ML23283A032

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Inservice Testing Program for Pumps and Valves - Part 10: IST Program Technical Positions Revision 2
ML23283A032
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 10/09/2023
From:
DTE Electric Company
To:
Office of Nuclear Reactor Regulation
Shared Package
ML23283A021 List:
References
NRC-23-0063
Download: ML23283A032 (1)


Text

Total Page Count=55 FERMI 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES FERMI 2 FOURTH 10 YEAR INTERVAL - START DATE 02/1712020 PART 10: IST PROGRAM TECHNICAL POSITIONS REVISION 2 Revision Summa1y:

1. Complete rewrite for start of 4th Interval OUAL Prepared:  ::J-cf"F.r Date: PE-03 ~

PE-03 ~

NIA Supervisor, Performance Engineering A p p r o v e d : & ~ /Sean Howell Date: 10/05/2021 NIA Manager, Performance Engineering INFORMATION AND PROCEDURES DSN: IST Program Tech Positions Rev: 2 Date: 1/14/22 DTC: TMPLAN File: 1715.04 Recipient: _ _ _ __

Date Approved: _ _ _ _ _ __ Release authorized by: _ _ _ _ _ _ _ __

IST PROGRAM PLAN PART 10 IST PROGRAM TECHNICAL POSITIONS INDEX Technical Position Description No.

TP-01 rator Verification El 100F078 TP-02 onditioning TP-03 ssive Valves without Test Requirements TP-04 Fail Safe Testing of Valves TP-05 Classification of Skid Mounted Components TP-06 Note Used TP-u; II Outside Design Basis TP-08 Not Used TP-09 Pump Testing Reference Values TP-10 Not Used TP-11 Not Used TP-12 Not Used TP-13 I Pum2 Testing Accuracy I

TP-14 Not Used TP-15 Obturator Verification B2100F248A/B & F249NB TP-16 Obturator Verification P5000, T2300, T4800 TP-17 j Obturator Verification T4600 I

TP-18 Obturator Verification E4100 and E5100 TP-19 Mandat01y Appendix V

Technical Position TP-01 Page 1 of 1 E11 00F078 Open Obturator Verification Purpose Open obturator verification for reactor vessel emergency injection check valve.

Applicability E1100F078

Background

10CFR 50.55(a) OM Condition on ISTC-3700 requires a supplemental obturator verification every two-years. This OM condition does not specify exact details on how to perform obturator verification. This OM condition does not specify the types of valves that applicable to obturator verification.

E1100F078 is designed to be used in an emergency to inject service water into the reactor pressure vessel.

The remote position indication test is performed quarterly per 24.204.06 using its testing actuator in parallel with the open and closed (BOO, CVC) check valve exercise. This is installing a hose between the downstream RHR system and the upstream RHR Service water to equalize the pressure on both sides of the disc. There is no reasonable method to measure a flow rate through the check valve due to concerns of cross contamination between RHR and RHR Service Water.

Furthermore, since this valve is in the RHR Heat Exchanger room, which has higher than normal dose rates, the trade off with ALARA to the connect additional test equipment to confirm an open di$c would not be beneficial.

Definitions The obturator (valve disc) is confirmed to be in the expected position by using plant parameters such as measured flow, decreasing tank levels, increased pressure, reduced pressure etc.

Position Confirm obturator verification every two years in the closed direction per 24.204.05 by observing changes in plant parameters. In addition, a disassembly and inspection will be performed on this valve per Event E130. These testing and inspection events will ensure that two know failure modes (failure of disc nut or failure of hinge arm) for stem to disc separation will not occur. The most recent inspection in 2015 confirmed these parts to be in good condition which is expected since they not exposed to service water.

Technical Position TP-02 Page 1 of 6 Preconditioning Purpose The purpose of this Technical Position is to establish the Fermi 1ST Program position on preconditioning.

Applicability This Technical Position is applicable to 1ST Program pumps and valves.

Background

There are no ASME Code requirements regarding preconditioning or the necessity to perform as-found testing, with the exception of setpoint testing of relief valves and some guidance in 10CFR50 Appendix J regarding leak rate testing of valves on extended frequencies.

Nevertheless, there has been significant concern raised by the NRC, and documented in numerous publications, over this issue. It is the intent of this Technical Position to provide a unified, consistent approach to the issue of preconditioning as it applies to the Fermi 1ST Program.

The purpose of 1ST is to confirm the operational readiness of pumps and valves within the scope of the 1ST Program to perform their intended safety functions whenever called upon. This is generally accomplished by testing using quantifiable parameters which provide an indication of degradation in the performance of the component. Preconditioning can diminish or eradicate the ability to obtain any meaningful measurement of component degradation; thus defeating the purpose of the testing.

Preconditioning is defined as the alteration, variation; manipulation, or adjustment of the physical condition of a system, structure, or component before Technical Specification surveillance or ASME Code testing. Since 1ST is a component-level program, this Technical Position will address preconditioning on a component-level basis. Preconditioning may be acceptable or unacceptable.

  • Acceptable preconditioning is defined as preconditioning which is necessary for the protection of personnel or equipment, which has been evaluated as having insufficient impact to invalidate the results of the surveillance test, or which provides performance data or information which is equivalent or superior to that which would be provided by the surveillance test.
  • Unacceptable preconditioning is preconditioning that could potentially mask degradation of a component and allow it to be returned to or remain in service in a degraded condition.

In most cases, the best means to eliminate preconditioning concerns is to perform testing in the as-found condition, prior to scheduled maintenance activities. When this is not practical, an evaluation must be performed to determine if the preconditioning is acceptable, unless the specific activity is already listed as acceptable in MOP03 Enclosure For this Technical Position.

Appendix I to this Technical Position may be used to document a preconditioning evaluation.

The acceptability or unacceptability of preconditioning should be evaluated on a case-by-case basis due to the extensive variability in component design, operation , and performance requirements. Preconditioning of pumps may include filling and venting of pump casings, venting of discharge piping, speed adjustments, lubrication, adjustment of seals or packing, etc.

Preconditioning of valves may include stem lubrication, cycling of the valve prior to the "test" stroke, charging of accumulators, attachment of electrical leads or jumpers, etc. Factors to be considered in the evaluation of preconditioning acceptability include component size and type,

Technical Position TP-02 Page 2 of 6 actuator or driver type, design requirements, required safety functions, safety significance, the nature, benefit, and consequences of the preconditioning activity, the frequencies of the test and preconditioning activities, applicable service and environmental conditions, previous performance data and trends, etc. A general rule is that if an 1ST exam interval is at least four times shorter than the applicable periodic maintenance interval then that maintenance would not be considered as unacceptable preconditioning. Example: A motor-operated valve (MOY) is stroke timed quarterly and has a PM event performed every 24 months. The PM includes activities such as stern and gearing lubrication. That MOY has been stroke time tested seven times in a true as found condition prior to the PM. The PM is performed and the PMT stroke timing is counted as the eighth quarterly test. It is unreasonable to assume that significant degradation could have only occurred between the 7th test stroke and the PM.

Lubrication of a valve stern provides a good example of the variability of whether or not a preconditioning activity is acceptable. For example, lubrication of the valve stem of an MOV would have no beneficial impact on its stroke time measurements (see Conduct Manual MOP03 Enclosure G). Lubrication of a valve stem for an air-operated valve (AOY) prior to exercise testing is likely to be unacceptable, unless it can be documented that the preconditioning (i.e.,

maintenance or diagnostic testing) can provide equal or better information regarding the as-found condition of the valve. Manipulation of a check valve or a vacuum breaker that uses a mechanical exerciser to measure breakaway force prior to surveillance testing would typically be unacceptable preconditioning. Additional information regarding preconditioning may be found in Fermi Conduct Manual MOP03 Enclosure F.

Definitions

  • Precondition ing The alteration, variation, manipulation, or adjustment of the physical condition of an SSC before ASME Code surveillance testing. The scope of this requirement is limited to components tested in accordance with the ASME OM Code and 10CFR50 Appendix J for inservice testing (1ST).
  • Acceptable Preconditioning The alteration, variation, manipulation, or adjustment of the physical condition of an SSC before ASME Code surveillance testing:

o For the purpose of protecting personnel or equipment or to meet the manufacturer's recommendations.

o Which has been evaluated to have no adverse impact on the ability to detect degradation.

o Which is a scheduled activity being performed at an interval at least four times longer than the 1ST test interval.

  • Unacceptable Preconditioning Performance of a maintenance activity or an equipment manipulation activity which is consistently performed prior to each surveillance test and where the activity could mask an unacceptable condition that may have been detected during the surveillance test.

Position Preconditioning shall be avoided unless a specific policy applies or an evaluation has been performed to determine that the preconditioning is acceptable. Appendix I to this Technical Position may be used as an aid within an 1ST Evaluation to document the preconditioning determination. In cases where the same information applies to more than one component, a single acceptability evaluation may be performed and documented.

Technical Position TP-02 Page 3 of 6 The evaluations should be prepared, reviewed and approved by persons with the appropriate level of knowledge and responsibility. The evaluation should be approved by an Engineering Manager or designee.

If it is determined that an instance of preconditioning has occurred without prior evaluation, the evaluation should be performed as soon as practical following discovery. If the evaluation concludes that the preconditioning is unacceptable, a CARD shall be written to evaluate the condition and identify corrective actions.

One example of acceptable preconditioning is the procedural allowance for a second stroke of an AOV or certain hydraulically-operated valves (HOV) when the initial stroke time is outside 1ST limits but within Owner Specified Limits (OSL). This is a process specifically described in ASME OM Code Section ISTC. The purpose is to identify if actual degradation may have occurred or if some other factor caused the abnormal reading, such as how the stopwatch was operated. Since the operability criteria (OSL) is not involved, this second stroke allowance does not constitute unacceptable preconditioning.

