NRC-19-0047, Submittal of Valve Relief Requests for the Inservice Testing Program Fourth 10-Year Interval

Submittal of Valve Relief Requests for the Inservice Testing Program Fourth 10-Year Interval

ML19165A134
Person / Time
Site:	Fermi
Issue date:	06/14/2019
From:	Fessler P DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-19-0047
Download: ML19165A134 (33)

Text

Paul Fessler Senior Vice President and Chief Nuclear Officer DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4153 Fax: 734.586.1431 Email: paul.fessler@dteenergy.com June 14, 2019 10 CFR 50.55a NRC-19-0047 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:

Submittal of Valve Relief Requests for the Inservice Testing Program Fourth 10-Year Interval Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z), DTE Electric Company (DTE) hereby requests NRC approval of the following relief requests for the Fermi 2 Inservice Testing (IST) Program fourth 10-year interval, which begins on February 17, 2020 and ends on February 16, 2030.

VRR-004, Relief to Utilize Diagnostic Testing to Confirm Obturator Verification VRR-006, Alternative for Preservice Testing of Butterfly Valves VRR-007, Relief from Conducting Obturator Verification for Certain Power Operated Valves VRR-009, Alternative for Motor Operated Valve Preservice/Inservice Testing The enclosures to this letter provide details of each of the individual relief requests.

Relief requests VRR-004, VRR-006, VRR-007, and VRR-009 are new relief requests for Fermi 2.

DTE requests NRC approval of relief requests VRR-004, VRR-007, and VRR-009 by March 16, 2020 to support planned testing during the next refuel outage scheduled in the spring of 2020.

DTE requests NRC approval of relief request VRR-006 by February 16, 2020 such that the request is approved prior to beginning the fourth 10-year interval.

No new commitments are being made in this submittal.

USNRC NRC-19-0047 Page 2 Should you have any questions or require additional information, please contact Mr. Jason R. Haas, Manager -Nuclear Licensing, at (734) 586-1769.

Sincerely, Paul Fessler Senior Vice President and CNO

Enclosures:

1. Relief Request VRR-004 for the IST Fourth 10-Year Interval

2. Relief Request VRR-006 for the IST Fourth 10-Year Interval

3. Relief Request VRR-007 for the IST Fourth 10-Year Interval

4. Relief Request VRR-009 for the IST Fourth 10-Year Interval cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure 1 to NRC-19-0047 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request VRR-004 for the IST Fourth 10-Year Interval to NRC-19-0047 Page 1 10 CFR 50.55a Relief Request VRR-004 Relief to Utilize Diagnostic Testing to Confirm Obturator Verification Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

Alternative Results in Hardship Without a Compensating Increase in Quality and Safety

1. ASME Code Component(s) Affected The ASME code components affected by this relief request are listed in Attachment 1 to this Enclosure.

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda 10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication.

3. Applicable Code Requirement

ASME OM Code, 2012 Edition, Subsection ISTC-3700, Position Verification Testing, states that valves with remote position indicators shall be observed locally at least once every two years to verify that valve operation is accurately indicated. In addition, ISTC-3700 states that, where practicable, this local position indication observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position.

10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication, states that when implementing ASME Code, 2012 Edition, Subsection ISTC-3700, Position Verification Testing, licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation, to provide assurance of proper obturator position.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(2), relief is requested from the requirement of ASME OM Code ISTC-3700 and 10 CFR 50.55a(b)(3)(xi), for the subject valves. The basis of the relief request is that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

DTE is requesting to align the performance of obturator verification as required by 10 CFR 50.55a(b)(3)(xi) with the air operated valve (AOV) diagnostic test frequency of 10 years or less rather than with the position indication test frequency of ISTC-3700. Position indication testing will still be performed every two years in accordance with ISTC-3700.

to NRC-19-0047 Page 2 10 CFR 50.55a Relief Request VRR-004 Relief to Utilize Diagnostic Testing to Confirm Obturator Verification NRC Information Notice (IN) 2012-14, Motor-Operated Valve Inoperable Due to Stem-Disc Separation, (Reference 1) highlighted the need to supplement valve position indicating lights with other indications to provide assurance of proper obturator position. ASME Code, 2012 Edition, included requirements for the use of other indications to supplement position indicating lights in Subsection ISTC-3700 as practicable. For the purpose of this relief request, obturator verification is used to describe stem-to-disc attachment or integrity.

Techniques considered for obturator verification included flow testing, seat leakage testing, observation of pressure decay following unseating, and diagnostics.

In some cases, verification of obturator position through other indications would require establishment of complex testing schemes that would increase radiation dose exposure and potentially increase the risk to various systems and equipment. For other cases, diagnostics provides the only reliable means of obturator verification. An example is where the existing leakage test or process flow is unreliable because the valve orientation is flow under the seat (FUS). In the case of FUS, the plug/disc could lift and allow flow even when the stem and disc are not attached due to system or testing pressure. For other cases, use of diagnostics results in less plant/component impact than other potential methods while providing at least an equivalent level of quality and safety. An example is where an existing test would need to be created or significantly modified, such as when the existing leakage test boundary currently includes a group of valves.

