ML100630051

Submittal of IST Program Relief Requests for Pumps and Valves - Third Ten-Year Interval - Request for Additional Information

ML100630051
Person / Time
Site:	Fermi
Issue date:	03/03/2010
From:	Mahesh Chawla Plant Licensing Branch III
To:	Hassoun A DTE Energy
chawla M, ADRO/DORL, 415-8371
References
TAC ME2557
Download: ML100630051 (2)

Text

From: Chawla, Mahesh Sent: Wednesday, March 03, 2010 5:29 PM To: Alan I Hassoun Cc: McMurtray, Anthony; Beckford, Kaydian; Farnan, Michael; Pascarelli, Robert

Subject:

Fermi 2 - Submittal of IST Program Relief Requests for Pumps and Valves -

Third Ten-year Interval - Request for Additional Information - ME 2557 By letter dated November 3, 2009 (ADAMS Accession No. ML093140302), Detroit Edison (licensee) requested approval of alternative testing associated with the inservice testing (IST) program third 10-year interval for Fermi 2. The Nuclear Regulatory Commission (NRC) staff is reviewing the submittal and has the following questions:

Request VRR-012 Revision 0:

Brief summation of Fermi 2 alternative request VRR-012:

1) Applicable ASME OM Code Requirement is ISTC-3700 Position Verification Testing which states: Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated. Where practicable, this local observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. These observations need not be concurrent. Where local observation is not possible, other indications shall be used for verification of valve operation.

2) Request VRR-012 includes 32 solenoid operated category A containment isolation valves.

The design of these valves is such that the coil position is internal to the valve body and not observable in either the energized or de-energized state. The method used to verify position verification involves pressurizing the containment penetration volume to approximately 55 psig, and verifying the penetration remains pressurized while the valve is indicating closed on the main control room board. The valve is then opened using the control switch in the main control room. A decrease in pressure is then verified along with valve position indicating open in the main control room.

3) In 1996, Fermi received approval to implement 10CFR50 Appendix J - Primary Reactor Containment Leakage Testing For Water-Cooled Power Reactors Option B. Option B is a performance based requirement that allows leakage testing to be extended out as far as 60 months.

4) Fermi desires to perform position verification testing for the 32 listed solenoid containment isolation valves in conjunction with 10CFR50 Appendix J Option B test frequencies.

Justification for extending the 2 year position verification frequency to an Option B program frequency include:

A) Radiation exposure and Operations/Test personnel time/labor involved will be significantly reduced.

B) Subject solenoid valves are exercised on a quarterly or refueling frequency and their stroke times are measured and compared to ASME OM Code acceptance criteria. By performing quarterly valve exercising and performance of position verification and seat

leakage test in accordance with 10CFR50 Appendix J Option B, an adequate assessment of valve health may be determined.

C) Solenoid valves are subject to Preventive Maintenance program coverage.

D) Many solenoid valves are periodically replaced to satisfy EQ program criteria NRC Request for Additional Information:

RAI #1 The Fermi 2 proposed request VRR-012 and justification is lacking specifics and does not shed much light on how the alternative testing will provide an acceptable level of quality and safety. It appears that the only benefit is the reduction in time/labor and ALARA savings. Please explain how much radiation dose would be saved should the alternative testing be approved to a 3 cycle interval.

RAI #2 It was stated that the 32 category A solenoid valves are exercised quarterly or at a refueling frequency and that their stroke times were measured and compared to ASME OM Code acceptance criteria. The stroke timing coupled with position verification testing and leakage testing provides a means for adequately assessing valve health. Stroke test acceptance criteria for solenoid valves can be found in ASME OM Code - 2004 Section ISTC-5152 which states:

Test results shall be compared to reference values established in accordance with ISTC-3300, ISTC-3310, or ISTC-3320.

(a) Valves with reference stroke times of greater than 10 seconds shall exhibit no more than +/-25% change in stroke time when compared to the reference value.

(b) Valves with reference stroke times of less than or equal to 10 seconds shall exhibit no more than +/-50% change in stroke time when compared to the reference value.

(c) Valves that stroke in less than 2 seconds may be exempted from ISTC-5152(b). In such cases the maximum limiting stroke time shall be 2 seconds.

Fermi 2 request VRR-012 Attachment 1 details a typical solenoid valve arrangement that is representative of the 32 category A solenoid valves. After review of attachment 1, it is assumed that the stroke time acceptance band would be applicable to section ISTC-5152(c), valve strokes in less than 2 seconds. Please confirm the solenoid stroke time and explain how the stroke time data is tracked and trended for degradation. Please provide a sample of historical stroke time data for all 32 subject solenoid valves in support of your response. Also please include maintenance history and overall performance data, including position verification and seat leakage testing results, for all 32 subject solenoid valves in support of your response.

RAI #3 It was stated that the 32 category A solenoid valves are subject to the Preventive Maintenance (PM) program. Please explain what preventive measures are performed on the 32 category A solenoid valves. Please include in your explanation the PM task intervals and a sample of historical PM tasks completed for the 32 category A solenoid valves.

RAI #4 It was stated that some of the 32 category A solenoid valves were part of the EQ program and that they were on a periodic replacement interval. Please identify which valves are EQ, their replacement interval and when they were last replaced.

Please arrange a teleconference to discuss the above information with the staff.

Mahesh Chawla Phone: 301-415-8371 Fax: 301-415-1222 mahesh.chawla@nrc.gov E-mail Properties Mail Envelope Properties ()

Subject:

Fermi 2 - Submittal of IST Program Relief Requests for Pumps and Valves -

Third Ten-year Interval - Request for Additional Information - ME 2557 Sent Date: 3/3/2010 5:19:23 PM Received Date: 3/3/2010 5:28:00 PM From: Chawla, Mahesh Created By: Mahesh.Chawla@nrc.gov Recipients:

hassouna@dteenergy.com (Alan I Hassoun)

Tracking Status: None Anthony.McMurtray@nrc.gov (McMurtray, Anthony)

Tracking Status: None Kaydian.Beckford@nrc.gov (Beckford, Kaydian)

Tracking Status: None Michael.Farnan@nrc.gov (Farnan, Michael)

Tracking Status: None Robert.Pascarelli@nrc.gov (Pascarelli, Robert)

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 17554 3/3/2010 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: