under these conditions, the O-ring plays no role. CARD 14-21704 associated with E1100F0508 documented a summary of seat performance: "Per CARD 01-20794, there was a noted improvement in the performance of E1100F050A & B over the past 3 cycles. There were no failures primarily because of enhancements to the test methodology. The enhancements to the test methodology provided a better initial closure of the valve before the LLRT. Since the closure of CARD 01-20704, the performance history for both E1100F050A and E1100F0508 has been excellent until the failure noted within this CARD. The surveillance and work order history shows that, as of 4/17/14, the soft seat within E1100F050A has been installed for just over 11 years with a leakage rate between 0.021 and 0.87 gpm out of an allowable Total Acceptance Criteria Maximum Leakage of 10.0 gpm. On 4/6/03, the disc and soft seat for E1100F050A were replaced under Work Order 000Z020786. Except for surveillance testing, no corrective, elective, or preventive maintenance was performed to the valve internals for E1100F050A. At the time of the LLRT failure for E1100F050B (i.e. 2127/14), the soft seat within E1100F050B had been installed for just over 12 years with a Jeakage rate between 0.002 to 0.42 gpm out of an allowable Total Acceptance Criteria Maximum Leakage of 10.0 gpm. On 11/3101, on the soft seat for E1100F050B was replaced under Work Order 000Z002031 even though it passed the LLRT. System Engineering did not find any historical evidence of a preventive maintenance regime for inspecting the internals of either E1100F050A or E1100F0508 in the CARD, surveillance, or work order history. As of 4/17/14, the maintenance strategy justification section for conducting a visual inspection the valve internals of both E1100F050A and E1100F050B within lnsertKey (!KS) states the following: "No PM needed at this time. Currently this PIS is leak tested every 3R under ST event 3589 /AW 43.401.516. Existing functional testing adequate with these valves. No intrusive inspection necessary unless testing shows the need."

Industry Servjce Exoerjence; Both INPO ICES and NIC database searches were performed based on the valve and model. The results are listed on Attachments 1 and 2. In general, the NIC results are bounded by the ICES search.

These valves appear to be unique to Fermi. There have been six (6) failures associated with seat degradation with one occurring at Browns Ferry. Browns Ferry attributed its failure to the incorrect material whereas the failures at Fermi appear to be more design related i.e. lack of anti-rotational devices, misalignment, etc. There were two (2) Fermi failures related to actuator design issues. There have been four (4) Fermi failures associated with human performance. One (1) failure at Clinton was related to the lack of a PM to lubricate the actuator. The last failure was a Fermi failure due to an actuator linkage issue.

All of the seat degradation issues at Fermi occurred from 1986 to 2000. Based on the PIV test results above, it would appear that the seat issues have been addressed based on the numerous satisfactory PIV test results. The same conclusion can be drawn related to the actuator design issues that occurred in 1990 and 1991 at Fermi that led to test failures. The four human errors by default are a valve issue based on INPO Page 5 of 22

Condition Monitoring Plan CVCM Group CMJ-13 Total Page Count (194 Pages) reporting criteria. The 2014 Fermi failure was related to linkage misalignment and not the valve internals. A failure occurred in 2017 (CARD 17-22684) when the cover was fully installed, the resulting deflection of the cover compressed against the spacers, spur gear, and shouldered actuator shaft, forcing the actuator shaft into the brass actuator shaft bushing. This failure was considered a procedure deficiency and not related to component degradation.

In summary, these failures do not indicate an industry service experience trend or design flaw.

Page 6 of 22

Total Page Count (194 Pages)

Condition Monitoring Plan CVCM Group CMJ-13 Historical failure Modes and Causes Statjon Specjfic Failure Modes; Failure to Open Failure to Close Restricted Motion Leak Test Failure Loose or Missing Parts station Specjfic Failure Causes:

Normal Wear Manufacturing Defect Abnormal Wear Corrosion Design Erosion Maintenance Error Foreign Material Disc Separation Hinge Pin Wear Recommended Act;v;t;es tor Condition Monjtorjng Corrosion Cracking Stress Corrosion Cracking Procedures Improper Installation Other:

1) Seat leakage testing per TS 3.4.5.1 in accordance with SP 43.401.516 following the alternative test frequencies as allowed by Relief Request VRR-003. This test performs the check valve closed (eVC) and obturator verification closed tests (OVC).

2) Forward flow testing per SOP 23.205 at a flow rate between 10,000 GPM and 10,700 GPM.. This method performs the check valve open (eVO) and obturator verification open tests (OVO). Alternate methods to satisfy the forward flow testing requirement are listed under Items 5 and 6 below.

3) Internal examination will be performed using 43.000.01 O and applicable 35 series Maintenance Procedure at an eight-year frequency which aligns with EPRI templates. If the valve is disassembled for any corrective maintenance work an inspection will be documented using 43.000.010. This method exercises the disc open and closed including obturator verification.

4) Remote Position Indication will be performed every two years using item 2 above or item 5 below.

5) Forward Flow Alternate Testing Method 1: As an alternate to forward flow testing, a full open stroke using the testing actuator per 24.204.05 may be performed. This alternate performs the check valve open exercise, obturator verification open tests (OVO), and the remote position indication test (RPI).

6) Forward Flow Alternate Testing Method 2: As an alternate to forward flow testing, a disassembly and inspection may be performed.

This alternative performs the check valve exercise and obturator verification in both directions (eVO, OVO, eve, OVe).

Page 7 of 22

Condition Monitoring Plan CVCM Group CMJ-13 Bases for Test and lospectjon Strategy:

Total Page Count (194 Pages)

From above, these valves have had failures related to restricted motion and excessive leakage.

Restricted motion failures have been attributed to a combination of human error and lack of detailed procedural guidance. Several CARDs' corrective actions have improved procedural guidance which ultimately should reduce human errors.

Leak test failures have been attributed to design flaws as well as human errors and procedure quality. A design flaw was been corrected related to the lack of an anti-rotation device thus allowing the disc to damage the soft seat material. Some leak test failures have been attributed to the actuator's disassembly/reassembly procedure which lacked critical steps to obtain the proper operation upon return to service. Refer to the Station Service Experience section for additional details.

With the improvement in seat performance stemming from improved actuator maintenance procedure guidance, installation of anti-rotation devices, etc. the trending of seat leakage will be used to monitor and assess component degradation. These improvements have aided in the elimination of the human and design issues thereby allowing any change in seat condition or critical piece/part clearances to be identified by changes in seat leakage. Industry operating experience indicates that seat leakage is an accepted methodology for the identification of changing valve internals typically related to early signs of wear in critical mating surfaces i.e. hinge pin/disc arm, b shing/hinge pin, etc. as well as disc-to-seat contact. Catastrophic seat failure is no longer expected.

These valves require PIV testing at the frequency specified in Fermi Relief Request VRR-003 which is the _primary means to meet the closed check valve exercise requirement. These valves are also cycled open with forward flow during the shutdown cooling mode in accordance with SOP 23.205 'Residual Hear Removal System' sections 6.1 and 6.2 as applicable to a flow rate between 10000 and 10700 gpm which provides reasonable assurance of disc operation in he interim period between leakage testing and disassembly inspections. Verification of the open light and shutdown flow cooling flow provides evidence the valves are open. The open light is set using the actuator which was designed to perform a full 100% stroke per EDP-11577. The disassembly and inspection may be used to verify full disc operation and inspect critical parts for wear and other indications that would prevent the disc from operating and seating properly.

These valves have had a significant history associated with each valves' actuator's position indication. There have been some issues where the actuator was not set up correctly which led to dual indication or no indication for the expected position. In another case, because of lack of adequate procedural details, valve operation was affected. Currently, there are plant modifications slated to remove these valves' actuators. Refer to Attachment 4 for additional details.

Based on the overall history and subsequent design changes and the low duty cycle (outage shutdown cooling), the trending of the results from these valves' PIV seat leakage test will be used to monitor and assess valve performance. In addition, a periodic disassembly to inspect/replace the seats is recommended as per the existing PM Maintenance Strategies.

Page 8 of 22

Total Page Count (194 Pages)

Condition Monitoring Plan CVCM Group CMJ 13 Ig11ll Di LU!,tiQ !l Attrjbute1 Ac,g12ti!a,e Critgcii!

D Full/Partial Stroke Open Full Open Required flow rate or change in tank level achieved D

Full Open Indication Required flow rate achieved or DP not exceeded D

Partial Open Required flow rate achieved or DO not exceeded D

Position Indication Required position indicated Flow Test (Backward)

D Pressure Profile Required DP achieved Back Leakage Flow rate not exceeded Temp Profile DT limits achieved Pump Reverse Rotation No Reverse Rotation observed IR Imaging OT limits not exceeded D

Stroke Timing D

Obturator Stroke Required lime achieved Pump Start/Stop Required time achieved Valve Open/Close Required lime achieved Seat Leak Detection D

Acoustics Required RMS level not exceeded D

Airborne Ultrasonic Verification by audible noise D

Pressure Decay Pressure drop not exceeded D

Flow Makeup (LLRT)

Leakage rate within limits Disassembly &

D Disc Movement Required Movement Examination Disc to Seat Contact Bluing, light, or feeler gauge Wear Measurements Dimensional requirements D

Acoustic Time Waveform Required close/open impacts indicated Frequency Verification of frequency peaks Impacts Verification of amplitude and duration Impact Rate Required number per unit time Audible Noise Verification by audible analysis Event Origin Verification of arrival time Magnetics DC Verification supported by acoustics and flow D

AC Verification supported by acoustics and flow D

Eddy Current D

Full stroke voltage delta Verification of delta voltage D

Stroke Time Required time achieved D

Ultrasonic Test D

Obturator Angular Velocity Required degrees per second achieved D

Obturator Open Angle Obturator not stuck and valve opens/closes D

Obturator Close Signal goes to zero D

Obturator Flutter Change in distance per unit of time within acceptable range D

Confirmation of internals Measurement verification Radiography D

Obturator close Verification on film observed D

Obturator open Verification on film observed D

Dimensional data Inches of wear within tolerances Page 9 of 22

ICES #40324 dated 1986 (Fermi)

Event Summary: - ICES Search Results Total Page Count (194 Pages)

E1100-F050A (V8-2163) DRYWELL HEAT REMOVAL 'A' RETURN CHECK VALVE FAILED LOCAL LEAK RATE TEST. THE VALVE LEAKED THROUGH THE SEAT.

Cause Summary:

THE RESILIENT SEAT OF THE VALVE HAD A SLIT WHICH PREVENTED THE VALVE FROM MAKING PROPER CONTACT ON CLOSING. ADDITIONALLY, THE VALVE WAS OUT OF ADJUSTMENT.

Corrective Action Summa1ry:

THE SOFT-SEAT OF THE VALVE WAS REPLACED. THE VALVE INTERNAL WAS CLEANED AND REASSEMBLED.

CVCM Evaluation Summary: Seat degradation ICES #41014 dated 1986 (Fermi)

Event Summary:

DRYWELL RESIDUAL HEAT REMOVAL (RHR) LOOP 'B' RETURN CHECK VALVE E1100-F050B (V8-2164) FAILED LOCAL LEAK RATE. THE VALVE WAS LEAKING FROM THE ACTUATOR AND FROM THE SEAT.

Cause Summary:

THE SOFT SEAT RING HAD A SPLIT AND FAILED TO MAINTAIN PRESSURE.

Corrective Action Summary:

THE SEAT RING WAS MACHINED TO IMPROVE THE SEATING ANGLE AND THE SOFT SEAT REPLACED.

CVCM Evaluation Summary: Seat degradation ICES #83197 dated 1989 (Fermi)

Event Summary:

RESIDUAL HEAT REMOVAL LOW PRESSURE COLLANT INJECTION LINE CHECK VALVE FAILED LOCAL LEAK RATE TEST. THE SOFT SEAT WAS FOUND HARDENED AND CRACKED. THE CRACKED SOFT SEAT WAS NO LONGER ABLE TO SEAL THE VALVE SEAT. REF. DER 88-0743, LCO 89-0840.

Cause Summary:

IT WAS SUGGESTED THAT THE DEGRADATION OF THE SOFT SEAT WAS DUE TO TORSIONAL LOADING. THE FLOW TO THE CHECK VALVE BECOMES TURBULENT AFTER THE ELBOW UPSTREAM, THEN POUNDS ON A PORTION OF THE SOFT SEAT OF THE VALVE MORE THAN THE OTHER PORTION. THE PROLONGED EFFECT OF THIS HYDRAULIC ACTION CONTRIBUTED TO DEGRADE THE SOFT SEAT.