Regardless of the specific case, obturator verification of each of the valves in Attachment 1 to this Enclosure presents hardship or difficulty without an increased level of quality and safety when compared to AOV diagnostic testing.

5. Proposed Alternative and Basis for Use The proposed alternative is to supplement valve position indication with AOV diagnostic testing at a frequency of 10 years or less.

A maximum frequency of 10 years is based on the frequency currently recommended in the OM Code (2017 Edition, Reference 2), Appendix IV for high safety significant valves. This is conservative since the valves associated with this relief request have been ranked by the Fermi 2 probabilistic safety assessment (PSA) as low safety significant valves. Mandatory Appendix III of the OM Code (2012 Edition) also includes a maximum frequency of 10 years for obturator verification.

The testing capability for each of the valves subject to this relief request were reviewed by the AOV Engineer using past AOV diagnostic data. It was determined that the unseating event can be monitored with gate valves in the open direction. Similarly, the back-seating event for globe valves can be detected in the open direction using AOV diagnostics.

to NRC-19-0047 Page 3 10 CFR 50.55a Relief Request VRR-004 Relief to Utilize Diagnostic Testing to Confirm Obturator Verification Use of AOV diagnostics is the only practical method to perform obturator verification either because of the current valve and piping configuration is not designed to support the use of a seat leakage test or process observations or because of the complexity of revising an existing leakage test. Attachment 1 provides a description of the various bases for the cases and identifies the basis that applies for each valve of this relief request. In all cases, the AOV diagnostics method will ensure obturator verification without increasing risk to the equipment and dose to personnel.

6. Duration of Proposed Alternative This proposed alternative will be utilized for the entire fourth 10-year interval. The fourth interval begins on February 17, 2020 and ends on February 16, 2030.

7. Precedent No precedent was identified for this relief request.

8. References

1. NRC Information Notice (IN) 2012-14, Motor-Operated Valve Inoperable Due to Stem-Disc Separation, dated July 24, 2012 (ML12150A046).

2. Division 1, Mandatory Appendix IV Preservice and Inservice Testing of Active Pneumatically Operated Valve Assemblies in Nuclear Reactor Power Plants (ASME OM-2017).

9. Attachments (1) Affected Components and Bases for Using AOV Diagnostics for Obturator Position Verification [6 pages]

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Valve ASME OM Valve Valve Manu- Flow Leak Identification Noun Description Code Valve Valve Model Basis Type1 facturer Direction2 Test (PIS) No. Class Category Reactor Recirculation (RR) A revision of the Control Rod Drive current leakage testing (CRD) Supply to procedure would be B3100F014A 2 A GL Rockwell 3624F316MMT FUS Individual Division 1 Inboard complex and increase Seal Cavity Inboard testing risk and dose Containment to test operators.

Isolation AOV RR CRD Supply to Division 2 Inboard B3100F014B Seal Cavity Inboard 2 A GL Rockwell 3624F316MMT FUS Individual Same as B3100F014A Containment Isolation AOV The local drain is not High Pressure visible for operators to Coolant Injection view flow. The drain (HPCI) Barometric line is in a congested /

Condenser high dose area next E4100F025 2 B GL Rockwell 3624GRIIMMT FOS None Condensate Outlet to the turbine. There is Floor Drain (FD) no practical method to Outboard Isolation use a leakage test to AOV perform obturator verification.

HPCI Barometric Condenser E4100F026 Condensate Outlet to 2 B GL Rockwell 3624GRIIMMT FOS None Same as E4100F025 FD Inboard Isolation AOV Page 1

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Valve ASME OM Valve Valve Manu- Flow Leak Identification Noun Description Code Valve Valve Model Basis Type1 facturer Direction2 Test (PIS) No. Class Category A test using the process flow will not HPCI Turbine validate stem to disc Exhaust Drain Pot integrity since flow is E4100F053 2 B GL Rockwell 3624MMLT2 FUS None Condensate Drain under the seat. No AOV test connections exist in the piping system to develop a leakage test.

A test using the Reactor Core process flow will not Isolation Cooling validate stem to disc (RCIC) Division 2 integrity since flow is Barometric under the seat. The E5150F005 Condenser 2 B GL Rockwell 3624GRIIMMT FUS None existing piping Condensate Pump to configuration is not Clean Radwaste suitable to develop a Outboard Drain leakage test to Isolation AOV pressurize air over the seat.

A test using the process flow will not validate stem to disc RCIC Division 1 integrity since flow is Steam Header Drain under the seat. The E5150F025 Pot to Condenser 2 B GL Flowserve D36124FJMMT2 FUS None test connection needed Inboard Drain to perform a leakage Isolation AOV test to pressurize air over the seat is blocked by a piping support.

Page 2

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Valve ASME OM Valve Valve Manu- Flow Leak Identification Noun Description Code Valve Valve Model Basis Type1 facturer Direction2 Test (PIS) No. Class Category A test using the process flow will not validate stem to disc integrity since flow is RCIC Division 2 under the seat. The Steam Header Drain current piping E5150F026 Pot to Condenser 2 B GL Rockwell 3624GRIIMMT FUS None configuration does not Outboard Drain have adequate Isolation AOV isolation valves and test connections to develop a leakage test to allow flow over the seat.

A complex leakage Non-Interruptable test would need to be Control Air Supply developed. This test P5000F403 3 B GL Rockwell 3624F316MMT FUS None (NIAS) Isolation would increase risk to AOV equipment and dose to test operators.

A revision of the current leakage testing procedure would be NIAS Station Air to complex and P5000F440 Control Air Isolation 3 A GA Powell 3003 WE FOS/Gate Group potentially increase AOV testing risk and dose exposure to test operators.

NIAS Station Air to P5000F441 Control Air Isolation 3 A GA Powell 3003 WE FOS/Gate Group Same as P5000F440 AOV Page 3

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Valve ASME OM Valve Valve Manu- Flow Leak Identification Noun Description Code Valve Valve Model Basis Type1 facturer Direction2 Test (PIS) No. Class Category Use of the process Containment flow or revision to the Atmospheric Control existing leakage test is (CAC) N2 Inerting to not practical to T4800F416 Vacuum Breaker 2 A GL Rockwell 3624MMT FUS Individual perform obturator Valve T23-F400A verification since the N2 Supply Isolation current flow direction AOV is under the seat.

CAC N2 Inerting to Vacuum Breaker T4800F417 Valve T23-F400B 2 A GL Rockwell 3624MMLT2 FUS Individual Same as T4800F416 N2 Supply Isolation AOV CAC N2 Inerting to Vacuum Breaker T4800F418 Valve T23-F400C 2 A GL Rockwell 3624MMLT2 FUS Individual Same as T4800F416 N2 Supply Isolation AOV CAC N2 Inerting to Vacuum Breaker T4800F419 Valve T23-F400D 2 A GL Rockwell 3624MMLT2 FUS Individual Same as T4800F416 N2 Supply Isolation AOV CAC N2 Inerting to Vacuum Breaker T4800F420 Valve T23-F400E 2 A GL Rockwell 3624MMLT2 FUS Individual Same as T4800F416 N2 Supply Isolation AOV Page 4

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Valve ASME OM Valve Valve Manu- Flow Leak Identification Noun Description Code Valve Valve Model Basis Type1 facturer Direction2 Test (PIS) No. Class Category CAC N2 Inerting to Vacuum Breaker T4800F421 Valve T23-F400F N2 2 A GL Rockwell 3624MMLT2 FUS Individual Same as T4800F416 Supply Isolation AOV A revision of the CAC N2 Inerting current leakage testing Drywell N2 Makeup procedure would be T4800F455 2 A GL Rockwell 3624MMT FOS/FUS Group Inboard Isolation complex and increase AOV testing risk and dose to test operators.

CAC N2 Inerting to Standby Gas Treatment System T4800F456 2 A GL Rockwell 3624MMT FOS Group Same as T4800F455 (SGTS) N2 Supply Bypass Isolation AOV CAC N2 Inerting to T4800F457 SGTS N2 Supply 2 A GL Rockwell 3624MMT FOS/FUS Group Same as T4800F455 Bypass AOV CAC N2 Inerting to T4800F458 SGTS N2 Supply 2 A GL Rockwell 3624MMT FUS Group Same as T4800F455 Bypass AOV A complex leakage Primary test would need to be Containment (PC) developed. This test T4901F467 Pneumatic Division 3 B GL Rockwell 3624MMT FUS None would increase risk to 1 NIAS Isolation equipment and dose to AOV test operators.

Page 5

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0047 (VRR-004)

Affected Components and Bases for Using AOV Diagnostics for Obturator Verification Valve ASME OM Valve Valve Manu- Flow Leak Identification Noun Description Code Valve Valve Model Basis Type1 facturer Direction2 Test (PIS) No. Class Category A revision of the PC Pneumatic current leakage testing Division 2 Supply procedure would be T4901F468 2 A GL Rockwell 3624MMLT2 FUS Group Outboard PC complex and increase Isolation AOV testing risk and dose to test operators.

Table Footnotes:

1: Valve types - GL = globe, GA = gate 2: Flow direction - FOS = flow over seat, FUS = flow under seat Page 6

Enclosure 2 to NRC-19-0047 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request VRR-006 for the IST Fourth 10-Year Interval to NRC-19-0047 Page 1 10 CFR 50.55a Relief Request VRR-006 Alternative for Preservice Testing of Butterfly Valves Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected Valve ASME OM Valve Plant Identification Noun Description Code Category Drawing (PIS) No. Class Containment Atmospheric Control T4803F601 (CAC) N2 Inerting Drywell Air 2 A M-5739-1 Purge Inlet Supply Valve CAC N2 Inerting Drywell Inboard T4803F602 2 A M-5737 Exhaust Isolation Valve

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda

3. Applicable Code Requirement

ASME OM Code Mandatory Appendix III, Preservice and Inservice Testing of Active Electric Motor Operated Valve Assemblies in Light-Water Reactor Power Plants, Section III-3200, Preservice Test, states that each Motor Operated Valve (MOV) shall be tested during the preservice test period or before implementing inservice testing. Section III-6100, Acceptance Criteria, states that [t]hrust, torque, or other measured engineering parameters correlated to thrust or torque consistent with [Paragraphs] III-6100 through III-6500, may be used to establish the acceptance criteria. Motor control center testing is acceptable if correlation with testing at the MOV has been established.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(1), relief is requested to deviate from OM-2012 Appendix III, Paragraph III-3200, which requires each MOV to be tested in accordance with the requirements of Appendix Paragraph III-6100 prior to implementation of inservice testing. The basis of the relief request is that the proposed alternative will provide an acceptable level of quality and safety.

