NRC-23-0056, Inservice Testing (IST) Program for the Fourth 10-Year Inspection Interval

Inservice Testing (IST) Program for the Fourth 10-Year Inspection Interval

ML23243A978
Person / Time
Site:	Fermi
Issue date:	08/31/2023
From:	Frank E DTE Electric Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-23-0056
Download: ML23243A978 (1)

Text

DTE Electric Company 6400 N. Dixie Highway Newport, MI 48166 DTE August 31, 2023 10 CFR 50.55a NRC-23-0056 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Fermi Unit 2 Inservice Testing (IST) Program for the Fourth 10-Year Inspection Interval In accordance with the American Society of Mechanical Engineers (ASME) OM Code, Section ISTA General Requirements, 2012 Edition, attached for your information is a copy of the Fermi 2 IST Program for the Fourth 10-Year Interval. The Fourth 10-Year Interval IST Program Plan complies with the requirements of the ASME Section ISTA-3120 2012 Code Edition. The Fourth 10-Year Interval began on February 17, 2020, and concludes on February 16, 2030. The IST Program plan was originally sent to the Fermis NRC Project Manager via e-mail on 10/18/2021 to comply 10 CFR 50.55a(f)(7). This submittal is being made to the Document Control Desk to allow the Fourth 10-Year Interval IST Program Plan to be retrievable through the Agencywide Documents Access and Management System (ADAMS).

No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact me at (734) 586-4772.

Sincerely, Eric Frank Manager - Nuclear Licensing

Enclosure:

IST Program Plan cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III

Enclosure to NRC-23-0056 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 IST Program Plan

DSN:IST Program Description , Rev.4 , Page 1 of 16 DTE Energy - Fermi 2 Inservice Testing Program Fourth Ten-Year Interval Fermi 2 Nuclear Operations Center 6400 N. Dixie Highway Newport, Michigan 48166 Date of Commercial Operation 23-1988 Fourth Interval Start - February 17, 2020 Revised per LCR 20-045-151.

APPROVALS:

QUAL Jeffrey D. Auler, e55603, see attached email.

Prepared By: PE-03 r@

1ST Program Manager Craig Shepherd, e55018, see attached email.

Reviewed By: -===============--- Date: ...1-18 1- -..... 1 PE-03 rgj Qualified Program Engineer James Wines, e54431, see attached email.

Date: ~111_81_2_1- ~ NIA Reviewed By:

...!:::::===============-----

Supervisor Performance Engineering Randy Breymaier, e50801, see attached I A pprove d B y: *1

..!e=m=a=1=.=============--- Date: ....1_18_12_1_ _..... NIA Manager Performance Engineering Date*. 11/19/21 C oncurrence By: -=================-

Mark D. Wilson, CA1702, see attached email

. NIA ANH INFORMATION AND PROCEDURES DSN: 1ST Program Description Rev: 4 Date: 1/25/21 DTC: TMPLAN File: 1715.04 Recipient: _ _ _ _ _ __

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

1ST PROGRAM PLAN PART l Page 1

DSN:IST Program Description, Rev.4, Page 2 of 16 1ST Program Plan Description 1ST PROGRAM PLAN MASTER INDEX Part 1 IST Program Description DSN: IST Program Description Part 2 IST Pump Testing Program DSN: IST Pump Testing Program Part 3 IST Pump Scope Table DSN: IST Pump Scope Table Part 4 IST Valve Testing Program DSN: IST Valve Testing Program Part 5 IST Valve Scope Table DSN: IST Valve Scope Table Part 6 IST Check Valve Condition Monitoring Plans DSN: IST CVCM Plans Part 7 IST Program Relief Requests DSN: IST Program Relief Requests Part 8 IST Program Cold Shutdown Justifications DSN: IST Program CSJ Part 9 IST Program Refueling Outage Justifications DSN: IST Program ROJ Part 10 IST Program Technical Positions DSN: IST Program Tech Positions Part 11 IST Program Valve Basis DSN: IST Program Valve Basis Part 12 IST Program Pump Basis DSN: IST Program Pump Basis PROGRAM PLAN TABLE OF CONTENTS PART 1 1ST Program Description 1.1 Purpose 1.2 Scope 1.3 Requirements 1.4 Plant Systems 1.5 Test Intervals PART 2 1ST Pump Testing Program 1.1 Pump Inservice Testing Plan Description 1.2 Pump Plan Table Description 1.3 Measurement of Test Quantities 1.4 Allowable Ranges of Test Quantities 1.5 Instrument Accuracy 1.6 Reference Values

