AEP-NRC-2020-51, CFR 50.55a Request Associated with the Fifth Ten-Year Inservice Testing Interval

CFR 50.55a Request Associated with the Fifth Ten-Year Inservice Testing Interval

ML20290A500
Person / Time
Site:	Cook
Issue date:	10/05/2020
From:	Lies Q Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2020-51
Download: ML20290A500 (7)

Text

m INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POWER One Cook Place Bridgman, Ml 49106 A unit ofAmerican Electric Power Indiana Michigan Power.com October 5, 2020 AEP-NRC-2020-51 10 CFR 50.55a Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 10 CFR 50.55a Request Associated with the Fifth Ten-Year lnservice Testing Interval

References:

1. Letter from Q. S. Lies, Indiana Michigan Power Company (l&M), to U. S. Nuclear Regulatory Commission (NRC), "Donald C. Cook Nuclear Plant Units 1 and 2, Fifth 10-Year Interval Pump and Valve lnservice Testing Program," dated June 30, 2016, Agency wide Documents Access and Management System (ADAMS) Accession No. ML16197A057.

Pursuant to 10 CFR 50.55a(f)(5)(i), Indiana Michigan Power Company, the licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, requests U. S. Nuclear Regulatory Commission (NRC) approval of the enclosed 10 CFR 50.55a request associated with the Fifth lnservice Testing Interval (Reference 1) for CNP.

Relief Request REL-PP2 is being submitted under the provisions of 10 CFR 50.55a(z)(1) as an alternative that provides an acceptable level of quality and safety. The applicable 10 CFR 50.55a provision is identified in the relief request.

Approval of the proposed relief request is requested in accordance with the normal NRC review schedule for such relief requests.

U.S. Nuclear Regulatory Commission AEP-NRC-2020-51 Page 2 Mr. Michael K. Scarpello, Regulatory Affairs Director, at (269) 466-2649.

Sinceirely,~A, Q. S ies Site ice resident JMT/mll

Enclosure:

Relief Request (REL-PP2) for Pump and Valve lnservice Test Program for Donald C. Cook Nuclear Plant Fifth Ten-Year Interval c: R. J. Ancona - MPSC.

EGLE - RMD/RPS J. B. Giessner, NRC, Region Ill NRC Resident Inspector S. P. Wall - NRC Washington, D.C.

A. J. Williamson - AEP Ft. Wayne, w/o enclosures

Enclosure to AEP-NRC-2020-51 Relief Request (REL-PP2} for Pump and Valve lnservice Test Program for Donald C. Cook RELIEF REQUEST REL-PP2 Smooth Running Pumps Proposed Alternative In accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Components Affected All pumps in the lnservice Testing (1ST) Program with vibration reference values (Vr) of< 0.05 inches per second (ips). A list of pumps in the program is provided in Table 1, at the end of this Enclosure.

2. Applicable Code Edition and Addenda

ASME OM Code-2004 Edition, with Addenda through 0Mb Code-2006.

3. Applicable Code Requirements

ISTB-3300, "Reference Values" ISTB-3300(a) requires that initial reference values shall be determined from the results of testing meeting the requirements of ISTB-3100, "Preservice Testing," or from the results of the first in-service test.

ISTB-3300(d) requires that reference values shall be established at a point(s) of operation (reference point) readily duplicated during subsequent tests.

ISTB-3300(f) requires that all subsequent test results shall be co'mpared 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" (Centrifugal Pumps, Except Vertical Line Shaft Centrifugal Pumps)

ISTB-5121(e) and ISTB-5123(e), "Group A Test Procedure and Comprehensive Test Procedure", require 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.

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. For example, if vibration exceeds either 6Vr, or 0.7 in/sec, the pump is in the required action range.

Enclosure to AEP-NRC-2020-51 Page2 ISTB-5221(e) and ISTB-5223(e), "Group A Test Procedure and Comprehensive Test Procedure", require that all deviations from the reference values shall be compared with the ranges of Table ISTB-5221-1 and corrective action taken as specified in ISTB-6200. Vibration measurements shall be compared to both the relative and absolute criteria shown in the alert and required action ranges of Table ISTB-5221-1.

ISTB-5320, "lnservice Testing" (Positive Displacement Pumps)

ISTB-5321(e) and ISTB-5323(e), "Group A Test Procedure and Comprehensive Test Procedure", require that all deviations from the reference values shall be compared with the ranges of Table ISTB-5321-1 and corrective action taken as specified in ISTB-6200. Vibration measurements shall be compared to both the relative and absolute criteria shown in the alert and required action ranges of Table ISTB-5321-1.

4. Reason for Request

Relief is being requested for establishing the Vr solely on the basis of data collected during preservice or lnservice testing for those vibration points that have unusually low levels of vibration. This request applies only to values for Vr associated with vibration testing. Small values for Vr result in small acceptable ranges for pump operation. The acceptable range defined in Table ISTB-5121-1, Table ISTB-5221-1 and Table ISTB-5321-1 is less than or equal to 2.5Vr. Based on such a small acceptable range, the smooth running pump (i.e., one that has a very low vibration reference value of ~0.05 ips) could be subject to unnecessary corrective action caused by numerically small changes in vibration levels.

5. Proposed Alternative and Basis for Use

For very small reference values, hydraulic noise and instrument error can be a significant portion of the vibration reading and could affect the repeatability of subsequent measurements.

To avoid unnecessary corrective action, a minimum Vr of 0.05 ips is being established for velocity measurements. Pumps with a measured Vr less than or equal to 0.05 ips for a particular vibration measurement location shall have subsequent test results for that location compared to an acceptable range based on 0.05 ips.