Preservice testing that meets the requirements of Paragraph III-6100 has not yet been performed for these valves. This testing requires plant cold conditions. The next testing opportunity is the next refueling outage, which is scheduled for the spring of 2020 (vs. an Appendix III required implementation date of 2/17/2020).

to NRC-19-0047 Page 2 10 CFR 50.55a Relief Request VRR-006 Alternative for Preservice Testing of Butterfly Valves

5. Proposed Alternative and Basis for Use The proposed alternative is to measure torque during a static diagnostic test during the first refueling outage after Appendix III implementation for each valve. The first refueling outage is planned for the spring of 2020. This test will serve as the preservice test for each valve.

T4803F601 and T4803F602 are butterfly valves. T4803F601 and T4803F602 are not practicable to test under dynamic conditions. The valves are all Class A under the Joint Owners Group (JOG) Periodic Verification approach. Bearing degradation was addressed by applying the JOG threshold Coefficient of Friction (COF) to these valves.

Design basis testing for each valve to meet Generic Letter (GL) 89-10 requirements consisted of a diagnostic test conducted under static conditions. During GL 89-10 implementation, valve travel in both directions was interrupted by a limit switch. A torque switch was included in the control circuit. Torque measured at torque switch trip was corrected and compared to the minimum required torque under design basis conditions to demonstrate margin was available.

Subsequent to GL 89-10 testing, a plant modification was implemented to remove the torque switch from the valve control circuit for the listed valves. Thus, the original testing methodology of measuring torque at torque switch trip was no longer possible. Since the valves have significant margin between actuator capability and valve operating requirements, a combination of condition monitoring from periodic motor control center testing and local leak rate testing is used to monitor for valve / actuator degradation. While this practice provides acceptable monitoring of valve / actuator condition, it does not meet Appendix III Section 6100 requirements for acceptance criteria.

Motor control center testing, preventive maintenance activities, stroke timing and periodic exercising and leak rate testing have been conducted for these valves. No anomalies or adverse trends have been identified from the motor control center testing. Stroke times have been consistent. No adverse findings have been identified in the preventive maintenance activities. While some local leak rate results have necessitated corrective actions, the causes of the leakage were not related to actuator capability or valve operational capability. This provides confidence that these valves and actuators will remain capable of meeting design basis requirements until the preservice test is performed.

6. Duration of Proposed Alternative This proposed alternative will be utilized from the beginning of the fourth 10-year interval on February 17, 2020 until the end of the refueling outage in the spring of 2020. The testing to NRC-19-0047 Page 3 10 CFR 50.55a Relief Request VRR-006 Alternative for Preservice Testing of Butterfly Valves during the refueling outage in the spring of 2020 will then be used as the preservice testing for the duration of the fourth interval, which ends on February 16, 2030.

7. Precedent No precedent was identified for this relief request.

Enclosure 3 to NRC-19-0047 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request VRR-007 for the IST Fourth 10-Year Interval to NRC-19-0047 Page 1 10 CFR 50.55a Relief Request VRR-007 Relief from Conducting Obturator Verification for Certain Power Operated Valves Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

Alternative Results in Hardship Without a Compensating Increase in Quality and Safety

1. ASME Code Component(s) Affected The ASME code components affected by this relief request are listed in Attachment 1 to this Enclosure.

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda 10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication.

3. Applicable Code Requirement

ASME OM Code, 2012 Edition, Subsection ISTC-3700, Position Verification Testing, states that valves with remote position indicators shall be observed locally at least once every two years to verify that valve operation is accurately indicated. In addition, ISTC-3700 states that, where practicable, this local position indication observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position.

10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication, states that when implementing ASME Code, 2012 Edition, Subsection ISTC-3700, Position Verification Testing, licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation, to provide assurance of proper obturator position.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(2), relief is requested from 10CFR50.55a(b)(3)(xi), for the subject valves. The basis of the relief request is that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

NRC Information Notice (IN) 2012-14, Motor-Operated Valve Inoperable Due to Stem-Disc Separation, (Reference 1) highlighted the need to supplement valve position indicating lights with other indications to provide assurance of proper obturator position. ASME Code, 2012 Edition, included requirements for the use of other indications to supplement position to NRC-19-0047 Page 2 10 CFR 50.55a Relief Request VRR-007 Relief from Conducting Obturator Verification for Certain Power Operated Valves indicating lights in Subsection ISTC-3700 as practicable. 10CFR50.55a(b)(3)(xi) does not allow for exceptions for the use of other indications to supplement position indicating lights.

For the purpose of this relief request, obturator verification is used to describe stem-to-disc attachment or integrity. In addition, position indication testing in accordance will still be performed every two years in accordance with ISTC-3700.

