NRC-19-0067, Submittal of Revised Valve Relief Request VRR-004 for the Inservice Testing Program Fourth 10-Year Interval

Submittal of Revised Valve Relief Request VRR-004 for the Inservice Testing Program Fourth 10-Year Interval

ML19281C656
Person / Time
Site:	Fermi
Issue date:	10/08/2019
From:	Fessler P DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-19-0067
Download: ML19281C656 (14)

Text

Peter Dietrich 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: peter.dietrich@dteenergy.com October 8, 2019 10 CFR 50.55a NRC-19-0067 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 Revised Valve Relief Request VRR-004 for the Inservice Testing Program Fourth 10-Year Interval

References:

1) DTE Electric Letter to NRC, Submittal of Valve Relief Requests for the Inservice Testing Program Fourth 10-Year Interval, NRC-19-0047, dated June 14, 2019 (ML19165A134)

2) NRC Letter to DTE, Supplemental Information Needed for Acceptance of Requested Licensing Action Re: Submittal of Valve Relief Requests for the Inservice Testing Program Fourth 10-Year Interval (EPID L-2019-LLR-0056 and L-2019-LLR 0058), dated July 30, 2019 (ML19197A287)

3) DTE Electric Letter to NRC, Withdrawal of the Inservice Testing Program Relief Requests VRR-004 and VRR-007 for the Fourth Ten-Year Interval, NRC-19-0061, dated August 7, 2019 (ML19219A104)

4) NRC Letter to DTE, Withdrawal of Requested Licensing Action Re:

Submittal of Valve Relief Requests for the Inservice Testing Program Fourth 10-Year Interval (EPID-L-2019-LLR-0056 and L-2019-LLR-0058),

August 14, 2019 (ML19219A775)

In Reference 1, DTE Electric Company (DTE) submitted relief requests VRR-004 and VRR-007 for the Fermi 2 Inservice Testing (IST) Program fourth 10-year interval. The Fermi 2 IST Program fourth 10-year interval begins on February 17, 2020 and ends on February 16, 2030.

By letter from Ms. Sujata Goetz dated July 30, 2019 (Reference 2), the NRC indicated that additional information was necessary to begin detailed technical review of relief requests VRR-004 and VRR-007. A clarification call was held between DTE and the NRC staff on July 24, 2019 to discuss and clarify the information requested by the NRC staff in Reference 2.

USNRC NRC-19-0067 Page 2 Following the clarification call and feedback from the NRC staff, DTE further reviewed the requirements of ASME OM Code, 2012 Edition, Subsection ISTC-3700, "Position Verification Testing," as well as 10 CFR 50.55a(b)(3)(xi), "OM condition: Valve Position Indication." The testing activities associated with each of the ASME code components (i.e. valves) listed in VRR-004 and VRR-007 were reviewed and DTE has determined that existing activities performed at Fermi 2 would meet the requirements for some of the valves without the need for relief under 10 CFR 50.55a(z). For the subset of valves that remained in scope and where relief was still required, it was determined that additional information would need to be gathered to address the specific NRC requests in Reference 2. For these reasons, DTE submitted a letter to withdraw VRR-004 and VRR-007 (Reference 3) so that a consolidated relief request could be prepared and submitted to the NRC at a later date.

In Reference 4, the NRC acknowledged the DTE request to withdraw VRR-004 and VRR-007.

The NRC also noted that if DTE were to re-submit the requests, the revised relief requests would need to address the items listed in Reference 4, which were the same as those in Reference 2.

DTE has now prepared a revised relief request, VRR-004 Revision 1. The revised relief request consolidates the information previously contained in relief requests VRR-004 and VRR-007, reduces the scope of ASME code components in the relief request, and addresses the information requested by the NRC in References 2 and 4. The revised relief request is enclosed.

DTE requests NRC approval of the relief request VRR-004 Revision 1 by March 16, 2020 to support planned testing during the next refuel outage scheduled in the spring of 2020.

No new commitments are being made in this submittal.

