NRC-10-0023, Response to Request for Additional Information Regarding Relief Requests PRR-004, PRR-005, PRR-007 and PRR-010 for the Inservice Testing Program Third Ten-Year Interval

Response to Request for Additional Information Regarding Relief Requests PRR-004, PRR-005, PRR-007 and PRR-010 for the Inservice Testing Program Third Ten-Year Interval

ML100820061
Person / Time
Site:	Fermi
Issue date:	03/22/2010
From:	Plona J DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-10-0023
Download: ML100820061 (13)

Text

Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport, MI 48166 Tel:

734.586.5910 Fax: 734.586.4172 DTE Energy 10 CFR 50.55a March 22, 2010 NRC-10-0023 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) Detroit Edison's Letter to NRC, "Submittal of the Inservice Testing Program Relief Requests for Pumps and Valves - Third Ten-year Interval," NRC-09-0064, dated November 3, 2009

Subject:

Response to Request for Additional Information Regarding Relief Requests PRR-004, PRR-005, PRR-007 and PRR-010 for the Inservice Testing Program Third Ten-Year Interval In Reference 2, Detroit Edison submitted proposed Relief Requests for the third ten-year interval of the Inservice Testing (IST) Program for Pumps and Valves. In an e-mail from Mr. Mahesh Chawla to Mr. Alan Hassoun dated February 5, 2010, the NRC requested additional information for Relief Requests PRR-004, Residual Heat Removal Pumps Vibration Alert Limits; PRR-005, Smooth Running Pump Vibration Acceptance Criteria; PRR-007, Relief from Comprehensive Pump Testing for Centrifugal Pumps; and PRR-010, Relief from Comprehensive Pump Testing for Standby Liquid Control and Diesel Generator Fuel Oil Transfer Pumps. This was discussed in a subsequent telephone conversation between NRC staff and Detroit Edison personnel on February 23, 2010. The additional information requested by NRC staff is enclosed.

There are no new commitments included in this document.

Should you have any questions or require additional information, please contact Mr.

Rodney W. Johnson of my staff at (734) 586-5076.

Sincerely,

^_^

.t/

76/^ -

Joseph H. Piona Site Vice President 6400 N. Dixie Highway, Newport, MI 481G6 Tel: 734.586.5910 Fa,x: 734.586.4172 10 CFR 50.55a March 22, 2010 NRC-10-0023

u. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington DC 20555-0001

References:

1) Fermi 2

Subject:

NRC Docket No. 50-341 NRC License No. NPF-43

2) Detroit Edison's Letter to NRC, "Submittal of the Inservice Testing Program Relief Requests for Pumps and Valves - Third Ten-year Interval," NRC-09-0064, dated November 3, 2009 Response to Request for Additional Information Regarding Relief Requests PRR-004, PRR-005, PRR-007 and PRR-OlO for the Inservice Testing Program Third Ten-Year Interval In Reference 2, Detroit Edison submitted proposed Relief Requests for the third ten-year interval of the Inservice Testing (1ST) Program for Pumps and Valves. In an e-mail from Mr. Mahesh Chawla to Mr. Alan Hassoun dated Febmary 5, 2010, the NRC requested additional infOlmation for Relief Requests PRR-004, Residual Heat Removal Pumps Vibration Alert Limits; PRR-005, Smooth Running Pump Vibration Acceptance Criteria; PRR-007, Relief from Comprehensive Pump Testing for Centrifugal Pumps; and PRR-OlO, Relief from Comprehensive Pump Testing for Standby Liquid Control and Diesel Generator Fuel Oil Transfer Pumps. This was discussed in a subsequent telephone conversation between NRC staff and Detroit Edison personnel on Febmary 23, 2010. The additional information requested by NRC staff is enclosed.

There are no new commitments included in this document.

Should you have any questions or require additional information, please contact Mr.

Rodney W. Johnson of my staff at (734) 586-5076.

Sincerely, C)y(llb~~-

USNRC NRC-10-0023 Page 2 Enclosure cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission USNRC NRC-IO-0023 Page 2 Enclosure cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

Enclosure To NRC-10-0023 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to Request for Additional Information Regarding Relief Requests PRR-004, PRR-005, PRR-007 and PRR-010 for the Inservice Testing Program Third Ten-Year Interval Enclosure To NRC-10-0023 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF -43 Response to Request for Additional Information Regarding Relief Requests PRR-004, PRR-005, PRR-007 and PRR-010 for the Inservice Testing Program Third Ten-Year Interval

Enclosure to NRC-10-0023 Page 1 The following is Detroit Edison's response to each NRC request for additional information (RAI):

RAI-PRR-004-01 Relief Request PRR-004 provides vibration data (Figures 1 thru 6) on pages 27 thru 32 of

79. ISTB-3540 provides the physical location on a pump for vibration measurements.

Relief Request Figure 17 shows the vibration monitoring points on the RHR motor/pump assembly, but these points do not show their physical location clearly. Please describe the physical location of points, EA1, EA2, EA3, EC1, and EC2 as required by ISTB-3540 for vibration measurements.