Obturator verification of each of the valves in Attachment 1 to this Enclosure presents hardship or difficulty without an increased level of quality and safety. The specific hardship or difficult for each valve is provided in Attachment 1 to this Enclosure.

5. Proposed Alternative and Basis for Use The proposed alternative is to supplement valve position indication with other indications to provide assurance of proper obturator position except for those cases identified in this relief request where obturator verification is not necessary or results in a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Techniques considered for obturator verification included flow testing, seat leakage testing, observation of pressure decay following unseating, and diagnostic testing. In some cases, verification of obturator position through other indications would require establishment of complex testing schemes or valve disassembly. For these situations, the licensee reviewed each power-operated valve individually to determine if the verification process would provide a compensating increase in quality and safety.

Establishment of a complex testing scheme or performance of valve disassembly to confirm obturator position can require safety system outages and can result in significant dose and system upsets. In most cases, the potential for a stem to disc separation is very low. In addition, there are a few stop check valves for which the stem is not attached to the disc by design, so that obturator verification is not necessary.

Attachment 1 provides a description of the various bases for each valve of this relief request to exclude obturator position verification through other indications as required by 10CFR50.55a(b)(3)(xi). For each valve, obturator position verification is not practicable per ASME OM Code, 2012 Edition, Subsection ISTC-3700.

6. Duration of Proposed Alternative This proposed alternative will be utilized for the entire fourth 10-year interval. The fourth interval begins on February 17, 2020 and ends on February 16, 2030.

to NRC-19-0047 Page 3 10 CFR 50.55a Relief Request VRR-007 Relief from Conducting Obturator Verification for Certain Power Operated Valves

7. Precedent No precedent was identified for this relief request.

8. References

1. NRC Information Notice (IN) 2012-14, Motor-Operated Valve Inoperable Due to Stem-Disc Separation, dated July 24, 2012 (ML12150A046).

9. Attachments (1) Affected Components and Bases for Exclusion of Obturator Position Verification

[9 pages]

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Valve ASME OM Valve Actuator Flow Leak Identification Noun Description Code Valve Basis Typea Typeb Directionc Test (PIS) No. Class Category Control Rod Drive (CRD)

Scram Discharge Headers C1100F011 2 A GL AO FUS Individual NOTE 1 Clean Radwwaste Drain AOV CRD Scram Discharge Volume to Torus Room C1100F181 2 A GL AO FUS Individual NOTE 1 Sump G1101D065 Drain AOV This valve is an interface between service water and RHR for emergency reactor vessel injection of service water. This configuration prevents using process flow.

The valve is exercised with an actuator as there is no Residual Heat Removal way to perform mechanical (RHR) Reactor Vessel E1100F078 2 C CK AO FOS No exercise and measure torque.

Emergency Injection Line The valve has a periodic Check AOV maintenance (PM) activity to disassemble and inspect internals, but the PM frequency (i.e. every 8 refueling outages) is much less frequent than would be necessary to meet 10 CFR 50.55a(b)(3)(xi).

Page 1

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Valve ASME OM Valve Actuator Flow Leak Identification Noun Description Code Valve a b Basis Type Type Directionc Test (PIS) No. Class Category NOTE 1.

In addition, the risk of RHR Division 1 Low stem/disc separation would E1150F017A Pressure Coolant Injection 2 B GL MO FUS No be minimal since the valve is (LPCI) MOV normally cycled under near-static conditions.

NOTE 1.

In addition, the risk of RHR Division 2 Heat stem/disc separation would E1150F048B Exchanger "B" Bypass 2 B GL MO FUS No be minimal since the valve is MOV normally cycled under near-static conditions.

HPCI Turbine Supply Drain Pot to Main E4100F028 2 B GL AO FUS No NOTE 1 Condenser Drain Line Isolation AOV HPCI Turbine Supply Drain Pot to Main E4100F029 2 B GL AO FUS No NOTE 1 Condenser Drain Line Isolation AOV HPCI Turbine Steam Line E4100F054 Drain Pot Steam Trap 2 B GL AO FUS No NOTE 1 Bypass AOV High Pressure Coolant Injection (HPCI) Main Pump E4101C001A E4150F012 2 B GL MO FUS No NOTE 1 Minimum Flow to Suppression Chamber Isolation MOV HPCI Turbine Exhaust E4150F021 2 B/C SCK MO FUS No NOTE 2 Stop Globe MOV Page 2

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Valve ASME OM Valve Actuator Flow Leak Identification Noun Description Code Valve a b Basis Type Type Directionc Test (PIS) No. Class Category HPCI Turbine Exhaust Condensate Drain to E4150F022 2 B/C SCK MO FUS No NOTE 2 Suppression Pool Stop Check MOV HPCI Lube Oil Cooling E4150F059 Water Supply Isolation 2 B GL MO FUS No NOTE 1 MOV HPCI Turbine Steam E4150F600 Supply Line E4150F003 1 A GL MO FUS Group NOTE 1 Bypass MOV Reactor Core Isolation Cooling (RCIC) Turbine E5150F001 2 B/C SCK MO FUS No NOTE 2 Exhaust Line Isolation MOV RCIC Barometric Condenser Vacuum Pump E5150F002 2 B/C SCK MO FUS No NOTE 2 Discharge Stop Check MOV RCIC Division 1 Barometric Condenser E5150F004 Condensate Pump to Clean 2 B GL AO FUS No NOTE 1 Radwaste (CRW) Inboard Drain Isolation AOV RCIC Supply to E5150F022 Condensate Storage Tank 2 B GL MO FUS No NOTE 1 (CST) Test Isolation MOV RCIC Lube Oil Cooler E5150F046 Cooling Water Supply 2 B GL MO FUS No NOTE 1 Isolation MOV Page 3

