NRC-95-0019, Forwards Response to NRC Re Violations Noted in Insp Rept 50-341/95-02.Corrective Actions:Valves Disassembled & Inspected Per Procedure 47.000.13, Pep Check Valve Insp Procedure

Forwards Response to NRC Re Violations Noted in Insp Rept 50-341/95-02.Corrective Actions:Valves Disassembled & Inspected Per Procedure 47.000.13, Pep Check Valve Insp Procedure

ML20081B981
Person / Time
Site:	Fermi
Issue date:	03/13/1995
From:	Mckeon R DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-95-0019, CON-NRC-95-19 NUDOCS 9503170061
Download: ML20081B981 (3)

Text

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F 3 E

Robert McKeon i

Assistant t/ce Pres ^.dert I

and Manager, operates

.j 00 North Dixie Hwy Edison "mA"m*"*"

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March 13, 1995 NRC-95-0019 l

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

20555 l

References:

1)

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

NRC Inspection Report 50-341/95002, dated February 10, 1995

Subject:

Response to Notice of Violation 95002-03 Encloset.' is the response to the Notice of Violation contained in Reference 2.

i The following commitments are being made in this letter:

1.

Check Valves E2100F003A, B, C and D will.be incorporated into the *ISI Check Valve Inspection Procedure", 43 000.010, for disassembly and t

inspection on a frequency of one valve per refueling outage.

2.

A partial stroke test will be defined for the IST Pump and Valve Program and listed against these check valves. This test will be incorporated into the Core Spray Division I and Division 2 Surveillance Test Procedures, 24.203 02 and 24.203 03 respectively.

If there are any questions related to this response, please contact Jim Martin, Compliance Engineer, at (313) 586-4225.

Sincerely, Y$

Enclosure cc: T. G. Colburn J. B. Martin M. P. Phillips A.

Vegel i

9503170061 950313 PDR ADOCK 05000341 0

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March 13,'1995 Page :1'_

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REPLY 10 NOTICE OF VIOLATION 50-341/95002-03 l

STA11BNGff OF NOTICE OF VIOLATION 95-002-03 Fermi 2 Technical Specification 4.0.5 states that inservice testing of ASME Code Class.1, Class 2 and Class 3 pumps and valves shall be performed in i

accordance with Section XI of the ASME Boiler and Pressure Vessel Code and 1

. applicable Addenda as required by 10 CFR 50, Section 50.55a, except where specific written relief has been granted by the NRC. ASME Code,Section XI, IWV-3522, " Exercising Procedure", states that " Check _ valves should be i

exercised to the position required to fulfill their. function......"

The IST program identified the core spray pump discharge' check valve.s (E2100F003A, -B, -C and -D) have an open safety function.

-l Contrary to the above, as of January 27,'1995, test procedures 24.203.02 and 24.303 03 for the core spray pump discharge check valves (E2100F003A,

-B, -C and -D) contained inadequate acceptance criteria to exercise the open safety function.

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REASON FOR 111E VIOLATION 1

i At the time that Core Spray Systes testing was developed, it was~ determined j

that the test valve characteristics made full flow testing of the pumps-M impractical on an individual basis. Based on this, relier request PR-6 was" i

submitted to provide for full flow testing of the subsystes (using both pumps),'as required by Technical Specification Surveillance Requirement J

4.5.1.b.

It was also thought that the obtaining of full flow through the

i check valves had adequately been demonstrated by the achievement of rated two pump flow. This method of testing the pumps results in only a partial i

stroke test of the discharge check valves since degradation of the check '

valves may be masked by the two pump test configuration and pump i

degradation. Under this testing configuration, the check valves should i

have been tested in accordance with the guidance of Position 2 of Generic l

Letter No. 89-04. This position provides the testing alternative of i

disassembly and inspection followed by a partial stroke, if possible. This would be accomplished on a Refueling Outage frequency.

t 00RRECTIVE ACTIONS TAKEN AND tile RESILTS ACHIEVED l

i Check Valves E2100F003A, B, C and D were already on a program of disasseinbly and inspection under the Feral Check Valve Program. These

-l valves are currently disassembled and inspected per precedure 47.000.13,

" PEP Check Valve Inspection Procedure". which has the tour valves on a 12 outage cycle.

Inspections of Core Spray Discharge Check Valves E2100F003A and E2100F003B were conducted under this procedure during refuel outages RF01 and RF03, respectively. These results indicated very little degradation.

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L1 Encloruro to 3

NRC-95-oo19 March 13. 1995 Page 2 The only other pumps which are tested in parallel are the RHR Service Water Pumps. These pumps, however, test the discharge checks one at a time with the respective pump running alone at near rated flow. Thus, this problem is unique to the Core Spray Pumps.

CORRECTIVE ACTION TO BE TAKEN 10 PREVENT RECURRENCE The following actions will be taken:

1.

Check Valves E2100Po03A, B, C and D will be incorporated into the "ISI l

Check Valve Inspection Procedure", 43 000.010, for disassembly and inspection on a frequency of one valve per refueling outage.

l 2.

A partial stroke test will be defined for the IST Pump and Valve l --

Program and listed against these check valves. This test will be incorporated into the Core Spray Division 1 and Division 2 Surveillance Test Procedures, 24.203 02 and 24.203 03 respectively.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The required procedure revisions will be completed prior to the next refueling outage to support disassembly and inspection of the check valves.

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