1. 7 Applicable Code Cases 1.8 Mandatory Appendix V PART 3 1ST Pump Scope Table PART 4 1ST Valve Testing Program 1.0 Inservice Testing Plan for Valves 2.0 IST Exam Definitions 3.0 MOV Program 4.0 Applicable Code Cases PART 5 1ST Valve Scope Table 1ST PROGRAM PLAN PART 1 Page 2

DSN:IST Program Description, Rev.4, Page 3 of 16 PART 6 1ST Check Valve Condition Monitoring Plans CMJNo. Description CMJ-01 RHR Service Water Return Checks CMJ-02 Standby Liquid Control CIV Checks CMJ-03 RHR Min Flow Checks CMJ-04 Core Spray Pump Discharge Checks CMJ-05 Core Spray Pump Min Flow Checks CMJ-06 HPCI Booster Pump Suction Checks CMJ-07 EECW Return/ RCIC Pump Suction Checks CMJ-08 EECW Pump Discharge Checks CMJ-09 HPCI Turbine / RCIC Pump Min Flow Checks CMJ-10 HPCI I RCIC Turbine Exhaust Checks CMJ-11 EECW Nozzle Checks CMJ-12 Nitrogen Inerting Checks CMJ-13 LPCI Injection Checks CMJ-14 RBCCW I CCHVAC Checks CMJ-15 EESW Min Flow Checks CMJ-16 RCIC Pump Discharge Check CMJ-17 Core Spray Injection Checks CMJ-18 EDG Starting Air Receiver Checks PART 7 1ST Program Relief Requests 7.1 DTE Relief Request Submittals 7.2 NRC Safety Evaluation Reports PART 8 1ST Program Cold Shutdown Justifications 8.1 CSJ Index 8.2 Cold Shutdown Justifications PART 9 1ST Program Refueling Outage Justifications 9.1 ROJ Index 9.2 Refueling Outage Justifications PART 10 1ST Program Technical Positions 10.1 Technical Positions Index 10.2 Fermi 2 IST Program Technical Positions PART 11 1ST Program Valve Basis 11.1 Plant Equipment Identification with IST scoping basis PART 12 1ST Program Pump Basis 12.1 Plant Equipment Identification with IST scoping basis 1ST PROGRAM PLAN PART 1 Page 3

DSN:IST Program Description, Rev.4, Page 4 of 16 1ST Program Plan Description 1.1 Purpose To provide requirements for the performance and administration of assessing the operational readiness of those pumps and valves whose specific functions are required to either:

Shutdown the reactor to the safe shutdown condition, and/or Maintain the safe shutdown condition, and/or To mitigate the consequences of an accident.

Fermi 2 was designed and licensed to operate with the Hot Shutdown condition (Mode

3) defined as the "safe" shutdown condition. Since Safe Shutdown is defined in the Fermi 2 licensing basis as the hot shutdown condition, inservice testing of components which are required to achieve cold shutdown is unwarranted. However, decay heat removal is an important safety function that must be accomplished or core damage could result. Although the RHR shutdown cooling subsystem does not meet a specific criterion of 10 CFR 50.36( c)(2)(ii), it is identified as a significant contributor to risk reduction. For the purposes ofIST scoping the term "Safe Shutdown" will be conservatively defined as a Cold Shutdown condition (Mode 4). All components necessary to achieve and maintain a Cold Shutdown condition will be included within the IST scope. OM ISTB-3420 and ISTC-3570 require IST Program testing to remain current unless a System is in a mode where it is not required to be operable. Systems must be tested within 3 months ofretuming to operable status. For Systems with requirements to remain operable during Modes 4 and 5, IST Program testing must commence prior to Mode 4. Reference TS 3.5.2.7 (CARD 20-27489) as an example.