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 Nuclear Generation, for Peter Dietrich, Senior Vice President and CNO

Enclosure:

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

USNRC NRC-19-0067 Page 3 cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Michigan Department of Environment, Great Lakes, and Energy

Enclosure 1 to NRC-19-0067 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revised Relief Request VRR-004 for the IST Fourth 10-Year Interval

Enclosure to NRC-19-0067 Page 1 10 CFR 50.55a Relief Request VRR-004, Revision 1 Relief to Confirm Obturator Position at Seat Leakage Testing Frequency 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 The ASME code components affected by this relief request are the 47 valves 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

10 CFR 50.55a(b)(3)(xi) states:

OM condition: Valve Position Indication. When implementing ASME OM 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.

ASME OM Code, 2012 Edition, Subsection ISTC-3700, Position Verification Testing, states:

Valves with remote position indicators shall be observed locally at least once every 2 yr to verify that valve operation is accurately indicated. 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. These observations need not be concurrent. Where local observation is not possible, other indications shall be used for verification of valve operation.

Position verification for active MOVs shall be tested in accordance with Mandatory Appendix III of this Division.

ASME OM Code, 2012 Edition, Mandatory Appendix III, Preservice and Inservice Testing of Active Electric Motor Operated Valve Assemblies in Light-Water Reactor Power Plants, Subsection III-3300, paragraph (e) states:

Enclosure to NRC-19-0067 Page 2 10 CFR 50.55a Relief Request VRR-004, Revision 1 Relief to Confirm Obturator Position at Seat Leakage Testing Frequency Remote position indication shall be verified locally during inservice testing or maintenance activities.

ASME OM Code, 2012 Edition, Mandatory Appendix III, Subsection III-3310 states:

The inservice test interval determination shall include the following:

(a) The inservice test interval shall be determined in accordance with para. III-6440.

(b) If insufficient data exist to determine the inservice test interval in accordance with para. III-6400, then MOV inservice testing shall be conducted every two refueling cycles or 3 yr (whichever is longer) until sufficient data exist, from an applicable MOV or MOV group, to justify a longer inservice test interval.

(c) The maximum inservice test interval shall not exceed 10 yr. MOV inservice tests conducted per para. III-3400 may be used to satisfy this requirement.

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 Subsections ISTC-3700 and III-3310 and 10 CFR 50.55a(b)(3)(xi), for the subject valves listed in Attachment 1. The proposed alternative is to perform the required verification of obturator position using seat leakage testing at the seat leakage testing frequency interval. The basis of the relief request is that the proposed alternative will provide an acceptable level of quality and safety.

For the purpose of this relief request, DTE will utilize the phrase obturator verification to denote the supplementing of valve position indicating lights with other conditions to confirm proper obturator position as described in ISTC-3700 and 10 CFR 50.55a(b)(3)(xi).

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. At Fermi 2, obturator verification will be performed in both the open and closed directions to comply with 10 CFR 50.55a(b)(3)(xi).

A review of all In-Service Testing (IST) Program valves equipped with remote position indication was performed to identify a method to provide reasonable assurance of proper obturator position. The use of process parameters such as flow or pressure, seat leakage testing, and existing diagnostic testing were all considered as methods. For all the valves listed in Attachment 1, confirmation of obturator position in conjunction with seat leakage testing was identified as the most practical or only method of obturator verification. The seat leakage testing associated with the valves in Attachment 1 is currently performed at a

Enclosure to NRC-19-0067 Page 3 10 CFR 50.55a Relief Request VRR-004, Revision 1 Relief to Confirm Obturator Position at Seat Leakage Testing Frequency frequency that is different than that prescribed in Subsections ISTC-3700 and III-3310.

Combining the obturator verification with the seat leakage testing and performing them together will reduce labor and overall dose while also providing a highly reliable means to demonstrate proper obturator position.

DTE is requesting to perform obturator verification for certain valves as required by ISTC-3700 and 10 CFR 50.55a(b)(3)(xi) at a frequency commensurate with the 10 CFR 50 Appendix J, Option B performance-based leakage testing program at Fermi 2 instead of the two-year frequency required by ISTC-3700. This request applies to all the valves listed in Attachment 1, with two variations as listed below:

1) For one set of valves in Attachment 1 (i.e., two valves total), obturator verification as required by ISTC-3700 and 10 CFR 50.55a(b)(3)(xi) will be performed at a frequency commensurate with the seat leakage testing frequency referenced in NEI 13-02, Industry Guidance for Compliance with Order EA-13-109, (Reference 2) instead of the two-year frequency required by ISTC-3700.

