ULNRC-06376, Submittal of 10 Crf 50.55a(z)(1) Request for Relief from ASME OM Code Pump and Valve Testing Requirements for Fourth 120-Month Inservice Testing Interval (Relief Request PR-07)

Submittal of 10 Crf 50.55a(z)(1) Request for Relief from ASME OM Code Pump and Valve Testing Requirements for Fourth 120-Month Inservice Testing Interval (Relief Request PR-07)

ML17153A067
Person / Time
Site:	Callaway
Issue date:	06/01/2017
From:	Wink R Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RR PR-07, ULNRC-06376
Download: ML17153A067 (9)

Text

Amemn MISSOURI (allaway Plant June 1,2017 ULNRC-063 76 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.55a Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

RENEWED FACILITY OPERATING LICENSE NPF-30 10 CFR 50.55a(z)(l) REQUEST FOR RELIEF FROM ASME OM CODE PUMP AND VALVE TESTING REQUIREMENTS FOR FOURTH 120-MONTH INSERVICE TESTING INTERVAL (RELIEF REQUEST PR-07)

Pursuant to 10 CFR 50.55a(z)(1), Union Electric Company (Ameren Missouri) requests NRC approval of the attached relief request for the fourth 10-year inservice testing interval at Callaway. The Code Edition and Addenda applicable to Callaway for its fourth inservice testing interval, which began December 20, 2014, are ASME CM Code 2004 Edition through 2006 Addenda.

The relief request, identified as PR-07, proposes an alternative to the method for establishment of vibration reference values as specified in ASME OM Code ISTB-3300, for selected smooth-running pumps. To avoid unnecessary corrective action being taken as a result of minor statistical variations in periodic vibration measurements, it is proposed that a minimum vibration reference value of 0.05 inches per second (ips) be estabLished for each of the applicable pumps (identified in the attached relief request) in lieu of establishing the value based on initial test results. The proposed alternative to the requirements of ISTB-3300 provides an acceptable level of quality and safety.

This letter does/does not contain new commitments.

If there are any questions, please contact Terry Becker at (573) 659-6068.

P 0 Box 620 Fulton MO 65251 AmerenMissouri corn

ULNRC-063 76 June 1,2017 Page 2 Sincerely,

(

/ R. C. Wink Manager, Regulatory Affairs JP K!

Attachment:

Relief Request PR-07

ULNRC-063 76 June 1,2017 Page 3 cc: Mr. Kriss M. Kennedy Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-45 11 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission

$201 NRC Road Steedman, MO 65077 Mr. L. John Kios Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O$H4 Washington, DC 20555-000 1

ULNRC-063 76 June 1,2017 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6100 Western Place, Suite 1050 Fort Worth, TX 76107 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Other Situations ULNRC Distribution:

F. M. Diya T. E. Hemriann B. L. Cox R. C. Wink T. B. Elwood T. L. Becker B. N. Oguejiofor Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission

Attachment to ULNRC-06376 RELIEF REQUEST PR-07 4 Pages

RELIEF REQUEST PR-O7 Proposed Alternative In Accordance with JO CFR 50.55a(z)f 1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Components Affected Pumps listed in Table 1.

2. Applicable Code Edition and Addenda ASME OM Code 2004 Edition through 2006 Addenda

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-31 00, Preservice Testing, or from the results of the first inservice 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 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, Inservice 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.

ISTB-5220, lnservice Testing (Vertical Line Shaft Centrifugal Pumps)

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.

4. Reason for Request Relief is being requested for establishing the vibration reference value (Vr) solely on the basis of the data collected during preservice or inservice 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 and Table ISTB-5221-1 is less than or equal to 2.5Vr. Based on such a small acceptable range, a smooth running pump (i.e.,

one that has a very low vibration reference value of < 0.05 inches per second (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 Vt of 0.05 ips is being established for velocity measurements.

Pumps with a measured Vt less than or equal to 0.05 inches per second (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 even if the pump is identified in Table 1. Conversely, if the measured Vt 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 requited action ranges.

In addition to the requirements of ISTB, the pumps in the ASME Inservice Testing Program are included in the Callaway Predictive Maintenance Program.

The Callaway Predictive Maintenance Program currently employs predictive monitoring techniques such as:

• vibration monitoring and analysis beyond that required by ISTB,

• oil sampling and analysis where applicable (e.g., for pumps with sufficiently large oil reservoirs).

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:

2

• increased monitoring to establish the rate of change,

• review of component and associated system specific information to identify the cause, and

• removal of the pump from service to perform maintenance.

It should be noted that all of the pumps in the 1ST Program will remain in the Callaway 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-5 120 and ISTB-5220, and Table ISTB-5121-1 and Table ISTB-5221-1 provides an acceptable level of quality and safety.

6. Duration of Proposed Alternative The proposed alternative will be utilized for the entire fourth 1 20-month Interval ending December 19, 2024.

7. Precedent A similar relief request (RP-04) was approved for Sequoyah Nuclear Plant Units 1 and 2, Fourth 1ST 10-year interval, in NRC Safety Evaluation dated May 12, 2016 (ADAMS Accession No. ML16123A131).

A similar relief request (P-i) was approved for Surry Power Station Units 1 and 2, Fifth 1ST 10-year interval, in NRC Safety Evaluation dated May 9, 2014 (ADAMS Accession No. ML14125A471).

A similar relief request (IST-RR-1) was approved for Watts Bar Nuclear Plant Unit 2, First 1ST 10-year interval, in NRC Safety Evaluation dated October21, 2014 (ADAMS Accession No. ML16123A131).

8. References NUREG 1482, Rev 2, Guidelines for Inservice Testing at Nuclear Power Plants, Section 5.12, Smooth Running Pumps.

3

Table 1 Callaway Plant Inservice Testing Program Pump Table Pump Number Description Pump Type Code OM Code Class Category PALOJNB MOTOR DRIVEN AUXILIARY FEEDWATER PUMPS Centrifugal 3 Group A PBGO2NB CVCS BORIC ACID TRANSFER PUMPS Centrifugal 3 Group A PEFO1NB ESSENTIAL SERVICE WATER PUMPS Vertical Line Shaft 3 Group A PEGO1A/B!C/D COMPONENT COOLING WATER PUMPS Centrifugal 3 Group A PEJO1NB RESIDUAL HEAT REMOVAL PUMPS Centrifugal 2 Group A PALO2 TURBINE DRIVEN AUXILIARY FEEDWATER PUMP Centrifugal 3 Group B PBGO5NB CENTRIFUGAL CHARGING PUMPS Centrifugal 2 Group B PEMO1AIB SAFETY INJECTION PUMPS Centrifugal 2 Group B PENO1NB CONTAINMENT SPRAY PUMPS Centrifugal 2 Group B 4