When new reference values are established, the measured parameters will be evaluated for each location to determine if the provisions of this relief request still apply. If the measured Vr is greater than 0.05 ips, the requirements of ISTB-3300 will be applied. Conversely, if the measured Vr is less than or equal to 0.05 ips, a minimum value of 0.05 ips will be used in determining the acceptable, alert, and required action ranges.

In addition to the requirements of ISTB, the pumps in the ASME lnservice Testing Program are included in the DC Cook Predictive Maintenance Program. The DC Cook Predictive Maintenance Program currently employs predictive monitoring techniques such as:

Enclosure to AEP-NRC-2020-51 Page 3

• Vibration monitoring and analysis beyond that required by ISTB.

• Oil sampling and analysis where applicable (e.g., for pumps with sufficient oil). If the measured parameters are outside the normal operating range or are determined by analysis to be trending toward an unacceptable degraded state, appropriate actions are taken that may include:

o Increased monitoring of reservoirs o Establish the rate of change o Review of component and associated system specific information to identify the cause o Removal of the pump from service to perform maintenance It should be noted that all the pumps in the 1ST Program will remain in the DC Cook Predictive Maintenance Program even if certain pumps have very low vibration readings and are considered to be smooth running pumps. This alternative to the requirements of ISTB-3300, ISTB-5120, ISTB-5220 and ISTB-5320, and Table ISTB-5121-1, Table ISTB-5221-1 and Table ISTB-5321-1 provides an acceptable level of quality and safety.

6. Duration of the Proposed Alternative The proposed alternative will be utilized for the duration of the Fifth Ten Year lnservice Testing Interval.

7. Precedents

The following relief requests for other plants are similar and were approved by the Nuclear Regulatory Commission:

Pump Relief Request RP-04 for Sequoyah Nuclear Plant Units 1 and 2 was approved by letter dated May 12, 2016 (ADAMS Accession No. ML16123A131).

Pump Relief Request IST-RR-1 for Watts Bar was approved by letter dated March 10, 2016 (ADAMS Accession No. ML16057A863).

Pump Relief Request P-01 for Millstone was approved by letter dated November 13, 2018 (ADAMS Accession No. ML18290A602).

8. References *

1. ASME OM Code-2004 Edition, with Addenda through 0Mb Code-2006

Enclosure to AEP-NRC-2020-51 Page 4 T ... ._,_ "' 111~T n -- ___ ,,

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Code OM Pump Groups System Description Pump Type Class Group 1-PP-10E Component 3 A Component Cooling Centrifugal 1-PP-10W Cooling Water Water Pump 1-PP-26N Emergency 2 B Safety Injection Pump Centrifugal 1-PP-26S Core Cooling 1-PP-3E Auxiliary 2 A Motor Driven Auxiliary Centrifugal 1-PP-3W Feedwater Feedwater Pump 1-PP-4 Auxiliary 3 B Turbine Driven Centrifugal Feedwater Auxiliary Feedwater Pump 1-PP-35E Residual Heat 2 A Residual Heat Centrifugal 1-PP-35W Removal Removal Pump 1-PP-46-1 Chemical and 3 A Boric Acid Storage Centrifugal 1-PP-46-2 Volume Control Tanks Transfer Pump 1-PP-50E Emergency 2 A Centrifugal Charging Centrifugal 1-PP-50W Core Cooling Pump 1-PP-?E Essential 3 A Essential Service Centrifugal 1-PP-?W Service Water Water Pump 1-PP-9E Containment 3 A Containment Spray Centrifugal 1-PP-9W Spray Pump 1-QT-106-AB1 Diesel Fuel Oil Non B Diesel Fuel Oil Positive I

1-QT-106-AB2 Transfer Class Transfer Pump Displacement 1-QT-106-CD1 1-QT-106-CD2 i

1-QT-130-AB1 Diesel Jacket Non A Diesel Jacket Water Centrifugal 1-QT-130-AB2 Water Cooling Class Cooling Pump 1-QT-130-CD1 1-QT-130-CD2 12-PP-31 N Spent Fuel Pool 3 A Spent Fuel Pit Pump Centrifugal 12-PP-31S 2-PP-10E Component 3 A Component Cooling Centrifugal 2-PP-10W Cooling Water Water Pump 2-PP-26N Emergency 2 B Safety Injection Pump Centrifugal 2-PP-26S Core Cooling

Enclosure to AEP-NRC-2020-51 Page 5 2-PP-3E Auxiliary

__ 2 A Motor Driven Auxiliary Centrifugal I  ?-DD_ 'l\111 .... _____

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I t;;t;;Uvvalt;;I t"UllifJ 2-PP-4 Auxiliary 3 B Turbine Driven Centrifugal Feedwater Auxiliary Feedwater Pump 2-PP-35E Residual Heat 2 A Residual Heat Centrifugal 2-PP-35W Removal Removal Pump 2-PP-46-3 Chemical and 3 A Boric Acid Storage Centrifugal I 2-PP-46-4 Volume Control Tanks Transfer Pump 2-PP-50E Emergency 2 A Centrifugal Charging Centrifugal 2-PP-50W Core Cooling Pump 2-PP-7E Essential 3 A Essential Service Centrifugal 2-PP-7W Service Water Water Pump 2-PP-9E Containment 3 A Containment Spray Centrifugal 2-PP-9W Spray Pump 2-QT-106-AB1 Diesel Fuel Oil Non B Diesel Fuel Oil Positive 2-QT-106-AB2 Transfer Class Transfer Pump Displacement 2-QT-106-CD1 2-QT-106-CD2 2-QT-130-AB 1 Diesel Jacket Non A Diesel Jacket Water Centrifugal 2-QT-130-AB2 Water Cooling Class Cooling Pump 2-QT-130-CD 1 2-QT-130-CD2