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| {{#Wiki_filter:200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 JAFP-21-0073 August 9, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 | | {{#Wiki_filter:}} |
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| ==Subject:==
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| Response to Request for Additional Information Regarding Application to Revise the James A. FitzPatrick Nuclear Power Plant Limiting Condition for Operation (LCO) 3.5.1, ECCS - Operating Surveillance Requirement (SR) 3.5.1.6
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| ==References:==
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| : 1. Letter from David T. Gudger (Exelon Generation Company, LLC) to U.S.
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| Nuclear Regulatory Commission, Application to Revise Surveillance Requirement (SR) 3.5.1.6 dated December 11, 2020.
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| : 2. Letter from David T. Gudger (Exelon Generation Company, LLC) to U.S.
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| Nuclear Regulatory Commission, Supplement to Application to Revise Surveillance Requirement (SR) 3.5.1.6 dated February 18, 2021 (EPID L-2020-LLA-0269).
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| : 3. Electronic Mail from Justin Poole (Nuclear Regulatory Commission) to Christian Williams (Exelon Generation Company, LLC) Request for Additional Information Regarding FitzPatrick Amendment Request to Modify SR 3.5.1.6 (EPID L-2020-LLA-0269) dated July 1, 2021.
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| By {{letter dated|date=December 11, 2020|text=letter dated December 11, 2020}} (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a license amendment request to revise the James A. FitzPatrick Nuclear Power Plant Technical Specifications Limiting Condition for Operation (LCO) 3.5.1, "ECCS -
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| Operating" Surveillance Requirement (SR) 3.5.1.6.
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| By {{letter dated|date=February 18, 2021|text=letter dated February 18, 2021}} (Reference 2), Exelon supplemented this request as requested by the Nuclear Regulatory Commission (NRC).
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| By electronic mail dated July 1, 2021 (Reference 3), the NRC requested additional information that was necessary to complete its review.
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| Response to Request for Additional Information Regarding Application to Revise the James A. FitzPatrick Nuclear Power Plant Limiting Condition for Operation (LCO) 3.5.1, ECCS - Operating Surveillance Requirement (SR) 3.5.1.6 August 9, 2021 Page 2 to this letter contains the NRC's requests for additional information (RAIs) followed by the Exelon response. Additional supporting detail for the response to RAI 4 is provided in Attachments 2, 3(a), 3(b), 3(c) and 3(d).
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| Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in References 1 and
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| : 2. The information attached to this letter does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.
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| Furthermore, the information attached to this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
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| There are no commitments contained in this response.
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| If you should have any questions regarding this submittal, please contact Christian Williams at 610-765-5729.
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| I declare under penalty of perjury that the foregoing is true and correct. Executed on the 9th day of August 2021.
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| Respectfully, David T. Gudger Senior Manager, Licensing Exelon Generation Company, LLC Attachments: 1. NRC Request for Additional Information and Detailed Response
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| : 2. Diagnostic Testing Schedule and History 3(a) Maintenance History 2MOV-53A, Reactor Water Recirculation Pump Discharge Isolation Valve (A) 3(b) Maintenance History 2MOV-53A OP, Reactor Water Recirculation Pump Discharge Isolation Valve (A) OPERATOR 3(c) Maintenance History 2MOV-53B, Reactor Water Recirculation Pump Discharge Isolation Valve (B) 3(d) Maintenance History 2MOV-53B OP, Reactor Water Recirculation Pump Discharge Isolation Valve (B) OPERATOR cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector - JAF NRC Project Manager, NRR - JAF A. L. Peterson, NYSERDA
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| ATTACHMENT 1 NRC Request for Additional Information and Detailed Response Request for Additional Information And Detailed Response Page 1 of 4 Request For Additional Information and Detailed Response
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| ===Background===
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| By {{letter dated|date=December 11, 2020|text=letter dated December 11, 2020}} (Reference 1), as supplemented by {{letter dated|date=February 18, 2021|text=letter dated February 18, 2021}} (Reference 2), Exelon Generation Company, LLC (Exelon) submitted a license amendment request for James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The proposed amendment request would revise Technical Specification (TS) Limited Condition for Operation (LCO) 3.5.1 ECCS - Operating Surveillance Requirement (SR) 3.5.1.6 from Once each startup prior to exceeding 25% RTP, as modified by a Note stating Not required to be performed if performed within the previous 31 days to 24 months.
