ML14128A299
| ML14128A299 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/14/2014 |
| From: | Robert Carlson Plant Licensing Branch III |
| To: | Plona J DTE Electric Company |
| Thomas Wengert, NRR/DORL 415-4037 | |
| References | |
| TAC MF2557 | |
| Download: ML14128A299 (8) | |
Text
Mr. Joseph H. Plana UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 14, 2014 Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2-210 NOC 6400 North Dixie Highway Newport, Ml 48166
SUBJECT:
FERMI 2-ALTERNATIVE REQUEST PRR-011 CONCERNING THE THIRD 10-YEAR INSERVICE TESTING PROGRAM (TAC NO. MF2557)
Dear Mr. Plana:
By letter dated August 7, 2013, as supplemented by letter dated January 30, 2014, DTE Electric Company (DTE, the licensee) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for the use of an alternative to certain American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) requirements at Fermi 2 Power Plant (Fermi 2).
Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) 50.55a(a)(3)(i),
the licensee requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety.
The NRC staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that DTE has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i) for alternative request PRR-011, and is in compliance with the ASME OM Code requirements.
Therefore, the NRC staff authorizes alternative request PRR-011 for Fermi 2 for the remainder of the third 1 0-year in service testing program interval, which began on February 17, 2010, and is scheduled to end on February 16, 2020. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request remain applicable.
If you have any questions, please contact the NRC Project Manager, Thomas Wengert, at 301-415-4037, or via e-mail at thomas.wengert@nrc.gov.
Docket No. 50-341
Enclosure:
Safety Evaluation cc w/encls: Distribution via ListServ Sincerely, Robert D. Carlson, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING ALTERNATIVE REQUEST NO. PRR-011 FOR THE THIRD 10-YEAR INTERVAL INSERVICE TESTING PROGRAM DTE ELECTRIC COMPANY FERMI2 POWER PLANT DOCKET NO. 50-341
1.0 INTRODUCTION
By letter dated August 7, 2013 (Agencywide Documents Access Management System (ADAMS)
Accession No. ML13220A156), as supplemented by letter dated January 30, 2014 (ADAMS Accession No. ML14031A418), DTE Electric Company (DTE, the licensee) submitted alternative request PRR-011 to the U.S. Nuclear Regulatory Commission (NRC) for two control center heating, ventilation and air conditioning (CCHVAC) chilled water pumps at Fermi 2 Power Plant (Fermi 2). The licensee proposed an alternative to the vibration testing requirements of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) for the inservice testing (1ST) program for the remainder of the third 1 0-year 1ST program interval.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i),
the licensee requested to use the proposed alternative in PRR-011 on the basis that the alternative provides an acceptable level of quality and safety.
2.0 REGULATORY EVALUATION
The regulation at 10 CFR 50.55a(f), "lnservice Testing Requirements," states, in part, that 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda.
The regulation at 10 CFR 50.55a(a)(3), states, in part, that alternatives to the requirements in paragraph (f) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternative provides an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Enclosure The Fermi 2 third 10-year 1ST interval began on February 17, 2010, and is scheduled to end on February 16, 2020. The Fermi 2 third 10-year 1ST program complies with the ASME OM Code, 2004 Edition.
Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request and the Commission to authorize the alternative requested by the licensee.
3.0 TECHNICAL EVALUATION
3.1 Licensee's Alternative Request PRR-011 ISTB-3300, "Reference Values," defines the requirements for obtaining reference values for the inservice testing of pumps.
ISTB-3300, "Reference Values," (a) states that "Initial reference values be determined from the results of testing meeting the requirements of ISTB-31 00, Preservice Testing, or from the results of the first inservice test."
ISTB-3300, "Reference Values," (d) states that "Reference values shall be established at point(s) of operation (reference point) readily duplicated during subsequent tests."
ISTB-3300, "Reference Values," (f) states that "All subsequent test results shall be compared to these initial reference values or to new reference values established in accordance with ISTB-3310, ISTB-3320, or ISTB-6200(c)."