The Fermi 2 Inservice Testing Program (IST) is required by 10CFR50.55a including applicable OM Code Conditions. Fermi 2 used the following guidance documents in developing the IST Program:

• System Design Basis Documents

• ISI Program Boundary Drawings

• Technical Specifications

• Technical Requirements Manual UFSAR

• NUREG-1482 Revision 2, Guidelines for Inservice Testing at Nuclear Power Plants" 1ST PROGRAM PLAN PART 1 Page 4

DSN:IST Program Description, Rev.4, Page 5 of 16 The Fermi 2 Fourth 120-month interval Pump and Valve Inservice Testing Plan will be in effect as follows:

Begin: 02/17/2020 End: 02/16/2030 The key features of this Plan are: the Pump and Valve table listings, Relief Requests, Refueling Outage Justifications, Cold Shutdown Justifications, Check Valve Condition Monitoring Plans, Technical Positions, and the Program Scoping Basis document. The component level basis information and testing data is maintained within the Iddeal software. The 2012 Edition of the ASME OM Code defines all scoping and classification requirements.

Grace for IST testing is 25% for periods specified as fewer than 2 years and 6 months for periods equal to or greater than 2 years per Code Case OMN-20.

The IST Program Interval history is as follows:

First Interval (Start 1/23/1988)

Second Interval (Start 2/17/2000)

Third Interval (Start 2/17/2010)

Fourth Interval (Start 2/17/2020)

The second interval started approximately twelve years after the start of the first interval. The extension was due to a 389 day extended outage for a main turbine blade failure and an elective 1 year extension. This extension follows the OM Code sections ISTA-3120 (d) and (e). No additional interval extensions can be applied in the future without NRC approval.

1.2 Scope The IST program plan has been prepared to meet the requirements of the American Society of Mechanical Engineers (ASME) OM Code 2012 Edition. Mandatory Appendix I, II, III, and V. As noted above, modification of the OM Code requirements is made as applicable by following the conditions listed in IOCFR 50.55a.

The IST Program Plan provides a complete listing of those pumps and valves included in the program per the requirements of the following:

ASME OM Code 2012, Subsection ISTA, "General Requirements" ISTA contains the requirements directly applicable to inservice testing including the Owner's Responsibility and Records Requirements.

ASME OM Code 2012, Subsection ISTB, "Inservice Testing ofPumps in Light-Water Reactor Nuclear Power Plants" 1ST PROGRAM PLAN PART 1 Page 5

DSN:IST Program Description, Rev.4, Page 6 of 16 ISTB establishes the requirements for inservice testing of pumps in light-water reactor nuclear power plants. The pumps covered are those provided with an emergency power source, which are required in the shutting down the reactor to the safe shutdown condition, in maintaining the safe shutdown condition, and/or in mitigation of the consequences of an accident.

ASME OM Code 2012, Subsection ISTC, "Inservice Testing of Valves in Light-Water Reactor Nuclear Power Plants" ISTC establishes the requirements for inservice testing of valves in light-water reactor nuclear power plants. The valves covered include those which provide overpressure protection and those which are required to perform a specific function, either actively through the changing of valve obturator position or passively by maintaining required obturator position in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident.

ASME OM Code 2012, Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants" ISTD establishes the requirements for inservice testing of snubbers in light-water reactor nuclear power plants including the Owner's Responsibility and Records Requirements. The Snubber Program is managed outside of the IST Program as an independent program.

ASME OM Code 2012, Mandatory Appendix I, "Inservice Testing ofPressure ReliefDevices in Light-Water Reactor Nuclear Power Plants" Provides the requirements for performance testing and monitoring of nuclear plant pressure relief devices. Methods, intervals, and record requirements for monitoring and testing are established, as well as guidelines for the evaluation of results. The Appendix applies to safety valves, safety relief valves, pilot-operated pressure relief valves, power-actuated pressure relief valves, nonreclosing pressure relief devices and vacuum relief devices, including all accessories and appurtenances.

ASME OM Code 2012, Mandatory Appendix II, "Check Valve Condition Monitoring Program" Provides an alternative to the testing or examination requirements ofISTC-3510 through ISTC-5221. The purpose of this program is both to improve valve performance and to optimize testing, examination, and preventive maintenance activities to maintain the continued acceptable performance of a select group of check valves.

ASME OM Code 2012, Mandatory Appendix III, "Preservice and Inservice Testing of Active Electric Motor Operated Valve Assemblies in Light-Water Reactor Power Plants" 1ST PROGRAM PLAN PART 1 Page 6

DSN:IST Program Description, Rev.4, Page 7 of 16 The purpose of this program is to establish the requirements for preservice and inservice testing of motor operated valves.