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| The NRC made requests for additional information (RAI) in an email dated July 1, 2021 (Reference 3). The additional information requests and the Exelon responses are provided below.
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| ===RAI-1===
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| The LAR proposes to change SR 3.5.1.6. The proposed change eliminates the notation of Not required to be performed if performed within the previous 31 days and changes the specified frequency from Once each startup prior to exceeding 25% RTP to 24 months.
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| Please explain the reason to modify SR 3.5.1.6 to require a frequency of 24-month instead of In accordance with the INSERVICE TESTING PROGRAM, which is specified in TSTF-545, TS Inservice Testing [IST] Program & Clarify SR Usage Rule Application to Section 5.5 Testing.
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| Response to RAI-1 The frequency of this SR was not In accordance with the Inservice Testing Program.
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| TSTF-545 affected SRs with a frequency that was In accordance with the Inservice Testing Program. As such, the frequency of SR 3.5.1.6 is not within the scope of the SRs affected by TSTF-545.
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| The proposed frequency of 24 months is, however, consistent with the license amendment submitted by Detroit Edison Fermi 2 on March 23, 1999 and approved by the NRC on May 25, 1999 (ML020720643) which allowed the licensee to revise the frequency from once every startup (which included start-ups from mid-cycle outages) to a frequency consistent with that licensees refueling cycle thus eliminating the unnecessary cycling during a startup from mid-cycle outages.
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| Further, maintaining the FitzPatrick SR 3.5.6.1 frequency independent of the Inservice Testing program is consistent with the current ITS SR 3.5.6.1 frequency which is also independent of the Inservice Testing Program.
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| Request for Additional Information And Detailed Response Page 2 of 4
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| ===RAI-2===
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| The proposed FitzPatrick LAR text of the SURVEILLANCE statement in SR 3.5.1.6 remains the same as Verify each recirculation pump discharge valve cycles through one complete cycle of full travel or is de-energized in the closed position. The NRC staff is concerned with potential unintended consequences of this proposed change as written. The Bases for SR 3.5.1.6 states, in part, that Cycling the recirculation pump discharge valves through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will close when required.
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| The proposed change does not appear to provide reasonable assurance that periodic cycling of the valve will be completed due to the portion of the SR which would state or is de-energized in the closed position. Satisfaction of the current proposed wording could be a simple turn of the electric breaker to the off position and then back to the on position when the valve is in the closed position.
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| Please explain why the portion of the SR which would state or is de-energized in the closed position is needed because the valves will be required to be stroked in accordance with the IST Program. In addition, please clarify the mismatch between the requirements of SR 3.5.1.6 and its Bases.
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| Response to RAI-2 The proposed change does not change the manner in which the valves are tested as required by the FitzPatrick IST Program. The change only alters the frequency at which the valves are required to cycled as required by SR 3.5.1.6 from an event based frequency to a time based frequency. IST and MOV program requirements are not superseded or bypassed by this change.
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| As stated in the Exelon {{letter dated|date=February 18, 2021|text=letter dated February 18, 2021}} Supplement to Application to Revise Surveillance Requirement (SR) 3.5.1.6 (Reference 2) the valves will continue to be tested in the same manner that they have been tested under the current frequency. The only difference being the elimination of the wear and tear of the valves by performing unnecessary mid-cycle testing and potentially delaying the restart of the unit which is contrary to the guidance in ISTC-3521(g) which states: valve exercising during cold shutdowns shall commence within 48 hours of achieving cold shutdown and continue until all testing is complete or the plant is ready to return to operation at power.
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| The Technical Specifications (TS) Bases for SR 3.5.1.6 states that the valve safety function is to close upon an automatic initiation of the LPCI subsystem. Cycling the valve through one complete cycle ensures that the valve is not mechanically bound and able to close when required. The statement, or is de-energized in the closed position exempts from the SR valves which are inoperable and are required to be de-energized in the closed position. The intent of this statement is to allow an inoperable isolation valve to remain secured in the actuated position by de-energizing the associated breaker thus meeting the intent, as described in the Bases, of the SR. It is understood that prior to restoring an inoperable valve to service, all SRs shall be completed including SR 3.5.1.6.