RESPONSE

The physical location of the vibration measurement points requested are:

EA1 - Radial 0 deg measurement on top portion of motor in line with upper bearing housing EA2 - Radial 90 deg measurement on top portion of motor in line with upper bearing housing EA3 - Axial at 0 deg measurement on top of motor upper end bell EC1 - Radial 0 deg measurement on top portion of pump casing EC2 - Radial 90 deg measurement on top portion of pump casing RAI-PRR-004-02 Please confirm that vibration data shown on Figures 1 thru 6 are measured as peak and inch/second.

RESPONSE

All vibration data shown on Figures 1 thru 6 in PRR-004 are the measurements of Peak Total Amplitude and all are in the units of inches per second. These measurements are in accordance with the requirements of ISTB-5123(d).

RAI-PRR-004-03 During the Fermi 2 Second 10-year IST interval, the licensee requested and NRC staff authorized relief to change the "Alert" range from 0.325 in/sec thru 0.7 in/sec to 0.4 in/sec.

thru 0.7 in/sec for EA1, EA2 and EA3 points. Whereas for the Fermi 2 third 10-year IST interval, the licensee is requesting relief to change the "Alert" range from 0.325 in/sec thru 0.7 in/sec to 0.415 in/sec thru 0.7 in/sec for all five points (EA1, EA2, EA3, EC1, and EC2).

Please explain and justify that (1) the new increased vibration level (Alert Range from 0.4 in/sec to 0.415 in/sec) is not a sign of degradation of RHR pumps; and (2) the new Alert Enclosure to NRC-IO-0023 Page 1 The following is Detroit Edison's response to each NRC request for additional information (RAI):

RAI -PRR-004-01 Relief Request PRR-004 provides vibration data (Figures 1 thru 6) on pages 27 thru 32 of

79. 1STB-3540 provides the physical location on a pump for vibration measurements.

Relief Request Figure 17 shows the vibration monitoring points on the RHR motor/pump assembly, but these points do not show their physical location clearly. Please describe the physical location of points, EAI, EA2, EA3, ECI, and EC2 as required by 1STB-3540 for vibration measurements.

RESPONSE

The physical location of the vibration measurement points requested are:

EAI - Radial 0 deg measurement on top portion of motor in line with upper bearing housing EA2 - Radial 90 deg measurement on top portion of motor in line with upper bearing housing EA3 - Axial at 0 deg measurement on top of motor upper end bell ECI - Radial 0 deg measurement on top portion of pump casing EC2 - Radial 90 deg measurement on top portion of pump casing RAI -PRR-004-02 Please confirm that vibration data shown on Figures 1 thru 6 are measured as peak and inch/second.

RESPONSE

All vibration data shown on Figures 1 thru 6 in PRR-004 are the measurements of Peak Total Amplitude and all are in the units of inches per second. These measurements are in accordance with the requirements ofISTB-5123(d).

RAI -PRR-004-03 During the Fermi 2 Second lO-year 1ST interval, the licensee requested and NRC staff authorized relief to change the "Aleli" range from 0.325 in/sec thru 0.7 in/sec to 0.4 in/sec.

thru 0.7 in/sec for EAI, EA2 and EA3 points. Whereas for the Fenni 2 third lO-year 1ST interval, the licensee is requesting relief to change the "Alert" range from 0.325 in/sec thru 0.7 in/sec to 0.415 in/sec thru 0.7 in/sec for all five points (EAI, EA2, EA3, ECI, and EC2).

Please explain and justify that (1) the new increased vibration level (Alert Range from 0.4 in/sec to 0.415 in/sec) is not a sign of degradation of RHR pumps; and (2) the new Alert

Enclosure to NRC-10-0023 Page 2 Range requested for all the EA1, EA2, EA3, EC1, and EC2 points instead of EA1, EA2, and EA3 points is not a sign of degradation of the RHR pumps.

RESPONSE

Relief Request PRR-004 provides RHR pump differential pressure trend graphs since 1990 (Figures 7 through 10 provided with the Relief Request). The figures indicate no evidence of pump degradation. These pumps do exhibit a very slight upward trend in Peak Total Amplitude vibration data; however, this upward trend is directly attributable to long term motor bearing degradation. The degradation rate is low and well within the existing timeframe for scheduled motor PMs. The slowly increasing nominal vibration readings combined with the flow-noise induced fluctuation problem described in the Relief Request increases the likelihood of exceeding the current Alert criteria. Detroit Edison is confident that we can accurately track the motor condition and that any change in the degradation rate will be evident. Increasing the Alert criteria to 0.415 provides the necessary margin to the true vibration levels such that flow-noise induced fluctuations will not unnecessarily trigger Alert criteria.

All of the vibration monitoring locations are subject to some degree of flow-noise induced fluctuation; however, it is highest at the EA1, EA2 and EA3 points. Including the EC1 and EC2 points in the Relief Request considers the slow increase in nominal values over the next ten years and provides for consistency in the procedural guidance.

