NRC-87-0253, Provides Justification for Deferral of Testing for Eight motor-operated Valves Until Spring 1988 Local Leak Rate Test Outage,Per 871003 Commitment Re IE Bulletin 85-003, Motor-Operated Valves Common Mode Failure During Plant..

Provides Justification for Deferral of Testing for Eight motor-operated Valves Until Spring 1988 Local Leak Rate Test Outage,Per 871003 Commitment Re IE Bulletin 85-003, Motor-Operated Valves Common Mode Failure During Plant..

ML20236Y629
Person / Time
Site:	Fermi
Issue date:	12/09/1987
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-87-0253, CON-NRC-87-253 IEB-85-003, IEB-85-3, NUDOCS 8712140175
Download: ML20236Y629 (3)

Text

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4 B. Ralph Sylvia Group Wce President Detroit 6

=r-Ec ison =400NorthDioeHighway December 9,1987 tE-87-0253 1

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

References:

1) Fermi 2 NIC Docket No. 50-341 NIC License No. NPF-43

2) Detroit Tilison Letter to NIC, " Readiness for Restart," dated 0 tober 3,1987 l'

3) NEDC-31322, BWR Owner's Group Report on Operational Design Basis of Selected Safety-Related Motor Operated Valves

Subject:

T_es._tlpa of Eight Additional MOV's Usino MOVATS Detroit Fdison Letter (Reference 2, Attachnent E.8) provided updated status pertaining to TE Bulletin 85-03 " Motor Operaterl Valves Comnon Mode Failures During Plant Transient Due to Tmproper Switch Settings". In the subject response Detroit Fdison committErl to test eight additional MOV's during the last quarter of 1987.

Based on the attached technical justification and alditional commitments on Preventive Maintenance, Detroit Edison proposes to test these eight valves with the remaining valves during the 1988 Spring LLIC Outage.

Tf you have any questions regarding this matter, please contact Mr. Lewis Bregni at (313) 586-4072.

Sincerely, fh -

Enclosure cc: Mr. A. B. Davis Mr. E. G. Greenman Mr. W. G. Rogers .0 Mr. J. J. Stefano }0 \

USTE Region TIT 8712140175 871209 PDR ADOCK 05000341 O PDR

Enclosure to l

IEC-87-0253 Page l i

l JUSTIFICATION FOR DEFERRING MOVA'IS VALVE TESI'ItG During the October 5,1987 meeting with the NIC to discuss the Fermi 2 restart, Detroit Edison committed to schdule aM cowlete the 757 never-cowleted, safety-significant PMs identified, in Reference 2, prior to startup following the 1988 Spring LLRT Outage. In order to accoglish this activity, various equipnent divisional outages will be needed. This process requires timely planning and schduling for various time-dependent ICOs.

Based on conflicting operability requirements and the high priority and inportance placed on conpletion of these PMs, performing MOVATS testing during the same period is not prmtical. In order to perform l MOVATS testing for four (4) valves in t!' IPCI system and an additional four (4) in the ICIC system, divisional outages, different from the PM divisional outages, would be required. The MOVATS divisional outages would be longer and inprt the PM work, thereby not allowing completion c.' the PM commitment on time.

Detroit Edison has tested ten (10) MOVs to date. Those tested did meet the criteria established using IE Bulletin 85-03. For one of the ten valves tested, the motor operator was replaced based on operator sizing criteria. The ten valves tested were safety-significant, active valves. Based on these results, Detroit Edison is confident that the remaining twenty-three (23) valves will also meet the criteria established by IE Bulletin 85-03. Deferring the testing of these eight (8) valves will not impact the overall MOVATS test program conpletion schedule. MOVATS testing will still be completcd by the end of the Spring 1988 LLRT Outage.

In applying the selection criteria specified in IE Bulletin 85-03 and NEDC-31322 dated September 1986, "BWR Owner 's Group Report on the Operational Design Basis of Selected Safety-Related Motor-Operated Valves" (Reference 3) to the twenty-three (23) untested notor operated valves, only one (1) ICIC aM two (2) HPCI system valves are classified as high differential pressure valves with active, safety-related functions. These valves are:

E4150F012 HPCI Minimum Flow Bypass  ;

Isolation Valve "

Normal Position: Closed Safety Function: Close E4150F001 IPCI Steam Admission Valves 1 Normal Position: Closed Safety Function: Open i E5150F045 ICIC Steam Admission Valve Normal Position: Closed Safety Function: Open/Close

Enclosure to NBC-87-0253 Page 2 E4150F012 (HPCI Mininum Flow Bypass Isolation Valve) will not substantially inpact system operation should the valve fail to operate. The HPCI pump is designed for high pressure and does not need the'mininum flow capability to perform its safety injection function. For an auto-initiatica response to a. transient event, injection begins within 30 seconds of an actuation signal. The HPCI discharge valve required to open has passed MOVATS testing and is expected to operate as designed. The operability of this valve is ,

additionally verified during required surveillance testing of the IPCI system. If the HPCI mini flow valve does not fully close, there is enough flow produced by the HPCI pump to provide adequate flow to the reactor.

Both E5150F045 (EIC Steam Mmission) and E4150F001 (HPCI Steam Admission) have demonstrated high reliability in operational testing which represents conparable differential pressure conditions to those required by Bulletin 85-03. Deferring the testing of these valves to 1988 Spring ILRT Outage, therefore, does not compromise the interded safety function of the HPCI and EIC systems.  !

l There are five (5) additional valves classified as high differential  !

pressure valves for Bulletin 85-03 testing. These valves are defined l to have non-active, safety-related functions per report NEDC-31322 ard l Fermi 2 specific design. The valves were evaluated in the report to  ;

have an extremely low probability of changing position during a transient event. Due to the significant involvement by Detroit Edison in preparing the BWR Owner's Group report, this evaluation applies to the Fermi 2 specific design. The valves include four (4) test line valves (2 each for HPCI and EIC) and the TIC Turbine Throttle valve.

Other factors which support testing these valves with these remaining to be tested during the ILRT outage include: j

1. MOVATS personnel will only need to be on site once (during LLRT outage).

2. Detroit M ison program for motor-operated valve testing will be i implemented.

3. The additional time will allow the valve and motor operator manufacturers, Detroit Edison, and MOVATS to establish acceptance criteria prior to testing and allow for a more thorough evaluation to reduce the potential for error.

Based on the above information, Detroit Mison proposes to test the remaining twenty-three (23) valves during the 1988 Spring ILRT j outage, l

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