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| FitzPatrick Surveillance Testing is scheduled and executed as informed by both the TS SR as well as the TS Bases for that SR and therefore, in practice, there is no mismatch between the requirements of SR 3.5.1.6 and its Bases.
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| Request for Additional Information And Detailed Response Page 3 of 4 During the conversion from the FitzPatrick custom TS (CTS) to ITS (Amendment 274),
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| FitzPatrick stated that in order to meet TS 3.5.1 requirements, inoperable isolation valves would not only to be closed but de-energized. It was further clarified that requiring the inoperable reactor water recirculation pump discharge valve to be de-energized in the closed position represents an additional restriction on plant operations. The following excerpt is from Table M of the NRC SER dated July 3, 2002.
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| M10 CTS 3.5.A.5 requires all recirculation pump discharge valves to be Operable prior to reactor startup (or closed if permitted elsewhere in these specifications). ITS 3.5.1 and associated SR 3.5.1.6 also require all recirculation pump discharge valves to be Operable. However, if this requirement cannot be met, then ITS SR 3.5.1.6 allows the associated recirculation pump discharge valve to be de-energized in the closed position.
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| Requiring the inoperable recirculation pump discharge valve to also be de-energized in the closed position represents an additional restriction on plant operation. This change is necessary to ensure the flow path for the associated LPCI subsystem.
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| ===RAI-3===
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| The proposed change references a precedent relating to a request made by the licensee of the Fermi 2 nuclear power plant in 1999. The Fermi 2 licensee requested to change its SR 4.4.1.1.1 to remove the notation that the surveillance is only required if it has not been performed within the last 31 days, and then to require that each pump discharge valve is OPERABLE by cycling each valve through at least one complete cycle of full travel at least once per 18 months. The request for the Fermi 2 nuclear power plant does not appear to be the same as the request for the FitzPatrick nuclear power plant. The NRC staff is unclear regarding the basis for referencing the Fermi 2 request in the FitzPatrick LAR.
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| Please clarify the basis for referencing the Fermi 2 request in the FitzPatrick LAR.
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| Response to RAI-3 Exelon believes that the reference to the Fermi 2 license amendment is directly applicable to this submittal.
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| As stated in response to RAI-1, Fermi submitted a license amendment on March 23, 1999 which proposed to modify Technical Specifications (TS) 4.4.1.1.1 (the equivalent surveillance as FitzPatricks SR 3.5.1.6). The Fermi 2 proposed change was identical to the proposed FitzPatrick change with the only difference being the number of months in each licensees operating cycle (18-months vs 24-months). By replacing the once every startup requirement with a fixed frequency, the footnote stating if not performed within the previous 31 days became unnecessary. This is re-stated at the top of page 2 of the NRC SER dated May 25, 1999. The statement reads: The licensee proposed to revise the frequency of SR 4.4.1.1.1 to once per 18 months. With this change the
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| * footnote would be unnecessary, and it would be deleted from the SR Request for Additional Information And Detailed Response Page 4 of 4 This precedent demonstrates an equivalent approval in which the licensee received NRC approval to move this requirement from event based to time based with the time between valve cycles being determined by the length of the operating cycle. Effectively, both applications eliminate the requirement to cycle the valves during mid-cycle outages thus minimizing unnecessary wear and tear on the valve and operator.
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| ===RAI-4===
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| The LAR provides a brief list of prior testing of motor-operated valves (MOVs) 053A and 053B, which appears to be stroke-time testing. The LAR also mentions that these valves are periodically tested under the MOV testing program established in accordance with Generic Letter 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves, dated September 18, 1996.
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| Please discuss the past historical performance of these valves with respect to how Fitzpatrick is meeting the requirements of 10 CFR 50.55a(b)(3)(ii). Historical performance should include the type of testing performed and any maintenance or modifications that may have been completed.
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| RESPONSE TO RAI-4.
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| The Reactor Water Recirculation pump discharge isolation valves, 02-2MOV-53A and 02-2MOV-53B, and associated operators are in scope of the FitzPatrick MOV Program as established in accordance with Generic Letter 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves, dated September 18, 1996. Diagnostic testing of these valves, as required by the MOV program is currently scheduled for performance on a four year interval beginning in September 2022.