Page 10 of 22

Total Page Count (194 Pages) - ICES Search Results Corrective Action Summary:

THE PLANT INSTALLED ANTI-ROTATIONAL LUGS ON THE VALVE DISC PER ENGINEERING DESIGN PACKAGE #10893.

REPLACED SOFT SEAT, INSTALLED SEAL RING AND RETAINER RING, THEN THE VALUE WAS REPACKED. REF. WR

1. 025C89072.

CVCM Evaluation Summary: Seat degradation ICES #85147 dated 1989 (Fermi)

Event Summary:

RESIDUAL HEAT REMOVAL DIVISION NO. 1 LOW PRESSURE COOLANT INJECTION LINE CHECK VALVE FAILED LOCAL LEAK RATE TEST. THE VALVE LEAKED AT THE RATE OF 164 STANDARD CUBIC FEET PER HOUR (SCFH). THE MAXIMUM ACCEPTABLE LEAK RATE 6.0 SCFH. (REF: DER 89-1063 AND DER 89-1100, LCO 89-0785)

Cause Summary:

THE SOFT SEAT ON THE CHECK VALVE WAS DEGRADED DUE TO DISC ROTATION. CAUSE OF FAILURE WAS SUSPECTED TO BE WEAR RELATED.

Corrective Action Summary:

REPLACED THE SOFT SEAT. INSTALLED ANTI-ROTATION DEVICE ON THE DISC (PER WR #002C890919).

CVCM Evaluation Summary: Seat degradation ICES #99908 dated 1990 (Fermi}

Event Summary:

DURING INSERVICE INSPECTION, THE RESIDUAL HEAT REMOVAL DIVISION 1 TESTABLE CHECK VALVE STUCK OPEN AND COULD NOT BE CLOSE. THE TWO SHAFTS FOR OPENING AND CLOSING THE PALLET MOVE IN THE SAME DIRECTION, INSTEAD OF EACH MOVING INDEPENDENT OF THE OTHER. THE FAILURE DOES NOT ADVERSELY AFFECT PLANT OPERATION BECAUSE THE PLANT WAS SHUTDOWN.

Cause Summary:

THE EXACT CAUSE FOR THE BINDING OF THE SHAFT WAS UNKNOWN. LACK OF LUBRICATION CONTRIBUTED TO THE FAILURE. THE SYSTEM OPERATION IS DEGRADED BECAUSE THE INJECTION LINE OF RESIDUAL HEAT REMOVAL LINE MUST BE OPERABLE PER PLANT TECHNICAL SPECIFICATION. (REF. LCO 90-0475 CRIS 307).

Corrective Action Summary:

THE SHAFT WAS LUBRICATED. THE RUBBER GASKET WAS REPLACED. A TEMPORARY MODIFICATION 90-0022 WAS INITIATED. ADDITIONAL DESIGN CHANGE THAT WILL INSTALL A NEW SHAFT ON THE VALVE WILL BE PERFORMED DURING Page 11 of 22

- ICES Search Results THE UPCOMING REFUEL OUTAGE.

CVCM Evaluation Summary: Design change needed for actuator ICES #102558 dated 1990 (Fermi)

Event Summary:

Total Page Count (194 Pages)

WHILE THE PLANT WAS IN COLD SHUTDOWN, IT WAS CASUALLY OBSERVED THAT RESIDUAL HEAT REMOVAL DIVISION ONE LOW PRESSURE COOLANT INJECTION (LPCI) LINE CHECK VALVE SHOWED THAT THE DISC WAS OPEN THOUGH THE SYSTEM WAS SHUTDOWN. THE DISC WAS NOT OPERATING, AND THE VALVE WAS STUCK OPEN. THE VALVE IS A CONTAINMENT ISOLATION VALVE FOR THE LPCI TRAIN.

Cause Summary:

THE FAILURE CAUSED A LOSS OF ONE REDUNDANT DIVISION BUT DID NOT AFFECT PLANT OPERATION. THE DISC FAILED TO MOVE BECAUSE OF DIRT BUILD UP ON THE ACTUATOR BUSHINGS. BUT THE ROOT CAUSE WAS THAT THE ACTUATOR WAS INCORRECTLY MOUNTED.

Corrective Action Summary:

TROUBLESHOOTING WAS PERFORMED. THE ACTUATOR WAS LUBRICATED, DISASSEMBLED, PROPERLY LEVELLED, SHIMMED, AND REASSEMBLED. THEN VALVE WAS EXERCISED TO FREE THE SEAT. (WR. 002D901206).

CVCM Evaluation Summary: Human error from prior maintenance ICES #107458 dated 1991 (Fermi)

Event Summary:

DURING THE SECOND REFUELING OUTAGE, LOCAL LEAK RATE TESTING OF THE RESIDUAL HEAT REMOVAL LOW PRESSURE COOLANT INJECTION LINE CHECK VALVE FAILED. THE LEAK RATE WAS 42.0 STANDARD CUBIC FEET PER HOUR.

THE LEAK WAS PASSED THE SEAT. AS THE PLANT WAS ON A COLD SHUTDOWN, THE CONCERN FOR PRIMARY CONTAINMENT INTEGRITY BREACHING WAS MINIMAL AND PLANT OPERATION WAS NOT AFFECTED.

Cause Summary:

WHEN THE VALVE WAS DISASSEMBLED, THERE WAS SIGNS OF SOFT SEAT DEGRADATION.

Corrective Action Summary:

AN ENGINEERING DESIGN PACKAGE 11577 WAS IMPLEMENTED TO REPLACE THE ACTUATORS WITH LARGE CYLINDERS THAT ARE CONNECTED BY A RACK AND PINION ARRANGEMENT TO THE DISC HINGE PIN THROUGH THE ACTUATOR SHAFT PROVIDING FULL STROKE CAPABILITY. THIS ALLOWS STROKING THE DISC TO A FULL OPEN, THUS REDUCING THE POTENTIAL OF DAMAGING THE SOFT SEATS DURING BACK FLOW CONDITIONS. (WR. 016E910117)

CVCM Evaluation Summary: Design change required for actuator and implemented Page 12 of 22

ICES #129871 dated 1992 (Fermi)

Event Summary: - ICES Search Results Total Page Count (194 Pages)

DURING A THIRD REFUELING OUTAGE LOCAL LEAK RATE TEST, THE RESIDUAL HEAT REMOVAL (RHR) DIVISION 1 INBOARD ISOLATION TESTABLE CHECK VALVE EXCEEDED ITS LEAK RATE ACCEPTANCE CRITERIA DUE TO A SEAT LEAK. THE LEAK DID NOT SIGNIFICANTLY AFFECT THE RHR SYSTEM OR PLANT OPERATIONS BECAUSE THE RHR SYSTEM WAS IN MAINTENANCE AND THE PLANT WAS IN COLD SHUTDOWN.

Cause Summary:

THE SOFT SEAT THAT COVERED THE HARD SEAT WAS WORN. UPON REMOVING THE SOFT SEAT, A LINEAR INDICATION, RESPONSIBLE FOR MOST OF THE LEAK, WAS FOUND ON THE HARD SEAT. THERE WERE SCRATCHES ON THE VALVE PRESSURE SEAL. THIS WEAR HAD ALSO CONTRIBUTED TO THE LEAK.

Corrective Action Summary:

A NEW SOFT SEAL AND RETAILER RINGS WERE INSTALLED. THE OPEN AND CLOSE LIMIT SWITCHES WERE ALSO REPLACED. NEW SCREWS WERE INSTALLED, AND THE VALVE SEAT WAS CLEANED. THE REWORK OF THE VALVE WAS PERFORMED UNDER THE DIRECTION OF THE VENDOR. (WR. 0002913948, PDC. 12195).

CVCM Evaluation Summary: Seat degradation ICES #161886 dated 1996 (Fermi)

Event Summary:

RESIDUAL HEAT REMOVAL (RHR) DIVISION 1 INBOARD ISOLATION TESTABLE CHECK VALVE FAILED ISI-LLRT TESTING WITH LEAKAGE ABOVE ALLOWABLE LEVELS. THE PLANT WAS SHUTDOWN FOR A REFUELING OUTAGE AND FELT NO EFFECT.

THE SYSTEM WAS ALSO UNAFFECTED.

Cause Summary:

THE VALVE'S SOFT SEAT WAS DISCOVERED TO BE DISTORTED. THE CAUSE FOR THIS FAILURE IS CONSIDERED TO BE NORMAL WEAR AND AGING.

Corrective Action Summary:

CORRECTIVE ACTION INCLUDED VALVE DISASSEMBLY, A NEW SOFT SEAT WAS INSTALLED. LEAK RATE TESTING WAS REPERFORMED WITH SATISFACTORY RESULTS. (000ZX952686)

CVCM Evaluation Summary: Seat degradation ICES #195130 dated 2001 (Fermi}

Event Summary:

Page 13 of 22

Total Page Count (194 Pages) - ICES Search Results ON NOVEMBER 9, 2001, LEAK RATE TESTING OF PRESSURE ISOLATION VALVE E1100F050A, DIVISION 1 RESIDUAL HEAT REMOVAL /LOW PRESSURE COOLANT INJECTION SYSTEM INJECTION LINE INBOARD ISOLATION CHECK VALVE, WAS PERFORMED IN ACCORDANCE WITH TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT SR 3.4.5.1. THE RESULTANT LEAK RATE WAS DETERMINED TO BE IN EXCESS OF THE SPECIFIED LEAKAGE CRITERIA OF 10 GPM. WHILE ATTEMPTING TO PRESSURIZE THE INBOARD SIDE OF THE VALVE, THE TEST PRESSURE COULD NOT BE ACHIEVED AND, THEREFORE, LEAKAGE PAST THE PIV WAS CATEGORIZED AS THROUGH SEAT LEAKAGE. VALVE E1100F050A AND ITS AIR OPERATED TEST ACTUATOR WERE DISASSEMBLED TO DETERMINE THE CAUSE OF THE EXCESSIVE LEAKAGE.

EXAMINATION REVEALED THAT THE VALVE DISK WAS BEING PREVENTED FROM FULLY CLOSING BY THE TEST ACTUATOR.

PREVIOUS ASSEMBLY OF THE ACTUATOR HAD RESULTED IN THE ACTUATOR SPUR GEAR AND THE ACTUATOR GEAR RACK BEING MISALIGNED BY ONE TOOTH SUCH THAT THE ACTUATOR SHAFT COULD NOT COMPLETE ITS FULL ROTATION. THIS PREVENTED THE VALVE DISK FROM FULLY CLOSING UNDER NO/LOW FLOW AND LOW DIFFERENTIAL PRESSURE CONDITIONS. THE LEAK TESTING METHOD USED ON NOVEMBER 9, 2001 INVOLVED VERY LOW FLOW CONDITIONS. VALVE E1100F050A HAD PASSED ITS LLRT COMING OUT OF THE PREVIOUS REFUELING OUTAGE BY EMPLOYING ANOTHER TEST METHOD CONSISTING OF PRESSURIZING THE LINE BEYOND THE CHECK VALVE TO THE NEXT ISOLATION VALVE, E1100F015A, AND THEN OPENING E1100F015A, SIMULATING A BREAK DOWNSTREAM. VALVE E1100F050A FULLY SEATED DURING THIS PREVIOUS TEST BECAUSE OF THE RESULTING DIFFERENTIAL PRESSURE EXERTED ON THE DISK. THE CAUSE OF THE FAILURE OF THE DISK TO FULLY CLOSE WAS DETERMINED TO BE IMPROPER REASSEMBLY OF THE ACTUATOR DURING THE PREVIOUS REFUELING OUTAGE BECAUSE OF INADEQUATE CRAFT SKILLS AND INSUFFICIENT CRAFT SUPERVISION DURING THIS PERIOD. THE PROCEDURE USED TO REASSEMBLE THE ACTUATOR FOLLOWING DISASSEMBLY PROVIDED DETAILED INSTRUCTIONS CONCERNING THE IMPORTANCE OF PROPER FIT, AND REQUIRED TH MATCH MARKS MADE DURING THE REMOVAL OF THE ACTUATOR TO BE PROPERLY ALIGNED UPON ITS RESTORATION. THIS WAS NOT PROPERLY PERFORMED DURING THE PREVIOUS REFUELING OUTAGE, RESULTING IN THE ACTUATOR SPUR GEAR AND THE ACTUATOR GEAR RACK BEING MISALIGNED BY ONE TOOTH SUCH THAT THE ACTUATOR SHAFT COULD NOT COMPLETE ITS FULL ROTATION.