10CFR50 Appendix J leak-rate tested valves follow the requirements as identified in this Technical Position. Appendix J valves will be as-found tested before any scheduled maintenance activities which could affect the valve's seat condition or closing force. If possible, the valve will be leak-rate tested prior to any stroking of the valve. If the required test conditions cannot be achieved (for example, to accommodate system draining) without stroking of the applicable valve, it is acceptable to cycle the affected valve as needed to achieve required test conditions.

Examples Acceptable Preconditioning:

1. Stroking of MOV as part of a system starting sequence prior to the timed stroke of that MOV.
2. Lubrication of an MOV stem prior to a stroke timing exam. This applies to both AC and DC MOVs.
3. Operation of a pre-lube system prior to a start of a large pump or EOG.
4. Pump venting directly prior to testing, provided that the venting operation has proper controls with a technical evaluation to establish that the amount of gas vented would not adversely affect pump operation.
5. Running a pump (e.g. for PMT) prior to a surveillance test that only measures the differential pressure and flow is acceptable because the starting, stopping, or running of a pump prior to the test is not expected to improve the pump's performance during the test.
6. Stroking of an Appendix J valve prior to its leak rate testing if necessary to establish required test conditions.

Unacceptable Preconditioning:

1. Lubrication of an AOV stem on a regular basis prior to surveillance testing of that AOV.
2. Lubrication of an AOV or MOV stem just prior to performance of an LLRT.
3. Routine calibration/adjustment of indicators prior to surveillance testing where the indication without adjustment might provide measurements outside surveillance acceptance criteria.
4. Maintenance on a leak-rate tested (LLRT) valve which improves the condition of the valve seats prior to the LLRT test.

Technical Position TP-02 Page 4 of 6

5. Maintenance and adjustments which increase the seating force of an LLRT valve prior to performance of an LLRT.

Summary CARD 98-10548 documents Fermi compliance to NRG Information Notice. 97-18 and evaluated site policies / processes for preconditioning. The policies contained in this 1ST Program Technical Position are in accordance with site policies as described in CARD 98-10548 and MOP03 Enclosure F. The intent of 1ST is to identify component degradation as early as possible and to ensure restoration of component capability prior to inability to perform its safety function.

Testing in the as-found condition is the preferable way to perform 1ST; however there are situations where this is not feasible. Adherence to this Technical Position will ensure the intent of 1ST is met even in those situations.

Technical Position TP-02 Page 5 of 6 Appendix I EVALUATION OF PRECONDIT IONING ACCEPTABI LITY I. NRC Inspection Manual Part 9900 Review Answer the following questions to determine the acceptability of the preconditioning activity.

NOT YES NO DETERMINED

1. Does the alteration, variation, manipulation, or adjustment ensure that the component will meet the surveillance test acceptance criteria?
2. Would the component have failed the surveillance without the alteration, variation , manipulation , or adjustment?
3. Does the practice bypass or mask the as-found condition?
4. Is the alteration, variation ,
  • manipulation, or adjustment routinely performed just before the testing?
5. Is the alteration, variation, manipulation, . or adjustment
  • performed only for scheduling convenience?

If all answers to Questions 1 through 5 are "No", the activity is acceptable. Otherwise, continue with Section II.

Technical Position TP-02 Page 6 of 6 Appendix I (cont)

II. Additional Evaluation The following questions may be used to determine if preconditioning activities that do not meet the screening criteria of Section I are acceptable.

NOT YES NO DETERMINED

6. Is the alteration, variation, manipulation, or adjustment required to prevent personnel injury or equipment damage? If yes, provide explanation.
7. Does the alteration, variation, manipulation , or adjustment provide performance data or information that is equivalent or superior to that provided by the surveillance test? If yes, provide explanation.
8. Is the alteration, variation, manipulation, or adjustment being performed to repair, replace, inspect, or test a component that is inoperable or is otherwise unable to meet the surveillance test

. acceptance criteria? If yes , provide explanation . .

9. Is there other justification to support classification of the alteration, variation, manipulation , or adjustment as acceptable preconditioning? If yes, provide explanation and references.

Provide sufficient details in the 1ST Evaluation to validate the answers to these questions.

Technical Position TP-03 Page 1 of 1 Passive Valves without Test Requirements Purpose The purpose of this Technical Position is to establish the Fermi 1ST Program position for valves which perform a passive safety function. However, no testing is required in accordance with ISTC.

Applicability This Technical Position is applicable to valves that perform a passive function in accordance with ISTA-2000 and do not have inservice testing requirements per Table ISTC-3500-1. This position is typical of Category B, passive valves that do not have position indication.

'An example is a manual valve which must remain in its normal position during an accident, to perform its intended function.'

Typically, manual valves that perform a safety function are locked in their safety position and administratively controlled by Fermi plant procedures. These valves would be considered passive. If they do not have remote position indicating systems and categorized as B, they would not be subjected to any test requirements in accordance with Table ISTC-3500-1.

Justification Valves that meet this position will not be listed in the 1ST Valve Scope Tables, however, the basis for categorization and consideration of active/passive functions shall be documented in the 1ST Program Basis Document.

Position The Fermi lnservice Testing Program Part 5 - Valve Scope Tables, will not list valves that meet ALL of the following criteria.

  • The valve is categorized B (seat leakage in the closed position is inconsequential for fulfillment of the valves' required function(s)) in accordance with ISTC-1300.
  • The valve is considered passive (valve maintains obturator position and is not required to change obturator position to accomplish the required function(s)) in accordance with ISTA-2000.
  • The valve does not have a remote position indicating system which detects and indicates valve position.

Technical Position TP-04 Page 1 of 1 Fail-Safe Testing of Valves Purpose The purpose of this Technical Position is to establish the Fermi 1ST Program position for fail safe testing of valves in conjunction with stroke time exercising or position indication testing.

Applicability This Technical Position is applicable to valves with fail-safe actuators required to be tested in accordance with ISTC-3560.

Background

The ASME OM Code 2012 Edition section ISTC-3560 requires; "Valves with fail-safe actuators shall be tested by observing the operation of the actuator upon loss of valve actuating power in accordance with the exercising frequency of ISTC-351 O."

Justification Fail Safe Testing tests the ability of the fail-safe mechanism of the valves to go to its fail safe condition. Whether or not the actuation of this fail safe mechanism is due to Operator Action or failure of the valves air/ electric power source, the resultant action of the valve will be the same.

Therefore, the verification of a valve fail safe ability can be taken credit for with the performance of either a stroke time exercising or full stroke position indication test Position In cases where the valve operator moves the valve to the open or closed position following de-energizing the operator electrically, by venting air, or both, the resultant valve exercise will satisfy the fail-safe test requirements and an additional test specific for fail safe testing will not be performed.

Fermi will also use remote position indication as applicable to verify proper fail-safe operation, provided that the indication system for the valve is periodically verified in accordance with ISTC-3700.

Technical Position TP-05 Page 1 of 4 Classification of Skid Mounted Components Purpose The purpose of this Technical Position is to clarify requirements for classification of various skid mounted components, and to clarify the testing requirements of these components.

Background

The ASME Code allows classification of some components as skid mounted when their satisfactory operation is demonstrated by the satisfactory performance of the associated major components. Testing of the major component is sufficient to satisfy lnservice Testing requirements for skid mounted components. In section 3.4 of NUREG 1482 Rev 2, the NRC supports the designation of components as skid mounted:

"The staff has determined that the testing of the major component is an acceptable means for verifying the operational readiness of the skid-mounted and component subassemblies if the licensee documents this approach in the 1ST Program. This is acceptable for both Code class components and non-Code class components tested and tracked by the 1ST Program."

ISTA-2000 Definitions skid-mounted pumps and valves: pumps and valves integral to or that support operation of major components, even though these pumps and valves may not be located directly on the skid. In general, these pumps and valves are supplied by the manufacturer of the major component. Examples include (a) diesel fuel oil pumps and valves (b) steam admission and trip throttle valves for high-pressure coolant injection pumps (c) steam admission and trip throttle valves for auxiliary feedwater turbine-driven pumps (d) solenoid-operated valves provided to control an air-operated valve Additionally the Subsections pertaining to pumps (ISTB) and valves (ISTC) includes exclusions/exemptions for skid mounted components; ISTB-1200(c) Exclusions Skid-mounted pumps that are tested as part of the major component and are justified by the Owner to be adequately tested.

ISTC-1200 Exemptions Skid-mounted valves are excluded from this Subsection provided they are tested as part of the major component and are justified by the Owner to be adequately tested.

Position

  • The 2012 ASME OM Code definition of skid mounted will be used for classification of components in the Fermi lnservice Testing Program. In add ition, for a component to be considered skid mounted:
  • The major component associated with the skid mounted component must be surveillance tested at a frequency sufficient to meet ASME Code test frequency for the skid mounted component.
  • Satisfactory operation of the skid mounted component must be demonstrated by satisfactory operation of the major component.

Technical Position TP-05 Page 2 of 4

  • The 1ST Bases Document should describe the bases for classifying a component as skid mounted, and the 1ST Program Plan should reference this technical position for the component.

Recognition and classification of components as skid mounted eliminates the need for the redundant testing of the sub component(s) as the testing of major (parent) component satisfactorily demonstrates operation of the "skid mounted" component(s).

The components designated as skid-mounted are identified as such in the 1ST Bases. These include auxiliary pumps for the Emergency Diesel Generators and the HPCI system. Also several valves mounted on the EOG skids which are part of the lube oil, fuel oil and cooling water sub-systems.

