JAFP-14-0096, Response to Request for Additional Information Regarding 10 CFR 50.55a Request PRR-05

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Response to Request for Additional Information Regarding 10 CFR 50.55a Request PRR-05
ML14213A115
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 07/31/2014
From: Adner C
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-14-0096, TAC MF3680
Download: ML14213A115 (9)


Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

  • James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Chris M. Adner Regulatory Assurance Manager JAF JAFP-1 4-0096 July 31, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Response to Request for Additional Information Regarding 10 CFR 50.55a Request PRR-05 (TAC No. MF3680)

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59

References:

1. Entergy letter, James A. FitzPatrick Nuclear Power Plant Inservice Testing Program 10 CFR 50.55a Request PRR-05, JAFP-14-0012, dated February 21, 2014
2. NRC letter, James A. FitzPatrick Nuclear Power Plant Request for Additional Information Regarding 10 CFR 50.55a Request PRR-05 (TAC NO. MF3680), dated July 2, 2014 Pursuant to 10 CFR 50.55a(a)(3)(ii), James A. FitzPatrick Nuclear Power Plant (JAF) requested NRC approval of the proposed alternative to the vibration criteria requirements of ASME OM Code ISTB Table ISTB-5100-1 and associated sections (ISTB-5121(e), ISTB-5122(b), and ISTB-6200(a)) [Reference 1].

In processing the submittal, the NRC determined that additional information was required to complete the review [Reference 2]. The specific questions provided to JAF in the NRC request for additional information (RAI) are addressed in the attachment to this letter.

There are no regulatory commitments in this submittal. Should you have any questions please contact Mr. Chris M. Adner at 315-349-6766.

Sincerely, Chris M. Adner Regulatory Assurance Manager CMA:ds

JAFP-14-0096 Page 2 of 2 Attachments: Response to Request for Additional Information cc: USNRC, Regional Administrator, Region I USNRC, Project Directorate USNRC, Resident Inspector

JAFP-14-0096 ATTACHMENT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (6 Pages)

JAFP-14-0096 Attachment Response to Request for Additional Information RAI PRR-05-1 Alternative request PRR-05 states that three vibration points are available from December of 1998 to present. However, Figures 12 through 20 in the submittal of PRR-005 do not contain data from the third vibration point (V3, axial direction) for pumps 10P-3B and 10P-3C. Please provide figures showing V3 (axial direction) as a function of time from December 1998 to present and a sample spectral analysis of the data measured in the V3 direction for pumps 10P-3B and 10P-3C.

Response

Vibration data, including axial (V3) measurements, is provided for pumps 10P-3B and 10P-3C in Figures 1 and 2. All data was recorded in units of inches per second, and is provided as a function of time from December 1998 to present. A sample spectral analysis of the axial vibration data for pumps 10P-3B and 10P-3C is provided in Figures 3 and 4.

Page 1 of 6

JAFP-14-0096 Attachment Response to Request for Additional Information Figure 1 - Pump 10P-3B Vibration Data Page 2 of 6

JAFP-14-0096 Attachment Response to Request for Additional Information Figure 2 - Pump 10P-3C Vibration Data Page 3 of 6

JAFP-14-0096 Attachment Response to Request for Additional Information Figure 3 - Pump 10P-3B Spectral Analysis Page 4 of 6

JAFP-14-0096 Attachment Response to Request for Additional Information Figure 4 - Pump 10P-3C Spectral Analysis Page 5 of 6

JAFP-14-0096 Attachment Response to Request for Additional Information RAI PRR-05-2 Alternative request PRR-05, under "Consultation - Pump Manufacturer I Vibration Expert,"

states that the pump vendor was contacted during the initial investigation of the cause for failed vibration acceptance criteria. Under "Basis for Code Alternative Alert Values," alternative request PRR-05 states that the basis for the 0.408 inches per second (ips) alert limit comes from the Technical Associates of Charlotte recommendations for vertical pumps. Is this recommendation applicable to all vertical pumps or were these recommendations developed specifically for residual heat removal (RHR) pumps 10P-3A, 10P-3B, 10P-3C, or 10P-3D?

Please provide any comments the pump vendor had regarding the recommended vibration alert values.

Response

The Technical Associates of Charlotte (TA) were consulted as part of establishing vibration criteria for the JAF Predictive Maintenance (PdM) Program. TA recommended 0.350 and 0.525 ips as bounding vibration values for vertical pumps. The JAF PdM incorporated 0.350 ips as the Watch criterion, and 0.525 ips as the Restricted criterion. In addition, the JAF PdM included two additional Warning Levels at 0.408 and 0.466 ips. These values are applicable to all vertical pumps in the JAF PdM. The new alert acceptance criterion requested in PRR-05 coincides with the lesser of these Warning Levels, at 0.408 ips.

The RHR Pump vendor (Byron Jackson, now owned by Flowserve) did not recommend a specific value regarding the increased vibration alert limit, but stated that the pumps should not be adversely impacted provided that no upward trend existed in the vibration measurement data.

RAI PRR-05-3 Alternative request PRR-05 proposes an alternative alert level for pumps 10P-3A, 10P-3B, 10P-3C, and 10P-3D. To date, the ASME OM Code alert range value of 0.325 ips has been exceeded only on pumps 10P-3B and 10P-3C. Please provide justification on why the alternative request is necessary for RHR pumps 10P-3A and 10P-3D.

Response

RHR pumps 10P-3A and 10P-3C are common to Train A; 10P-3B and 10P-3D are common to Train B. JAF is requesting to apply the increased vibration alert limit to all four pumps due to the IST Program implementing procedures, which require increased frequency testing of both pumps in each particular train if the ASME OM Code alert range value is exceeded. Compliance with this requirement contributes to JAFs conclusion that the current vibration alert limit results in a Hardship or Unusual Difficulty without a Compensating Increase in Level of Quality or Safety.

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