CVCM Evaluation Summary: Human error from prior maintenance ICES #230443 dated 2008 (Clinton}

Event Summary:

EXCESSIVE LEAKAGE THROUGH FEEDWATER ISOLATION VALVE 1821 F032A (LER461-08003) ON 1/21/08, PRIMARY CONTAINMENT LOCAL LEAK RATE TEST (LLRT) PERFORMED ON FEEDWATER CHECK VALVE, 1B21-F032A, EXCEEDED ACCEPTANCE CRITERIA.

Cause Summary THE CAUSE OF THE 1B21-F032A CHECK VALVE TO FAIL ITS LEAK RATE TEST IS CONSIDERED TO BE AGE-RELATED DEGRADATION OF LUBRICATION CAUSING INCREASED FRICTION IN THE ACTUATOR, THE SAME CAUSE FOR THE SIMILAR FAILURE OF THE 1 821 F0328 FAILURE WHEN TESTED IN 2010 DURING REFUELING OUTAGE C1 R12. THE ACTUATOR HAD NOT BEEN RE-LUBRICATED SINCE INITIAL INSTALLATION DURING A REFUELING OUTAGE THAT ENDED IN MAY 1999. NO Page 14 of 22

- ICES Search Results PREVENTIVE MAINTENANCE ACTIVITIES EXISTED TO LUBRICATE OR OVERHAUL THE ACTUATOR.

CVCM Evaluation Summary: No preventive maintenance task ICES #231614 dated 2008 (Browns Ferry)

Event Summary:

Total Page Count (194 Pages) 3-CKV-69-629 AS FOUND LEAK RATE OF 105.0796 SCFH EXCEEDED THE ADMINISTRATIVE LEAK RATE OF 12 SCFH.

IMPROPER SEAT MATERIAL. REPLACED THE PRESENT KALREZ RESILENT SEAT MATERIAL WITH EPR SEAT MATERIAL CVCM Evaluation Summary: Seat degradation due to incorrect material ICES #234868 dated 2008 (Browns Ferry)

Repeat of 231614 above.

ICES #234883 dated 2008 (Browns Ferry)

Repeat of 231614 above.

ICES #234898 dated 2008 (Browns Ferry)

Repeat of 231614 above.

ICES #310645 dated.2014 (Fermi)

Event Summary:

DURING THE PERFORMANCE OF 43.401.516, "PRESSURE ISOLATION VALVE LEAKAGE TEST - LPCI INJECTION VALVES" IN A REFUELING OUTAGE, THE REQUIRED TEST PRESSURE OF 1,041 TO 1,060 PSIG COULD NOT BE ACHIEVED ON E1100F050B, DIVISION 2 RESIDUAL HEAT REMOVAL (RHR) LOW PRESSURE COOLANT INJECTION (LPCI) TESTABLE CHECK VALVE.

SEVERAL ATTEMPTS WERE MADE TO SEAT E1100F050B. AFTER EACH ATTEMPT, TEST PERSONNEL OBSERVED FLOW DOWNSTREAM OF E1100F050B. THE ABILITY TO ISOLATE PRIIMARY CONTAINMENT PENETRATION X-13A WAS CONFIRMED VIAA SUCCESSFUL LOCAL LEAK RATE TEST (LLRT) OF E1150F015B EARLIER IN THE OUTAGE.

Cause Summary:

THE CHECK VALVE INTERNALS WERE DISASSEMBLED AND INSPECTED, AND THE LINKAGE WAS DETERMINED TO BE THE LIKELY CAUSE OF THE LLRT FAILURE.

CVCM Evaluation Summary: Actuator linkage misalignment Page 15 of 22

ICES #321711 dated 2015 (Fermi)

Event Summary: - ICES Search Results Total Page Count (194 Pages)

ON FEBRUARY 26, 2014 (REFUEL OUTAGE 16), A CORRECTIVE ACTION DOCUMENT WAS INITIATED AFTER THE LLRT TEST PRESSURE COULD NOT BE ACHIEVED FOR THE DIVISION 2 RESIDUAL HEAT REMOVAL INBOARD ISOLATION AIR OPERATED TESTABLE CHECK VALVE. SUBSEQUENT TROUBLESHOOTING IDENTIFIED THAT WHEN THE AIR OPERATED ACTUATOR WAS DISCONNECTED FROM THE VALVE, THE AIR OPERATED ACTUATOR SHAFT EXHIBITED ADDITIONAL TRAVEL IN THE CLOSED DIRECTION.

Cause Summary:

THIS EVENT WAS CAUSED BY MECHANICAL BINDING DUE TO THE OMISSION OF ASSEMBLY CLEARANCES WITHIN THE MAINTENANCE PROCEDURE. IN ADDITION, THE CREW DID NOT STOP WHEN UNSURE DURING INSTALLATION OF THE ACTUATOR COVER.

CVCM Evaluation Summary: Human error from prior maintenance Page 16 of 22

Tolal Page Count (194 Pages) - NIC Database Search Results FAILURE failure VLV MFG MODEL VLV RECORD AGE

~ear UNIT NAME SYSTEM VLVID SIZE NAME NO BODY FAILURE DESCRIPTION FAILURE CAUSE CORRECTIVE ACTION NUMBER (in)

MATL RESIDUALHt:AI t-(t:rAUVAL UIVl:SIUN NU. 1 LUW I

PRESSURE COOLANT INJECTION LINE CHECK THE SOFT SEAT ON THE CHECK VN..VE WAS REPLACED THE SOFT SEAT. INSTALLED ANTI-Anchor/

VALVE FAILED LOCAL LEAK RATE TEST. THE RHR E 1100-FOSOA 24 Da~lng 2229-3 Carbon VALVE LEAKED AT THE RATE OF 164 STANDARD DEGRADED DUE TO DISC ROTATION. CAUSE OF ROTATION DEVICE ON THE DISC (PER WR 89-155 6

89 FERMl2 Stoel FAILURE WAS SUSPECTED TO BE \\/VEAR RELATED.

1. 002C890919)

Valve Co CUBIC FEET PER HOUR (SCFH). THE MAXIMUM ACCEPTABLE LEAK RATE 6.0 SCFH. ( REF : DER 89-10 DURING INSERVICE INSPECTION, THE RESIDUAL THE EXACT CAUSE FOR THE BINDING OF THE THE SHAFT WAS LUBRICATED. THE RUBBER GASKET HEAT REMOVN.. DIVISION 1 TESTABLE CHECK SHAFT WAS UNKNOWN. LACK OF LUBRICATION WAS REPLACED. A TEMPORARY MODIFICATION 90-Anchor/

Carl>or1 VALVE STUCK OPEN ANO COULD NOT BE CONTRIBUTED TO THE FAILURE. THE SYSTEM 0022 WAS INITIATED. ADDITIONAL DESIGN CHANGE RHR E1100-F050A 24 Oa11lng 2229-3 CLOSED. THE TWO SHAFTS FOR OPENING AND OPERATION IS DEGRADED BECAUSE THE THAT WILL INSTALL A NEW SHAFT ON THE VALVE WILL 90-153 7

90 FERMI 2 Steel INJECTION LINE OF RESIDUN.. HEAT REMOVAL LINE Valve Co CLOSING THE PN..LET MOVED IN THE SAME BE PERFORMED DURING THE UPCOMING REFUEL OIRECTION, INSTEAD OF EACH MOVING MUST BE OPERABLE PER PLANT TECHNICAL OUTAGE.

INDEPENDENT OF THE OTHER.

SPECIFICATION, AS THE PLANT WAS ON A COLO SHUTDOWN, IT WAS CASUALLY OBSERVED THAT RESIDUAL THE FAILURE CAUSED A LOSS OF ONE TROUBLESHOOTING WAS PERFORMED. THE Anchor/

Carl>or, HEAT REMOVN.. DIVISION ONE LOW PRESSURE REDUNDANT DIVISION BUT 010 NOT AFFECT PLANT ACTIJATOR WAS LUBRICATED ANO EXERCISED TO 90-193 7

90 FERM12 RHR E1100-F050A 24 Oarllng 2229-3 Sleet COOLANT INJECTION ( LPCI ) LINE CHECK VALVE OPERATION. THE DISC FAILED TO MOVE BECAUSE FREE VN..VE SEAT.

Valve Co SHOWED DISC OPEN WHEN THE SYSTEM WAS OF DIRT BUILD UPON ITS SURFACE AREA.

SHUTDOWN. THE o*sc WAS NOT OPERATING l

AND THE VN..VE WAS STUCK OPEN, AN ENGINEERING DESIGN PACKAGE 11577 WAS DURING THE SECOND REFUELING OUTAGE, IMPLEMENTED TO REPLACE THE ACTIJATORS WITH Anchor/

LOCAL LEAK RATE TESTING OF THE RESIDUAL LARGE CYLINDERS THAT ARE CONNECTED BY A RACK Carl>or1 HEAT REMOVAL LOW PRESS~E COOLANT WHEN THE VN..VE WAS DISASSEMBLED, IBERE AND PINION ARRANGEMENT TO THE DISC HINGE PIN 91-056 6.85 91 FERMI 2 RHR E1100-FOSOB 24 Darling 2229-3 Steel INJECTION LINE CHECK VN..VE FAILED. THE WAS SIGNS OF SOFT SEAT DEGRADATION.

THROUGH THE ACTUATOR SHAFT PROVIDING FULL Valve Co LEAK RATE WAS 42.0 STANDARD CUBIC FEET STROKE CAPABILITY. THIS ALLOWS STROKING OF THE PER HOUR. THE LEAK WAS PAST THE SEAT.

VALVE.

DURING A THIRD REFUELING OUTAGE LOCAL IBE SOFT SEAT THAT COVERED THE HARO SEAT A NEW SOFT SEAL AND RETAILER RINGS WERE LEAK RATE TEST, THE RESIDUAL HEAT WAS WORN. UPON REMOVING THE SOFT SEAT, A INSTALLED. THE OPEN AND CLOSE LIMIT S\\MITCHES Allcllor/

Carbon REMOVAL (RHR) DIVISION 1 INBOARD ISOLATION LINEAR INDICATION, RESPONSIBLE FOR MOST OF WERE ALSO REPLACED, NEW SCREWS WERE 92-370 92 FERMI 2 RHR E1100-F050A 24 Darling 2229-3 Steel TESTABLE CHECK VALVE EXC EEDEO ITS LEAK THE LEAK, WAS FOUND ON THE HARO SEAT. THERE INSTALLED. ANO THE VN..VE SEAT WAS CLEANED. THE Valve Co RATE ACCEPTANCE CRITERIA DUE TO A SEAT WERE SCRATCHES ON THE VALVE PRESSURE REWORK OF THE VALVE WAS PERFORMED UNDER LEAK. THE LEAK DID NOT SIGNIFICANTLY SEAL THE DIRECTION OF THE VENDOR.

AFFECT THE RHR SYSTEM.

RESIDUAL HEAT REMOVAL (RHR) DIVISION 1 INBOARD ISOLATION TESTABLE CHECK VN..VE THE VALVE'S SOFT SEAT WAS DISCOVERED TO BE CORRECTIVE ACTION INCLUDED VALVE Aitch<< I FAILED ISi-Li.RT TESTING WITH LEAKAGE ABOVE DISASSEMBLY, A NEW SOFT SEAT WAS INSTALLED.

96--163 12 96 FERMl2 E 11 OO-F050A 24 Oar1ing 2229-3 ALLOWABLE LEVELS. THE PLANT WAS DISTORTED. THE CAUSE FOR THIS FAILURE IS LEAK RATE TESTING WAS REPERFORMEO WITH VatveCo SHUTDOWN FOR A REFUELING OUTAGE AND CONSIDERED TO BE NORMAL WEAR AND AGING.

SATISFACTORY RESULTS. ( OOOZX952686 )

FELT NO EFFECT. THE SYSTEM WAS ALSO UNAFFECTED.

Page 17 of 22

Total Page Count (194 Pages) - Fermi CARD and WO Histories E1100F050A Document Condition Date Evaluation While conducting LLRT, E1100-DER 96-1219 F050A would not maintain test 9/29/96 Seat issue - soft seat replaced pressure While conducting LLRT, E1100-Seat issue - examination revealed that the valve disc soft seat had become CARD 00-degraded and would not provide the necessary sealing of the disc at the valve 23873 F050A would not maintain test 4/7/00 seat. During disassembly, the elastomer seal ring appeared desiccated and pressure crvstallized.