RAI-PRR-004-04 During the Fermi 2 Second 10-year IST interval, the relief was only authorized for RHR pumps B and C. For the Fermi third 10-year IST interval, the relief is being requested for all the RHR pumps A, B, C, and D. Please justify that the increased vibration measurement requested for all RHR pumps A, B. C, and D instead of only B and C is a not a sign of pump degradation.

RESPONSE

Vibration from flow-noise fluctuations and the 0.325 Alert level has resulted in early, costly and unnecessary RHR pump motor testing and replacement. For example, the testing frequency for RHR pump A motor was doubled in 2005 resulting in a replacement in 2007 as a corrective action for the several instances of flow-noise induced fluctuations above the 0.325 Alert level. However, pre and post motor replacement data indicates that minimal vibration improvement was achieved. RHR pump D has also resulted in many instances of triggering Alert level over the last several years. Relief Request PRR-004 seeks to provide reasonable criteria for all four pumps to avoid unnecessary testing and costly rework, while still assuring the ability to detect and monitor for degrading trends. Pump degradation is addressed in the response to RAI-PRR-004-03 above.

Enclosure to NRC-lO-0023 Page 2 Range requested for all the EAl, EA2, EA3, ECl, and EC2 points instead of EAl, EA2, and EA3 points is not a sign of degradation of the RHR pumps.

RESPONSE

Relief Request PRR-004 provides RHR pump differential pressure trend graphs since 1990 (Figures 7 through 10 provided with the Relief Request). The figures indicate no evidence of pump degradation. These pumps do exhibit a very slight upward trend in Peak Total Amplitude vibration data; however, this upward trend is directly attributable to long term motor bearing degradation. The degradation rate is low and well within the existing timeframe for scheduled motor PMs. The slowly increasing nominal vibration readings combined with the flow-noise induced fluctuation problem described in the Relief Request increases the likelihood of exceeding the current Alert criteria. Detroit Edison is confident that we can accurately track the motor condition and that any change in the degradation rate will be evident. Increasing the Alert criteria to 0.415 provides the necessary margin to the true vibration levels such that flow-noise induced fluctuations will not unnecessarily trigger Alert criteria.

All of the vibration monitoring locations are subject to some degree of flow-noise induced fluctuation; however, it is highest at the EAl, EA2 and EA3 points. Including the ECI and EC2 points in the Relief Request considers the slow increase in nominal values over the next ten years and provides for consistency in the procedural guidance.

RAI -PRR-004-04 During the Fermi 2 Second lO-year 1ST interval, the relief was only authorized for RHR pumps Band C. For the Fermi third lO-year 1ST interval, the relief is being requested for all the RHR pumps A, B, C, and D. Please justify that the increased vibration measurement requested for all RHR pumps A, B. C, and D instead of only Band C is a not a sign of pump degradation.

RESPONSE

Vibration from flow-noise fluctuations and the 0.325 Alert level has resulted in early, costly and unnecessary RHR pump motor testing and replacement. For example, the testing frequency for RHR pump A motor was doubled in 2005 resulting in a replacement in 2007 as a corrective action for the several instances of flow-noise induced fluctuations above the 0.325 Alert level. However, pre and post motor replacement data indicates that minimal vibration improvement was achieved. RHR pump D has also resulted in many instances of triggering Alert level over the last several years. Relief Request PRR-004 seeks to provide reasonable criteria for all four pumps to avoid unnecessary testing and costly rework, while still assuring the ability to detect and monitor for degrading trends. Pump degradation is addressed in the response to RAI-PRR-004-03 above.

Enclosure to NRC-10-0023 Page 3 RAI-PRR-005-01 In Pump Relief Request PRR-005, the licensee is requesting relief for various pumps at Fermi 2. The ASME OM Code acceptance criteria of vibration for various pumps are different for various types of pumps, as specified in various Tables ISTB-5121-1, ISTB-5221-1, ISTB-5321-1, and ISTB-5321-2. The various pumps are (1) centrifugal pumps (except vertical line shaft centrifugal pumps); (2) vertical line shaft centrifugal pumps; (3) positive displacement pumps (except reciprocating); and (4) reciprocating positive displacement pumps. Therefore, please provide the following information related to each pump listed in PRR-005.

(1) Type of pump; (2) Description of pump; (3) Pump Categories: Group A or B based on its function as defined in ISTB; and (4) Pump operating speed (rpm), because pump operating speed is a critical component in the vibration acceptance criteria.

RESPONSE

The response to RAI-PRR-005-01 is combined with that for RAI-PRR-005-02 below.

RAI-PRR-005-02 Relief Request PRR-005 lists all the applicable pumps on page 47 thru 48 and provides measured reference vibration values at points EA1, EA2, EA3, EC1, and EC2. (1) Please describe the physical location of these points, and (2) Please confirm that pumps' vibration values provided are based on historical data.

RESPONSE

The Table below provides responses to both RAI-PRR-005-01 and RAI-PRR-005-02:

ISTB Pump Operating Vibration PIS No.