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| These valves have a LOW Risk Rank and based on the most recent performances in 2020, both valves are characterized as having HIGH Margin. As such diagnostic testing is bound by the program MAXIMUM interval of 10 years. A discussion of the diagnostic testing results from the past three performances is provided in Attachment 2.
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| Historically, valve diagnostic testing was performed consistent with the MOV program requirement of every six (6) years. A more detailed maintenance history for the subject MOVs is provided in Attachments 3(a), 3(b), 3(c) and 3(d). The Program required maximum interval is 10 years. Neither the MOV program required interval of ten (10) years, nor the current scheduled interval of four (4) years will be affected by revising the SR from an event based frequency to a time based frequency. In the event that future diagnostic testing indicates the need for a shorter interval for MOV program required testing, the SR frequency of 24 months will continue to support a reduced interval.
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| The interval required for diagnostic testing is established based on risk and diagnostic test margin. The limits established for stroke time testing are in accordance with the design basis and will not be changed as part of this request. All MOV and IST Program requirements remain in place with this change as do all commitments made regarding these valves.
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| ==REFERENCES:==
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| : 1. Letter from David T. Gudger (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, Application to Revise Surveillance Requirement (SR) 3.5.1.6 dated December 11, 2020.
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| : 2. Letter from David T. Gudger (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, Supplement to Application to Revise Surveillance Requirement (SR) 3.5.1.6 dated February 18, 2021 (EPID L-2020-LLA-0269) ," dated February 18, 2021.
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| : 3. Electronic Mail from Justin Poole (NRC Project Manager) to Christian Williams (Exelon)
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| Request for Additional Information Regarding FitzPatrick Amendment Request to Modify SR 3.5.1.6 (EPID L-2020-LLA-0269) dated July 1, 2021
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| Attachment 2 Diagnostic Testing Schedule and History
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| Attachment 2 Diagnostic Testing Schedule and History The following information is provided to illustrate diagnostic testing has been completed in accordance with program requirements and that the testing results support the proposed frequency change to SR 3.5.1.6 from event based to time based 02-2MOV-53A:
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| Completed:
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| * 2014: Diagnostic test performed
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| * 2018: As-Found and As-Left test, including Rotation check performed
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| * 2020 As-Left test, including Rotation check. All criteria SAT.
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| Upcoming:
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| * 2022 Scheduled motor replacement and As-Left diagnostic
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| * 2024 Commitment letter for diagnostic and rotation check
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| * 2028 Commitment letter for diagnostic and rotation check Discussion:
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| MOV has been diagnostically tested in 2018 and 2020 RFOs as part of the response to Anchor/Darling Part 21, including rotation checks of the stem to ensure stem to upper wedge integrity. The last diagnostic test results show the MOV to have high margin (> 10%). This MOV is scheduled to be tested again 2022 RFO as PMT following a motor replacement as EOC from the February 2020 motor failure of the 53B MOV. Additionally, this MOV is scheduled for diagnostic testing, including rotation checks, in 2024 and 2028 RFOs. Following that series of tests, the MOV Engineering will review MOV performance history, diagnostic test margin, and PRA risk ranking to establish an appropriate PM/PVT interval in association with MOV Program guidance.
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| 02-2MOV-53B:
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| Completed:
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| * 2014 Diagnostic test performed
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| * 2018 As-Found and As-Left, including Rotation check performed
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| * 2020 (mid-cycle, Feb) - motor replacement and As-Left diagnostic performed
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| * 2020 Refueling Outage (RFO) As-Left test including Rotation check performed Upcoming:
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| * 2024 Commitment letter for diagnostic and rotation check
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| * 2028 Commitment letter for diagnostic and rotation check Discussion:
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| MOV was diagnostically tested in 2018 RFO as part of the response to Anchor/Darling Part 21, including rotation check of the stem to ensure stem to upper wedge integrity. In February of 2020 this MOV failed to stroke due to a failed motor. The motor was replaced and the MOV was diagnostically tested SAT as PMT. In the 2020 RFO, the MOV was diagnostically tested, including rotation check, as part of the Commitment response to the Anchor/Darling Part 21.
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| The result of the most recent diagnostic test show the MOV has high margin (> 10%).