CARD 01-DIV I LPCI Testable Check Valve 9/4/01 Indication Issue - not valve related 17152 Closed Indication Flickerinq Human error, actuator reassembly issue - Valve E1100F050A and its air operated test actuator were disassembled to determine the cause of the CARD 01-While conducting LLRT, E1100-excessive leakage. Examination revealed that the valve disk was being 20111 F050A would not maintain test prevented from fully closing by the test actuator. Previous assembly of the pressure actuator had resulted in the actuator spur gear and the actuator gear rack being misaligned by one tooth such that the actuator shaft could not complete its full rotation.

Test Issue - not valve related. E11 00F050A did not actually fail RF11 leak rate testing. This CARD was written following the first attempted test. Within the CARD 06-E1100F050A Failed PIV Leak 3/29/06 same surveillance a different section of the test procedure was used which was 21618 Test SR 3.4.5.1 successful in fully closing the valve and allowing for a meaningful test, which passed. This CARD was used to make enhancements to the procedure and test method, to avoid "false" negative results in the future.

CARD 14-E1100F050A closed light did not 2/21/14 Indication Issue - not valve related 21515 extinquish durinq 24.204.05 CARD 15-E1100F050A is Indicating Dual in 4/03/15 Indication Issue - not valve related 22243 the MCR CARD 15-Dual indication on E 11 00F050A 10/15/15 Indication Issue-not valve related 27824 Page 18 of 22

Total Page Count (194 Pages) - Fermi CARD and WO Histories E1100F0508 Document Condition Date Evaluation While conducting LLRT, E1100-CARD 98-16435 F050B would not maintain test 9/08/98 Seat issue - soft seat replaced pressure CARD 12-23670 E11 00-F0508 indicates dual when 4/23/12 Indication Issue - not valve related strokina ooen Due to LLRT failure, valve was disassembled.

Disc was not inspected but replaced, soft seat WO 38090984 was worn and flat, disc moved 2/26/14 Valve issue - cause attributed to soft seat CARD 14-21704 freely, pin to disc looked slightly oblong to disc yet disc appeared to be in full closed position with 360 dearee contact.

Clearance on new hinge arm and Parts issue - during rework due to LLRT failure, parts were out of spec.

CARD 14-22017 disc washer out of specification 3/6/14 Reference WO 38090984 and requires evaluation CARD 14-22664 E1100F050B D2 RHR Testable 3/21/14 Indication Issue - not valve related Check Valve indicates dual Following shutdown of Division 2 CARD 14-22900 RHR from SDC mode and placing 3/28/14 Indication Issue - not valve related in STBY, E11 00F0508 indicated dual.

CARD 15-22065 E11 00-F050B would not fully open 3/20/15 Indication Issue - not valve related when actuated from the MCR.

Valve issue WO 42774669 was generated to initially repair the actuator and CARD 15-27568 Failed PMT on E1100F050B 10/10/15 verify position indication in RF17. WO 42774669 took the place of vyo WO 42774669 38221429 written to troubleshoot position indication which resulted 1n CARD 15-28948 and WO 44298095 Division 2 LPCI testable Check Valve issue during manual full stroke, the valve opened but showed signs of drag at full open and hung up at full open and would not close without CARD 15-28948 valve remained in open position 11/13/15 assistance. As documented in CARD 15-28948, several problems were WO 44298095 following full stroke test positively identified regarding the mechanical assembly of the valve's internal IAW MMA 26 troubleshooting actuator shaft components and external actuator shaft gearing components, in Page 19 of 22

CARD 16-2371 5 CARD 16-2887 4 CARD 17-22589 RHR Flow indicated on E11R608B is 10,200gpm. With these indications the E11 OOF050B (Division 2 LPCI testable check valve) should be indicating Full open with no abnormalities E1100F050B, Division 2 RHR LPCI Testable Check Valve, does not indicate full open Following the shutdown of Division 2 RHR the E1100F050B did not indicate full shut and Total Page Count (194 Pages) - Fermi CARD and WO Histories addition to some parts found damaged during disassembly. These problems were corrected by the installation of new (or modified) parts, machined to provide the proper clearances and allow the valve to operate as designed.

Three adverse mechanical conditions were found during the repair process on E1 100F050B:

1) The valve disc contacting the valve body at the end of its mechanical stroke, coupled with zero axial clearance between the swing arm, actuator clutch, and indicator bushing resulted in the disc binding to the valve body and remaining in the open position.

2) The actuator shaft was found mechanically bound to the indicator bushing, effectively locking together the actuator shaft, indicator bushing, swing arm, and actuator shaft clutch. This prevented independent movement between the actuator shaft and swing arm.

3) The actuator shaft spur gear and gear spacers were being compressed by the actuator frame assembly housing cover, in addition to the actuator gear rack not being aligned to the spur gear. This created additional friction and binding that the actuator cylinder return spring could not overcome, and the actuator could not return to its fully retracted position. This in turn prevented the valve disc from returning to its fully closed position when stroked with the actuator.

The valve procedure did not contain any guidance or instruction to verify the necessary clearances were present between components to allow the valve to function as designed, nor did it contain detailed instructions to stroke the valve prior to bonnet installation to verify all modes of valve stroking are functional.

This CARD concluded that the work in 2014 (CARD 14-21704) contributed to this failure condition.

5/5/16 I Indication Issue - not valve related 11/7/16 I Indication Issue-not valve related 3/26/17 I Indication Issue - not valve related Page 20 of 22

Total Page Count (194 Pages) - Fermi CARD and WO Histories would onlv indicate dual.

Actuator issue - Prior to valve disassembly, E11 00F0S0B was externally troubleshot (WO 47379827) to rule out actuator binding, misalignment, or over-torqued packing. All attempts to free the valve were unsuccessful, and WO 47381211 was initiated to perform disassembly and internal rework.

E11D0F050B was disassembled, and found to be mechanically bound.

Referencing M-5883, the actuator shaft and indicator shaft and bushing were During the performance of found mechanically bound together, and the brass indicator shaft bushing was CARD 17-22684 43.401.516 "Pressure Isolation found mechanically bound to the valve body, with evidence of brass shavings WO 47399434 Valve Leakage Test - LPCI within the valve body. With this binding present, the valve disc was being held at WO 47379827 Injection Valves", test pressure 3/28/17 approximately half stroke, and also enslaving the actuator to the hinge arm. The WO 47381211 could not be achieved on check force of binding was more than the actuator could overcome. As the both valve E 11 00F0S0B "Division 2 actuator and indicator stuffing boxes were loosened, the binding lessened and LPCI Testable Check Valve" the valve disc was free to fall closed. Following RF17, 35.205.009 was extensively revised to capture lessons learned and provide instructions for obtaining proper clearance between components. 35.205.009 Section 5.5 was rewritten to obtain the necessary 0.060-0.070" clearance between the spur gear and locating spacers prior to installing the actuator housing cover. Had this revision been available in RF17, the housing cover would not have been installed with interference.

Page 21 of 22

Purpose:

ATTACHMENT 4 Condition Monitoring Plan CVCM Group CMJ-13 Total Page Count (194 Pages)

Upon incorporation of these valves into the Fermi 1ST CVCM Program, this attachment will provide a guideline to address future remote position indication issues during the interim period until each valve's actuator and indication is removed.

current Jssue; Both E 1100F050A and E 11 00F050B have exhibited indication issues over the course of plant operation. These issues have resulted in pl'ant restart delays and operability evaluations. Each valve has a pending plant modification to remove the actuator and its position indication.

Current OM Code Reaujrements; The necessary valve obturator movement shall be determined by exercising the valve while observing an appropriate indicator, such as indicating lights that signal the required changes of obturator position, or by observing other evidence, such as changes in system pressure, flow rate, level, or temperature, that reflects change of obturator position. (ISTC-3530)

Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated. Where practicable, this local observation should be supplemented by other indications such as use of flowmeters or other suitable instrumentation to verify obturator position. These observations need not be concurrent. Where local observation is not possible, other indications shall be used for verification of valve operation. (ISTC-3700)

If a check valve fails to exhibit the required change of obturator position, it shall be declared inoperable. A retest showing acceptable performance shall be run following any required corrective action before the valve is returned to service. (ISTC-5224)

Evaluation:

The results of this evaluation indicates there are some actions Fermi can ake that will result in addressing by separating actual indication issues from those that are indicative of a specific check valve operation deficiency. Obviously, based on the safety functions of these check valves, any condition that can be attributed to actual check valve operation will require corrective action prior to plant power operation. However, upon ruling out a valve operational deficiency, an indication deficiency should be considered a nonconforming condition and not an operability issue. The scheduling and subsequent maintenance corrective action would be scheduled based on normal scheduling procedural guidelines and not necessarily driven by applicable system LCOs.

As one follows the OM Code excerpts above, ultimately as long as a check valve's obturator exhibits the required change in position, a check valve is operable. This OM Code requirement thereby supports the conclusion that a deficiency in these valves' position indication is a 1 0CFR Appendix B nonconforming condition.

As documented in the AP-913 Maintenance Strategy for each valve, these valves are equipped with air operators for two reasons (non-sa ety): allows full stroke testing to satisfy operability requirements; and can be opened to allow reverse flow through the LPCI lines to prewarm and flush these lines prior to entry into shutdown cooling.

Consequently, the following decision making flow chart should be used as guidance for proper OM Code application to respect to testing.

Page 22 of 22

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-14: RBCCW to EECW supply and CCHVAC Chilled Water Pump Discharge Check Valves 1.0 GROUP INFORMATION 1.1 Valve List P4200F037 RBCCW SUPPLY HEADER TO DIV 2 EECW CHECK VALVE P4200F049 RBCCW SUPPLY HEADER TO DIV 1 EECW CHECK VALVE T4100F352A CCHVAC Div. I Chilled Water Pump C041 Discharge Check Valve T4100F3528 CCHVAC Div. II Chilled Water Pump C040 Dischan::ie Check Valve 1.2 Manufacturing Data Manufacturer:

Valve Type:

Model:

Size:

350".

Valve Body Material:

Disc Material:

Design Feature:

1.3 Service Conditions Service Duty:

System Flow:

System Pressure:

System Temperature:

1.4 Grouping Bases Powell Swing Check 1561 AWE 4", 8" and 10" A-216 GrWCB A-216 Gr WCB / stainless facing (P4200) / A-473 Type 416 (T4100)

Bolted Bonnet Closed cooling water Continuous (P4200) / 50% duty - 2 Divisions (T 4100)

Approx. 250 GPM (T4100) / Approx. 1500 GPM (P4200) 150 PSIG (P4200) / 22 PSIG (T4100)

P4200 < 150F / T4100 - 45F These valves are grouped together based on having the same manufacturer, model, and service application. The following were considered in group determination:

t81Same Mfg 181Service Conditions Identical Application Identical Test Methodology Infrequent Operation 1.5 Safety Function Discussion P4200F037 181Like Orientation 181Like Design Maximum Flow Unachievable Sim ilar Upstream Downstream Flow Turbulence O t her This check valve does NOT have a safety function in the OPEN Position. This check valve has a safety function in the CLOSE position. Check valve P4200F037 is credited with limiting EECW water loss from RBCCW MELB during the period when P4400F603B is closing. Reference Design Basis Document P44~00 Tables 1-A and 1-B for flow requirements.

Total Page Count (194 Pages)

P4200F049 This check valve does NOT have a safety function in the OPEN Position. This check valve has a safety function in the CLOSE position. Check valve P4200F049 is credited with limiting EECW water loss from RBCCW MELB during the period when P4400F603A is closing. Reference Design Basis Document P44-00 Tables 1-A and 1-8 for flow requirements.

T 41 00F352A&B These check valves have a safety function in the OPEN position. These check valves open to provide chilled water to CCHVAC. These check valves have a safety function in the CLOSED position. These check valves close to isolate the chilled water pump and prevent a reverse flow through the cooler and evaporator when the pump is idle. Surveillance !Procedure 24.413.01 provides a reference to the flow requirement for these valves.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience Plant service experience for the valves in this group has been good overall. No failures of significant degradation have been identified during performance of past disassembly and inspection activities.

2.2 Industry Service Experience Generic NRC Notices An electronic search of the NRC document collection was performed using keywords Powell 1561 and Powell 1561 AWE, and 1561 A-WE. No applicable generic notices were found.