EOG-related Skid Mounted Pumps In addition to the component level justifications in the 1ST Bases, the following provides an overall description of the exclusion basis for several EOG-related pumps.

The following EOG support system pumps are designated as skid-mounted:

Fuel Oil subsystem -

Motor-driven fuel oil pumps (R3001 C021, C022, C023 and C024)

Engine-driven fuel oil pumps Engine Cooling subsystem -

Motor-driven standby jacket cooling pumps (R3001 C025, C026, CO2? and C028)

Engine-driven jacket coolant pumps Engine-driven air coolant pumps Engine Lube Oil subsystem -

Motor-driven standby lube oil pumps (R3001C017, C018, C019 and C020)

Motor-driven lube oil pre-lube pumps (R3001C013, C014, C015 and C016)

Engine-driven lube oil pumps J ustifi cation Classification of components as skid-mounted eliminates the need for testing of sub components that are redundant with testing of major components. Testing of the major components demonstrates satisfactory operation of the "skid-mounted" components. The following is a description of the system monitoring done for the EOG support systems skid-mounted pumps:

1. EOG motor driven fuel oil pump: This pump is a backup to the engine driven pump and has no safety function. It is used for Post Maintenance Testing and discharge fuel oil pressure is verified. Reliability is assured through periodic maintenance per 34.307.001.
2. EOG Engine-driven fuel oil pump: This pump is monitored by trending of fuel oil pressure.

The capability of the pump is also checked via the 5 minute high load run (3150 - 3250 KW) contained in 24.307.45-48. The system engineers EOG system monitoring plan contains additional details on data collection and analysis.

3. EOG motor-driven standby jacket cooling pump: This pump is verified to work by jacket coolant temperature being maintained in standby. If the pump is not working, standby jacket

Technical Position TP-05 Page 3 of 4 coolant temperature will drop. Low jacket coolant temperature is alarmed. Standby jacket coolant temperature is recorded daily in Operator rounds. Standby jacket coolant temperature is trended by System Engineering. The system engineers EDG system monitoring plan contains additional details on data collection and analysis.

4. EDG engine driven jacket cooling pump: This pump is monitored by trending of jacket coolant pressure, jacket coolant pressure fluctuations and jacket coolant temperature in to and out of the engine. The system engineers EDG system monitoring plan contains additional details on data collection and analysis.
5. EDG engine driven air coolant pump: water pressure in the air coolant loop is not monitored (no instrument). Performance of the entire cooling loop (including the pump) is verified by trending of scavenge air temperature. The system engineers EDG system monitoring plan contains additional details on data collection and analysis.
6. EOG motor-driven standby lube oil pump: This pump is verified to work by lube oil temperature being maintained in standby. If the pump is not working, standby lube oil temperature will drop. Low lube oil temperature is alarmed. Standby lube oil temperature is recorded daily in Operator rounds. Standby lube oil temperature is trended by System Engineering. Reliability is assured through periodic maintenance per 34.307.001. The system engineers EDG system monitoring plan contains additional details on data collection and analysis.
7. EDG motor-driven Pre-lube pump: Reliability is assured through periodic maintenance per 34.307.001. Bearing checks done in 34.307.001 would indicate bearing damage if this pump were not working properly. System Engineers also check for proper operation of this pump when they observe surveillance testing of the EDGs (verify slight increase in upper header lube oil pressure).
8. EDG engine driven lube oil pump: This pump is monitored by trending of lube oil pressure (at filter, strainer and upper lube oil header) and temperature into and out of the engine. The system engineers EOG system monitoring plan contains additional details on data collection and analysis.

Additional skid-mounted components at Fermi:

Diesel Generator Air Starting, Fuel Oil, Lube Oil, Jacket and Air Coolant Systems Control and Check Valves are located on the engine skid. They perform various active safety functions to maintain EDG operability. These valves will be tested as part of the Diesel Generator performance testing, which are subjected to Technical Specification Surveillance Requirement 3.8.1 .3 and 3.8.1.7. These Skid Mounted valves that are satisfied during performance testing are:

R3000F015A-D, R3000F027A-D, R3000F029A-D, R3000F052A-D, R3000F053A-D, R3000F054A-D, R3000F055A-D,R3000F056A-D, R3000F057A-D, R3000F058A-D, R3000F059A-D, R3000F060A-D, R3000F061A-D, R3000F062A-D, R3000F063A-D, R3000F094A-D, R3000F097A-D, R3000F100A-D, R3000F110A-D, R3000F116A-D, R3000F117A-D, R3000F189A-D, R30FA02A-D, R30FA04A-D and R30FA05A-D Control Rod Drive Valves are located on the hydraulic control units for the 185 control rod drives. They perform the active safety function of rapidly inserting the control rods into the reactor core, upon receipt of a reactor scram signal from the reactor protection system. These valves will be tested as part of the control rod insertion times subject to the conservative limitations of Technical Specification Surveillance Requirements 3.1.4.1, 3.1.4.2, 3.1.4.3 and 3.1 .4.4. These Skid Mounted valves that are satisfied during Technical Specification testing are:

Technical Position TP~OS Page 4 of 4 are:

C1103F114, C1103F115, C1103F120, C1103F121, C1103F122, C1103F123, C1103F126, C1103F127 and C1103F138 The High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC),

Turbines Stop and Control Valves . These Stop and Control valves closures are accomplished by spring force. These rapid acting valves, closures cannot be timed accurately nor trended from test-to-test . In contrast, opening is accomplished hydraulically by oil pressure working against spring force. The valve has no independent manual control, but rather is controlled only by HPCI/RCIC turbine oil pressure. The turbine stop and control valves are skid-mounted components of the HPCI/RCIC turbine and structurally integrated with the turbine . These Skid Mounted valves that are satisfied during HPCI/RCIC testing are:

E4100F067 , E4100F068 , E5150F044 and E5150F059 The HPCI Booster Pump, E4101 C001 B, ensures adequate NPSH is available to the Main Pump to prevent cavitation . The Booster Pump is a single stage centrifugal pump with a capacity of 5,100 gpm. Its normal speed range is between 1,000 rpm and 2,000 rpm. The pump is designed to pump water with a temperature range of 40 to 140 deg F. Booster Pump discharge pressure into the Main Pump is 290 psig at 2,000 rpm. The 12 inch piping connection between the booster pump and the main pump does include a 2 inch outlet which provides cooling water flow to the HPCI Lube Oil cooler and the barometric condenser. The flow in this line is controlled by design to 70 gpm (see HPCI Design Spec DSN: 22A 1362AR).

This flow control is established by the setpoint operation of the E41 F035 valve as well as by restricting orifices- E4150D008 and E4150D009. This flow path is not mon itored during HPCI Pump 1ST, however due to its fixed value and the consistency of the testing methodology since the inception of 1ST there is no adverse impact. Performance testing of the Main pump adequately monitors the performance of the booster pump.

The HPCI Main and Auxiliary Oil Pumps provide pressurized oil for lubrication and control oil functions. The capacity of each pump is approximately 30 gpm . The DC motor-driven Aux Oil Pump supplies lubrication and control oil pressure at 90-100 psig to the turbine during startup, shutdown, and whenever the turbine speed is too low for the turbine driven Main Oil Pump to deliver operating pressure . A pressure switch in the Main Oil Pump discharge line controls automatic operation of the Aux Oil Pump. The Aux Oil Pump will start when HPCI receives an initiation signal and low oil pressure is sensed . The Main Oil Pump is driven by the HPCI Tu rbine shaft and delivers oil at 105-1 15 psig to the system once the turbine reaches a speed of 1,450-1,650 rpm on start up. If turbine speed falls below 1,200-1 ,500 rpm during operation, the Mail Oil Pump can no longer maintain proper operating oil pressure , and the Auxiliary Oil Pump will automatically start. Proper operation of the HPCI pump during testing and monitoring of several turbine/pump parameters ensures adequate testing of the skid mounted component.

The Station and Control Air System Control Air Dryer Pre-Filter Auto Drain valves, are normally closed solenoid valves operate as required to maintain moisture removed from the Control Air Dryer Assembly inlet piping and Pre-filter. These Skid Mounted valves that are satisfied during Station and Control Air Skid testing are:

P5000F515A and P5000F515B

Technical Position TP-07 Page 1 of 2 Outside Design Basis Purpose The purpose of this Technical Position is to establish the Fermi 1ST Program position for scoping decisions on components which may be functionally credited within the Appendix R program or "Beyond Design Basis" but are not considered in the scope of the 1ST Program.

Applicability This Technical Position is applicable to components outside the scope of UFSAR Chapter 15 accident mitigation or which have no specific functional requirement to achieve or maintain cold shutdown.

Background

The ASME Code 2012 Edition section ISTA-1100, "Scope", states that lnservice Testing requirements pertain to:

"Pumps and Valves that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident."

The Appendix R Program examines accident scenarios triggered predominantly by fires in various plant locations. An Appendix R scenario may verify the ability of operators to travel to a specific plant location and to manually manipulate a valve in a BOP system which would be operated as part of an orderly plant shutdown. The ASME 1ST scoping process looks at safety related equipment - for example, the need to provide adequate makeup water to the reactor must be fulfilled by our ECCS systems with an underlying assumption that all non-ASME systems are unavailable. We would provide for testing of those ECCS systems to ensure they can meet their design basis capabilities. This is only one example of the differences between ASME 1ST pump and valve scoping and Appendix R scoping. Another example is the components installed in the T49 system under EDP 33934. This mod installed a sub-system of N2 bottles / piping / valves which would provide a backup to the Interruptible Air System for supplying air/N2 to the Division II SRVs. The Division II SRVs have an active opening safety function within the 1ST Program to protect primary piping from over pressurization. This safety function is met by the ability of those SRVs to open as a relief valve against a spring-setpoint pressure. The air/N2 supply to these SRVs is only to allow for remote opening by Operations for testing or if Operations deems it necessary. There is no accident scenario within Chapter 15 which would require the capability for remote-manual operation of those SRVs. However, a specific Appendix R scenario based on certain fire-damage conditions determined that Operator ability to remotely open those SRVs needed to be assured. The components installed per EDP 33934 were not ASME Class 1, 2 or 3. Those components are not credited with an active safety function as defined by the ASME 1ST scoping definitions, and will not be tested under the auspices of the Fermi 1ST Program.