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| Additionally, this MOV is scheduled for diagnostic testing, including rotation checks, in 2024 and 2028 RFOs. Following that series of tests, the MOV Engineering will review MOV performance history, diagnostic test margin, and PRA risk ranking to establish an appropriate PM/PVT interval in association with MOV Program guidance.
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| Attachment 3(a)
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| Maintenance History 2MOV-53A, Reactor Water Recirculation Pump Discharge Isolation Valve (A)
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| Attachment 3(a) Maintenance History 2MOV-53A, Reactor Water Recirculation Pump Discharge Isolation Valve (A)
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| Diagnostic Complete WO WO description Due Date WO comments Testing Date AS FOUND - SAT WORK PERFORMED - TORQUED CHECK ON BOTTOM 04854937-01 REPACK 02-2MOV-53A YES N/A 9/17/2020 PACKING NUTS. REPACKED OF STUFFING BOX & TORQUED TO 200 FT / LB PM - TORQUE CHECK 04880203-01 9/14/2020 9/17/2020 AS FOUND - N/A WORK PERFORMED ON WO 4854937-02 PACKING AS FOUND SYSTEM CONDITIONS: IDENTIFIED COMPONENT 02-2MOV-53A DRAIN LINES AS FOUND EQUIPMENT C-PF 2MOV-53A - CUT CONDITIONS: MORE WATER THAN EXPECTED. WORK 80468249-01 / CAP / REMOVE BODY N/A 9/26/2018 PERFORMED: CUT THE DRAIN LINES AND CAPPED PER THE DRAIN LINES WORK INSTRUCTIONS. REOVED EXCESS PIPE AND THE SPRING CAN HANGER. QV. INSPECTED SAT.
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| AS FOUND: AS EXPECTED , SAT. EJ 9-14-18 AS LEFT:
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| (OPCC) PM - TORQUE REFORMED PROCEDURE STEPS, TORQUE CHECK, SAT. EJ 9-04653256-01 CHECK PACKING 02- 2/6/2019 9/14/2018 14-18 COMMENTS: TOP PACKING GLAND IS BOTTOMED OUT.
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| 2MOV-53A RECOMMEND REPACK NEXT OUTAGE.
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| REMOVED INSULATION. COMPLETED WELDS 1,2,3 WITH 2:1 EOC PERFORM 2:1 PROFIILE OVERLAYS. PERFORMED VT+ PT FINAL ON FIELD 80466201-01 SOCKET WELD N/A 2/3/2017 WELDS 1,2 +3. SAT. WELD MAP REVISED PER FIELD BUILDUPS CONDITIONS.
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| NDE- PT and Final VT-W of Welds #1,2,3,4,5,6. First 6 Socket joints (EXTENT OF CONDITION) coming off of "A" Recirc pump on Line # 02-3-3/4"-WH-1504-28A.
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| 80465584-01 VENT PIPE OVERLAY OF N/A 1/28/2017 EC-69139. MT and PT SAT. COMPELTED WELDS 1,2,3,4,5,6 TO 02-2MOV-53A SATISFY WELD OVERLAY PROFILES REQUIRED.
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| PM - TORQUE CHECK UTC: M-1190 TORQUE WRENCH CHECKOUT 1/17/17, RETURN 82606942-01 9/13/2016 1/17/2017 PACKING 1/17/17 NONE TORQUED PER VPDS AND ALL SAT Performed visual weld inspection on all 3/4" bonnet vent line socket PERFORM VISUAL welds. All socket welds meet ASME III NDE visual requirements. No 80465233-01 INSPECTION AT 02-2MOV- N/A 1/17/2017 visual indication of service induced degradation. NDE Rpt #
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| 53A ON 3/4" VENT LINES B17PT016 PM - TORQUE CHECK COMPLETED CHECKING TORQUE OF PACKING. ADMIN CLOSE 82471549-01 10/9/2014 9/13/2014 PACKING TO 52377637-01 PM - TORQUE CHECK 82290112-01 10/7/2012 9/24/2012 PERFORMED PACKING TORQUE. ALL SAT.
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| PACKING PM - TORQUE CHECK Verified packing torque valves per valve packing data sheet, two 81690512-01 10/2/2010 9/13/2010 PACKING flats movement PM - TORQUE CHECK WALKDOWN COMPLETE PACKING CHECK AND 81194252-01 10/17/2008 10/2/2008 PACKING CONSOLIDATED PER PACKING DATA SHEETS.