ISTB-5120, "lnservice Testing," ISTB-5121, "Group A Test Procedure," (e), and ISTB-5123, "Comprehensive Test Procedure", (e), state, in part, that "All deviations from the reference values shall be compared with the ranges of Table ISTB-5121-1 and corrective action taken as specified in ISTB-6200. The vibration measurements shall be compared to both the relative and absolute criteria shown in the alert and required action ranges of Table ISTB-5121-1."
Table ISTB-5121-1, "Centrifugal Pump Test Acceptance Criteria," states that the alert range for pumps with an operating speed of greater than or equal to 600 revolutions per minute (rpm) is greater than 2.5 to 6 times the reference value (Vr), or greater than 0.325 to 0.7 inches per second (ips).
ISTB-6200 states, in part, that "If the measured test parameter values fall within the alert range of Table ISTB-5121-1, the frequency of testing specified in ISTB-3400 shall be doubled until the cause of the deviation is determined and the condition is corrected."
In its submittal, the licensee has proposed an alternative to the ASME OM Code vibration testing requirements for the pumps listed in Table 1 below. The licensee requests an alternative to the requirements of ASME OM Code paragraphs ISTB-5120, ISTB-5121, and Table ISTB-5121-1 for the pumps listed in Table 1.
Table 1 ASME Pump ID Pump Description Code ASME OM Type Speed Class Code Group T4100C040 South CCHVAC Chilled 3
A Centrifugal 1745 RPM Water Pump T4100C041 North CCHVAC Chilled 3
A Centrifugal 1745 RPM Water Pump
Reason for Request
The licensee states that the pumps listed in Table 1 have at least one vibration reference value that is less than or equal to 0.04 inches per second, which results in very small acceptable ranges for pump operation. The licensee further states that using very small acceptable ranges in accordance with ASME OM Code Table ISTB-5121-1 for the pumps in Table 1 could subject these pumps to unnecessary corrective action.
Proposed Alternative The licensee proposes to establish a minimum velocity measurement value of 0.04 ips for velocity reference values (Vr). The licensee proposes to apply this minimum value to an individual vibration location where the measured reference value is less than or equal to 0.04 ips and use it to calculate acceptable ranges as specified in Table ISTB 5121-1. The value of 0.04 ips results in an alert range of >0.1 00 ips to 0.240 ips.
The licensee also states that experience gathered from the predictive maintenance program has shown that changes in vibration levels in the range of 0.04 ips are not typically indicative of degradation in pump or motor condition.
The licensee proposes that when new reference values are established, the measured parameters will be evaluated for each vibration location to determine if the provisions of this alternative request are applicable. If the measured Vr is greater than 0.04 ips, the licensee will not apply the provisions of this alternative request, and has committed to utilize the acceptance criteria requirements of Table ISTB 5121 -1. If a measured Vr is less than or equal to 0.04 ips, the licensee will apply the provisions of this alternative request and utilize the minimum Vr value of 0.04 ips and will apply the acceptance criteria requirements of Table ISTB 5121-1 to this minimum Vr value.
The licensee notes that pump T 41 OOC041 currently has reference vibration points with both less than 0.04 ips and greater than 0.04 ips. In this case, the licensee will utilize both sets of acceptance criteria discussed above depending on the measured Vr at each vibration location.
The licensee has also included the pumps listed in Table 1 in the Fermi 2 Preventative and Predictive Maintenance Program Scope. The licensee's Predictive Maintenance Program employs predictive monitoring techniques, including vibration monitoring and analysis, beyond that required by subsection ISTB of the ASME OM Code. Vibration data, collected quarterly, is analyzed to determine if the component is exhibiting abnormal vibration trends. If a component exhibits abnormal vibration trends, a detailed spectral analysis is performed. If measured parameters are outside the normal operating range, the licensee states that appropriate actions are taken that may include increased monitoring, review of component specific information to identify cause, and removal of the pump from service to perform maintenance.