Justification Components credited in Appendix R or other outside design basis evaluations may or may not be safety-related. Testing of these components may be accomplished through the plant PM Program or other test scheduling processes. The expertise of the ISI/IST qualified personnel may be utilized to develop and even perform such testing. The 1ST Program involves a significant administrative burden and the scope of components within the program needs to be limited and in line with standard industry norms.

Technical Position TP-07 Page 2 of 2 Position Consistent-with industry practice, components required solely to mitigate the consequences of 10CFR50 Appendix R fires and station blackout events are outside the scope of the 1ST Program since these events are beyond the facility design basis. Beyond design basis events are initiated by multiple (and sometimes complete) failures of safety-related components and systems. The facility design is based on requirement that each safety system be capable of performing its safety-related functions given a failure of the most limiting active component.

Although regulations have been imposed that require the capability to cope with, or to mitigate these events, they are outside the scope of the facility accident analyses. Components whose sole safety functions are to mitigate these "outside design basis" events are not required by regulations to be classified as safety-related, nor would they meet the ASME OM Code scoping definitions.

Technical Position TP-9 Page 1 of 9 Pump Reference Value Testing Ranges Purpose Provide documentation on the pump testing flow and pressure bands used for field testing.

Applicability All active 1ST Program pumps.

Background

The 2012 edition of the ASME OM Code defines the testing bands for centrifugal and positive displacement pumps. Centrifugal (includes vertical line shaft) pumps require a flow band of +2%,

-1 % of the reference. Positive displacement pumps require a discharge pressure band to be set at + 1%, -2% of the reference. These bands are identical for Group A, Group B, and Comprehensive Pump Testing. In addition, these bands are exclusive of instrument accuracy.

Definitions NIA Position Th~ existing 1ST Pumps testing band around the reference will either meet the 2012 OM Code requirements listed in ISTB or be more conservative.

Technical Position TP-9 Page 2 of 9 PIS Pump Reference 2012 OM Code Surveillance Comments Reference Type Band C4103C001A PD 1232.5 1207.9 - 1220-1240 Surveillance band is 1ST Evaluation 84-03 1244.8 more conservative PSIG PSIG compared to OM Code PSIG requirement. No change will be made to this test band.

C4103C001B PD 1232.5 1207.9 - 1220-1240 Surveillance band is 1ST Evaluation 99-034 1244.8 more conservative PSIG PSIG compared to OM Code PSIG requirement. No change will be made to this test band.

E1102C001A-D Cen 10,210 10,107.9- 10,110- Surveillance band is 1ST Evaluation 12-033 GPM 10,414.2 GPM 10,310 GPM more conservative compared to OM Code requirement. No change will be made to this test band.

E1151C001A-D VLS 5400 GPM 5346-5508 5346-5464 Surveillance band is 1ST Evaluations10-006, 5-GPM GPM more conservative 021,16-022, 20-001,20-003 compared to OM Code requirement. No change will be made to this test band.

E2101C001A-D Cen NIA NIA NIA Pumps are tested using a pump curve methodoloqv. No

Technical Position TP-9 Page 3 of 9 PIS Pump Reference 2012 OM Code Surveillance Comments Reference Type Band change will be made to this test band.

E4101C001A Cen 3975 RPM 3935.3-4014.8 3950-4000 Surveillance band is 1ST Evaluation 19-014 RPM RPM more conservative compared to OM Code requirement. No change will be made to this test band.

E4101C001A Cen 5000 GPM 4950-5100 5000-5100 Surveillance band is 1ST Evaluation 19-014 GPM more conservative compared to OM Code requirement. No change will be made to this test band.

E5101C001 Cen 4355 RPM 4311.5-4398.6 4305-4405 Revision made to Also see 1ST Evaluation 10-RPM RPM 24.206.01. 006.

E5101C001 Cen 655 GPM 648.5-668.1 605-705 Revision made to 1ST Evaluation 10-006 GPM GPM 24.206.01.

P4400C001A Cen 1862 GPM 1848.4-1899.0 1830-1899 The surveillance band is Per 1ST Evaluation 18-001 GPM GPM slightly larger than 2012 (EECW A Replacement), a OM Code value. flow band of +/-1.5% was set However, the difference (1835 - 1889 GPM) around is negligible with respect the reference (1862 GPM).

to trending. In addition, Later per CARD 08-23999, the surveillance band the band was set at +/- 2%

extends to the same (1825-1899 GPM). 1ST point pump curve which Evaluation 18-014 was is provides the same created to allow and create degree of performance alternate acceptance criteria

Technical Position TP-9 Page 4 of 9 PIS Pump I Reference 2012 OM Code I Surveillance Comments Reference Type Band testing. No change will based on a pump curve for be made to this test surveillance runs during band. times when various loads are isolated. The band for this particular pump curve test was established at 1550-1830 GPM. This band overlapped with the fixed band (1825-1899 GPM) discussed above and therefore corrected in the surveillance procedure to 1830-1899 GPM. The 2012 OM Code band is +2%, -1 %

of the reference and applies to the fixed band test only.

P4400C001B Cen 1730 GPM I 1712.7-1764.6 1696-1764 The surveillance band is Per 1ST Evaluation 08-004 GPM GPM slightly larger than 2012 (EECW B Replacement), a OM Code value. flow band of +/- 1.45% was However, the difference set (1705-1755 GPM). Later, is negligible with respect CARD 08-23999 revised the to trending. In addition, band to +/- 2% (1696-1764 the surveillance band GPM). 1ST 18-015 was extends to the same created to allow and create point pump curve which alternate acceptance criteria is provides the same based on a pump curve for degree of performance surveillance runs durin_g_

Technical Position TP-9 Page 5 of 9 PIS Pump I Reference 12012 OM Code I Surveillance I Comments Reference Type Band testing. No change will times when various loads are be made to this test isolated. The band for this band. particular pump curve test was established at 1450-1700 GPM. 1ST 12-037 revised the related pump curve tables to ensure all testing is performed greater 1550 GPM per Third Interval relief request PRR-003.

P4400C002A Cen 14.85 14.7-15.1 GPM I 14.55-15.14 The surveillance band is 11ST Evaluation 10-006 GPM GPM slightly larger than 2012 (Quarterly Test)

OM Code value.

However, the difference is negligible with respect to trending. In addition, the surveillance band extends further on the pump curve which is more conservative. No change will be made to this test band.

P4400C002A Cen 19.95 19.8-20.3 GPM I 19.55-20.34 I The surveillance band is 11ST Evaluation 12-028 GPM GPM slightly larger than 2012 (Comprehensive Pump Test)

OM Code value.

However, the difference is negligible with respect to trending. In addition, the surveillance band extends further on the pum_Q_ curve which is

Technical Position TP-9 Page 6 of 9 PIS Pump Reference 2012 OM Code Surveillance Comments Reference Type Band more conservative. No change will be made to this test band.

P4400C002B Cen 15.17 15.0-15.5 GPM 14.87-15.47 The surveillance band is 1ST Evaluation 16-006 / 18-GPM GPM slightly larger than 2012 003 (Quarterly Test)

OM Code value.

However, the difference is negligible with respect to trending. In addition, the surveillance band extends further on the pump curve which is more conservative. No change will be made to this test band.

P4400C002B Cen 20.9 GPM 20.7-21.3 20.49-21.30 The surveillance band is 1ST Evaluation 16-006 I 18-GPM GPM slightly larger than 2012 003 (Comprehensive Pump OM Code value. Test)

However, the difference is negligible with respect to trending. In addition, the surveillance band extends further on the pump curve which is more conservative. No change will be made to this test band.

P4500C002A VLS 1683 GPM 1666.2-1716.7 1660-1700 Original band is tighter 1ST Evaluation 11-025.

GPM GPM than code by 1OGPM.

Technical Position TP-9 Page 7 of 9 PIS Pump Reference 2012 OM Code Surveillance Comments Reference Type Band No change will be made Post SOE 20-04 continue to to this test band. use 1660-1700.

P4500C002B VLS 1680 GPM 1663.2-1713.6 1660-1700 Original band is tighter 1ST Evaluation 15-008 GPM GPM than code by 10GPM.

No change will be made to this test band.

R3001C005- VLS 980 GPM 970.2-999.6 974-986 Surveillance band is 1ST Evaluation 17-042 COO? GPM GPM more conservative compared to OM Code 1ST Evaluation 18-008 requirement. No change will be made to this test 1ST Evaluation 10-006 band.

R3001C008 VLS 983 GPM 973.2-1002.7 977-989 Surveillance band is 1ST Evaluation 18-006 GPM GPM more conservative compared to OM Code requirement. No change will be made to this test band.

R3000C001 PD 9.9 PSIG 9.70-10.00 9.76-10.04 Surveillance variance is 1ST Evaluation 10-006 and PSIG PSIG more conservative than 20-021 code variance. No change will be made to this test band.