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| Attachment 3(b)
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| Maintenance History 2MOV-53A OP, Reactor Water Recirculation Pump Discharge Isolation Valve (A) OPERATOR
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| Attachment 3(b) Maintenance History 2MOV-53A OP, Reactor Water Recirculation Pump Discharge Isolation Valve (A)
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| OPERATOR Diagnostic Complete WO WO description Due Date WO comments Testing Date PM - MINOR PREVENTIVE 04880673-01 9/15/2020 9/29/2020 ADMIN CLOSE (to Major PM)
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| MAINTENANCE PM - INSPECT AS FOUND - FAILURE CRITERIA ON GROUP B MOTOR WAS-04833580-01 MAGNESIUM ROTOR IN 9/10/2020 9/28/2020 DISCOVERED, CORROSION OF COOLING FINS. AS LEFT - AR MOV MOTOR. WRITTEN TO REPLACE MOTOR NEXT OUTAGE AR#04370093.
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| PM MAJOR PREVENTIVE AS FOUND: CONDITION WAS AS EXPECTED. AS LEFT:
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| 04887382-01 MAINTENANCE ON 02- 10/4/2020 9/19/2020 CONDITION IS SAT 2MOV-53A(OP)
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| AS FOUND: VALVE ACTUATOR CONDITIONS AS EXPECTED AS LEFT: PM COMPLETED SAT, ALL RESULTS AS EXPECTED.
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| PM - MINOR PREVENTIVE 04644748-01 1/17/2019 9/15/2018 GOOD WORKING CONDITION COMMENTS: ALL SAT MAINTENANCE EVERYTHING IN GOOD WORKING ORDER, GREASE AND COMPONENTS LOOK AS EXPECTED MINOR PM COMPLETE WITH EXCEPTION OF POST - MAINT STROKE (5.20) OPS CONTACTED AND WAITING FOR CALL BACK AS OF 01/17/17 16:20 - ND - 16:50 OPS CANNOT PM - MINOR PREVENTIVE SUPPORT STROKE - ND NO MT AND E USED OR NEEDED FOR 82606593-01 9/11/2016 1/17/2017 MAINTENANCE MINOR PM - ALL SAT PER EN-MA-141. STROKE WILL BE PERFORMED UNDER WO 52606942-02 AND WO 52606938-01 PRIOR TO START UP. VALVE WILL BE STROKED UNDER ST-27A.
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| PM - MINOR PREVENTIVE Admin close --- creditted by performance of major PM 52467955-01--
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| 82467955-01 MAINTENANCE PER MP- 9/22/2014 9/13/2014 13-14 059.51 PM- MAJOR PREVENTIVE 82377634-01 MAINTENANCE ON 02- 9/30/2014 9/13/2014 Performed PM per 0.59.51. ALL SAT 2MOV-53A(OP)
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| DIAGNOSTIC TESTING OF Performed as-found test. Torque switch was found preloaded. Pulled 82288863-01 LIMITORQUE OPERATOR Yes 10/1/2014 9/13/2014 torque switch and set to 1+1 and reinstalled. Performed as-left test -
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| AS FOUND AS LEFT adjusted torque switch. Restored actuator.
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| PM - STEM LUBE AND EVERYTHING FOUND TO BE SAT. FALL PROTECTION WAS 82285061-01 GEARCASE GREASE 9/12/2012 9/22/2012 REQUIRED TO CLEAN & LUBRICATE THE STEM CHECK PM - STEM LUBE AND Cleaned all grease off stem and regreased with MOV Lamb Life 81690511-01 GEARCASE GREASE 10/2/2010 9/13/2010 Grease, all SAT 9/13/10 CHECK PM - INSPECT 81689195-01 MAGNESIUM ROTOR IN 10/6/2010 9/13/2010 Boroscope Inspection - SAT MOV MOTOR.
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| AS FOUND BASELINE, PM 81695764-01 OPERATOR, AS LEFT YES 10/30/2010 2008 Credited to WO 81194251 and 81193648 in 2008, no issues noted.