ASME OM Code 2012, Mandatory Appendix V, "Pump Periodic Verification Test Program" The purpose of this program is to establish the requirements for implementing a pump periodic verification test for certain pumps with specific design basis accident flow rates in Technical Specifications, Technical Requirements, or updated safety analysis report. The test verifies that a pump can meet the required pressure as applicable, at the highest design basis accident flow rate.

1ST PROGRAM PLAN PART 1 Page 7

DSN:IST Program Description, Rev.4, Page 8 of 16 1.3 Requirements 1.3.1 The IST Plan is implemented through the performance of implementing procedures to satisfy testing requirements identified for each component in the program.

1.3 .2 The acceptability of component performance is determined by comparison to the identified acceptance criteria contained in the implementing procedure.

That acceptance criteria are derived from Technical Specifications and ASME Code requirements.

1.3 .3 Periodic review of selected performance data associated with pumps and valves is performed for trending purposes.

1.3.4 Maintenance activities are reviewed to determine the impact on the performance of the IST Program pumps and valves.

1.3.5 The content of the IST Plan is revised as necessary during the interval due to Code edition upgrade, design changes or program enhancements.

1.3.6 Applicable changes to implementing test procedures are reviewed to ensure IST Plan compliance.

1.3.7 Component performance anomalies are analyzed, and input provided for program resolution.

1.4 Plant Systems Plant systems are identified by a single alphabetic character followed by two numeric characters. The list below identifies the three character system identifiers and system names included in the In-service Testing Program for Pumps and Valves. Plant drawing 6M721-5808 identifies the individual ISI boundary drawings for each system.

Plant Identification System (PIS) Codes for Plant Systems B21 - PIS Number for the Nuclear Boiler System B31 - PIS Number for the Reactor Recirculation System Cl I - PIS Number for the Control Rod Drive System C41 - PIS Number for the Standby Liquid Control System CS I - PIS Number for the Neutron Monitoring System El I - PIS Number for the Residual Heat Removal System E21 - PIS Number for the Core Spray System 1ST PROGRAM PLAN PART 1 Page 8

DSN:IST Program Description, Rev.4, Page 9 of 16 E41 - PIS Number for the High Pressure Coolant Injection System ES I - PIS Number for the Reactor Core Isolation Cooling System G 11 - PIS Number for the Radwaste System G33 - PIS Number for the Reactor Water Cleanup System G41 - PIS Number for the Fuel Pool Cooling and Cleanup System G51 - PIS Number for the Torus Water Management System NI 1 - PIS Number for the Main Steam Supply System N21 - PIS Number for the Feedwater System Pl I - PIS Number for the Condensate Storage and Transfer System P34 - PIS Number for the Post Accident Sampling System P42 - PIS Number for the Reactor Building Closed Cooling Water System P44 - PIS Number for the Emergency Equipment Cooling Water System P45 - PIS Number for the Emergency Equipment Service Water System PSO - PIS Number for the Station and Control Air System R30 - PIS Number for the Diesel Generator System T23 - PIS Number for the Primary Containment System T41 - PIS Number for the RBHVAC & CCHVAC Systems T46 - PIS Number for the Standby Gas Treatment System T48 - PIS Number for the Containment Atmosphere Control System T49 - PIS Number for the Primary Containment Pneumatic System TSO - PIS Number for the Primary Containment Atmosphere Monitoring System 1ST PROGRAM PLAN PART 1 Page 9

DSN:IST Program Description, Rev.4, Page 10 of 16 1.5 Test Intervals The following table lists the codes that may be used in the valve tables to describe the intervals at which various tests are performed IST Exam Interval table Frequency Frequency in Code Days (app.) Frequency Description Q 92 Quarterly RO 550 Reactor Refuel cs NIA Cold Shutdown AppJ NIA Per Appendix J Option B 2Y 732 2 Years App3 NIA Per Appendix III MOV PM frequencies 6M 183 183 Days SY 1825 5 Years 6Y 2190 6 Years IOY 3652 10 Years CM Varies Check Valve Condition Monitoring Frequency 3Y 1100 3 Years 3C 2190 6 Years based on two-year cycle 1ST PROGRAM PLAN PART 1 Page 10