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Valve ASME OM Valve Actuator Flow Leak Identification Noun Description Code Valve a b Basis Type Type Directionc Test (PIS) No. Class Category EECW Division 2 Supply P4400F604 to CRD Pumps Isolation 3 B GL MO FUS No NOTE 1 MOV EECW Division 1 Supply to Reactor Building (RB)

P4400F605A Equipment Sump Heat 3 B GL MO FUS No NOTE 1 Exchanger G1101B002A Isolation MOV EECW Division 2 Supply to RB Equipment Sump P4400F605B Heat Exchanger 3 B GL MO FUS No NOTE 1 G1101B002B Isolation MOV EECW Division 1 Supply to Battery Room Space P4400F613 3 B GL MO FUS No NOTE 1 Cooler T4100B033 Isolation MOV EECW Division 1 Supply to Drywell (DW)

P4400F614 2 B GL MO FUS No NOTE 1 Penetration Coolers Isolation MOV Standby Gas Treatment System (SGTS) from RB T4600F407 Aug. B NC BF AO FOS No NOTE 3 Exhaust System Isolation AOV SGTS Secondary Containment (SC) to T4600F408 Aug. B NC BF AO FOS No NOTE 3 Division 2 SGTS Isolation AOV SGTS SC to Division 1 T4600F409 Aug. B NC BF AO FOS No NOTE 3 SGTS Isolation AOV Page 4

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Valve ASME OM Valve Actuator Flow Leak Identification Noun Description Code Valve a b Basis Type Type Directionc Test (PIS) No. Class Category SGTS from Air Inlet T4600F410 Refueling Area Isolation Aug. B NC BF AO FOS No NOTE 3 AOV SGTS Division 1 Torus T4600F420 Hardened Vent SC Inboard Aug. B NC BF AO FOS No NOTE 3 Isolation AOV SGTS Division 2 Torus T4600F421 Hardened Vent SC Aug. B NC BF AO FOS No NOTE 3 Outboard Isolation AOV Containment Atmospheric Control (CAC) N2 Inerting T4800F422 to Vacuum Breaker Valve 2 A GL AO FUS Individual NOTE 1 T23-F400G N2 Supply Isolation AOV CAC N2 Inerting to Vacuum Breaker Valve T4800F423 2 A GL AO FUS Individual NOTE 1 T23-F400H N2 Supply Isolation AOV CAC N2 Inerting to Vacuum Breaker Valve T4800F424 2 A GL AO FUS Individual NOTE 1 T23-F400J N2 Supply Isolation AOV CAC N2 Inerting to Vacuum Breaker Valve T4800F425 2 A GL AO FUS Individual NOTE 1 T23-F400K N2 Supply Isolation AOV CAC N2 Inerting to Vacuum Breaker Valve T4800F426 2 A GL AO FUS Individual NOTE 1 T23-F400L N2 Supply Isolation AOV Page 5

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Valve ASME OM Valve Actuator Flow Leak Identification Noun Description Code Valve a b Basis Type Type Directionc Test (PIS) No. Class Category CAC N2 Inerting to Vacuum Breaker Valve T4800F427 2 A GL AO FUS Individual NOTE 1 T23-F400M N2 Supply Isolation AOV CAC N2 Inerting DW T4800F453 Pressure Control Vent 2 A GL AO FOS/FUS Group NOTE 1 AOV CAC N2 Inerting DW N2 T4800F454 Makeup Outboard 2 A GL AO FOS/FUS Group NOTE 1 Isolation AOV PC Pneumatic Division 1 T4901F465 Supply Outboard PC 2 A GL AO FUS Group NOTE 1 Isolation AOV PC Pneumatic Division 1 T4901F466 3 B GL AO FUS No NOTE 1 N2 Supply Isolation AOV PC Pneumatic Division 2 T4901F469 3 B GL AO FUS No NOTE 1 N2 Supply Isolation AOV NOTE 1.

Primary Containment (PC)

In addition, risk of stem/disc Pneumatic Division 1 separation would be minimal T4901F601 Instrument N2 Inerting 2 A GL MO FUS Group since the valve is normally Supply Inboard PC cycled under near-static Isolation MOV conditions.

NOTE 1.

Compressor Air PC In addition, risk of stem/disc Pneumatic Division 2 separation would be minimal T4901F602 Instrument N2 Inerting 2 A GL MO FUS Group since the valve is normally Supply Inboard PC cycled under near-static Isolation MOV conditions.