R3000C002 PD 9.8 PSIG 9.60-9.90 PSIG 9.66-9.94 Surveillance variance is 1ST Evaluation 10-006 and PSIG more conservative than 20-021 code variance. No

Technical Position TP-9 Page 8 of 9 PIS Pump Reference 2012 OM Code Surveillance Comments Reference Type Band change will be made to this test band.

R3000C003 PD 9.78 PSIG 9.58-9.88 PSIG 9.64-9.92 Surveillance variance is 1ST Evaluation 10-006 and PSIG more conservative than 20-021 code variance. No change will be made to this test band.

R3000C004 PD 9.93 PSIG 9.73-10.03 9.79-10.07 Surveillance variance is 1ST Evaluation 10-006 and PSIG PSIG more conservative than 20-021 code variance. No change will be made to this test band.

R3000C009 PD 9.80 PSIG 9.60-9.90 PSIG 9.66-9.94 Surveillance variance is 1ST Evaluation 10-006 and PSIG more conservative than 20-021 code variance. No change will be made to this test band.

R3000C010 PD 9.50 PSIG 9.31-9.60 PSIG 9.36-9.64 Surveillance variance is 1ST Evaluation 10-006 and PSIG more conservative than 20-017.

code variance. No change will be made to this test band.

R3000C011 PD 9.80 PSIG 9.60-9.90 PSIG 9.66-9.94 Surveillance variance is 1ST Evaluation 10-006 and PSIG more conservative than 20-021 code variance. No change will be made to this test band.

Technical Position TP-9 Page 9 of 9 PIS Pump Reference 2012 OM Code Surveillance Comments Reference Type Band R3000C012 PD 9.60 PSIG 9.41-9.70 PSIG 9.46-9.74 Surveillance variance is 1ST Evaluation 10-006 and PSIG more conservative than 20-017.

code variance. No change will be made to this test band.

T4100C040 Cen 233 GPM 230.7-237.7 230-236 Surveillance variance is 1ST Evaluation 10-006 GPM more conservative than code variance. No change will be made to this test band.

T4100C041 Cen 233 GPM 230.7-237.7 230-236 Surveillance variance is 1ST Evaluation 10-006 GPM more conservative than code variance. No change will be made to this test band.

Page 1 of 1 Technical Position TP-13 (Pump Testing Instrument Accuracy)

Purpose Document pump testing instruments meet 2012 OM Code accuracy requirements.

Applicability All active JST Program pumps.

Background

The 2012 edition of the ASME OM Code (Table ISTB-3510-1) defines the accuracy requirements for pump testing. This is applicable for flow, pressure, speed, and vibration.

Definitions Code Requirements (2012 OM Code, NUREG 1482 Rev. 2):

Flow:(+/- 2% accuracy) Requirement for Group A, B, and Comprehensive Pump Test Vibration: (+/- 5% accuracy) Requirement for Group A, B, and Comprehensive Pump Test Pressure: Group A and B pump testing requires an accuracy of(+/- 2%). Comprehensive Pump Testing requires an accuracy of(+/- 0.5%).

Speed: (+/- 2%)

Individual Analog Instruments (Accuracy is percent of full scale)

Individual Digital Instruments (Accuracy is over calibrated range or percent of reading) and reference values must not exceed 90% of the calibrated range. Reference the ASME OM Code for requirements on Analog instrum ents.

For a combination of instruments (Loop accuracy applies)

Position The instruments used for pump testing at Fermi 2 meet the 2012 OM requirements.

Attachments

1. JST Accuracy Statement for Tempora1y Flow Instrument
2. IST Accuracy Statements for Pump Instruments

Technical Position TP-13, Attachment 1 {1ST Accuracy Statement for Temporary Flow Instrumentation)

Page 1 of 2 Flow measurement accuracy using M&TE - Rosemount model 3051 /

Decade Box 250ohm / Digital Voltmeter Purpose The purpose of this Technical Position is to establish the IST Program position on the accuracy of flow readings taken using the standard M&TE setup connected to system flow elements.

Applicability This Technical Position is applicable to all IST program pumps which are tested using this M&TEsetup.

Justification Several surveillance procedures stipulate the use of the following temporary M&TE equipment for flow measurement:

  • Rosemount model 3051Smart Pressure Transmitter
  • Decade Box or dedicated 250 ohm test resistor
  • Digital Voltmeter equipped for averaging function The Rosemount transmitter is connected directly to the flow element upstream (HP) and downstream (LP) pressure connections. The transmitter output is connected to a simple series circuit supplied with 24 VDC. The cuITent through the 250 ohm resistor is a linear 0-20 mA directly proportional to the differential pressure (inH2O) produced by the flow element. The voltmeter reads the voltage drop across the 250 ohm resistor. The procedures provide a data table that relates the V de ( or inH2O) to system flow in gpm based on the flow element design data.

The accuracy of the Rosemount transmitter is 0.1 % of full scale (0.7 inH2O@ 700 inH2O). The precise accuracy at readings of interest is determined as follows:

Div l RHR Flow minimum= 10,000 gpm = 1.565 Vdc = 6.26 mA Div 1 RHRSW Flow minimum= 5300 gpm = 1.751 Vdc = 7.0 mA Div l EESW Flow minimum= 1660 gpm = 155.6 inH2O = 7.556 m.A The 6.26mA minimum reading for RHR is the most limiting in terms of accuracy. The 6.26mA conesponds to 98.919 inH2O. The specified accuracy is+/- 0.7 inH2O therefore the limiting accuracy for the Rosemount 3051 is 0.7 / 98.919 = 0.708%.

Technical Position TP-13, Attachment 1 (1ST Accuracy Statement for Temporary Flow Instrumentation)

Page 2 of 2 The individual accuracies of the digital voltmeter and decade box/resistor are both better than 0.01 %. Conservative straight addition yields an overall accuracy of 0.708 + .01 + .01 = 0.728%.

A conservative value of+/- 0.8% total accuracy will be assumed for any flow readings taken using this typical M&TE setup.

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 1 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References C4103C001A Flow C41R400 CARD 06-24380 +l-2%.

C4103C001A Discharge 1-4 MT48 Item 1: 61 % of scale therefore accuracy is Pressure +l-0.1%

Pressure range -1220-1240PSIG Item 2:41 % of scale therefore accuracy is

+l-0.1%

Item 3:At 1220 PSIG, accuracy is +I-0.08%

Item4:At 1220 PSIG0.01%+0.15%=0.16%

C4103C001A Vibration NIA NIA :S 5%

C4103C001B Flow C41R400 CARD 06-24380 +l-2%

C4103C001B Discharge 1-4 MT48 Item 1: 61 % of scale therefore accuracy is Pressure +l-0.1%

Item 2:41 % of scale therefore accuracy is

+l-0.1%

Item 3:At 1220 PSIG, accuracy is +I-0.08%

Item4:At 1220 PSIG0.01 %+0.15%=0.16%

C4103C001B Vibration NIA NIA :S5%

El 102C001A/C Flow 10 MTIO See attachment 1

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 2 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Suction 5-9 (Suction 3-6 MTIO Item 5:Using 3PSIG, +/-0.25%.

and PSIG), 11-16 Discharge (Discharge Item 6: Using 3 PSIG, =/-0.5%.

Pressure Item 7: Conservatively use 3 PSIG. Full scale accuracy +/-0.03% + 0.05% (IR) =

0.08%

Item 8: Conservatively use 3 PSIG (20%FS) following +/-0.02% ACC @FS yields +/-0.1 %.

Item 9: Conservatively use 6 PSIG (20%FS) following +/-0.02% ACC @FS yields +/-0.1 %.

Item 11: Conservatively use 258.1 PSIG (based on sampling discharge pressures for A/C pumps) yields+/- 0.10%.

Item 12: Conservatively use 258.1 PSIG (based on sampling discharge pressures for A/C pumps) yields+/- 0.19%.

Item 13: Conservatively use 258.1 PSIG (based on sampling discharge pressures for A/C pumps) yields+/- 0.29%.

Item 14: Conservatively use 258.1 PSIG (based on sampling discharge pressures for A/C pumps) yields+/- 0.15% + 0.03% or

+/- 0.18%.

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 3 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Item 15: Using 258.1 PSIG, use accuracy statement for greater than 20% FS or +I-0.1%

Item 16: Using 258.1 PSIG, use accuracy statement for greater than 20% FS or +I-0.1%

Vibration NIA NIA :s 5%

Ell02C001B/D Flow 10 MTll See attachment 1.

Suction 5-9, 11-16 MTll Apply analysis for El 102C00 lA/C due to and similarity of pressures and instruments.

Discharge Pressure Vibration NIA NIA :s 5%

El151C001A/C Flow 10 MT20 See attachment 1.

Pressure 17-19 MT20 Item 17: (Discharge): Conservatively use 50 PSIG, accuracy is +I- 0.1%

Item 18 (Discharge): Item 17:

Conservatively use 50 PSIG, accuracy is

+I- 0.2%

Item 19: Item 17 (Discharge):

Conservatively use 50 PSIG, accuracy is

+I- 0.3%

Suction Pressure per Relief Request PRR-003 .

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 4 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Vibration NIA NIA  ::; 5%

E1151C001B/D Flow 10 MT21 See attachment 1.

Pressure 17-19 MT21 Item 17: (Discharge): Conservatively use 50 PSIG, accuracy is +I- 0.1 %

Item 18 (Discharge): Item 17:

Conservatively use 50 PSIG, accuracy is

+I- 0.2%

Item 19: Item 17 (Discharge):

Conservatively use 50 PSIG, accuracy is

+I- 0.3%

Suction Pressure per Relief Request PRR-003.

Vibration NIA NIA  ::; 5%

E2101C001A/C Flow Item 10 for CPT Reference CARD 06- Quarterly test uses E21R600A. Instrument only. 24380. loop accuracy is 104 GPM/6600 GPM or

+I- 1.58%.