2) For active motor operated valves in Attachment 1, position indication testing requirements are identified in Mandatory Appendix III as described in ISTC-3700.

Per Subsections III-3300 and III-3310, position indication testing is performed with inservice testing, which itself is performed at a variable frequency. The minimum frequency specified in Subsection III-3310 for inservice testing is every two refueling cycles or 3 years (whichever is longer, although the two options are currently equal for Fermi 2 given the current 18 month refueling cycles). As a result, the requested relief from the code required frequency for obturator verification of active motor operated valves is from the three-year minimum frequency in Mandatory Appendix III Subsection 3310 rather than from the two-year frequency in ISTC-3700. Seat leakage testing, at the Appendix J frequency, will also be utilized as the method for performing obturator verification of these Mandatory Appendix III valves.

5. Proposed Alternative and Basis for Use The proposed alternative is to perform the required verification of obturator position using seat leakage testing at the seat leakage testing frequency interval specified by either 10 CFR 50 Appendix J or the guidance in NEI 13-02 as described below.

For most of the valves in Attachment 1, the proposed alternative is to supplement valve position indication to confirm obturator position during the existing seat leakage testing performed in accordance with 10 CFR 50 Appendix J. The frequency of this obturator verification will be aligned to the frequency of the seat leakage testing frequency commensurate with the 10 CFR 50 Appendix J, Option B performance-based leakage testing program at Fermi 2, which incorporates NEI 94-01, Revision 3-A (ADAMS Accession No.

Enclosure to NRC-19-0067 Page 4 10 CFR 50.55a Relief Request VRR-004, Revision 1 Relief to Confirm Obturator Position at Seat Leakage Testing Frequency ML12221A202), and the conditions and limitations specified in NEI 94-01, Revision 2-A (ML100620847).

In 1996, Fermi 2 received approval of License Amendment 108 (ADAMS Accession No. ML020730597) to implement Option B of the 10 CFR 50 Appendix J Program. This program permits the extension of the Appendix J seat leakage testing to a frequency corresponding to the specific valve performance. Valves whose leakage test results indicate good performance may have their interval of testing increased based on these test results.

On March 9, 2017, Fermi 2 received approval of License Amendment No. 205 (ADAMS Accession No. ML16351A460) to implement NEI 94-01, Revision 3-A and the conditions and limitations specified in NEI 94-01, Revision 2-A, to implement the performance-based leakage-testing program in accordance with 10 CFR 50 Appendix J, Option B. This License Amendment increased the containment isolation valves leakage test intervals (i.e., Type C tests) from 60 months to 75 months.

The Fermi 2 program which implements Appendix J, Option B requires individual containment isolation valves to pass three successful seat leakage tests before they can be placed on extended seat leakage testing frequency.

In addition, for one set of valves in Attachment 1 (i.e., two valves total), valve position indication will be supplemented to confirm obturator position by utilizing the existing seat leakage testing performed in accordance with the NEI 13-02, Industry Guidance for Compliance with Order EA-13-109. Valves T4600F420 & T4600F421 are the Torus Hardened Vent Isolation Valves which are credited for compliance with NRC Order EA 109. Section 6.2 of NEI 13-02 identifies that leak rate testing of hardened containment vent system valves should be performed at a frequency of once every three operating cycles.

Consistent with the NEI 13-02 guidance, valves T4600F420 & T4600F421 will be leak tested at a maximum frequency of every three operating cycles. Therefore, the obturator verification of valves T4600F420 & T4600F421 will be performed in conjunction with this seat leakage testing at a maximum frequency of every three operating cycles.

To support the use of seat leakage testing at the Appendix J or NEI 13-02 frequency, Attachment 1 identifies testing or maintenance activities, such as position indication testing, stroke timing, actuator maintenance, and valve diagnostic testing, that will also provide reasonable assurance of overall valve health including indication. Note that this relief request is not proposing to alter the frequency of position indication testing itself, as required by Subsection ISTC-3700 (or Subsection III-3300(e) for active motor operated valves).