Page 6

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Valve ASME OM Valve Actuator Flow Leak Identification Noun Description Code Valve a b Basis Type Type Directionc Test (PIS) No. Class Category Primary Containment Monitoring (PCAM)

T5000F401A 2 A BA AO FOS Group NOTE 4 T50L400A CT Outboard Sample AOV PCAM T50L400B CT T5000F401B 2 A BA AO FOS Group NOTE 4 Outboard Sample AOV PCAM T50L401A CT T5000F402A 2 A BA AO FOS Group NOTE 4 Outboard Sample AOV PCAM T50L401B CT T5000F402B 2 A BA AO FOS Group NOTE 4 Outboard Sample AOV PCAM T50L402A CT T5000F403A 2 A BA AO FOS Group NOTE 4 Outboard Sample AOV PCAM T50L402B CT T5000F403B 2 A BA AO FOS Group NOTE 4 Outboard Sample AOV PCAM T50L403A CT T5000F404A 2 A BA AO FOS Group NOTE 4 Outboard Sample AOV PCAM T50L403B CT T5000F404B 2 A BA AO FOS Group NOTE 4 Outboard Sample AOV PCAM T50L404A CT T5000F405A 2 A BA AO FOS Group NOTE 4 Outboard Sample AOV PCAM T50L404B CT T5000F405B 2 A BA AO FOS Group NOTE 4 Outboard Sample AOV PCAM T50L410A CT T5000F407A 2 A BA AO FOS Individual NOTE 4 Outboard Sample AOV PCAM T50L410B CT T5000F407B 2 A BA AO FOS Individual NOTE 4 Outboard Sample AOV PCAM T50L411A CT T5000F408A Outboard Sample Return 2 A BA AO FOS Individual NOTE 4 AOV Page 7

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Valve ASME OM Valve Actuator Flow Leak Identification Noun Description Code Valve a b Basis Type Type Directionc Test (PIS) No. Class Category PCAM T50L411B CT T5000F408B Outboard Sample Return 2 A BA AO FOS Individual NOTE 4 AOV PCAM PC Pressure T5000F420A Monitor T50L406A PT 2 A BA AO FOS Individual NOTE 4 Outboard Sample AOV PCAM PC Pressure T5000F420B Monitor T50L406B PT 2 A BA AO FOS Individual NOTE 4 Outboard Sample AOV PCAM PC Torus Water Level Monitor Division 1 T5000F421A 2 B BA AO FOS No NOTE 4 Torus Level Instrument Line Isolation AOV PCAM PC Torus Water Level Monitor Division 2 T5000F421B 2 B BA AO FOS No NOTE 4 Torus Level Instrument Line Isolation AOV PCAM PC Torus Water Level Monitor Division 1 T5000F422A 2 B BA AO FOS No NOTE 4 Torus Level Instrument Line Isolation AOV PCAM PC Radiation Monitor Rack H21P284 T5000F455 2 A BA AO FOS Individual NOTE 4 Outlet Secondary Isolation AOV Division 2 PCAM PC Radiation Monitor Rack H21P284 T5000F456 2 A BA AO FOS Individual NOTE 4 Inlet Secondary Isolation AOV Page 8

ATTACHMENT 1 TO ENCLOSURE 3 OF NRC-19-0047 (VRR-007)

Affected Components and Bases for Exclusion of Obturator Verification Table Footnotes:

a: Valve types - BA = ball, BF = butterfly, CK = check, SCK = stop check, GL = globe, GA = gate b: Actuator type - AO = air operated, MO = motor operated c: Flow direction - FOS = flow over seat, FUS = flow under seat Note 1 - Globe valve with flow under the seat:

Flow presence or isolation does not prove indication of stem and disc connection. Since flow is under the seat, flow could occur with the stem in the open position even if the stem and disc are not attached. Flow isolation also does not prove the stem and disc are connected because a detached stem could seat the disc. For diagnostics, there is no unseating event or other indications that would provide conclusive indication the stem and disc are connected. Creating or revising an existing leakage test to validate stem to disc integrity is not practical and would result in additional dose to personnel. Valve disassembly is the only method to positively confirm stem to disc integrity.

Note 2 - Stop check valve:

The stem and disc are not attached by design; the stem moves independently of the disc. Thus, alternate indications to supplement valve position indication is not necessary. Presence of flow with the stem in the open position merely verifies the disc is not stuck in the seat as for any other check valve. Flow isolation also does not confirm obturator position because the detached stem will seat the disc by design. Diagnostic testing does not provide any indication of stem and disc attachment.

Note 3 - Butterfly valve in gas service:

The stem and disc on these butterfly valves are connected by taper pins. There is no reasonable mechanism for the pins to shear or become detached in gas service. Diagnostic testing does not provide any indication of stem and disc attachment.

Note 4 - Ball valve in gas service:

The stem fits into a cavity on the ball. There is no reasonable mechanism that would result in failure of the stem/disc connection, particularly in gas service. Diagnostic testing does not provide any indication of stem and disc attachment.

