NRC-14-0079, Notification of Deviation from BWRVIP-205 Guidelines
| ML14325A521 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/21/2014 |
| From: | Kaminskas V DTE Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC-14-0079 | |
| Download: ML14325A521 (3) | |
Text
Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasv@dteenergy.com DTE Enegy-November 21, 2014 NRC-14-0079 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001
References:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
- 2) BWRVIP-205, BWR Vessel and Internals Project, Bottom Head Drain Line Inspection and Evaluation Guidelines.
EPRI, Palo Alto, CA: 2008. 1018428.
- 3) BWRVIP-94NP, Revision 2: BWR Vessel and Internals Project Program Implementation Guide. EPRI, Palo Alto, CA: 2011. 1024452.
- 4) DTE Electric Company Letter to NRC, "Notification of Deviation from BWRVIP-205 Guidelines," NRC-12-0068, dated October 19, 2012 (ML12296A082)
Subject:
Notification of Deviation from BWRVIP-205 Guidelines The purpose of this letter is to notify the Nuclear Regulatory Commission (NRC) of a deviation from the Boiling Water Reactor Vessel and Internals Project (BWRVIP) guideline for the inspection of the Reactor Water Cleanup (RWCU) bottom head drain line (Reference 2) at Fermi 2. DTE Electric Company (DTE) is a member of the BWRVIP and has committed to implementing applicable BWRVIP products as provided in Reference 3 and to notify the NRC staff if an applicable BWRVIP product was not implemented. This notification is due within 45 days of DTE Executive's concurrence with the Deviation Disposition.
A Deviation Disposition for the RWCU bottom head drain line was signed by the Fermi 2 Site Vice President on October 17, 2014. The deviation is from a guideline that is designated as "needed" by the BWRVIP. The guidance requires that inspections of the RWCU bottom head drain line be performed using methods such as ultrasonic testing or radiography. Due to the location of the drain line nozzle, remote methods and
USNRC NRC-14-0079 Page 2 specialized tooling must be utilized. This requirement is applicable to plants ranked as Category C by the Electric Power Research Institute (EPRI) in Reference 2. This piping wall thickness examination at Fermi 2 was scheduled to be completed during the sixteenth refueling outage (RF16) which ended on April 5, 2014.
DTE attempted a radiography inspection of the RWCU bottom drain line per the requirements in Reference 2. This inspection was not successfully completed during RF 16 due to obstructions preventing the inspection tool from reaching the inspection location. Reference 4 provided previous notification to the NRC regarding the results of inspections attempted in the fifteenth refueling outage (RF15) on this piping.
The Deviation Disposition recently submitted to the BWRVIP concluded that operation of the RWCU bottom head drain line at Fermi 2 is acceptable until the eighteenth refueling outage (RF18) currently planned for the Spring of 2017. The Deviation Disposition conclusion is based on successful inspections at other plants with similar Flow Accelerated Corrosion (FAC) susceptibility to Fermi 2, which found no FAC wall thinning on the RWCU bottom head drain line. In addition, examinations were performed during RF 15 and RF 16 at Fermi 2 on similar RWCU under vessel piping and other RWCU piping considered more susceptible to FAC compared to the bottom head drain line. These examinations supported the conclusion in the Deviation Disposition allowing DTE to complete the RWCU bottom head drain line inspection in RF18.
The RWCU bottom head drain line inspection is currently planned to be completed by RF 18. A more detailed access study of the under vessel area will be performed during the seventeenth refueling outage (RF 17) in the Fall of 2015 to determine an alternate inspection strategy that can be utilized to successfully perform the inspection in RF 18.
This letter is being transmitted to the NRC for information only, based on the requirement in Reference 3.
No regulatory commitments are included in this letter.
Should you have any questions or require additional information, please contact Mr.
Christopher R. Robinson at (734) 586-5076.
Sincerely,
USNRC NRC-14-0079 Page 3 cc:
NRC Plant Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III NRC BWRVIP Project Manager Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)