Therefore, position indication testing of the valves in Attachment 1 will continue to be performed at a frequency of two years in accordance with ISTC-3700 (or at the frequency in accordance with Subsection III-3310 for active motor operated valves).

Enclosure to NRC-19-0067 Page 5 10 CFR 50.55a Relief Request VRR-004, Revision 1 Relief to Confirm Obturator Position at Seat Leakage Testing Frequency For all the valves in Attachment 1, seat leakage testing is the most practical or only method to validate the obturator is in the proper open or closed position as required. Seat leakage testing would identify problems with obturator integrity. Any identified issues would then be repaired using the Corrective Action Program.

In conclusion, the ability to detect degradation and ensure the operational readiness of the subject valves to perform their intended function is not jeopardized by performing the obturator verification at the same frequency as the seat leakage testing specified by 10 CFR 50 Appendix J or the guidance in NEI 13-02. This frequency of testing provides reasonable assurance of the operational readiness of the subject valves, as well as that the indicating system accurately reflects the valve disc position. Thus, the proposed alternative provides an acceptable level of quality and safety.

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. NEI 13-02, Industry Guidance for Compliance with Order EA-13-109: BWR Mark I &

II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 1, dated April 2015 (ML15120A360).

9. Attachments

1. Affected Components and Bases for Using Seat Leakage Testing to Confirm Obturator Position [5 pages]

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0067 (VRR-004, Revision 1)

Affected Components and Bases for Using Seat Leakage Testing to Confirm Obturator Position Valve ID Code OM Valve Valve Actuator IST Program Safety Method of Obturator Verification / Relief Testing /

Valve Description Function of Valve (PIS) Nos. Class Category Type* Type* Classification Direction Requested Maintenance**

Verification of obturator in the open position will be performed using feedwater flow and at a frequency in accordance with the ASME OM code Subsection ISTC-3700 and 10 CFR 50.55a(b)(3)(xi). Therefore, no relief is required These check valves open to allow feedwater flow for the open position.

B2100F076A Feedwater Supply Check to the reactor pressure vessel (RPV) during power 1 A/C CHK AO Active Closed 1, 2, & 4 B2100F076B Air Operated Valves operation. The safety function is to close to There is no practical method to validate valve isolate primary containment. closure other than seat leakage testing.

Verification of obturator in the closed position will be performed during seat leakage testing.

Relief is requested to align the frequency of the closed position verification to the Appendix J seat leakage testing frequency.

Verification of obturator in the open position will be performed during SLC pump testing and at a frequency in accordance with the ASME OM code Subsection ISTC-3700 and 10 CFR 50.55a(b)(3)(xi). Therefore, no relief is required The open safety function of this valve is to open for the open position.

Standby Liquid Control Open / to provide a flow path from the SLC tank to the C4100F006 (SLC) Outboard Check 1 A/C CHK N/A Active 1, 2, & 10 Closed RPV. The closed safety function of this valve is There is no practical method to validate valve Valve to close to isolate primary containment. closure other than seat leakage testing.

Verification of obturator in the closed position will be performed during seat leakage testing.

Relief is requested to align the frequency of the closed position verification to the Appendix J seat leakage testing frequency.

Since the head spray piping is cut and capped, there is no method to use process indicators to The RHR RPV head spray piping has been cut validate obturator position. Seat leakage testing Residual Heat Removal and capped inside the primary containment. This is the only practical method to validate position.

(RHR) RPV Head Spray E1150F022 motor operated valve has a safety function in the Verification of obturator in both the open and Inboard and Outboard 2 A GA MO Passive Closed 1&2 E1150F023 closed position to isolate primary containment. closed positions will be performed during seat Containment Isolation This valve is normally closed and maintained leakage testing. Relief is requested to align the Motor Operated Valves closed for isolation of penetration X-17. frequency of both the open and closed position verification to the Appendix J seat leakage testing frequency.

Page 1

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0067 (VRR-004, Revision 1)

Affected Components and Bases for Using Seat Leakage Testing to Confirm Obturator Position Valve ID Code OM Valve Valve Actuator IST Program Safety Method of Obturator Verification / Relief Testing /

Valve Description Function of Valve (PIS) Nos. Class Category Type* Type* Classification Direction Requested Maintenance**

Verification of obturator in the open position will be performed during HPCI and RCIC pump testing and at a frequency in accordance with the ASME OM code Subsection ISTC-3700 and 10 High Pressure Coolant CFR 50.55a(b)(3)(xi). Therefore, no relief is Injection (HPCI) and These normally open valves have a safety required for the open position.