Page 9

Enclosure 4 to NRC-19-0047 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request VRR-009 for the IST Fourth 10-Year Interval to NRC-19-0047 Page 1 10 CFR 50.55a Relief Request VRR-009 Alternative for Motor Operated Valve Preservice/Inservice Testing Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected Valve ASME OM Valve Plant Identification Noun Description Code Category Drawing (PIS) No. Class Containment Atmospheric Control T4804F601A (CAC) H2 Recombiner to Torus Division 2 A M-5739-2 1 H2 Control Return Isolation Valve CAC H2 Recombiner to Torus Division 2 T4804F601B 2 A M-5739-2 H2 Control Return Isolation Valve CAC H2 Recombiner Division 1 H2 T4804F602A 2 A M-5739-2 Control Torus Suction Isolation Valve CAC H2 Recombiner Division 2 H2 T4804F602B 2 A M-5739-2 Control Torus Suction Isolation Valve CAC H2 Recombiner Division 1 H2 T4804F603A 2 A M-5739-2 Control Drywell Suction Isolation Valve CAC H2 Recombiner Division 2 H2 T4804F603B 2 A M-5739-2 Control Drywell Suction Isolation Valve CAC H2 Recombiner Division 1 H2 T4804F604A 2 A M-5739-2 Control Return Outboard Isolation Valve CAC H2 Recombiner Division 2 H2 T4804F604B 2 A M-5739-2 Control Return Outboard Isolation Valve CAC H2 Recombiner Division 1 Drywell T4804F605A 2 A M-5739-2 Outboard Suction Isolation Valve CAC H2 Recombiner Division 2 Drywell T4804F605B 2 A M-5739-2 Outboard Suction Isolation Valve CAC H2 Recombiner Division 1 Torus T4804F606A 2 A M-5739-2 Outboard Suction Isolation Valve CAC H2 Recombiner Division 2 Torus T4804F606B 2 A M-5739-2 Outboard Suction Isolation Valve

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda to NRC-19-0047 Page 2 10 CFR 50.55a Relief Request VRR-009 Alternative for Motor Operated Valve Preservice/Inservice Testing

3. Applicable Code Requirement

ASME OM Code Mandatory Appendix III Preservice and Inservice Testing of Active Electric Motor Operated Valve Assemblies in Light-Water Reactor Power Plants, Section III-3200 Preservice Test states that each motor operated valve (MOV) shall be tested during the preservice test period or before implementing inservice testing. It also states that testing that meets the requirements of this Mandatory Appendix but conducted before implementation of this Mandatory Appendix may be used.

Section III-6100 Acceptance Criteria states that thrust, torque, or other measured engineering parameters correlated to thrust or torque consistent with paragraphs III-6100 through III-6500, may be used to establish the acceptance criteria. It also states that motor control center (MCC) testing is acceptable if correlation with testing at the MOV has been established.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(1), relief is requested from the requirements of ASME OM Code Appendix III, Paragraph III-6100. The basis of the relief request is that the proposed alternative will provide an acceptable level of quality and safety.

MCC testing is utilized for the subject valves. Appendix III, Paragraph III-6100 allows MCC testing to be used if correlation with testing at the MOV has been established. Correlation with thrust or torque has not been performed for the subject valves. Relief from Appendix III, Paragraph III-6100 is needed to utilize MCC testing for the subject valves without prior correlation with thrust or torque.

5. Proposed Alternative and Basis for Use The proposed alternative is to conduct periodic MCC testing for these valves to demonstrate operational readiness without prior correlation with thrust or torque. Margin will be expressed in terms of calculated actuator output capability and calculated valve operating requirements. MCC testing will identify any performance-related degradation and analysis of this data will ensure the inservice test interval is appropriate.

The listed valves are all butterfly valves. The valves have high margin between calculated actuator capability and valve operating requirements. The valves are only required to operate under static conditions to meet their design basis function. The valves are classified as Class A under the MOV Joint Owners Group Periodic Verification (JOG PV) approach since they are only required to operate under static conditions and have bearing and shaft materials that were covered by the JOG PV. Thus, per the JOG PV, these valves are not susceptible to to NRC-19-0047 Page 3 10 CFR 50.55a Relief Request VRR-009 Alternative for Motor Operated Valve Preservice/Inservice Testing degradation. The valves are low risk per the JOG PV, corresponding to a low safety significant component (LSSC) per III-3720.

The valves are controlled by a limit switch in both directions; the torque switch is removed from the control circuit. Thus, actuator output capability is calculated vs. being determined from torque measurement taken at the torque switch trip event.

Since these valves are only required to operate under static conditions, each static stroke demonstrates their capability to operate under design basis conditions. Only that portion of the closing stroke beyond cessation of motor power (valve seating) would not be monitored by MCC testing as compared to torque measurement at the valve. However, MCC testing includes monitoring during valve unseating. MCC testing can identify newly developed anomalies as well as small changes in valve and actuator performance. Significant changes in valve and/or actuator performance would be necessary to compromise operational capability since margin is high. These anomalies and adverse trends can be detected and assessed without the need for torque measurement.

Fermi 2 has and will continue to conduct numerous MCC tests on each of these valves as well as other plant MOVs. The testing has provided Fermi 2 with the historical data and experience necessary to identify anomalies and/or adverse conditions.

Thus, periodic MCC testing will provide assurance that the valves remain capable of performing under design basis conditions throughout each testing interval.

6. Duration of Proposed Alternative This proposed alternative will be utilized for the entire fourth 10-year interval. The fourth interval begins on February 17, 2020 and ends on February 16, 2030.

7. Precedent No precedent was identified for this relief request.