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| BASELINE
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| Attachment 3(c)
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| Maintenance History 2MOV-53B, Reactor Water Recirculation Pump Discharge Isolation Valve (B)
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| Attachment 3(c) Maintenance History 2MOV-53B, Reactor Water Recirculation Pump Discharge Isolation Valve (B)
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| Complete WO WO description PM Due Date WO comments Date PM - TORQUE CHECK 04888246-01 10/6/2020 9/17/2020 WORK PERFORMED ON WO# 04854938-01 PACKING 04854938-01 REPACK 02-2MOV-53B N/A 9/17/2020 Torque Checked Middle & Bottom and Repacked & torqued Top As Found: Top packing gland is bottomed out. No sign of leakage.
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| (OPCC) PM - TORQUE As Left: Top packing gland is still bottomed out. All else SAT. Top 04652723-01 CHECK PACKING 02- 2/5/2019 9/13/2018 packing gland is bottomed out. Recommend repack next outage.
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| 2MOV-53B Also got about 1/2 flat movement on middle follower. All SAT.
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| COMPLETED WELD 2,3,4 PER WELD MAP, NEEDS FINAL (EXTENT OF CONDITION)
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| VISUAL FROM CRAFT. COMPLETED WELDS 1,5,6 PER WELD 80465598-01 VENT PIPE OVERLAY OF N/A 1/31/2017 MAP, BOUGHT OFF BY NDE. FINAL VT-WELDS 1,2,3,4,5 +6-SAT 02-2MOV-53B PT WELDS 1,2,3,4,5 + 6- SAT.
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| PM - TORQUE CHECK 82607299-01 9/15/2016 1/17/2017 ALL SATISFACTORY.
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| PACKING Performed visual weld inspection on all 3/4" bonnet vent line socket PERFORM VISUAL welds. All socket welds meet ASME III NDE visual requirements. No 80465234-01 INSPECTION AT 02-2MOV- N/A 1/17/2017 visual indication of service induced degradation. NDE Rpt #
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| 53B 0N 3/4" VENT LINES B17PT019 PM - TORQUE CHECK Performed torque check on packing on valve 02-2MOV53B per work 82469011-01 9/27/2014 9/12/2014 PACKING instructions.
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| PRE-JOB BRIEF. PICK UP NEEDED TOOLS & NEVER SIEZE PM - TORQUE CHECK CHECK IN AT DRYWELL CHECK POINT. WENT IN DRYWELL 80290630-01 9/5/2013 9/22/2012 PACKING WITH ENGINEER TO VALVE AND PERFORMED STEPS 4.1 THRU 4.11 PM - TORQUE CHECK 81690825-01 PACKING ON 02-2MOV- 9/16/2012 10/1/2010 Performed torque check of packing per this work order SAT.
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| 53B.
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| PM - TORQUE CHECK WALKDOWN COMPLETE CONDUCTED TORQUE CHECH OF 81194175-01 10/24/2008 10/3/2008 PACKING PACKING- SAT.
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| Attachment 3(d)
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| Maintenance History 2MOV-53B OP, Reactor Water Recirculation Pump Discharge Isolation Valve (B) OPERATOR
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| Attachment 3(d) Maintenance History 2MOV-53B OP, Reactor Water Recirculation Pump Discharge Isolation Valve (B)
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| OPERATOR Diagnostic Complete WO WO description Due Date WO comments Testing Date AS FOUND - MOTOR FAILED MEGGER AND OHM READINGS.
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| 80424890-02 REPLACE MOV MOTOR Yes 2/4/2020 DAY SHIFT REMOVED OLD MOTOR, PLACED NEW MOTOR ON MOV. RETERMED AND BUMPED.
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| MINOR PM - STAND AS FOUND, SAT LUBE WAS GOOD. AS LEFT, BETTER THAN 05010799-01 ALONE STEM LUBE PER 2/3/2022 9/19/2020 FOUND LUBE WAS STILL GOOD.
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| MP-059.51 work is complete PERFORMED Minor Preventive Maintenance on 02-2MOV-53B per steps in MP-059.51. Stem was cleaned and PM - MINOR PREVENTIVE 04879739-01 9/13/2020 2/3/2020 greased with mov long life grease, utc# 606130. As left condition is MAINTENANCE satisfactory Also cleaned limit switch, finger bases, all internals of limit torque to satisfy AR# 04314832 PM - MINOR PREVENTIVE As Expected, SAT. Inspection Completed SAT Minor PM performed.