OE Notices INPO OE Obtained from ICES ICES Reports 70, 363,367, 1288, 5412, 7850, 7851, 11205, 17321,25782, 32125, 37902, 39236, 40761, 45275, 53759, 63697,69842, 81409, 86839, 91917, 92847, 107150, 122172, 141842 144224, 156597, 188496, 191857, 210480, 245533, and 317751 were found to be applicable to a Powell 1561 AWE swing check valve. A separate search was performed under 1561A-WE. An additional 18 ICES reports were found applicable to the Powell 1561-AWE. The following failures were discussed:

1. Disk failed to close because the disk nut and disk post were made of dissimilar metals. Per DSN: 044028, the disc stud is carbon steel while the disc nut is stainless steel and therefore applicable to the P42 System check valves.

However, this is not a serious concern since the water in RBCCW / EECW water is deionized and does not contain the electrolytes necessary for galvanic corrosion. Also, the past internal visual inspections have not identified galvanic corrosion. This issue is not applicable to the T 41 System check valves since the

Total Page Count (194 Pages) disc and disc nut are both made of stainless steel. Reference DSN: 048120 1.

Also, the past internal visual inspections have not identified galvanic corrosion.

2. Valve disk found hung up due to hinge pin wear or similar wear and corrosion.

This is applicable to Fermi 2 especially for a check valve in normal operation.

3. Excessive leakage discovered while testing. The cause includes misalignment, design (orientation/ size), debris I corrosion products, packing & seal leaks.

Most of the cases were due to debris / corrosion products which is not applicable to closed D/I water systems. Two cases were due to failure of a viton softseat which is not applicable to the design of the subject valves.

Vendor Input There was no vendor input or Part 21 Reports associated with the Powell 1561 AWE check valve.

Internal CARD Search No CARDs were found describing reliability concerns.

2.3 Valve History Information A work order search was performed using Maximo and Insert Key work history. No corrective work orders were found based on reliability issues. The following internal inspection work orders were found. Reference PM events G321, G322, 1270 and 1271.

WO#

Date Complete Examination Results 43798825 12/13/16 T4100F352A (SAT) 43798908 9/28/16 T4100F352B (SAT) 51235321 12/11/19 T4100F352A (SAT) 50524710 6/17/19 T41 00F352B (SAT) 1270040100 4/1/06 P4200F037 (SAT) 1270120100 4/13/12 P4200F037 (SAT) 46483868 10/6/18 P4200F037 (SAT) 1271060100 4/3/06 P4200F049 (SAT) 1271120100 4/1/12 P4200F049 (SAT) 46483177 10/7/18 P4200F049 (SAT)

3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO)

Internal Leakage (IL)

Disk Separation (OS)

Not Applicable 3.2 Failure Causes Normal Wear C8J Abnormal Wear Design Human Error Procedure Erosion/Corrosion Other Remarks:

C8J 121 Failure to Close (FTC)

External Leakage (EL)

Hinge Pin Wear (HPW)

Restricted Motion (RM)

Maintenance Error Manufacturing Error Corrosion Foreign Material Stress Corrosion Cracking Improper Installation Total Page Count (194 Pages)

C8J C8J C8J C8J C8J 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.

4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Effectiveness of Activity to Failure Modes Test/Inspection Activity Detect Failure Detect Degradation Detected 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

Total Page Count (194 Pages)

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 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation The valves in this Group have been periodically disassembled and inspected at a frequency established by the Site Preventative Maintenance Program.

There are no different or additional testing requirements imposed prior to CMJ implementation.

5.2 Condition Monitoring Program Plan Status:

Interim Plan IZ!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 position, with no evidence of binding of the internals.

Frequency:

Each valve within 7 years.

Tasks:

43.000.010 Notes:

Procedure inspection / measurement results shall be trended to monitor for evidence of degradation.

2. Plan Activity: Open exercise with flow (T4100F352A/8)

Demonstrates the valve opens fully to meet design flow Frequency:

92 days

Tasks:

24.413.01 Notes:

Total Page Count (194 Pages)

The open exercise is verified by passing 240 GPM (F352B) or 246 GPM (F352A) 5.2.3 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the disassembly &

inspection identified in Section 5.2.1 has been selected to ensure continued acceptable and reliable check valve performance. There have been no failures of the valves in Group CMJ-14. This supports placing this Group in a Final CMJ plan.

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 condiUon. 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. This inspection covers both the open and closed exercise for valves P4200F037/F049. In addition, this inspection covers the closed direction exercise for valves T 41 00F352A/B; the open direction is verified per 24.413.01 for both T 4100 check valves.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-15: EESW Pump Minimum Flow Valve 1.0 GROUP INFORMATION 1.1 Valve List P45F400 Division 2 EESW Pum Minimum Flow Valve 1.2 1.3 1.4 P45F401 Division 1 EESW Pum Minimum Flow Valve Manufacturing Data Manufacturer:

Target Rock Valve Type:

Back Pressure Regulating Valve Model:

992510-002 Size:

2"x3" Valve Body Material:

SA-182 F316 Disc Material:

SA-564, GR 630 Design Feature:

Tack weld I sealed Service Conditions Service Water Service Duty:

Water System Flow:

200 GPM (DBD P45-00)

System Pressure:

175 PSIG, Design System Temperature:

125 F, Design Grouping Bases These valves are grouped together based on having the same manufacturer, model, and service application. The following were considered in gro p determination:

IZ!Same Mfg IZ!Service Conditions IZI Identical Application IZI Identical Test Methodology IZI Infrequent Operation IZ!Like Orientation

~ Like Design Maximum Flow Unachievable IZ!Similar Upstream Downstream Flow Turbulence Other 1.5 Safety Function Discussion P45F400 and P45F401 have a safety function in the Open position. These valves open at their design setpoint (80-88) to provide minimum flow pump protection.

The EESW Pump minimum flow requirement is 200 GPM. P45F400 and P45F401 have a safety function in the Closed position. These valves close to prevent diversion of EESW back to the reservoir.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience

Total Page Count (194 Pages)

A CARD search on P45F400 and P45F401 was performed in Crystal Reports. The following table summarizes the results:

CARD Description Summary 06-20430 Erosion of EESW An inspection noted inlet Minimum Flow Valve Body and outlet side erosion.

This is due to water service water laying inside the horizontal valve body and piping during stand-by. This corrosion did not affect the valve function.

06-21271 UT EESW minimum flow Same as CARD 06-20430.

valve bodies 06-27841 02 EESW minimum flow Same as CARD 06-20430 piping however the focus is on the attached horizontal run of piping.

07-24010 02 EESW Pump Minimum Minimum flow valve did Flow Valve P45F400 did not open during the not open during step 5.1.4 surveillance. Valve was of 24.208.03 Section 5.1 disassembled and significant corrosion was found in disk /seat area.

No shims were found in valve body however this did not have any impact on the valve opening.

11-28924 Request WO to replace Request to replace piping the horizontal piping based on corrosion of upstream of P45F401, Div horizontal section of 1 EESW minimum flow piping. See CARD 06-back pressure limiting 20430.

valve.

2.2 Industry Service Experience A search on the INPO and NRC websites specifically for Target Rock backflow regulating valve model 99Z510 series did not result in any notewort y operating experience.

As discussed in the table above, these valves are mounted in a honizontal section of piping used for pump EESW pump minimum flow. These valves are tested to open at a set pressure during surveillances 24.208.02/03. After the surveillances, a small amount of service water lays in the horizontal run of piping / valve body which

3.0 Total Page Count (194 Pages) caused corrosion to appear. The corrosion does appear to have affected P45F400 on one occasion. There are PM events (A473 and B929) to replace these valves with a tested spare. The valve removed from the field is shipped off site for set-point testing and overhaul. No other failures were observed that affected valve operation.

Vendor Input A review of Part 21 Report titles/ descriptions using the NRC website back through 2009. No Part 21 report was found related to the Target Rock Back Pressure Regulating Valve.

FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO)

[Z)

Failure to Close (FTC)

C8l Internal Leakage (IL)

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM) 3.2 Failure Causes Normal Wear Maintenance Error Abnormal Wear Manufacturing Error Design Corrosion

!ZI Human Error Foreign Material fgl Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Other 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Effectiveness of Activity to Failure Modes Test/Inspection Activity Detect Failure Detect Degradation Detected

. Full Open Stroke w/Flow NA NA All Partial Open Stroke w/Flow NA NA Back Flow/Reverse Flow NA NA All Manual Exercise NA NA Leak Test NA NA Disassembly & Inspection High High All Temperature Monitoring NA NA

Total Page Count (194 Pages)

Radiography NA NA Ultrasonic Testing NA NA Magnetics NA NA Acoustics NA NA Routine Operator Rounds NA NA Eddy Current Testing Test Effectiveness Rating:

NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but> 25%

Low -

probability of detection < 25%

N/A -

test method not available 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements Prior to CMJ Implementation The valves in this Group have been periodically disassembled and inspected at a frequency established by the Site Preventative Maintenance Program.

There are no different or additional testing requirements imposed prior to CMJ implementation.

5.2 Condi ion Monitoring Program Plan Status:

Interim Plan IZI Fi11al 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: Replacement with tested spare Valves are removed and replaced with a tested spare. Af er removal, all valves are sent off-site for refurbishment and set-point testing. PM events A473 and 8929 frequencies were optimized based on initial corrosion concerns. Reference CARD review in section 2.

Frequency: 4 years Tasks:

PM event job plans Notes:

None

2. Plan Activity: Open exercise and closed exercise.

Frequency:

92 days Tasks:

24.208.02/03 Notes:

Total Page Count (194 Pages)

During the EESW pump testing, the opening and closing of the minimum flow valve can be detected visually by looking through a viewing window slightly downstream of the valves.

5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the PM events associated with the refurbishment / set point test will detect major issues with P45F400/F401. This will allow the System Engineer to make preventative maintenance adjustments or i11vestigate system related issues based on the feedback from the off-site vendor. This ability was proven in the past per CARD 06-20430. In addition, the valves are exercised open and closed during EESW pump testing. There has only been one case where the valve failed to open on demand. This supports placing this Group in a Final CMJ plan.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Fermi Nuclear Station CMJ-16: RCIC Pump Discharge Check Valve 1.0 GROUP INFORMATION 1.1 Valve List E5100F014 RCIC Pump Discharge Check Valve 1.2 Manu 'acturing Data Manufacturer:

Valve Type:

Model:

Size:

Powell Y Check 16065-Y WE 6"

Total Page Count (194 Pages)

Valve Body Material:

CARBON STEEL A-216 Gr. WCB (stellite seat & guides)

Disc Material:

Design Feature:

1.3 Service Conditions Service Duty:

Syste Flow:

System Pressure:

System Temperature:

1.4 Grouping Bases A-216 Gr. WCB (stellite facing)

See Deco file P1 -916 (Y Lift check. No spring)

Water 655 GPM 1280 PSIG Design 170°F Design N/A - Only one valve in group.

Page 1 of 7

1.5 Safety Function Discussion Open Position - Safety This check valve opens to allow RCIC injection.

Closed Position - Safety Total Page Count (194 Pages)

This closes to serve as a pressure isolation valve. Reference LCR 20-025-IS1.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience Plant service experience for the valve in this group has been good overall based on a Fermi Condition Report Search. Only one CARD was identified (97-13070) however this CARD does not reference any specific conditions or work orders. The corrective maintenance log (IQ Review) was also searched and work order 00002935833 was found; no CARD was listed with this work order however this work order is linked to INPO OE 142309. A blue check of the seat was found unsatisfactory. The seat was lapped and the disc was replaced.

2.2 Industry Service Experience Generic Notices The NRC Document Reading Room was searched for Generic Notices or Information Bulletins pertaining to the Powell 16065-Y WE Check Valve using search terms 16065, 16065-Y, 16065-Y WE, and Powell Y Check.

o related Generic Notices were found for this valve design.

LER/OE Notices INPO's IRIS Network was reviewed for LER/OE reports on failures of the Powell 16065-Y WE check valve. The following OE was found:

Fermi 2 (OE 236778)

The discharge check (N2000F146A) failed to reposition. The lower guide rib (6 o' clock position) had significant and uneven wear which caused the disc to hang up in the open position. The cause appears to be from service wear due to excessive vibration coupled with the lack of a preventative maintenance strategy.

Page 2 of 7

Total Page Count (194 Pages)

Applicability: Applicable.

This type of failure is possible in E5100F014 but not likely due to service duty.

N2000F146A is oriented vertically downstream of a heater feed pump which is in continuous operation. E51 00F014 is typically exercised open during a RCIC pump surveillance every 92 days.