MT0lCPT See Attachment 1 for CPT flow accuracy statement.

Pressure 6,9,11 ,15,20,21- MT0l or MT0lCPT Item 6: Q or CPTsuc, Conservatively using Quarterly 5 PSIG yields +I- 0.3%.

6 and 11 -CPT Item 9:QSuc, Conservatively use +I- 0.02%

FS for 5 PSIG yields +l-0.12%.

Technical Position TP-13, Attachment 2 {1ST Accuracy Statements for Pump Instruments)

Page 5 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Item 20:QSuc, Conservatively use +I-0.02% FS for 5 PSIG yields +l-0.4%.

Item 11:Q or CPTDis, Conservatively use 270 PSIG yields +l-0.09%.

Item 15:QDis, Using 270 PSIG, accuracy is

+l-0.1%.

Item 21:QDis, Using 270 PSIG, which is conservative for FS instrument accuracy yields +I- 0.09%.

Vibration NIA NIA :S5%

E2101C001B/D Flow Item 10 for CPT Reference CARD 06- Quarterly test uses E21R600A. Instrument only. 24380. loop accuracy is 104 GPM/6600 GPM or

+I- 1.58%.

MT02CPT See Attachment 1 for CPT flow accuracy statement.

Pressure 6,9,11,15,20,21- MT02 or MT02CPT Item 6: Q or CPTsuc, Conservatively using Quarterly 5 PSIG yields +I- 0.3%.

6 and 11 -CPT Item 9:QSuc, Conservatively use +I- 0.02%

FS for 5 PSIG yields +l-0.12%.

Item 20:QSuc, Conservatively use +I-0.02% FS for 5 PSIG yields +l-0.4%.

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 6 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Item 11 :Q or CPTDis, Conservatively use 270 PSIG yields +/-0.09%.

Item 15:QDis, Using 270 PSIG, accuracy is

+/- 0.1%.

Item 21 :QDis, Using 270 PSIG, which is conservative for FS instrument accuracy yields +/- 0.09%.

Vibration NIA NIA $5%

E4101C001A Flow E41R613 E41N008-SS, CARD +/- 0.52% at 5000 GPM 07-23338 E4101C001A Pressure 1, 2, 9, 20, 22, 23 MT60 Item 9: Suction, +/-0.1% IR Item 20: Suction, +/-0.1 % IR Item 22: Suction, Conservatively use 20 PSIG yields +/- 0.07% based on FS instrument accuracy.

Item 1: Discharge, +/-0.1% IR Item 2: Discharge, +l-0.1 % IR Item 23: Discharge, using 1210 PSIG yields +/- 0.162%

E4101C001A Vibration NIA NIA  :'S 5% (Locally installed sensors)

E5101C001 Flow E51R613 44.110.004, DC-4561 , 0.57-0.67% within 600- 700 GPM band.

TE-E51-07-029

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 7 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References E5101C001 Pressure 1,3, 20 MT85 Item 20 (Suction): Conservatively using 20 PSIG and the FS accuracy statement yields

+/-0.1%

Item 22 (Suction): Conservatively using 20 PSIG and the FS accuracy statement yields

+l-0.07%

Item 1 (Discharge): Using 1100 PSIG yields+/- 0.1 % of IR.

Item 3 (Discharge): Conservatively using 1100 PSIG at 3/4FS accuracy yields +I-0.09%.

E5101C001 Vibration NIA NIA  ::::; 5% (Locally installed sensors)

P4400C001A Flow See comment MT75 +I- 2% Ultrasonic Flow Meter P4400C001A Pressure 11 ,17,18, 19, MT71 Item 17 (suction): Conservatively using 30 22,23, and 24 PSIG yields +I- 0.17%

Item 18 (suction): Conservatively using 30 PSIG yields +I- 0.33%

Item 22 (suction): Conservatively using 30 PSIG yields +I- 0.04%

Item 23 (suction): Conservatively using 30 PSIG yields +I- 0. 165%

Item 24 (suction): Conservatively using 30 PSIG yields +I- 0.2%

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 8 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Item 11 (Disch): Conservatively using 100 PSIG yields +I- 0.25%

Item 18 (Disch): Conservatively using 100 PSIG yields +I- 0.1 %

Item 19 (Disch): Conservatively using 100 PSIG yields +I- 0.15%

Item 23 (Disch): Conservatively using 100 PSIG yields +I- 0.165%

Item 24 (Disch): Conservatively using 100 PSIG yields+l-0.1%

P4400C001A Vibration NIA NIA :S5%

P4400C001B Flow MT76 +I- 2% IBtrasonic Flow Meter P4400C001B Pressure 11 ,17,18, 19, MT72 Item 17 (suction): Conservatively using 30 22,23, and 24 PSIG yields +I- 0.17%

Item 18 (suction): Conservatively using 30 PSIG yields +I- 0.33%

Item 22 (suction): Conservatively using 30 PSIG yields +I- 0.04%

Item 23 (suction): Conservatively using 30 PSIG yields +I- 0.165%

Item 24 (suction): Conservatively using 30 PSIG yields +I- 0.2%

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 9 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Item 11 (Disch): Conservatively using 100 PSIG yields +/- 0.25%

Item 18 (Disch): Conservatively using 100 PSIG yields+/- 0.1%

Item 19 (Disch): Conservatively using 100 PSIG yields+/- 0.15%

Item 23 (Disch): Conservatively using 100 PSIG yields+/- 0.165%

Item 24 (Disch): Conservatively using 100 PSIG yields+/- 0.1 %

P4400C001B Vibration NIA NIA  ::::;5%

P4400C002A Flow 10 MT73A/C See attachment 1 P4400C002A Pressure 17,20 MT73A/C Item 17 (suction): Using 16 PSIG, error is

+!- 0.3%

Item 20 (suction): Using 16 PSIG, error is

+/- 0.125%

Item 17 (discharge): Using 40 PSIG, error is +l-0.125%

Item 20 (discharge): Using 40 PSIG, error is +/-0.1%

Vibration NIA NIA  ::::;5%

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 10 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References P4400C002B Flow 10 . MT73B/D See attachment 1 P4400C002B Pressure 17,20 MT73B/D Item 17 (suction): Using 16 PSIG, error is

+I- 0.3%

Item 20 (suction): Using 16 PSIG, error is

+I- 0.125%

Item 17 (discharge): Using 40 PSIG, error is +l-0.125%

Item 20 (discharge): Using 40 PSIG, error is +l-0.1%

Vibration NIA NIA ~5%

P4500C002A Flow 10 MT73A/C See attachment 1 Pressure 17, 18 MT73A/C Suction Pressure per Relief Request PRR-003.

Items 17, 18 (Discharge): Conservatively using 40 PSIG, error is +l-0.125%.

Vibration NIA NIA ~5%

P4500C002B Flow 10 MT73B/D See attachment 1 Pressure 17, 18 MT73B/D Suction Pressure per Relief Request PRR-003.

Technical Position TP-13, Attachment 2 {1ST Accuracy Statements for Pump Instruments)

Page 11 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Items 17, 18 (Discharge): Conservatively using 40 PSIG, error is +l-0.125%.

Vibration NIA NIA  ::; 5%

R3001C005 Flow R30R850A R30N568-SS Between +I- 1.05% and +I- 1.32% in range of910GPM to 1050GPM Pressure 17,18,19,and 23 MT51 Suction Pressure per Relief Request PRR-003.

Conservatively use 30 PSIG.

Item 17: +I- 0.17%

Item 18: +I- 0.33%

Item 19: +I- 0.50%

Item 23 : +I- 0.20%

Vibration NIA NIA s; 5%

R3001C006 Flow R30R850C R30N568C-SS Between +I- 1.05% and +I- 1.32% in range of 91 0GPM to I 050GPM Pressure 17,18,19,and 23 MT52 Suction Pressure per Relief Request PRR-003.

Conservatively use 30 PSIG.

Item 17: +I- 0.17%

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 12 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Item 18: +I- 0.33%

Item 19: +I- 0.50%

Item 23 : +I- 0.20%

Vibration NIA NIA '.S 5%

R3001C007 Flow R30R850B R30N568B-SS Between +I- 1.05% and +I- 1.32% in range of 910GPM to 1050GPM Pressure 17,18,19,and 23 MT53 Suction Pressure per Relief Request PRR-003.

Conservatively use 30 PSIG.

Item 17: +I- 0.17%

Item 18: +I- 0.33%

Item 19: +I- 0.50%

Item 23 : +I- 0.20%

Vibration NIA NIA '.S 5%

R3001C008 Flow R30R850D R30N568D-SS Between+/- 1.05% and+/- 1.32% in range of910GPMto 1050GPM

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 13 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Pressure 17,18,19,and 23 MT54 Suction Pressure per Relief Request PRR-003.

Conservatively use 30 PSIG.