E4150F007 Reactor Core Isolation Open / function to allow HPCI and RCIC injection to the 2 A GA MO Active 1, 2, 4, 11, & 12 E5150F012 Cooling (RCIC) Pump Closed RPV. These valves have a closed safety function There is no practical method to validate valve Discharge Isolation Motor to serve as pressure isolation valves. closure other than seat leakage testing.

Operated Valves Verification of obturator in the closed position will be performed during seat leakage testing.

Relief is requested to align the frequency of the closed position verification to the Appendix J seat leakage testing frequency.

Verification of obturator in the open position will be performed during sump pump operation and at a frequency in accordance with the ASME OM code Subsection ISTC-3700 and 10 CFR These valves are normally open to provide a flow 50.55a(b)(3)(xi). Therefore, no relief is required Radwaste Drywell Sump path for water from the drywell sumps to be for the open position.

G1100F003 Pumps Outboard transferred to collector tanks. These air operated 2 A GA AO Active Closed 1, 2, 3, & 7 G1100F019 Containment Isolation Air valves have a safety function in the closed There is no practical method to validate valve Operated Valves position. These valves isolate penetrations X-18 closure other than seat leakage testing.

and X-19 to maintain containment integrity. Verification of obturator in the closed position will be performed during seat leakage testing.

Relief is requested to align the frequency of the closed position verification to the Appendix J seat leakage testing frequency.

These air operated butterfly valves have a safety function in the open position. The function of There is no practical method to use process these normally closed reactor building-to-indicators to validate obturator position.

suppression chamber isolation valves is to relieve Primary Containment Verification of obturator in both the open and the vacuum when primary containment depressurizes T2300F409 Suppression Chamber Open / closed position will be performed during seat 2 A BF AO Active below reactor building pressure. These air 1, 2, 3, & 7 T2300F410 Reactor Building Vacuum Closed leakage testing. Relief is requested to align the operated butterfly valves also have a safety Breaker Valves frequency of both the open and closed position function in the closed position. T2300F409 is the verification to the Appendix J seat leakage testing penetration X-205B containment inboard frequency.

isolation valve. T2300F410 is the penetration X-205A containment inboard isolation valve.

Page 2

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0067 (VRR-004, Revision 1)

Affected Components and Bases for Using Seat Leakage Testing to Confirm Obturator Position Valve ID Code OM Valve Valve Actuator IST Program Safety Method of Obturator Verification / Relief Testing /

Valve Description Function of Valve (PIS) Nos. Class Category Type* Type* Classification Direction Requested Maintenance**

This valve is not routinely operated under system operation where system parameters could be used to validate obturator position. Seat leakage Standby Gas Treatment These air-operated butterfly valves are normally testing is the only practical method to validate System (SGTS) Torus locked closed to maintain the secondary position. Verification of obturator in both the T4600F420 Hardened Vent Secondary Aug. containment boundary for SGTS. The valves can NC BF AO Passive Closed open and the closed position will be performed 1, 2, 7, & 8 T4600F421 Containment Inboard and B be opened for venting primary containment. The during seat leakage testing. Relief is requested to Outboard Isolation Air valves have a safety function to remain closed to align the frequency of both the open and closed Operated Valves maintain secondary containment.

position verification to the seat leakage testing frequency in accordance with NEI 13-02 Industry Guidance for Compliance with Order EA-13-109.

T4800F416 T4800F417 Validation of obturator position using process T4800F418 parameters would require the nitrogen supply to Containment Atmospheric These valves are normally locked closed and T4800F419 be isolated during vacuum breaker testing, which Control (CAC) N2 Inerting remain closed to isolate control N2 to the drywell-T4800F420 could result in equipment risk to the vacuum to Vacuum Breaker Valves to-torus vacuum breaker. These valves close to T4800F421 breakers. Verification of obturator in both the (T2300F400A - 2 A GL AO Passive Closed isolate the applicable penetration to maintain 1, 2, & 7 T4800F422 open and the closed position will be performed T2300F400M) N2 Supply containment integrity and isolate the nitrogen T4800F423 during seat leakage testing. Relief is requested to Isolation Air Operated inerting system and the reactor building from the T4800F424 align the frequency of both the open and closed Valves drywell.