Pump Name Category Type ()

Speed Points (2)

RHR Service E1151C001A RHRerce A

VLSC 1800 Fig. 1 Water Pump A B

RHR Service 1800 Fig. 1 E1151C001B A

VLSC Water Pump B E1151C C

RHR Service 1800 Fig. 1 EWt51C001C A

VLSC Water Pump C Enclosure to NRC-1O-0023 Page 3 RAI-PRR-005-01 In Pump Relief Request PRR-005, the licensee is requesting relief for various pumps at Fermi 2. The ASME OM Code acceptance criteria of vibration for various pumps are different for various types of pumps, as specified in vmious Tables ISTB-5121-1, ISTB-5221-1, ISTB-5321-1, and ISTB-5321-2. The various pumps m'e (1) centrifugal pumps (except vertical line shaft centrifugal pumps); (2) vertical line shaft centrifugal pumps; (3) positive displacement pumps (except reciprocating); and (4) reciprocating positive displacement pumps. Therefore, please provide the following information related to each pump listed in PRR-005.

(1) Type of pump; (2) Description of pump; (3) Pump Categories: Group A or B based on its function as defined in ISTB; and (4) Pump operating speed (rpm), because pump operating speed is a critical component in the vibration acceptance criteria.

RESPONSE

The response to RAI-PRR-005-01 is combined with that for RAI-PRR-005-02 below.

RAI-PRR-005-02 Relief Request PRR-005 lists all the applicable pumps on page 47 thru 48 and provides measured reference vibration values at points EA1, EA2, EA3, EC1, and EC2. (1) Please desclibe the physical location of these points, and (2) Please confilID that pumps' vibration values provided are based on historical data.

RESPONSE

The Table below provides responses to both RAI-PRR-005-01 and RAI-PRR-005-02:

PIS No.

Pump Name ISTB Pump Operating Vibration Category Type (1)

Speed Points (2)

E1l51COOIA RHR Service A

VLSC 1800 Fig. 1 Water Pump A E1l51COOlB RHR Service A

VLSC 1800 Fig. 1 WaterPumpB E1l51COOIC RHR Service A

VLSC 1800 Fig. 1 Water Pump C

Enclosure to NRC-10-0023 Page 4 ISTB Pump Operating Vibration PIS No.

Pump Name Category Type (

Speed Points 2)

E1151C D

RHR Service 1800 Fig. 1 E1151C001D A

VLSC Water Pump D Emergency Equip 1800 Fig. 2 P4400C001A Cooling Water B

CENT Div 1 Pump Emergency Equip 1800 Fig. 2 P4400C001B Cooling Water B

CENT Div 2 Pump P4400C02A EECW Makeup 1800 Fig. 2 P4400C002A B

CENT Div 1 Pump P4400C02B EECW Makeup 1800 Fig. 2 P4400C002B B

CENT Div 2 Pump Emergency Equip 1800 Fig. 1 P4500C002A Service Water B

VLSC South Pump Emergency Equip 1800 Fig. 1 P4500C002B Service Water B

VLSC North Pump EDG 11 Diesel 1200 Fig. 2 R3000C001 Fuel Oil Xfer B

PD Pump A EDG 12 Diesel 1200 Fig. 2 R3000C002 Fuel Oil Xfer B

PD Pump A EDG 11 Diesel 1200 Fig. 2 R3000C003 Fuel Oil Xfer B

PD Pump B EDG 12 Diesel 1200 Fig. 2 R3000C004 Fuel Oil Xfer B

PD Pump B EDG 13 Diesel 1200 Fig. 2 R3000C009 Fuel Oil Xfer B

PD Pump A EDG 14 Diesel 1200 Fig. 2 R3000C010 Fuel Oil Xfer B

PD Pump A EDG 13 Diesel 1200 Fig. 2 R3000C011 Fuel Oil Xfer B

PD Pump B EDG 14 Diesel 1200 Fig. 2 R3000C012 Fuel Oil Xfer B

PD Pump B EDG 11 DG 1800 Fig. 1 R3001C005 Service Water B

VLSC Pump Enclosure to NRC-lO-0023 Page 4 PIS No.

E1151C001D P4400C001A P4400COOlB P4400C002A P4400C002B P4500C002A P4500C002B R3000C001 R3000C002 R3000C003 R3000C004 R3000C009 R3000COlO R3000C011 R3000C012 R3001C005 Pump Name RHR Service WaterPumpD Emergency Equip Cooling Water Div 1 Pump Emergency Equip Cooling Water Div2Pump EECWMakeup Div 1 Pump EECWMakeup Div2Pump Emergency Equip Service Water South Pump Emergency Equip Service Water North Pump EDG 11 Diesel Fuel Oil Xfer Pump A EDG 12 Diesel Fuel Oil Xfer Pump A EDG 11 Diesel Fuel Oil Xfer PumpB EDG 12 Diesel Fuel Oil Xfer PumpB EDG 13 Diesel Fuel Oil Xfer Pump A EDG 14 Diesel Fuel Oil Xfer Pump A EDG 13 Diesel Fuel Oil Xfer PumpB EDG 14 Diesel Fuel Oil Xfer PumpB EDG 11 DG Service Water Pump ISTB Pump Operating Vibration Category Type (1)