Item 17: +I- 0.17%

Item 18: +I- 0.33%

Item 19: +I- 0.50%

Item 23: +I- 0.20%

Vibration NIA NIA  :::;5%

R3000C001 Flow R30R411A EDP 70274 +l-1%

Pressure 6,8,25 24.307.34 Conservatively using 9 PSIG:

Item 6: +I- 0.17%

Item 8: +I- 0.1 %

Item 25: +I- 0.5%

Vibration NIA NIA  :::;5%

R3000C002 Flow R30R411C ERE45585 +I- 1%

Pressure 6,8,25 24.307.35 Conservatively using 9 PSIG:

Item 6: +I- 0.17%

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 14 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Item 8: +I- 0.1%

Item 25: +I- 0.5%

Vibration NIA NIA :s 5%

R3000C003 Flow R30R411A EDP 70274 +l-1%

Pressure 6,8,25 24.307.34 Conservatively using 9 PSIG:

Item 6: +I- 0.17%

Item 8: +I- 0.1 %

Item 25: +I- 0.5%

Vibration NIA NIA :s 5%

R3000C004 Flow R30R411C ERE 45585 +l-1%

Pressure 6,8,25 24.307.35 Conservatively using 9 PSIG:

Item 6: +I- 0.17%

Item 8: +I- 0.1%

Item 25: +I- 0.5%

Vibration NIA NIA :S5%

R3000C009 Flow R30R411B ERE45585 +/-1%

Pressure 6,8,25 24.307.36 Conservatively using 9 PSIG:

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 15 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Item 6: +I- 0.17%

Item 8: +I- 0.1%

Item 25: +I- 0.5%

Vibration NIA NIA  ::; 5%

R3000C010 Flow R30R411D EDP 70130 +l-1 %

Pressure 6,8,25 24.307.37 Conservatively using 9 PSIG:

Item 6: +I- 0.1 7%

Item 8: +l-0.1%

Item 25: +I- 0.5%

Vibration NIA NIA  ::;5%

R3000C011 Flow R30R411B ERE 45585 +l-1%

Pressure 6,8,25 24.307.36 Conservatively using 9 PSIG:

Item 6: +I- 0.17%

Item 8: +I- 0.1 %

Item 25: +I- 0.5%

Vibration NIA NIA :S5%

R3000C012 Flow R30R411D EDP 70130 +l-1%

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 16 of 18 PIS Parameter Instrument item Comments I Accuracy Statement for individual pump number References Pressure 6,8,25 24.307.37 Conservatively using 9 PSIG:

Item 6: +I- 0.17%

Item 8: +I- 0.1 %

Item 25: +I- 0.5%

Vibration NIA NIA  ::; 5%

T4100C040 Flow T41R405B T41R405B-S +I- 2% of full scale. Analog instrument Pressure 6,17 MT14 Item 6: +l-0.07% based on suction pressure of23 PSIG.

Item 17: +I- 0.11 % based on discharge pressure of 46 PSIG.

Vibration NIA NIA  ::; 5%

T4100C041 Flow T41R405A T41R405A-S +I- 2% of full scale. Analog instrument Pressure 6,17 MT15 Item 6: +l-0.15% based on suction pressure of 10 PSIG.

Item 17: +I- 0.15% based on discharge pressure of33 PSIG.

Vibration NIA NIA  ::; 5%

Technical Position TP-13, Attachment 2 {1ST Accuracy Statements for Pump Instruments)

Page 17 of 18 M&TE Model Accuracy Item Number 1 Crystal 2KPSIXP2i +/- 0.1 % IR from 20-IO03/4FS 2 Crystal 3KPSIXP2i +/- 0.1% IRfrom20-100%FS 3 Heise HQS-2-2000 +/-0.05% FS 4 Crystal 33-3000 200 - 3000 PSIG: +/- 0.15% IR+ 0.005% FS 5 Heise HQS-2-15 +/- 0.05% FS 6 Heise HQS-2-30 +!- 0.05% FS 7 Crystal 33-300 (16 psi CARD 12-21856, +/- 0.05% IR++/- 0.005%FS range) 8 Crystal 15PSIXP2I +/- 0.1% IR from 20 -100%FS

+/- 0.02% FS from 0-20%FS 9 Crystal 30PSIXP2I +/- 0.1% IR from 20 -l 10%FS

+/- 0.02% FS from 0-20%FS 10 Special Flow Refer to Attachment 1.

Instrumentation.

11 Heise HQS-2-500 +/- 0.05% FS 12 Heise HQS-2-1000 +/- 0.05% FS

Technical Position TP-13, Attachment 2 (1ST Accuracy Statements for Pump Instruments)

Page 18 of 18 13 Heise HQS-2-1500 +/- 0.05% FS 14 Crystal 33-1500 Pressure 200 - 1500 PSIG: +/- 0.15% IR+ 0.005% FS 15 Crystal 500PSIXP2I +/- 0.1 % IR from 20 -1 l03/4FS 16 Crystal 1KPSIXP2I +/- 0.1 % IR from 20 -100%FS 17 Heise HQS-2-100 +/-0.05% FS 18 Heise HQS-2-200 +/-0.05% FS 19 Heise HQS-2-300 +/-0.05% FS 20 Crystal 100PSIXP2I +/- 0.1 % IR from 20 -100%FS

+/- 0.02% FS from 0-20%FS 21 Fluke 700P07 +/-0.05% FS 22 Heise HQS-2-50 +/-0.025% FS 23 Crystal 33-300 (200-3000 +/-0.15% IR+ 0.005% FS PSIG) 24 Crystal 300PSIXP2I +/- 0.1 % IR 20-I003/4FS, +/- 0.02% FS 0-20% FS 25 Heise +/- 0.15% FS 303086D02L30#

Technical Position TP-15 Page 1 of 1 Testing of Reactor Pressure Vessel (RPV) Water Level Instrumentation Check Valves from Control Rod Drive (CDR) System

Purpose:

To provide justification for these Class D [Non-Code (NC)] check valves, testing extension, to a Refueling Outage (RO)

Applicability:

This Technical Position is applicable to all RPV Water Level Instrumentation Backfill Check Valves.

Valve PIS No. Code Class Category Drawing B2100F248A D A/C 5701-2 B2100F248B D A/C 5701-2 B2100F249A D A/C 5701-2 B2100F249B D A/C 5701-2 These backfill check valves function to provide continuous flow to the Reactor Pressure Vessel (RPV) Water Level Instrumentation from the Control Rod Drive (CRD) System. This cross connect provides a path from Primary Containment through Secondary Containment, a Bypass Leakage path. These check valves serve as Bypass Leakage Valves and must close (CVC) to perform their safety function. This check opens (BOO) to provide a continuous flow to the RPV Water Level Instrumentation from the CRD system. This function is not required for safe shutdown or accident mitigation by maintaining an acceptable reference leg fill for RPV monitoring instrumentation .

Justification:

These check valves cannot be tested during reactor power operation, as the isolation of flow is required to perform the test. The instrument backfill flow is needed to prevent reactor water level indication errors during plant depressurization transients. Valve manipulations required to perform these tests, during system operation, could result in a reactor scram. The back flow check valves will be verified to perform their safety function to close during their seat leakage test.

This testing is not practical during non-refueling Cold Shutdown conditions because of the time /

dose required to set up the leak rate testing equipment for the performance of the tests.

Position:

These check valves will be exercise tested in the open (BOO) and close (CVC) direction during reactor refueling outages.

Technical Position lP-16 Page 1 of 'I Obturato r Verification P5000, T2 300, and T4800 Valves Purpose Provide technical position for various methodologies to perform obturator verification.

~plicability P5000F440, P5000F441, T2300F400A-M , T2300F450A&B, and T4800F416-F427.

Background

10CFR 50.55(a) OM Condition on ISTC-3700 requires a supplemental obturator verification every two-years. This OM condition does not specify exact details on how to perform obturator verification. This OM condition does not specify the types of valves that applicable to obturator verification.

Definitions The obturator (valve disc) is confirmed to be in the expected position by using plant parameters such as measured flow, decreasing tank levels, increased pressure, reduced pressure etc.

Position P5000F440 & F441 (NIAS Station Air to Control Air Isolation AOV) :

These valves are normally open to supply IAS to various loads. If these valves were not indicating properly (indication problem / disc positioned closed) an alarm would occur possibly staring the Division 1 / 2 Control Air Compressors. This condition along with a two-year frequency seat leakage test (LT/OVC) provides assurance that the valve / disc is functioning as expected.

Therefore, only closed obturator verification will be performed during the two-year frequency seat leakage test.

T2300F400A-M, T2300F450A&B (Primary Containment / Suppression Chamber Vacuum Breakers):

The standard vacuum breaker testing performed in procedures 44.220.203, 44.220.204, and 24.402.01 perform testing that is adequate to verify obturator verification by performing position indication calibrations, set point tests / force measurements, and valve exercising using the actuators. The testing/ procedures mentioned above will be used to satisfy obturatorverification requirements in both the open and closed directions.

T4800F416-F427 (CAC N2 lnerting to Vac BKR Isolation Valves):

These isolation valves supply nitrogen to the vacuum breakers for testing purposes only. The closed position verification (OVC) is performed when LLRT is performed on these valves per Relief Request VRR-004. The open obturator position is verified by successful vacuum breaker testing each cycle.

Technical Position TP-17 Page 1 of 1 Obturator Verification T4600 Valves Purpose Provide technical position for various methodologies to perform obturator verification.

Applicability T4600F407, F408, F409, F410

Background

10CFR 50.SS(a) OM Condition on ISTC-3700 requires a supplemental obturator verification every two-years. This OM condition does not specify exact details on how to perform obturator verification. This OM condition does not specify the types of valves that applicable to obturator verification.

Definitions The obturator (valve disc) is confirmed to be in the expected position by using plant parameters such as measured flow, decreasing tank levels, increased pressure, reduced pressure etc.

Position T4600F407 (SGTS From RB EXH ISO VLV):

T4600F408 (Div 2 SGTS SC INBD ISO DMPR)

T4600F409 (Div 1 SGTS SC INBD ISO DMPR)

T4600F410 (RS AIR INLET ISO VLV)

All flow for SGTS is through Augmented 1ST valves T4600F407, F408, F409, F410 during the draw down test per 24.405.03 or 43.404.01 (3-year frequency). In additional three valves are seat tested per 47.000.94 (3-cycle frequency). During this testing, if the valve disc was in a position other than the desired position, the testing could not be performed. Therefore, these tests are adequate to alert Fermi Engineering or Operations personnel to issues related to obturator verification

Technical Position TP-18 Page 1 of 3 Obturator Verification Various HPCI & RCIC Valves Purpose Provide technical position for various methodologies to perform obturator verification.