T4800F425 position verification to the Appendix J seat T4800F426 leakage testing frequency.

T4800F427 There is no practical method to use process These valves are normally closed and open to indicators to validate obturator position.

allow inerting of the drywell with N2 gas, purging Verification of obturator in both the open and the T4800F456 CAC N2 Inerting to SGTS for personnel entry into containment, and closed position will be performed during seat T4800F457 N2 Supply Bypass Air 2 A GL AO Active Closed 1, 2, 3, & 7 treatment of the containment atmosphere prior to leakage testing. Relief is requested to align the T4800F458 Operated Valves its release to the environment. The valves close frequency of both the open and closed position to isolate containment penetration X-205D. verification to the Appendix J seat leakage testing frequency.

The hydrogen recombiner Technical T4804F601A Specification requirements were removed by T4804F601B License Amendment 159, dated March 15, 2004.

T4804F602A There is no routine event to run the system which T4804F602B These normally closed valves are opened to would create an opportunity to validate obturator T4804F603A provide a return flow path to the torus when the position using process variables. Seat leakage T4804F603B H2 Recombiner Isolation 2 A BF MO Active Closed hydrogen recombiner is in service. The safety testing is the only practical method to validate 2, 4, & 6 T4804F604A Valves function of these valves is to provide containment closure. Verification of obturator in both the T4804F604B isolation for penetrations. open and the closed position will be performed T4804F605A during seat leakage testing. Relief is requested to T4804F605B align the frequency of both the open and closed T4804F606A position verification to the Appendix J seat T4804F606B leakage testing frequency.

Page 3

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0067 (VRR-004, Revision 1)

Affected Components and Bases for Using Seat Leakage Testing to Confirm Obturator Position Valve ID Code OM Valve Valve Actuator IST Program Safety Method of Obturator Verification / Relief Testing /

Valve Description Function of Valve (PIS) Nos. Class Category Type* Type* Classification Direction Requested Maintenance**

Verification of obturator in the open position will These valves are normally open to supply: control be performed by monitoring pneumatic pressure nitrogen from the Nitrogen Inerting System; or to and at a frequency in accordance with the ASME supply control air from the Non-Interruptible Air OM code Subsection ISTC-3700 and 10 CFR Supply (NIAS) system; or to provide control 50.55a(b)(3)(xi). Therefore, no relief is required nitrogen from the nitrogen back-up bottles. The for the open position.

pneumatic pressure is used for air operated valves Primary Containment (PC) located in the drywell. The valves have a safety T4901F465 Pneumatic Supply Open / Validation of obturator in the closed position 2 A GL AO Active function in the closed direction to isolate primary 1, 2, 7, & 9 T4901F468 Outboard PC Isolation Air Closed using process parameters would result in containment penetrations X-22 and X-36. The Operated Valves pneumatic pressure being lost to the drywell.

valves have a safety function in the open Seat leakage testing is the only practical method direction to allowing for re-opening following to validate closure. Verification of obturator in containment isolation to provide a long-term the closed position will be performed during seat safety-related pneumatic supply to the Automatic leakage testing. Relief is requested to align the Depressurization System (ADS) Safety Relief frequency of the closed position verification to Valves (SRVs) following a design basis accident.

the Appendix J seat leakage testing frequency.