Fermi 2 (OE 142309)

E5100F014 was found leaking by the seat due to pitting. This was attributed to normal wear. The valve seat was lapped to remove the pits and a new disk was installed.

Applicability: Applicable.

The same valve is in service and therefore this type of failure is expected at similar servioe life. During RF20, this valve was seat leakage tested and passed acceptance criteria per 43.401.515.

Vendor Input No Part 21 Reports related to the Powell model 16065-Y WE check valve was found.

Industry Template The EPRI Preventative Maintenance Basis Database (PMBD) does provide a template for a lift/ piston type check valve (critical high/ mild service conditions -

CHM). It provides the typical failure locations as the following:

1. Disc failure (piston or plug) - Detected by evidence of seat leakage

2. Seat failure (body or disc) - Detected by evidence of seat leakage

3. Seat ring seal weld failure (as applicable) - Detected by evidence of seat leakage.

Various methods including In-Service Testing, Internal Inspection, Non-Intrusive Diagnostics, Operator Rounds, Radiography, and Walk-downs have the capability to deted some or all of these failure mechanisms. The maximum frequency for internal inspection (CHM) is 8 years.

2.3 Valve History Information Historically, E5100F014 has not had a PM event for disassembly and inspection.

However, as noted above, corrective maintenance work order 000Z935833 will serve as a baseline inspection (1993)

Page 3 of 7

Total Page Count (194 Pages)

E5100F014 WO#

Date Complete Examination Results No visible degradation found per 47.000.13, however blue 000Z935833 4/18/94 check was found unsatisfactory. Lapped seat and replaced disc.

3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO)

~

Failure to Close (FTC)

IZI Internal Leakage (IL)

~

External Leakage (EL)

Disk Separation (OS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM)

IZI Broken/Detached Pars (BOP) 3.2 Failure Causes Normal Wear IZI Maintenance Error Abnormal Wear Manufacturing Error Desig Corrosion IZI Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Other Page 4 of 7

Total Page Count (194 Pages) 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure Detect Degradation Detected NA NA Failure to open NA NA NA NA NA NA NA NA Seat Leakage High High All NA NA NA NA NA NA NA NA NA NA NA NA NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but> 25%

Low -

probability of detection < 25%

N/A -

test method not available Page 5 of 7

Total Page Count (194 Pages) 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Test and Inspection Requirements P *or to CMJ Implementation The valve in this Group has not had a formal disassembly and inspection since 1994.

One disassembly and inspection event must be worked prior to finalization of the plan.

5.2 Condition Monitoring Program Plan Status:

l:8llnterim Plan Final Plan 5.2.1 Condition Monitoring Test and Inspection Program Plan The following activities together represent the Condition Monitoring Program Plan for this valve.

1. Plan Activity: Disassembly & Inspection Demonstrates the valve has freedom of movement from full closed to full open and back to full closed position, with no evidence of binding of the internals. This inspection formally covers the check valve closed exercise (CVC).

Frequency:

Each valve in group will be inspected at a frequency of 2R.

Tasks:

43.000.010 Notes:

Once one disassembly and inspection event has been successfully completed, the frequency may be evaluated per Appendix II of the 2012 OM Code.

2. Plan Activity: Forward Flow Exercise Demonstrates the valve has freedom of movement from full closed to full open by passing the RCIC 1ST reference flow of 655 GPM. This test Page 6 of 7

Total Page Count (194 Pages) formally covers the check valve open exercise (CVO).

Frequency:

Every 92 days..

Tasks:

24.206.01 Notes:

None 5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition onitoring activities, the CMJ 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 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.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operational readiness.

Page 7 of 7

Total Page Count (194 Pages)

Fermi Nuclear Station CMJ-17 Core Spray Containment Isolation Check Valves 1.0 GROUP INFORMATION 1.1 Valve List E2100F006A CS DIV1 Inboard Primary Containment Check AOV E21 00F006B CS DIV2 Inboard Primary Containment Check AOV 1.2 Manufacturing Data Manufacturer:

Anchor Valve Co.

Valve Type:

Swing Model:

2226-3 Size:

12" Valve Body Material:

SA-352 LCB Disc Material:

SA-105 Design Feature:

Bolted 1.3 Service Conditions Service Duty:

Water System Flow (per Division):

System Pressure:

System Temperature:

1.4 Grouping Bases 6,350 gpm (Normal)/ 7,900 gpm (Design) 1050 PSIG (Normal)/ 1250 PSIG (Design) 546 °F (Normal)/ 575 °F (Design)

These valves have the same manufacture, model number and size. They are also serve the same function in their respective division of the Core Spray system and are exposed to the same operating conditions. Both valves are installed vertically and remain closed under normal plant operation, with RPV pressure proving the closing force.

These valves are grouped together based on having the same manufacturer, model, and service application. The following were considered in group determination:

1:81Same Mfg 181Service Conditions 1:81 Identical Application 1:81 Identical Test Methodology 18lFrequent Operation 181 Like Orientation 181 Like Design 181Maximum Flow Unachievable 181Similar Upstream Downstream Flow Turbulence Other Page 1 of 19

Total Page Count (194 Pages) 1.5 Safety Function Discussion E21 00F006A/B Checks These air operated testable check valves have a safety function in the OPEN position. They open on forward flow to permit Core Spray (CS) flow to the Reactor Pressure Vessel (RPV) during a postulated Loss of Coolant Accident (LOCA).

These testable check valves have a safety function in the CLOSED position. They are the inboard Containment Isolation Valves (CIVs) for penetrations X-16A/B. The valves close on reverse flow to isolate the penetration to maintain containment integrity. They also close as a Reactor Coolant Pressure Boundary (RCPB) isolation to protect the low-pressure piping of the Core Spray (CS) system from over pressurization.

2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience Review of the Fermi 2 CARD system was performed for E21 00F006A/B check valves and documented in Attachment 1. The CARDs related to these two valves were assigned different categories - Indication Problem, Seat Leakage, Air-operated Actuator Failure, Body-to-Bonnet Leak, Packing Leak, and Miscellaneous.

The three categories most consequential to the check valve meeting 1ST requirements are Indication Problem, Seat Leakage and AO Actuator Failure.

Therefore, only CARDs in these three categories were further discussed below.

E21 00F006A station experience There are seven recorded instances of indication problems related to this valve (CARD/DERs NP-85-168, 97-0090, 97-0146, 03-11442, 06-22342, 07-26743, and 14-21842). In five of those, the cause was determined to be issues related to the limit switch assembly. The remaining two instances (DERs 97-0090 and 97-0146),

which relate to the same indication problem, the cause was determined to be improper packing valve assembly preventing the disc from closing.

In addition to the indication problems, two documented instances of seat leakage were found (DERs 95-0214 and 96-1219). DER 95-0214 describes a seat leakage past E21 00F006A and E2150F005A, resulting in increase of Div. 1 Core Spray pumps discharge pressure. This issue was resolved by exercising and both PIVs, causing them to reseat properly. No work on the PIVs was necessary. DER 96-1219 describes seat leakage past E21 00F006A, discovered during LLRT testing. That leakage was also resolved by stroking the valve multiple times during the troubleshooting process, resulting in successfully reseating it.

Page 2 of 19

Total Page Count (194 Pages)

E21 00F006B station experience There are six instances of indication related problems related to this valve (CARD/DERs 00-16236, 01-19598, 03-11463, 03-17516, 07-26644, and 09-21991).

In all those instances, the cause was determined to be issues related to the limit switch assembly.

In addition to the indication problems, two documented instances of seat leakage were found (CARDs 07-25588, 09-22283, and 09-22834). CARD 07-25588 describes seat leakage past E21 00F006B, discovered during LLRT testing.

Troubleshooting involving valve stroking was not successful and replacement of the resilient seal of the seat was required to resolve the issue. CARDs 09-22283 and 09-22834, which both document the same seat leakage issue, describe LLRT test failure due to failure of the disc to fully close against the seat. Subsequent investigation determined that actuator shaft slippage prevented the valve from closing fully. The issue was resolved after the valve air operated actuator was reworked.

One Air Operated Actuator failure was also found for this valve. CARD 12-237 41 describes failure of the actuator to op,en the valve, because a failed solenoid. The actuator was subsequently rebuilt, and the issue resolved.

Finally, one instance of body to bonnet leakage was also found for this valve. CARD 10-30199 describes an external leakage developing on the E21 00F006B, due to failed pressure seal and segment ring. These components were subsequently replaced, and the leak was resolved.

2.2 Industry Service Experience Generic Notices All Ge eric Notices available from the NRCs reading room were reviewed. No Generic Notices relevant to Anchor Darling dual seat swing check valve model number 2226-3 were found.

All Generic Letters available from the NRCs reading room were reviewed. No Generic Notices relevant to Anchor Darling dual seat swing check valve model number 2226-3 were found.

Page 3 of 19

Total Page Count (194 Pages)

All information Notices available from the NRCs reading room were reviewed. No Generic Notices relevant to Anchor Darling dual seat swing check valve model number 2226-3 were found. However, a more generic search found IN 84-12, which discussed LLRT failures of dual seat Anchor Darling check valves at the LaSalle Unit 1, Pilgrim, and Brunswick Units 1 and 2 nuclear stations. These events were attributed to failure of the seat seals made from either ethylene-propylene or extruded-vulcanized rubber. Fermi 2 Core Spray system isolation valves E21 00F006NB also utilize ethylene propylene rubber seals and has experienced LLRT failures attributed to their failure in the past.

LER/OE Notices Search of the NRC and INPO's (IRIS) websites for LERs and/or OE Notices related to Anchor Darling dual seat swing check valve model number 2226-3 resulted in no matches.

NIC Database Review The NIC failure database was reviewed for applicable failure history. The review was performed by polling the industry check valve component specialists at other nuclear stations. No entries relevant to Anchor Darling dual seat swing check valve model number 2226-3 were found.

INPO IRIS Database Review INPOs IRIS database was searched for "anchor darling dual seat check 2226-3" and no results were found. Subsequently the search term was made more generic

("anchor darling dual seat check") and eight results were found. However, upon close review of each OE documentation, it was revealed that none of the eight records pertained exactly to an Anchor Darling swing check valve model number 2226-3. The closest match was an OE 321711 from Fermi 2, anchor darling dual seat check E11 00F050B valve (model 2229-3), which is the same style valve at a larger size. In that OE, the E11 00F050B valve had failed a PIV test, due to seat leakage, likely caused by a combination of disc binding and disc seat condition.

Vendor Input There was no vendor input or Part 21 Reports associated with 12" Anchor dual seat, swing check valves (model 2226-3).

Industry Template There was no Anchor Darling Swing Check Valve Industry Template available on the Nuclear Industry Check (NIC) Valve Group's website.

Page 4of 19

2.2.1 References Generic Notices LER/OE Notices IN 84-12 None None Total Page Count (194 Pages)

NIC Database Review INPO IRIS DB Review Vendor Input Event No. 321711 None Industry Template None 2.3 Valve History Information 1ST Testing results have been very good overall. Valve exercising for both E2100F006A and E21 00F006B has been performed satisfactorily.

Both E2100F006A and E2100F0068 have been disassembled and inspected multiple times. In all instances the results of these inspections were satisfactory with valve internals in good condition.

E2100F006A (E548)

WO#

Date Examination Results Comments Complete 32622286 4/18/2012 DI - Good condition E548040100 11/14/2010 DI - Job canceled E548010100 11/16/2001 DI - Good condition E548971107 10/6/1998 DI - Good condition E548930414 6/27/1994 DI - Good condition E21 00F0068 (E 109)

WO#

Date Examination Results Comments Complete DI - Good condition This WO AO'd WO 29705897 11/16/2010 E109090100.

E109970307 4/23/2003 DI - Good condition E109950216 10/7/1996 DI - Good condition E109911008 9/15/1992 DI - Good condition Page 5 of 19

Total Page Count (194 Pages) 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO) lZI Failure to Close (FTC) lZI Internal Leakage (IL) lZI External Leakage (EL) 181 Disk Separation (DS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM)

Broken/Detached Pars (BOP) 3.2 Failure Causes Normal Wear

~

Maintenance Error IZl Abnormal Wear

~

Manufacturing Error Design Corrosion Human Error Foreign Material lZI Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation

~

Other 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Effectiveness of Activity to Failure Modes Detect Failure Detect Degradation Detected 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 High High All 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 Page 6 of 19

Total Page Count (194 Pages) 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ)

PLAN 5.1 Condition Monitoring Program Plan Status:

Interim Plan

~ 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 and Inspection Frequency: 12 years (SR): One valve (E2100F006A or B) at a time Tasks: 43.000.010 and 35.000.232; PMs E548 (F006A), E109 (F006B)

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.