Applicability PIS Number Applicable Test PIS Number Applicable Test E4100F025 OVO/OVC E5150F001 ovo E4100F026 OVO/OVC E5150F002 ovo E4100F028 OVO/OVC E5150F004 OVO/OVC E4100F029 OVO/OVC E5150F005 OVO/OVC E4100F053 OVO/OVC E5150F025 OVO/OVC E4150F021 ovo E5150F026 OVO/OVC E4150F022 ovo

Background

10CFR 50.55(a) OM Condition on ISTC-3700 requires a supplemental obturator verification every two-years. This OM condition does not specify exact details on how to perform obturator verification. This OM condition does not specify the types of valves that applicable to obturator verification.

Definitions The obturator (valve disc) is confirmed to be in the expected position by using plant parameters such as measured flow, decreasing tank levels, increased pressure, reduced pressure etc.

Position HPCI and RCIC Stop Checks (E4150F021&F022, E5150F001&F002)

The motor operated stop check valves can open independently of the motor. These valves function as a standard check valve to allow turbine exhaust steam or vacuum tank effluent to flow to the suppression pool. The closed obturator position will be validated using procedure 47.306.06 at the Appendix Ill frequency. This test alone is adequate to provide reasonable assurance for the obturator position. The open obturator direction will not be verified in surveillance procedures (i.e., 24.202.01, 24.202.08, 24.206.01 ). If the open obturator position is compromised, an alarm will be received in the control room as follows:

E4150F021: If this valve were not open, alarm 2D52 (HPCI Turbine Exhaust Line Pressure High) would be received.

Technical Position TP-18 Page 2 of 3 E4150F022: If this valve were not open, alarm 2065 (HPCI Turbine Exhaust Drain Pot Level High) would be received.

E5150F001: If this valve were not open, alarm 1063 (RCIC CNDR VAC Tank Level High) would be received.

E5150F002: If this valve were not open, alarm 1071 (RCIC CNDR Vac Tank Pressure High) would be received.

HPCI and RCIC Steam Supply Drain Pot (E4100F028/F029 & E5150F025/F026)

There is no practical testing method to determine obturator open and closed other than the drain pot level alarm. There is no method of measuring or visually seeing flow or lack of flow downstream of these valves. The only method for determining obturator verification for these valves would be to cycle individual valves while running P11 water through the upstream test connection while monitoring flow through tubing to a floor drain downstream of these valves. This method is not practical since it would need to be performed when the HPCI drain pot was isolated from main steam most likely during a refuel outage and would contribute to dose and contamination in addition to distracting operators in the control room. The following position will be used rather than creating a special test:

The HPCI and RCIC steam supply drain pot valves are normally open to the main condenser. If the open indication for these valves was not accurate for any reason, the main steam drain pots will reach a high level as realized through Alarms 1078 or 2077. These valves automatically isolate when the HPCI and RCIC turbine starts for testing and for injection into the vessel.

Isolation is required per UFSAR Table 6.2-14. If this position was not accurate, there is evidence the problem would be realized. DER 89-0286 provides evidence that the Operators can detect if the valves were open when expected to be closed by dual indication. Furthermore, it is reasonable to assume that operating the turbine the with the inboard and outboard isolation valves open with full system rated steam flow (E4150F002 & F003 Full Open) would be detected while setting turbine speed and pump flow. Operation of the turbine is possible with both valves open per DER 89-0286 however it is reasonable to assume that Operators experienced with HPCI and RCIC would detect anomalies or differences in system performance. Finally, the likelihood of having these valves stuck in the open position while indicating closed is low because of the valve design, performance of a two-year frequency position indication test, and quarterly stroke timing in both directions. Based on this position, no test specific (OVO/OVC) steps will be added to surveillance procedures 24.202.01, 24.202.08, or 24.206.01. The position of these valves is adequately tested during the pump and valve test.

HPCI Turbine Exhaust Drain Pot Isolation valve (E4100F053)

There is no practical testing method to determine obturator open and closed other than the drain pot level alarm. There is no method of measuring or visually seeing flow or lack of flow downstream of these valves. In addition, there are no upstream or downstream test connections that could be used to monitor flow while cycling E41 00F053. The following position will be used rather than creating a special test:

Normally closed E41 00F053 opens and closes based on the turbine exhaust drain pot level. If this valve were mispositioned, alarm 2065 would be received in the control room during the HPCI pump test due to a high turbine exhaust drain pot level. Furthermore, quarterly stroke time and two-year remote position testing performed in both the open and closed directions would alert Operators of any valve issues. Based on this position, no test specific (OVO/OVC) steps will be

Technical Position TP-18 Page 3 of 3 added to 24.202.01 or 24.202.08. The position of these valves is adequately tested during the pump and valve test.

HPCI and RCIC Barometric Condenser Outlet Drain Valves (E4100F025/F026, E5150F004/F005)

There is no practical testing method to determine obturator open and closed other than normal monitoring of the barometric condenser vacuum tank level alarm. There are test connections that could allow pressurization of these valves using plant air or P11 water however it involves distractions to operators in the field and control room in addition to dose and contamination concerns. In addition, since the HPCI and RCIC condensate pumps inject back into the suction side of the pumps, a different valve line up would be required to open the inboard valve so an operator could watch water flow into the floor drain. Also, an observation of the floor drains would involve an operator working close to the turbine while it is in operation. The following position will be used rather than creating a special test:

These valve pairs modulate open and closed as required to occasionally drain down the vacuum tanks during stand-by. As noted above, once the turbines are in operation, the condensate flow from the vacuum tanks is pushed forward to the suction side of each pump; not to the floor drains.

If these valves were not positioning as indicated in the control room, eventually an alarm (1063 or 2066) would be received which would alert operators of a problem. Also, these valves are stroke timed and receive remote position indication testing. Based on this position, no specific test steps will be added to 24.202.01, 24.202.08, or 24.206.01 to document an obturator verification test (OVO/OVC).

Technical Position TP-19 Page 1 of 2 Mandatory Appendix V 1 Purpose The purpose of this Technical Position is to establish the Fermi 1ST Program position on crediting Appendix V required pump testing for those pumps with Licensing Basis differential pressure or discharge pressure at their highest design basis accident flow rate, during the Comprehensive or Group A pump tests.

Applicability This Technical Position is applicable to the following 1ST Program pumps:

Pump Class Group Type Function Reciprocating C4103C001A 2 A Positive Standby Liquid Control Pump Displacement Reciprocating C4103C001B 2 A Positive Standby Liquid Control Pump Displacement E1102C002A 2 A Centrifugal Residual Heat Removal Pump A E1102C002B 2 A Centrifugal Residual Heat Removal Pump B E1102C002C 2 A Centrifugal Residual Heat Removal Pump C E1102C002D 2 A Centrifugal Residual Heat Removal Pump D Vertical Line E1151C001A 3 A RHR Service Water Pump A Shaft Centrifugal Vertical Line E1151C001B 3 A RHR Service Water Pump B Shaft Centrifugal Vertical Line E1151C001C 3 A RHR Service Water Pump C Shaft Centrifugal Vertical Line E1151C001D 3 A RHR Service Water Pump D Shaft Centrifugal E2101C001A 2 B Centrifugal Core Spray Pump A E2101C001B 2 B Centrifugal Core Spray Pump B E2101C001C 2 B Centrifugal Core Spray Pump C E2101C001D 2 B Centrifugal Core Spray Pump D E4101C001A 2 A Centrifugal High Pressure Core Spray Main Pump E5101C001 2 B Centrifugal Reactor Core Isolation Cooling Pump

Technical Position TP-19 Page 2 of 2

Background

The OM Code, 2012 Edition requires the adoption of Division 1, Mandatory Appendix V, Pump Periodic Verification Test Program. This is required per Section ISTB-1400, Owner's Responsibility which states "In addition to the requirements of paragraph ISTA-1500, the Owner's responsibility includes", paragraph (d), which states "establishing a pump periodic verification test program in accordance with Division 1, Mandatory Appendix V".

This testing is only required for those pumps specifically defined within the Mandatory Appendix V.

Purpose This Mandatory Appendix establishes the requirements for implementing a pump periodic verification test. As discussed in ISTB-1400, the Owner shall establish a pump periodic verification test program for certain applicable pumps that are tested in accordance with paragraph ISTA-1100.

Definitions

  • Pump Periodic Verification Test 2 A test that verifies a pump can meet the required (differential or discharge) pressure as applicable, at its highest design basis accident flow rate.

2 A pump may have several design basis post-accident operating points due to different system configurations or single vs. parallel pump operation. Reference ASME OM Standard, Part 28, Standard for Performance Testing of Systems in Light-Water Reactor Power Plants, for additional information on testing of power plant systems.

Position Footnote 1 of Mandatory Appendix V states "This Mandatory Appendix contains requirements to augment the rules of Subsection ISTB, lnservice Testing of Pumps in Light Water Reactor Nuclear Power Plants. The Owner is not required to perform a pump periodic verification test, if the design basis accident flow rate in the Owner's safety analysis is bounded by the comprehensive pump test or Group A test."

Summary For the aforementioned 1ST pumps, Footnote 1 is satisfied. All of these pump's Licensing Basis differential pressure or discharge pressure at their highest design basis accident flow rates are met within their associated Comprehensive or Group A surveillance tests, which in turn eliminates the requirement of performing a separate surveillance test to satisfy Mandatory Appendix V.