Verification of obturator in the open position will These valves are normally open to supply: control be performed by monitoring pneumatic pressure nitrogen from the Nitrogen Inerting System; or to and at a frequency in accordance with the ASME supply control air from the Non-Interruptible Air OM code Subsection III-3310 and 10 CFR Supply (NIAS) system; or to provide control 50.55a(b)(3)(xi). Therefore, no relief is required nitrogen from the nitrogen back-up bottles. The for the open position.

pneumatic pressure is used for air operated valves PC Pneumatic Supply located in the drywell. The valves have a safety T4901F601 Open / Validation of obturator in the closed position Inboard PC Isolation Motor 2 A GL MO Active function in the closed direction to isolate primary 2, 5, & 6 T4901F602 Closed using process parameters would result in Operated Valves containment penetrations. The valves have a pneumatic pressure being lost to the drywell.

safety function in the open direction to allowing Seat leakage testing is the only practical method for re-opening following containment isolation to to validate closure. Verification of obturator in provide a long-term safety-related pneumatic the closed position will be performed during seat supply to the Automatic Depressurization System leakage testing. Relief is requested to align the (ADS) Safety Relief Valves (SRVs) following a frequency of the closed position verification to design basis accident.

the Appendix J seat leakage testing frequency.

Page 4

ATTACHMENT 1 TO ENCLOSURE 1 OF NRC-19-0067 (VRR-004, Revision 1)

Affected Components and Bases for Using Seat Leakage Testing to Confirm Obturator Position Valve ID Code OM Valve Valve Actuator IST Program Safety Method of Obturator Verification / Relief Testing /

Valve Description Function of Valve (PIS) Nos. Class Category Type* Type* Classification Direction Requested Maintenance**

Verification of obturator in the open position will be performed by monitoring drywell pressure and at a frequency in accordance with the ASME OM code Subsection ISTC-3700 and 10 CFR 50.55a(b)(3)(xi). Therefore, no relief is required for the open position.

These valves are normally open to allow Primary Containment monitoring of drywell pressure during normal T5000F420A Atmosphere Monitoring Open / Validation of obturator in the closed position 2 A BA AO Active operations and following a design basis accident. 1, 2, 3, & 7 T5000F420B (PCAM) Outboard Sample Closed using process parameters would require bleed-off The valves are closed to isolate primary Valves of pressure during power operation. Seat leakage containment penetrations.

testing is the only practical method to validate closure. Verification of obturator in the closed position will be performed during seat leakage testing. Relief is requested to align the frequency of the closed position verification to the Appendix J seat leakage testing frequency.

Verification of obturator in the open position will be performed during radiation sample pump operation and at a frequency in accordance with the ASME OM code Subsection ISTC-3700 and 10 CFR 50.55a(b)(3)(xi). Therefore, no relief is required for the open position.

PCAM PC Radiation This valve is normally open to allow radiation Monitor Rack H21P284 monitoring of primary containment atmospheric Validation of obturator in the closed position T5000F455 2 A BA AO Active Closed 1, 2, & 3 Secondary Isolation Air conditions. This valve closes to isolate primary using process parameters would trip the radiation Operated Valves containment penetrations. sample pump. Seat leakage testing is the only practical method to validate closure. Verification of obturator in the closed position will be performed during seat leakage testing. Relief is requested to align the frequency of the closed position verification to the Appendix J seat leakage testing frequency.

• AO = air operated, BA = ball, BF = butterfly, CHK = check, GA = gate, GL = globe, MO = motor operated

• • Table footnotes for information regarding testing/maintenance performed on the subject valves:

1: The standard method for performing position indication test will be performed every two years in accordance with the ISTC-3700 frequency requirements.

2: Seat leakage testing is currently performed on the subject valve. Leakage testing for the hardened vent isolation valves T4600F420 & F421 will be performed in accordance with NEI 13-02.

3: Quarterly stroke timing test is to be performed during the 4th IST Interval.

4: Exercise test is to be performed during the 4th IST Interval at two-year (or less) frequency.

5: Two-year exercise and stroke time are to be performed during the 4th IST Interval.

6: MOV Mandatory Appendix III diagnostic and position indication testing is to be performed during the 4th IST Interval.

7: A recurring preventive maintenance (PM) event exists for AOV diagnostic testing / actuator re-build.

8: Stroke timing is to be performed every operating cycle.

9: Stroke timing is to be performed during cold shutdown.

10: Exercise test is to be performed within the Check Valve Condition Monitoring Program.

11: Position indication of these active motor operated valves will follow more restrictive ISTC-3700 frequency requirement (2 year) instead of Mandatory Appendix III due to in-progress valve re-classification.

12: These pressure isolation valves will be aligned with the 10 CFR 50 Appendix J frequency per 4th Interval Fermi 2 Relief Request VRR-003 (ML19149A329).

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