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| 04647478-01 1/25/2019 9/13/2018 MAINTENANCE All SAT DIAGNOSTIC TESTING As Found: SAT as to be expected. As Left: Complete and restored.
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| 04761997-01 AND STEM ROTATION N/A 9/13/2018 Work Performed: Stem rotation check, AF test complete.
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| CHECK PM - MINOR PREVENTIVE 82606594-01 9/11/2016 1/25/2017 This package is close out to major PM package WO-00426645-01 MAINTENANCE FWC All SAT, OPS indication and alarm SAT, COMPLETE UTC E-1150 - CHECK OUT 17-17 / RETURN 17-17 UTC E-2082-PM- MAJOR PREVENTIVE 80426645-01 10/4/2018 1/17/2017 CHECK OUT 17-17 / RETURN 17-17 UTC G-15006 -
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| MAINTENANCE CHECK OUT 17-17 / RETURN 17-17 Performed PM per EN-MA-141 PM - MINOR PREVENTIVE Performed minor preventive maintenance on 02-2MOV53B(op) 82470534-01 MAINTENANCE PER MP- 10/3/2014 9/12/2014 using MP-059.51 Limitorque Actuators inspection and lubrication 059.51 SAT DIAGNOSTIC TESTING OF PERFORMED AS LEFT VIPER TEST. ALL DATA IS WITHIN 82288865-01 LIMITORQUE OPERATOR Yes 10/1/2014 9/11/2014 VIPER CRITERIA AS FOUND AS LEFT DUE TO THE SPACE RESTRICTIONS WHEN REMOVING LIMIT SWITCH COVER ROTOR #4 WAS CRACKED. ROTOR WAS MAJOR PREVENTIVE REPLACED PER MP-059.51. MAJOR PM PER MP-059.51 WAS MAINTENANCE PER MP-82288864-01 10/1/2012 10/3/2012 PERFORMED. WOS 29630-02 AND 52288699-01 WERE TAKEN 059.51, LIMITORQUE TO FINISHED AS THIS TASK COVERED THEM. CORRECTION ACTU TO ABOVE WO 290630-02 WAS TAKEN TO FINISHED.
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| COMPLETED TIME AND CURRENT PM - STEM LUBE AND no work performed. R20 WO 52288864-01 covered scope of this 82288699-01 GEARCASE GREASE 9/30/2012 10/3/2012 work therefore this task has been satified and go to FINISHED.
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| CHECK INSPECT MAGNESIUM performed broscope all SAT BOROSCOPE INSPECTION OF 80288735-01 ROTOR MOV MOTOR. N/A 9/21/2012 2MOV-53B MAG ROTOR SAT NO ISSUES IDENTIFIED BY MOV REPLACE IF REQUIRED ENGINEER PM - STEM LUBE AND 81690508-01 GEARCASE GREASE 10/2/2010 10/1/2010 Performed PM per MP-059.51 section 8.4 CHECK PM - INSPECT Performed boroscope of motor, unsat, changing motor in WO 81688897-01 MAGNESIUM ROTOR IN 10/4/2010 10/1/2010 51688897-02 PM Feedback: Based on boroscope, MOV MOV MOTOR. engineering is requiring motor be replaced.
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| PERFORM AS FOUND Initial Walkdown Complete. WORK WAS PERFORMED UNDER 81193646-01 AND AS LEFT BASELINE Yes 10/14/2008 10/2/2008 51193647-01. DOCUMENTATION IN MERLIN UNDER THAT WO.
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| TEST PER MP-59.36. EVA PM - PERIODIC PREV Initial Walkdown Complete COMPLETE PERFORMED PM IAW 81193647-01 MAINT - LIMITORQUE 10/6/2008 10/2/2008 PROCEDURE MP-059.51 RESULTS SAT.
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| ACTUATOR PM - Stem Lube and Initial Walkdown Complete COMPLETE NO WORK PERFORMED.
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| 81194174-01 Gearcase Grease Check 10/24/2008 10/2/2008 TAKE CREDIT ONLY WORK WAS PERFORMED UNDER WO (RWP) 51193647-01.}}
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