The maximum inspection frequency allowed by the 2012 OM Code was selected, because of the satisfactory D&I inspection and LLRT history.

All D&I inspections performed on these check valves (four for each valve) have been satisfactory. This activity covers CVO (check valve open exercise) and OVO (open obturator verfication).

2. Plan Activity: Remote Position Indication Verification Frequency: 2 years (1 R): Both Valves (E21 00F006A/B)

Tasks: 24.203.04 Notes:

1. Frequency required by the 2012 OM Code.

Page 7 of 19

Total Page Count (194 Pages)

2. Alternate methods may be used per the 1ST Evaluation 20-009

3. Plan Activity: Seat Leakage Test Frequency: Appendix J: Both Valves (E2100F006A/B)

Tasks: 43.401.312 Notes:

This task covers CVC (check valve closed exercise) and OVC (Closed obturator verification) 5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMJ 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 identilfier 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.

Page 8 of 19

CARD/DIR PIS No.

No.

E2100F006A 01-14848 E2100F006A 01-21945 E2100F006A 03-11442 E2100F006A 03-14555 E2100F006A 04-26217 E2100F006A 04-26877 E2100F006A 06-22125 E2100F006A 06-22342 E2100F006A 06-22910 E2100F006A 06-23375 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 - CARD HISTORY FOR E2100F006A/B Date Date Title Issued Closed Category ELIMINATE REPEATED 05/03/2001 10/06/2003 Miscellaneous DISASSEMBLY OF THESE VALVES FOR INSPECTION UNDER PM EVENTS E548 AND E109.

PACKING LEAK 11/22/2001 04/12/2004 Packing Leak E2100F006A LIMIT SWITCH 04/21/2003 05/22/2003 Indication Problem PACKING LEAK ON 04/30/2003 08/08/2003 Packing Leak VALVE E2100F006A Packing leaks observed 11/29/2004 02/22/2005 Packing Leak on valves WR enhancements for 12/28/2004 05/31/2005 Miscellaneous special test.

Broken electrical flex 04/10/2006* 04/18/2006 Miscellaneous conduit.

limit switch broken to 04/14/2006 04/18/2006 Indication limit switch for E2100-Problem F006A.

Packing leak on E2100-04/28/2006 04/29/2006 Packing Leak F006A Check Valve lift test 05/16/2006 11/21/2006 Miscellaneous procedures need revised Page 9 of 19 Total Page Count (194 Pages)

Comments Disc open light did not go off during testing. Limit swithch was adjusted under WO 0002031623 and problem was resolved.

Limit switch flexible conduit broken and some wires exposed. Condition fixed by WO G973060100.

E2100F006A 06-23770 E2100F006A 07-26743 E2100F006A 07-26856 E2100F006A 07-26940 E2100F006A 08-22919 E2100F006A 09-22033 E2100F006A 09-23222 E2100F006A 09-23224 E2100F006A 10-31115 E2100F006A 11-26359 E2100F006A 12-23284 E2100F006A 12-23640 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 - CARD HISTORY FOR E21 00F006A/B Revise PM events, 06/01/2006 12/08/2006 Miscellaneous procedure & WR's for Stroking E21 00F006A/B valves.

Dual indication following 10/28/2007 11/06/2007 Indication fill and vent Problem I

Broken Conduit On 10/31/2007 11/13/2007 Miscellaneous E2100F006A Leakage identified 11/02/2007 11/27/2007 Packing Leak during RPV hydro Need CECO change for 05/01/2008 06/02/2008 Miscellaneous CS Injection Check Valves Valve would not open 03/31/2009 08/28/2009 Miscellaneous manually during surveillance Leakage identified 04/25/2009 05/12/2009 Packing Leak during RPV hydro Leakage noted during 04/25/2009 05/05/2009 Packing Leak the RPV Hydro Leakage identified 11/24/2010 12/01/2010 Packing Leak during RPV Pressure Test (E21 0OF006a)

Maintenance procedure 06/29/2011 07/12/2011 Miscellaneous revision needed.

Packing torque values 04/15/2012 06/14/2012 Miscellaneous questionable 1 dpm leak 04/22/2012 08/15/2012 Packing Leak Page 10 of 19 Total Page Count (194 Pages)

Valve was indicating dual in the Control Room, but verified closed in the field.

Repairs of the limit switch underWO26031959 resolved the issue.

E2100F006A 12-23833 E2100F006A 14-21208 E2100F006A 14-21842 E2100F006A 14-22426 E2100F006A 14-22674 E2100F006A 15-29171 E2100F006A 97-11291 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 - CARD HISTORY FOR E2100F006A/B Leakage identified 04/26/2012 05/15/2012 Packing Leak during RPV Pressure Test E21 00-F006A Request for Nuclear 02/16/2014 04/02/2014 Miscellaneous Training Evaluation of 43.401.. 711 Division 1 Core Spray Injection Check Valve Exercise Test for Revision 7 Failed PMT-03/01/2014 03/25/2014 Indication E21 00F006A Position Problem Indication Failed PMT PIS# for E21 00F006A 03/15/2014 03/20/2014 Miscellaneous

& B have typo's in SOP 23.203 Attachments 4A/4B, they are listed as E2150F006A / B which does not exist Leakage identified 03/22/2014 05/05/2014 Packing Leak during RPV Pressure Test E2100F006A Leakage identified 11/20/2015 12/18/2015 Packing Leak during RPV Pressure Test E2100F006A GENERATE 10/17/1997 11/12/1997 Miscellaneous CONTINGENCY WORK PACKAGES FOR POTENTIAL LLRT FAILURES FOR RFO6 Page 11 of 19 Total Page Count (194 Pages)

Valve was indicating dual in the Control Room, but verified closed in the field.

Repairs of the limit switch resolved the issue.

E2100F006A 98-15716 E2100F006A 98-17547 E2100F006A 98-18077 E2100F006A 98-19005 E2100F006A 98-23132 E2100F006A 88-0913 E2100F006A 95-0214 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 -CARD HISTORY FOR E2100F006A/B PM EVENTS E548 AND 07/09/1998 02/26/1999 Miscellaneous E109 HAVE US DISASSEMBLING THESE VALVES FOR INSPECTION. THE CODE REQUIREMENT MAY BE ACHIEVED BY STROKING ONLY -

E2100F006NB WATER SPILL DURING 09/21 /1. 998 09/22/1998 Miscellaneous SYSTEM DRAIN SENT TO RECORDS PROCESSING 10/20/98 POOR PACKAGE 09/28/1998 10/26/1998 Miscellaneous PLANNING AND SCHEDULING SENT TO RECORDS PROCESSING 11/19/98 PROCEDURE 10/12/1998 12/17/1998 Miscellaneous 43.000.010 HAS ERRORS(TYPOS)

NEEDING CORRECTION CONTAINMENT 11/18/1998 12/13/1999 Miscellaneous ISOLATION CHECK VALVES VALVE LIVE LOADING 04/24/1988 06/15/1988 Miscellaneous AS BUILT NOTICES DIVISION I CORE 03/22/1995 06/30/1995 Seat Leakage SPRAY LOOP 'A' DISCHARGE PRESSURE HIGH Page 12 of 19 Total Page Count (194 Pages)

Increase in Div 1 CS system pump discharge pressure was noted due to leak past E2100F006A and E2150F005A seat leakage.

Both valves were

E2100F006A 96-1219 E2100F006A 97-0090 E2100F006A 97-0146 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 - CARD HISTORY FOR E21 00F006A/B FAILURE OF LLRT 09/29/1996 02/13/1997 Seat Leakage CONTAINMENT ISOLATION VALVES E21-F006A VALVE 01/24/1997 07/14/1997 Indication ACTUATOR/DISC Problem OPEN LIGHTS IMPROPER 02/03/1997 06/07/1997 Indication REASSEMBLY OF Problem E2100F006A Page 13 of 19 Total Page Count (194 Pages) subsequently stroked and leakage stopped as the discs reseated properly.

Valve failed as-found LLRT due to disc not being fully closed. Actuator was exercised several times during troubleshooting and the disc was reseated properly. As-left LLRT was satisfactory.

Valve indicated dual in the Control Room.

Investigation performed under WO 0002970711 (DER 97-0146) determined that limit switched are operating correctly, but the disc could not be fully closed due to incorrect packing configuration.

Packing was adjusted to allow disc to close.

Valve indicated dual in the Control Room.

Investigation performed under WO 0002970711 (DER 97-0146) determined that limit switched are operating correctly, but the disc could not be fully closed due to incorrect packing configuration.

E2100F006A NP-85-168 E2100F0068 00-16236 E2100F0068 01-12263 E2100F006B 01-14848 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 - CARD HISTORY FOR E21 00F00GA/B E21-F006A POSITION 04/17/1985 10/18/1985 Indication INDICATION FAILURE Problem DISC ACTUATOR 05/03/2000 05/25/2000 Indication CLOSED LIMIT Problem SWITCH DID NOT GO OUT WHEN STROKEN OPEN RECOMMEND 06/12/2001 10/24/2001 Packing Leak REPACKING DRYWELL VALVES DURING RF08 FOR PREVIOUSLY IDENTIFIED RECURRING LEAKERS. REVIEW OTHER VALVES IN THE DRYWELL FOR POTENTIALLY SIMILAR ELIMINATE REPEATED 05/03/2001 10/06/2003 Miscellaneous DISASSEMBLY OF THESE VALVES FOR INSPECTION UNDER PM EVENTS E548 AND E109.

Page 14 of 19 Total Page Count (194 Pages)

Packing was adjusted to allow disc to close.

Valve was indicating dual in the Control Room. During subsequent troubleshooting, the limit switch assembly found loose.

Actuator closed light did not go off during position indication testing. Limit switch was adjusted under WO 0002001693 and the problem was fixed.

E2100F0068 01-19598 E2100F0068 03-11463 E2100F0068 03-14557 E2100F0068 03-14988 E2100F006B 03-17516 E2100F0068 06-22912 E2100F0068 06-23375 E2100F0068 06-23770 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 - CARD HISTORY FOR E2100F006A/B POSITION INDICATION 11/16/2001 12/12/2001 Indication FOR E2100F0068 DISC Problem OPEN & ACT OPEN DID NOT WORK WHEN TESTING 04/22/2003 04/29/2003 Indication E2100F0068 DID NOT Problem GET PROPER INDICATION PACKING LEAK ON 04/30/2003 08/08/2003 Packing Leak VALVE E21 00F0068 PLUGGED EXHAUST 04/10/2003 04/30/2003 Miscellaneous PORT INDICATION FOR 05/04/2003 08/18/2003 Indication VALVES NOT Probl-em FUNCTIONING PROPERLY Packing leak on E2100-04/28/2006 04/29/2006 Packing Leak F0068 Check Valve lift test 05/16/2006 11/21/2006 Miscellaneous procedures need revised Revise PM events, 06/01/2006 12/08/2006 Miscellaneous procedure & WR's for Stroking E21 00F006A/B valves.

Page 15 of 19 Total Page Count (194 Pages)

Actuator open light did not come on. WO 0002013910 was implemented and indication issue was fixed.

Valve indicated dual in the Control Room. Limit switch was adjusted under WO E109970307 and indication issue was fixed.

Actuator open light did not extinguish and closed light did not come on upon valve closure. The valve appeared to function properly in the field. Limit switch was adjusted under WO 0002031988 and indication issue was fixed.

E2100F0068 07-.25588 E21 00F0068 07-26644 E2100F0068 07-26940 E2100F0068 08-22919 E2100F0068 09-21991 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 -CARD HISTORY FOR E2100F006A/B Div 2 Core Spray 10/02/2007 10/30/2007 Seat Leakage Injection check valve failed LLRT PMT Failure for 10/25/2007 11/06/2007 Indication 25764056. Limit switch Problem for E21 0OF0068 Leakage identified 11/02/2007 11/27/2007 Packing Leak during RPV hydro Need CECO change for 05/01/2008 06/02/2008 Miscellaneous CS Injection Check Valves E21 00-F0068, Div 2 CS 03/30/2009 05/01/2009 Indication Testable Check Viv, Problem indicates open with no CS flow.

Page 16 of 19 Total Page Count (194 Pages)

Gross failure (failure to reach tests pressure) of LLRT tets. Attempts to troubleshoot by cycling the valve were unsuccessful.