Speed Points (2)

A VLSC 1800 Fig. 1 1800 Fig. 2 B

CENT 1800 Fig. 2 B

CENT B

CENT 1800 Fig. 2 B

CENT 1800 Fig. 2 1800 Fig. 1 B

VLSC 1800 Fig. 1 B

VLSC 1200 Fig. 2 B

PD 1200 Fig. 2 B

PD 1200 Fig. 2 B

PD 1200 Fig. 2 B

PD 1200 Fig. 2 B

PD 1200 Fig. 2 B

PD 1200 Fig. 2 B

PD 1200 Fig. 2 B

PD 1800 Fig. 1 B

VLSC

Enclosure to NRC-10-0023 Page 5 ISTB Pump Operating Vibration PIS No.

Pump Name (1)

SCategory Type Speed Points (2)

EDG 12 DG 1800 Fig. 1 R3001C006 Service Water B

VLSC Pump EDG 13 DG 1800 Fig. 1 R3001C007 Service Water B

VLSC Pump EDG 14 DG 1800 Fig. 1 R3001C008 Service Water B

VLSC Pump Pump type codes:

(1)

(CENT)

Centrifugal pump (except vertical line shaft centrifugal pump)

(VLSC)

Vertical line shaft centrifugal pump (PD)

Positive displacement pump (except reciprocating)

(2)

Vibration monitoring point locations are shown on Figures 1 and 2 below.

Figure 1 - VLSC Figure 2 - Centrifugal horizontal j

SIDE VIEW The measured reference vibration values provided in the Relief Request are the IST reference values for the particular monitoring point. These reference values were established during baseline testing at reference flow when the pump was known to be operating acceptably.

Enclosure to NRC-10-0023 Page 5 PIS No.

R3001C006 R3001C007 R3001C008 Pump type codes:

Pump Name ISTB Category EDG12DG Service Water B

Pump EDG 13DG Service Water B

Pump EDG14DG Service Water B

Pump Pump Operating Vibration Type (1)

Speed Points (2) 1800 Fig. 1 VLSC 1800 Fig. 1 VLSC 1800 Fig. 1 VLSC (1)

(CENT)

Centrifugal pump (except vertical line shaft centrifugal pump)

(VLSC)

Vertical line shaft centrifugal pump (PD)

Positive displacement pump (except reciprocating)

(2)

Vibration monitoring point locations are shown on Figures 1 and 2 below.

Figure 1 - VLSC Figure 2 - Centrifugal horizontal r-B

~

.-c~=~L-l __ ~

~

-+-_-'

\\::J Sll)EVIEW The measured reference vibration values provided in the Relief Request are the 1ST reference values for the particular monitoring point. These reference values were established during baseline testing at reference flow when the pump was known to be operating acceptably.

Enclosure to NRC-10-0023 Page 6 RAI-PRR-005-03 Relief Request PRR-005 establishes a vibration reference value (Vr) of 0.04 in/sec (Fermi selected value) for smooth running pumps. The relief request lists all of the pumps with Vr above and below values of 0.04 in/sec. For a smooth-running pump, the measured vibration values at all points (EA1, EA2, EA3, EC1, and EC2) must be less or equal to established reference value Vr. Therefore, please explain how all of the pumps included in PRR-05 are defined as smooth-running pumps since many have vibration values greater than 0.04 in/sec.

RESPONSE

There is no definition of smooth-running pump provided in ASME OM 2004, NUREG-1482 Rev. 1 or Generic Letter 89-04. Relief Request PRR-005 defines smooth-running pumps as those having one or more vibration reference values at or below 0.04 in/sec, which is slightly more conservative than the three approved relief requests cited in the Precedents section of the Relief Request. The Relief Request proposes the use of a minimum reference value of 0.04 only for those points and pumps identified in PRR-005 which are below 0.04.

RAI-PRR-005-04 Please confirm that the Preventive and Predictive Maintenance Program for the specified pumps at Fermi 2 includes such items as bearing temperature trending, oil sampling and analysis, and thermographic analysis including with enhanced vibration monitoring.

RESPONSE

Preventive and Predictive Maintenance Program elements for the specified pumps are shown in the following table:

PIS No.

Pump Name

?

I I

4 0

E1151C001A RHR Service Water Pump A X

X X

X E1151C001B RHR Service Water Pump B X

X X

X E1151C001C RHR Service Water Pump C X

X X

X E1151C001D RHR Service Water Pump D X

X X

X Enclosure to NRC-IO-0023 Page 6 RAI-PRR-005-03 Relief Request PRR-005 establishes a vibration reference value (Vr) of 0.04 in/sec (Fermi selected value) for smooth running pumps. The relief request lists all of the pumps with Vr above and below values of 0.04 in/sec. For a smooth-running pump, the measured vibration values at all points (EAI, EA2, EA3, ECI, and EC2) must be less or equal to established reference value Vr. Therefore, please explain how all of the pumps included in PRR-05 are defined as smooth-running pumps since many have vibration values greater than 0.04 in/sec.