DSN:IST Program Description, Rev.4, Page 11 of 16 Jeffrey D Auler From: Craig E Shepherd Sent: Friday, January 8, 2021 12:39 PM To: Jeffrey D Auler

Subject:

Approvals, 1ST Program Description To: Jeff Auler, 1ST Program Manager I have reviewed and approved the following OTC DSN Revision Approval TM PLAN 1ST Program 4 Reviewer:

Description Craig Shepherd I also authorize any page renumbering required by inclusion of this email within the overall document as required per NSI P-20-0005.

Regards, Craig Shepherd 1

DSN:IST Program Description, Rev.4, Page 12 of 16 Jeffrey D Auler From: Jeffrey D Auler Sent: Friday, January 8, 2021 1:15 PM To: Jeffrey D Auler

Subject:

1ST Program Description I have prepared and approve the following OTC DSN Revision Approval TM PLAN 1ST Program 4 Preparer:

Description Jeffrey D. Auler /s/

I also authorize any page renumbering required by inclusion of this email within the overall document as required per NSI P-20-0005.

Regards, Jeffrey D. Auler 1

DSN:IST Program Description , Rev.4, Page 13 of 16 Jeffrey D Auler From: James D Wines Sent: Monday, January 11, 2021 3:48 PM To: Jeffrey D Auler Cc: Randy D Breymaier

Subject:

FW: Program Description Attachments: 1ST Program Plan Part 1 Program Description.pdf I have reviewed and approve the following as the Supervisor - Programs Engineering OTC DSN Revision Approval TMPLAN 1ST Program 4 Reviewed by or Description Approved by:

I also authorize any page renumbering required by inclusion of this email within the overall document as required per NSIP-20-0005.

James Wines I Supervisor- Nuclear Engineering (Programs)

Phone: 734.586.1701 I Text : 734.625.3154 I Pager: 734.227.0076 I eMail: James.Wines@dteenergy.com 1

DSN:IST Program Description , Rev.4, Page 14 of 16 Jeffrey D Auler From: Mark D Wilson Sent: Tuesday, January 19, 2021 7:43 AM To: Jeffrey D Auler

Subject:

RE: ANII signature for 1ST Program Parts

Jeff, I have reviewed and concur as the ANII with the following Revision to the 1ST Program:

OTC DSN Revision Approval TM PLAN 1ST Program 4 Concurred by: Mark D.

Description Wilson -ANII /s/

Mark D. Wilson, ANII The Hartford Steam Boiler Inspection and Insurance Company From: Jeffrey D Auler <jeffrey.auler@dteenergy.com>

Sent: Wednesday, January 13, 2021 9:45 AM To: Mark D Wilson <mark.wilson@dteenergy.com>

Subject:

ANII signature for 1ST Program Parts Mark, I placed a copy of 1ST Program Parts 1, 3, 5, 7, 11, and 12 into the Y: temp folder under your name.

Part 1 is the only cover page that requires a signature however I put all the documents in the drop box for you for reference .

These documents have been reviewed by Craig Shepherd, the Licensing Engineer, Jim, and Randy. I would have attached the signature emails but Randy filled his out incorrectly.

Please send back the following:

I have reviewed and concur as the ANII - Programs Engineering OTC DSN Revision Approval TM PLAN 1ST Program 4 Concurred by: Mark D.

Description Wilson -ANII /s/

1

DSN:IST Program Description, Rev.4, Page 15 of 16 I also authorize any page renumbering required by inclusion of this email within the overall document as required per NSI P-20-0005.

Regards, Mark D. Wilson 2

DSN:IST Program Description, Rev.4, Page 16 of 16 Jeffrey D Auler From: Randy D Breymaier Sent: Friday, January 15, 2021 1:54 PM To: Jeffrey D Auler

Subject:

Approval of program description (part 1)

I have reviewed and approve the following as Manager, Engineering Programs OTC DSN Revision Approval TM PLAN 1ST Program 4 Manager Approval Description Randy Breymaier /s/

I also authorize any page renumbering required by inclusion of this email within the overall document as required per NSI P-20-0005.

Randy Breymaier Manager Performance Engineering 734 586-1811 1