Valve was subsequently re-worked under WO 25764056. No apparent cause for seat leakage could be determined, however, the problem was resolved by replacing the resilient seat.

Disc open light did not come on during testing.

Valve was open in the field.

Limit switches were adjusted under WO 26009339 and the issue was resolved.

Valve indicated dual in the Control Room. Limit switch was adjusted under WO 29654434 and indication issue was fixed.

E2100F006B 09-22283 E2100F006B 09-22834 E2100F006B 09-22877 E2100F006B 10-29730 E2100F006B 10-30199 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 - CARD HISTORY FOR E21 00F006A/B E21 00-F0068 failed its 04/04/2009 05/04/2009 Seat Leakage LLRT; gross failure.

Excessive actuator shaft 04/16/2009 05/12/2009 Seat Leakage slippage - dead band Training impact due to 04/17/2009 06/16/2009 Miscellaneous procedure revision 24.203.03 Broke Flex on Limit 10/29/2010 11/09/2010 Miscellaneous Switch Connection Division 2 Core Spray 11/06/2010 12/07/2010 Body to Bonnet Testable Check Valve Leak Leakinq from bonnet Page 17 of 19 Total Page Count (194 Pages)

Gross failure (failure to reach tests pressure) of LLRT tets. Follow up troubleshooting indicated that the cause for failure was the disc not closing completely. Valve was forced closed and passed LLRT. Additional investigation performed underWO29654434 determined that the disc closure issue is related to actuator shaft slippage (CARD 09-22834).

Excessive actiator shaft slippage was discovered, which resulted in valve disc remaining open after actuator bleed-off. This condition was determined to be responsible for failed LLRT test (CARD 09-22283). Valve was reworked per WO 29705897 and the issue was resolved.

Body to bonnet leakage discovered. New pressure seal and segment ring

E2100F006B 10-30529 E2100F006B 12-23741 E2100F006B 12-23750 E2100F006B 12-23832 E2100F006B 14-21855 E2100F006B 15-29172 E2100F006B 17-21795 E2100F006B 17-23428 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 - CARD HISTORY FOR E21 00F00GA/8 E2100F006Blea~ng 11/12/2010 12/16/2010 Packing Leak water while pressurized to perform 43.401.513.

While performing 04/25/2012 05/22/2012 AO Actuator 24.203.04 section 5.4, Failure E21 00F006B failed to move.

Procedure Change for 04/25/2012 04/28/2012 Miscellaneous Testing E21 00-F006A and B Leakage identified 04/26/2012 05/15/2012 Packing Leak during RPV Pressure Test E21 O0-F006B Procedure 43.401.712 03/01/2014 07/30/2014 Miscellaneous clarification on torque wrench size Leakage identified 11/20/2015 12/18/2015 Packing Leak during RPV Pressure Test E.21 00F006B DIV II CSS INJ VAL 03/04/2017 04/05/2017 Miscellaneous LEAK PRESS HIGH (2D16) DURING 24.203.03 Leakage identified 04/12/2017 05/08/2017 packing Leak during RPV Pressure Test E2100F006B Page 18 of 19 Total Page Count (194 Pages) installed under WO 29705897 and the leak was resolved.

Valve failed to open during testing. The air actuator solenoid appeared to have failed, causing no response from the actuator. Actuator was rebuilt under WO 34381192 and the issue was resolved.

E2100F006B 98-15716 E2100F006B 98-19005 E2100F006B 99-13695 E2100F006B 88-0913 CMJ-17 Core Spray Containment Isolation Check Valves ATTACHMENT 1 - CARD HISTORY FOR E2100F006A/B PM EVENTS E548 AND 07/09/1998 02/26/1999 Miscellaneous E109 HAVE US DISASSEMBLING THESE VALVES FOR INSPECTION. THE CODE REQUIREMENT MAY BE ACHIEVED BY STROKING ONLY -

E2100F006A/B PROCEDURE 10/12/1998 12/17/1998 Miscellaneous 43.000.010 HAS ERRORS(TYPOS)

NEEDING CORRECTION CREATE WORK 05/03/1999 02/09/2005 Miscellaneous REQUESTS FOR ASME CHECK VALVE(S)

INSPECTIONS DURING RFO7 VALVE LIVE LOADING 04/24/1988 06/15/1988 Miscellaneous AS BUil T NOTICES Page 19 of 19 Total Page Count (194 Pages)

1.0 GROUP INFORMATION 1.1 Valve List Fermi Nuclear Station CMJ-18:

Total Page Count (194 Pages)

R3000F031A-D EDG Starting Air Receiver Check Valves

& R3000F032A-D 1.2 Manufacturing Data Manufacturer:

Valve Type:

Model:

Siz,e:

Valve Body Material:

Disc Material:

Design Feature:

BNL Industries Spring / poppet CBV-A5-06-0031 3/4" ASME-SA-479 Ty. 316 ASME-SA-479 Ty. 316 In-line Nozzle type (See Deco file P1-16218 and P1-16225)

1.3 1.4 Total Page Count (194 Pages)

Service Conditions Service Duty:

Air System Flow:

N/A System Pressure:

260 PSIG Normal System Temperature:

60°F Normal Grouping Bases These valves are grouped together based on having the same manufacturer, model, and service application. The following were considered in group determination:

~ Same Mfg Service Conditions Identical Application Identical Test Methodology Infrequent Operation tK Like Orientation IZI Like Design Maximum Flow Unachievable Similar Upstream Downstream Flow Turbulence other 1.5 Safety Function Discussion Open Position - Safety Open to charge starting air receiver.

Closed Position - Safety Close to preserve starting air receiver pre-charge

Total Page Count (194 Pages) 2.0 PERFORMANCE ANALYSIS 2.1 Fermi Service Experience Plant service experience for the valve in this group has been good overall based on a Fermi Condition Report Search. A twenty-year CARD search was performed. Four CA Os (02-01002, 04-20332, 07-27258, and 15-23206) identified leaking check valves. It should be noted that most inspections resulted in conservative decisions to replace o-rings, seat rings, and in some cases a new disk. Finally, the 1ST testing (open exercise, closed exercise, and AT-3 leakage tests) was reviewed back to late 2015 / early 2016 and no test failures were found.

2.2 Industry Service Experience Generic Notices The NRC Document Reading Room was searched for Generic Notices or Information Bulletins pertaining to the BNL Industries CBV-A5-06-0031 check valves. No related*

Generic Notices were found for this valve design.

LER/OE Notices INPO's IRIS Network was reviewed for LER/OE reports on failures of the BNL Industries CBV-A5-06-0031 check valve. The following OE was found:

OE 453938 A similar BNL Industries check valve (CBV-AS-04-0005) used in an air system accumulator was found leaking by the seat. The valve poppet (disk) and spring was found defective.

Applicability: Applicable.

This type of a failure is consistent with failures at Fermi. The failures at Fermi were caused by a defective disk or seat ring due to normal wear.

OE159216 A similar BNL Industries check valve (N9212003-1-15393) used in an air system was found leaking by the seat. The valive poppet spring was found defective.

Applicability: Applicable.

This type of a failure is consistent with failures at Fermi. The failures at Fermi were caused by a defective disk or seat ring due to normal wear.

Total Page Count (194 Pages)

Vendor Input No Part 21 Reports related to the BNL Industries check valve CBV-AS-06-0031 or similar was found.

Industry Template The EPRI Preventative Maintenance Basis Database (PMBD 4.6) does provide a template for an in-line spring type check valve (critical low/ mild service conditions -

CHIM). It provides the typical failure locations as the following:

1. Disc failure - Detected by evidence of seat leakage

2. Seat failure (body or disc) - Detected by evidence of seat leakage

3. Seat ring to Body Interference Fit or Thread - Detected by evidence of seat leakage.

4. Spring - Detected by evidence of seat leakage Various methods including In-Service Testing, Internal Inspection, Non-Intrusive Diagnostics, Operator Rounds, Radiography, and Walk-downs have the capability to detect some or all of these failure mechanisms. For a critical (low duty cycle)/ mild service condition valve, the template provides a frequency for internal inspection (CHM) is 14 years. The lnservice inspections, which focusses on seat leakage testing is "AR" or as required.

2.3 Valve History Information Historically, R3000F031A-D ad F032A-D, a quarterly exercise/ seat leakage test per 24.307.34-.37, and a six-year inter al inspection per events G734 - G737.

A CARD search was performed over the last twenty years. Four CARDs identified failures as follows:

Total Page Count (194 Pages)

CARD / Work Order Valve Comment 02-01002 / 0002021134 R3000F032A Poppet (disk) was found hanging up due to grooves and scratches in housing. Polished poppet/ cylinder and replaced all seals. All other similar valves were inspected as well.

04-20332/

R3000F031A/F032A Issue related to leakage through G7340601 00/000Z02373 drain valve rather than check valves 07-27258/26228176 R3000F032B Poppet (disk) was found hanging up which caused leak by the seat. The seat ring was found defective.

Replaced seat ring and o-rings.

15-23206/43020232 R3000F031 D /

Seats found leaking. Replaced F032D poppets, springs, and seats.

A maxi mo work order history search was performed on PM events G734 - G737. The typical search found three work orders dating back to 2009/2010. The valves were found in satisfactory condition with the exception of R3000F031 Das discussed above per WO 43020232.

The lddeal Database was searched on 24.307.34 through 24.307.37 for quarterly 1ST testing results (CVO, CVC, AT-3 Leakage) back to late 2015. All tests were found acceptable.

Total Page Count (194 Pages) 3.0 FAILURE MODES AND CAUSES ANALYSIS 3.1 Failure Modes Failure to Open (FTO)

~

Failure to Close (FTC)

~

Internal Leakage (IL)

~

External Leakage (EL)

Dis Separation (OS)

Hinge Pin Wear (HPW)

Not Applicable Restricted Motion (RM)

~

Broken/Detached Pars (BOP) 3.2 Failure Causes Normal Wear

~

Maintenance Error Abnormal Wear

~

Manufacturing Error Design Corrosion

~

Human Error Foreign Material Procedure Stress Corrosion Cracking Erosion/Corrosion Improper Installation Other

Total Page Count (194 Pages) 4.0 TEST AND INSPECTION EFFECTIVENESS ASSESSMENT Test/Inspection Activity Full Open Stroke w/Flow Partial Open Stroke w/Flow Back Flow/Reverse Flow Manual Exercise Leak Test Disassembly & Inspection Temperature Monitoring Radiography Ultrasonic Testing Magnetics Acoustics Routine Operator Rounds Eddy Current Testing Test Effectiveness Rating:

Effectiveness of Activity to Failure Modes Detect Failure Detect Degradation Detected NA NA NA NA Failure to open NA NA NA NA NA NA Seat Leakage High High NA NA NA NA NA NA NA NA NA NA NA NA NA NA High -

probability of detection > 75%

Medium -

< 75% probability of detection but > 25%

Low -

probability of detection < 25%

N/A -

test method not available

Total Page Count (194 Pages) 5.0 RECOMMENDED ACTIVITIES FOR CONDITION MONITORING PROGRAM (CMJ) PLAN 5.1 None, there is adequate history to implement plan immediately.

5.2 Condition Monitoring Program Plan Status:

Interim Plan IZl 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: Forward Flow Exercise Demonstrates the valve has freedom of movement from full closed to full open.

Frequency:

Every Two-Years Tasks:

24.307.34 through 24.307.37.

Notes:

None

2. Plan Activity: Reverse Flow Exercise and Seat Leakage Demonstrates the valve has freedom of movement from full open to full closed by performing a drop test {leakage).

Frequency:

Every Two-Years Tasks:

24.307.34 through 24.307.37 Notes:

Total Page Count (194 Pages)

3. Plan Activity: Disassembly & Inspection Demonstrates that the valves have freedom of movement from full closed to full open and back to full closed position, with no evidence of internal binding.

Frequency: Six year frequency for each valve.

Tasks:

PM Events G734 through G737.

Notes:

5.2.2 Basis for Testing and Inspection Strategy (Analysis)

For optimization of condition monitoring activities, the CMJ 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 disassembly was historically used to confirm reliability and good working history as a basis for the plan activities (Events G734 through G737).

These disassembly & inspection events and a two-year frequency exercise (open and closed) are adequate to monitor the valve condition as proven in all operating history cases. The two-year frequency is adequate based on the infrequent valve performance problems discovered over the last 20 years. Also, it should be noted that the closed exercise test is in itself a leakage test which provides valuable information the seat condition.

It is Fermi's position that the proposed Condition Monitoring testing and inspection activities will be effective for ensuring operation.