RESPONSE

There is no definition of smooth-running pump provided in ASME OM 2004, NUREG-1482 Rev. I or Genetic Letter 89-04. Relief Request PRR-005 defines smooth-running pumps as those having one or more vibration reference values at or below 0.04 in/sec, which is slightly more conservative than the three approved relief requests cited in the Precedents section of the Relief Request. The Relief Request proposes the use of a minimum reference value of 0.04 only for those points and pumps identified in PRR-005 which are below 0.04.

RAI -PRR-005-04 Please confirm that the Preventive and Predictive Maintenance Program for the specified pumps at Fermi 2 includes such items as beating temperature trending, oil sampling and analysis, and thermographic analysis including with enhanced vibration monitOling.

RESPONSE

Preventive and Predictive Maintenance Program elements for the specified pumps are shown in the following table:

I,.l

~

a fr"S

't:l = ell J.J =

~[/l eIl[/l

~~ Qj Qj 0.9

~.S e':I.....

=.....

I,.l ;:1 '"'

ell....

[/l

=

[/l PIS No.

Pump Name

~~~ = e':I 0

= 3 ell>'

~>.

'"'~

e':I

'"' -8 o-S";!

• ....c

""~

S ~

~~ ~:90 '"' '"'

e':I =

e':I~

~<

00.<

~~ ~>~

Qj =

~-

..=

==

Eo-;

0 E1l51COOIA RHR Service Water Pump A X

X X

X E1l51COOlB RHR Service Water Pump B X

X X

X E1l51COOIC RHR Service Water Pump C X

X X

X El151COOID RHR Service Water Pump D X

X X

X

Enclosure to NRC-10-0023 Page 7 PIS No.

Pump Name P4400COOIA Emergency Equip Cooling x

Water Div 1 Pump P4400CO01B Emergency Equip Cooling x

Water Div 2 Pump P4400CO02A EECW Makeup Div 1 Pump X

X P4400CO02B EECW Makeup Div 2 Pump X

X P4500CO02A Emergency Equip Service x

xx Water South Pump P4500CO02B Emergency Equip Service x

xx Water North Pump R3000COOI EDG 11 Diesel Fuel Oil Xfer x

Pump A R3000C002 EDG 12 Diesel Fuel Oil Xfer x

Pump A R3000C003 EDG 11 Diesel Fuel Oil Xfer x

Pump B R3000C004 EDG 12 Diesel Fuel Oil Xfer x

Pump B R3000C009 EDG 13 Diesel Fuel Oil Xfer x

Pump A________

R3000CO10 EDG 14 Diesel Fuel Oil Xfer x

Pump A R3000COll EDG 13 Diesel Fuel Oil Xfer x

Pump B R3000C012 EDG 14 Diesel Fuel Oil Xfer x

Pump B R3001C005 EDG 11 DG Service Water x

x x

Pump R3001C006 EDG 12 DG Service Water x

x x

Pump R3001C007 EDG 13 DG Service Water x

x x

Pump R3001C008 EDG 14 DG Service Water x

x x

_____________Pump Enclosure to NRC-1O-0023 Page 7 PIS No.

P4400COOIA P4400COOlB P4400COO2A P4400COO2B P4500COO2A P4500COO2B R3000COOI R3000COO2 R3000COO3 R3000COO4 R3000COO9 R3000COI0 R3000COll R3000C012 R3001COO5 R3001COO6 R3001COO7 R300lCOO8 Pump Name Emergency Equip Cooling Water Div 1 Pump Emergency Equip Cooling Water Div 2 Pump EECW Makeup Div 1 Pump EECW Makeup Div 2 Pump Emergency Equip Service Water South Pump Emergency Equip Service Water North Pump EDG 11 Diesel Fuel Oil Xfer Pump A EDG 12 Diesel Fuel Oil Xfer Pump A EDG 11 Diesel Fuel Oil Xfer PumpB EDG 12 Diesel Fuel Oil Xfer PumpB EDG 13 Diesel Fuel Oil Xfer Pump A EDG 14 Diesel Fuel Oil Xfer Pump A EDG 13 Diesel Fuel Oil Xfer PumpB EDG 14 Diesel Fuel Oil Xfer PumpB EDG 11 DG Service Water Pump EDG 12 DG Service Water Pump EDG 13 DG Service Water Pump EDG 14 DG Service Water Pump

~

Q(:l

a

~.....

'e = ~ dl =

eJJ<I'l Q,l =

~.S

~<I'l

~~ Q,l Q,l 0 '1:

~.....

=.....

~;=

eJJ.....

r-.

<I'l

.=

<I'l

£.0> = ~.s = e eJJ>'

~>.

r-.~

~ r-. 'S 0-8";

8 ~

~~ -§=o r-.

r-.

~ =

~.o

~<

00<

~~ ~>~

Q,l ::s

~-

..=

=

E-i 0

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

X X

Enclosure to NRC-10-0023 Page 8 RAI-PRR-007-01 Please provide the current classification (Group A or Group B) for each of the pumps associated with this relief request.

RESPONSE

The table below indicates the current pump classifications in accordance with ISTB-2000.

Pump No.

Description ISTB-2000 classification E1102C002A RHR Pump A A*

E1102C002B RHR Pump B A*

E1102C002C RHR Pump C A*

E1102C002D RHR Pump D A*

E1151C001A RHR Service Water Pump A A*

E1151C001B RHR Service Water Pump B A*

E1151C001C RHR Service Water Pump C A*

E1151C001D RHR Service Water Pump D A*

E4101C001 High Pressure Injection Pump B

P4400C001A Emergency Equip Cooling Water Div 1 Pump B