In addition to enhanced vibration monitoring, the licensee's Preventative Maintenance Program includes an event to inspect, lubricate, and perform Electrical Predictive Maintenance testing on these pumps.
3.2
NRC Staff Evaluation
The NRC staff notes that pumps with vibration levels of 0.1 ips or less are generally considered "smooth running pumps," and that the licensee's proposed minimum vibration level of 0.04 ips is well below this point. In addition, as per ASME OM Code Table ISTB-5121-1, the alert range for pumps that operate with a pump speed greater than 600 rpm is >0.325 to 0.7 ips. Therefore, action is required for vibration greater than 0.7 ips. The pumps listed in Table 1 operate at 1745 rpm. It is also noted that for reference values smaller than 0.04 ips, hydraulic noise and instrument error can be a significant portion of the reading and, therefore, can affect the repeatability of subsequent measurements. If a very small reference value were utilized, non-repeatable measurements may result in unneeded testing or maintenance. Therefore, the NRC staff finds that the licensee's proposal to use 0.04 ips as a minimum threshold in the evaluation of vibration velocity is appropriate.
The licensee has also included the pumps in Table 1 in a Predictive Maintenance Program. The NRC staff issued request for additional information (RAI) PRR-011-1 to ask if thermographic analysis and oil sampling and analysis were performed on these pumps, and to clarify if any additional techniques were utilized to monitor the performance of these pumps. In a January 30, 2014, response to RAI PRR-011-1, the licensee stated that thermographic analysis and oil sampling are not performed on these pumps. The licensee further stated that the North and South CCHVAC chilled water pumps are lubricated with grease, which is not typically sampled for analysis. The licensee also clarified that the Preventative Maintenance Program activities include lubrication, inspection, cleaning, and electrical preventative maintenance, and that no additional techniques beyond those described in alternative request PRR-011 are applied to these pumps. The NRC staff determined that the proposed preventative maintenance activities, along with application of the alternative alert and action ranges proposed by the licensee, provide reasonable assurance that the licensee will be able to detect degradation of the pumps listed in Table 1.
Based on the alternative limits proposed by the licensee for vibration monitoring for the pumps listed in Table 1, and the inclusion of these pumps in a predictive maintenance program, the NRC staff finds that the licensee's proposed alternative provides an acceptable level of quality and safety for vibration testing of these pumps.
4.0 CONCLUSION
As set forth above, the NRC staff determines that for alternative request PRR-011 for Fermi 2, the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i) for alternative request PRR-011, and is in compliance with the ASME OM Code requirements.
Therefore, the NRC staff authorizes alternative request PRR-011 for Fermi 2 for the remainder of the third 1 0-year 1ST program interval, which began on February 17, 2010, and is scheduled to end on February 16, 2020. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request remain applicable.
Principal Contributor: Jason Carneal, NRR Date: May 14, 2014
If you have any questions, please contact the NRC Project Manager, Thomas Wengert, at 301-415-4037, or via e-mail at thomas.wengert@nrc.gov.
Docket No. 50-341
Enclosure:
Safety Evaluation cc w/encls: Distribution via ListServ DISTRIBUTION:
PUBLIC LPL3-1 R/F RidsNrrDoriDpr Resource RidsNrrDorllpl3-1 Resource RidsNrrLAMHenderson Resource JCarneal, NRR Accession No.: ML14128A299 OFFICE NRR/LPL3-1/PM NAME TWengert DATE 05/12/14 Sincerely, IRA/
Robert D. Carlson, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsAcrsAcnw_MaiiCTR Resource RidsNrrDeEpnb Resource RidsNrrPMFermi2 Resource RidsRgn3MaiiCenter Resource NRR/LPL3-1/LA NRR/EPNB/BC MHenderson Tlupold*
05/12/14 04/02/14
- via e-mail N RR/LPL3-1 /BC RCarlson 05/14/14 OFFICIAL RECORD COPY