P4400C001B Emergency Equip Cooling Water Div 2 Pump B

P4500C002A Emergency Equip Service Water South Pump B

P4500C002B Emergency Equip Service Water North Pump B

R3001C005 EDG 11 DG Service Water Pump B

R3001C006 EDG 12 DG Service Water Pump B

R3001C007 EDG 13 DG Service Water Pump B

R3001C008 EDG 14 DG Service Water Pump B

T4100C040 South CCHVAC Chilled Water Pump A

T4100C041 North CCHVAC Chilled Water Pump A

A* - These pumps could be classified as Group B based on very low run-hours per month, however since they are run periodically for various non-test system operations they were conservatively classified as Group A.

Enclosure to NRC-10-0023 Page 8 RAI-PRR-007-01 Please provide the CUlTent classification (Group A or Group B) for each of the pumps associated with this relief request.

RESPONSE

The table below indicates the CUlTent pump classifications in accordance with ISTB-2000.

Pump No.

Description ISTB-2000 classification E1102COO2A RHRPumpA A*

E1102COO2B RHR Pump B A*

E1102COO2C RHRPumpC A*

E1102COO2D RHRPumpD A*

E1151COO1A RHR Service Water Pump A A*

E1151COO1B RHR Service Water Pump B A*

E1151COO1C RHR Service Water Pump C A*

E1151COO1D RHR Service Water Pump D A*

E4101COO1 High Pressure Injection Pump B

P4400COO1A Emergency Equip Cooling Water Div 1 Pump B

P4400COO1B Emergency Equip Cooling Water Div 2 Pump B

P4500COO2A Emergency Equip Service Water South Pump B

P4500COO2B Emergency Equip Service Water North Pump B

R3001COO5 EDG 11 DG Service Water Pump B

R3001COO6 EDG 12 DG Service Water Pump B

R3001COO7 EDG 13 DG Service Water Pump B

R3001COO8 EDG 14 DG Service Water Pump B

T4100C040 South CCHVAC Chilled Water Pump A

T4100C041 North CCHVAC Chilled Water Pump A

A * - These pumps could be classified as Group B based on very low run-hours per month, however since they are run periodically for various non-test system operations they were conservatively classified as Group A.

Enclosure to NRC-10-0023 Page 9 RAI-PRR-007-02 In order to use the modified Group A test for pumps currently classified as Group B, the Group B pumps must be re-classified as Group A pumps. If any of the pumps associated with this relief request are currently classified as Group B, please confirm that you reclassifying them as Group A pumps.

RESPONSE

Detroit Edison has re-classified all of the pumps associated with Relief Request PRR-007 that are currently classified Group B pumps as Group A pumps.

RAI-PRR-007-03 It is not clear what flow rate is being used for the design flow rate stated in ISTB-3300(e)(1) for the pumps. If the design accident flow rate is being used, then some of the pump quarterly test flow rates are outside of the +/- 20% band allowed in ISTB-3300-(e)(1). Please provide the design flow rates for each pump.

RESPONSE

Column 3 in the table provided in Relief Request PRR-007 lists the design accident flow rate which is synonymous with design flow rate. Column 4 in the table lists Best Efficiency Point (BEP) values from the pump curve for each pump. The reference flow rates shown as quarterly test flow rates in column 2 in the table are at or above 80% of design flow and are as close to the BEP points as possible to ensure data may be trended.

RAI-PRR-007-04 The table in Section 8 of the relief request has indications for footnotes 1, 2, and 4. These footnotes do not appear in the relief request package. Please provide these footnotes.

RESPONSE

The information was provided on page 56 of 79 of Reference 2. The footnotes are as follows:

1 - Curve shows linear Q-P relationship from 4500 gpm - 8000 gpm (reference VMR4-3.2) 2 - Curve shows linear Q-P relationship from 1200 gpm - 2600 gpm (references C1-6858 and C1-6859) 3 - Curve shows linear Q-P relationship from 200 gpm - 420 gpm (reference VMB9-19) 4 - Notes for each system substantiating Design Accident Flow Rates as follows:

Enclosure to NRC-10-0023 Page 9 RAI -PRR-007 -02 In order to use the modified Group A test for pumps cUlTently classified as Group B, the Group B pumps must be re-classified as Group A pumps. If any of the pumps associated with this relief request are cUlTently classified as Group B, please confirm that you reclassifying them as Group A pumps.

RESPONSE

Detroit Edison has re-classified all of the pumps associated with Relief Request PRR-007 that are cUlTently classified Group B pumps as Group A pumps.

RAI -PRR-007 -03 It is not clear what flow rate is being used for the design flow rate stated in ISTB-3300(e)(1) for the pumps. If the design accident flow rate is being used, then some of the pump quarterly test flow rates are outside of the +/- 20% band allowed in ISTB-3300-(e)(1). Please provide the design flow rates for each pump.

RESPONSE

Column 3 in the table provided in Relief Request PRR-007 lists the design accident flow rate which is synonymous with design flow rate. Column 4 in the table lists Best Efficiency Point (BEP) values from the pump curve for each pump. The reference flow rates shown as quarterly test flow rates in column 2 in the table are at or above 80% of design flow and are as close to the BEP points as possible to ensure data may be trended.

RAI -PRR-007 -04 The table in Section 8 of the relief request has indications for footnotes 1,2, and 4. These footnotes do not appear in the relief request package. Please provide these footnotes.

RESPONSE

The information was provided on page 56 of 79 of Reference 2. The footnotes are as follows:

1 - Curve shows linear Q-P relationship from 4500 gpm - 8000 gpm (reference VMR4-3.2) 2 - Curve shows linear Q-P relationship from 1200 gpm - 2600 gpm (references Cl-6858 and Cl-6859) 3 - Curve shows linear Q-P relationship from 200 gpm - 420 gpm (reference VMB9-19) 4 - Notes for each system substantiating Design Accident Flow Rates as follows:

Enclosure to NRC-10-0023 Page 10 RAI-PRR-007-05 Please verify that vibration monitoring will be performed as part of the quarterly testing.

RESPONSE

All quarterly testing at Fermi 2 includes vibration monitoring. As stated in Relief Request PRR-007, Detroit Edison will continue to perform vibration monitoring as part of normal quarterly testing.

RAI-PRR-010-01 Please confirm that the pumps will be re-classified as Group A pumps.

RESPONSE

Detroit Edison has re-classified all of the pumps associated with Relief Request PRR-010 that are currently classified Group B pumps as Group A pumps.

RAI-PRR-010-02 Please provide the equipment number for each SLC pump and each Fuel Oil Transfer pump.

RESPONSE

The requested information is provided below:

C4103C001A - Standby Liquid Control pump A C4103C001B - Standby Liquid Control pump B R3000C001 - EDG 11 Diesel Fuel Oil Transfer Pump A R3000C002 - EDG 12 Diesel Fuel Oil Transfer Pump A R3000C003 - EDG 11 Diesel Fuel Oil Transfer Pump B R3000C004 - EDG 12 Diesel Fuel Oil Transfer Pump B R3000C009 - EDG 13 Diesel Fuel Oil Transfer Pump A R3000C010 - EDG 14 Diesel Fuel Oil Transfer Pump A R3000C011 - EDG 13 Diesel Fuel Oil Transfer Pump B R3000C012 - EDG 14 Diesel Fuel Oil Transfer Pump B Enclosure to NRC-I0-0023 Page 10 RAI-PRR-007-05 Please verify that vibration monitoring will be performed as part of the quarterly testing.

RESPONSE

All quarterly testing at Fenni 2 includes vibration monitoring. As stated in Relief Request PRR-007, Detroit Edison will continue to peliorm vibration monitoring as part of normal quarterly testing.

RAI-PRR-OIO-Ol Please confirm that the pumps will be re-classified as Group A pumps.

RESPONSE

Detroit Edison has re-classified all of the pumps associated with Relief Request PRR-OlO that are cUlTently classified Group B pumps as Group A pumps.

RAI-PRR-OIO-02 Please provide the equipment number for each SLC pump and each Fuel Oil Transfer pump.

RESPONSE

The requested information is provided below:

C4103COOIA - Standby Liquid Control pump A C4103COOIB - Standby Liquid Control pump B R3000COO 1 - EDG 11 Diesel Fuel Oil Transfer Pump A R3000C002 - EDG 12 Diesel Fuel Oil Transfer Pump A R3000C003 - EDG 11 Diesel Fuel Oil Transfer Pump B R3000C004 - EDG 12 Diesel Fuel Oil Transfer Pump B R3000C009 - EDG 13 Diesel Fuel Oil Transfer Pump A R3000CO 10 - EDG 14 Diesel Fuel Oil Transfer Pump A R3000CO 11 - EDG 13 Diesel Fuel Oil Transfer Pump B R3000C012 - EDG 14 Diesel Fuel Oil Transfer Pump B