NRC-19-0015, Submittal of Pump Relief Requests for the Inservice Testing Program Fourth 10-Year Interval

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Submittal of Pump Relief Requests for the Inservice Testing Program Fourth 10-Year Interval
ML19086A284
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 03/27/2019
From: Fessler P
DTE Electric Company
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-19-0015
Download: ML19086A284 (56)
v • d • e


Text

Paul Fessler Senior Vice President and Chief Nuclear Officer DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4153 Fax: 734.586.1431 Email: paul.fessler@dteenergy.com March 27, 2019 10 CFR 50.55a NRC-19-0015 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Submittal of Pump Relief Requests for the Inservice Testing Program Fourth 10-Year Interval Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z), DTE Electric Company (DTE) hereby requests NRC approval of the following relief requests for the Fermi 2 Inservice Testing (IST) Program fourth 10-year interval, which begins on February 17, 2020.

PRR-001, Alternative for Residual Heat Removal Pump Vibration Alert Limits PRR-002, Alternative Vibration Acceptance Criteria for Smooth Running Pumps PRR-003, Relief for Service Water Pump Suction Pressure Accuracy PRR-004, Relief from Quarterly Test of Core Spray Pumps The enclosures to this letter provide details of each of the individual relief requests.

Relief requests PRR-001, PRR-002, PRR-003, and PRR-004 are all based on relief requests currently approved by the NRC for use at Fermi 2 during the IST Program third 10-year interval, which ends on February 16, 2020.

DTE requests NRC approval of these relief requests by February 16, 2020.

No new commitments are being made in this submittal.

USNRC NRC-19-0015 Page 2 Should you have any questions or require additional information, please contact Mr. Scott A. Maglio, Manager - Nuclear Licensing, at (734) 586-5076.

Sincerely, Paul Fessler Senior Vice President and CNO

Enclosures:

1. Relief Request PRR-001 for the IST Fourth 10-Year Interval
2. Relief Request PRR-002 for the IST Fourth 10-Year Interval
3. Relief Request PRR-003 for the IST Fourth 10-Year Interval
4. Relief Request PRR-004 for the IST Fourth 10-Year Interval cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure 1 to NRC-19-0015 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request PRR-001 for the IST Fourth 10-Year Interval to NRC-19-0015 Page 1 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

Hardship without a Compensating Increase in Quality and Safety

1. ASME Code Component(s) Affected Pump ASME OM Speed(3)

Identification Pump Description Code Type(2)

Group(1) (RPM)

(PIS) No. Class Residual Heat Removal (RHR)

E1102C002A 2 A CENT 1800 Pump A E1102C002B RHR Pump B 2 A CENT 1800 E1102C002C RHR Pump C 2 A CENT 1800 E1102C002D RHR Pump D 2 A CENT 1800 (1) All pumps on list are vibration tested quarterly (2) CENT = centrifugal (3) Pump speed is synchronous motor speed

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda

3. Applicable Code Requirement

ISTB Table ISTB-5121-1, Centrifugal Pump Test Acceptance Criteria

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(2), relief is requested from the vibration criteria requirements of ASME OM Code ISTB Table ISTB-5121-1 during the Group A or biennial comprehensive pump test or any other time vibrations are taken to determine pump acceptability (i.e., post-maintenance testing, other periodic testing, etc.).

Compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Relief is requested from ISTB Table ISTB-5121-1 requirements to test the pump on an increased periodicity due to vibration levels exceeding the ISTB alert range absolute limit of 0.325 inches per second (ips). This request is based on analysis of vibration and pump differential pressure data indicating that no pump degradation is taking place.

to NRC-19-0015 Page 2 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits

5. Proposed Alternative and Basis for Use Fermi 2 is proposing to use an alternative vibration alert limit of 0.415 ips. This provides an alternative method that continues to meet the intended function of monitoring the pump for degradation over time while keeping the required action level unchanged.

Pump Testing Methodology The RHR pumps at Fermi 2 are tested using a full flow recirculation test line back to the suppression pool each quarter. These pumps have a minimum flow line (per division) which is used only to protect the pump from overheating when pumping against a closed discharge valve. The mini-flow line isolation valve for each division is initially open when the pump is started, and flow is initially recirculated through the mini-flow line back to the suppression pool. Then, the full-flow test line isolation valve is throttled open to establish flow through the full-flow recirculation test line. The mini-flow line is then isolated automatically, and all flow remains through the full-flow test line for the Inservice Testing (IST) Program test.

The RHR system is operated in the same manner and under the same conditions for each IST test, regardless of whether Fermi 2 is operating or shut down. Consequently, the pumps will experience the same potential for flow-induced, broad band vibration whenever they are tested, whether Fermi 2 is operating or shut down. As a result, this relief is requested for the inservice testing of RHR pumps when vibration measurements are required or any other time vibrations are recorded to determine pump acceptability (i.e., post-maintenance testing, other periodic testing, etc.).

NRC Staff Document NUREG/CP-0152 NRC staff document NUREG/CP-0152, entitled Proceedings of the Fourth NRC/ASME Symposium on Valve and Pump Testing, dated July 15-18, 1996, included a paper entitled Nuclear Power Plant Safety Related Pump Issues, by Joseph Colaccino of the NRC staff.

That paper presented four key components that should be addressed in a relief request of this type to streamline the review process. These four key components are as follows:

I. The licensee should have sufficient vibration history from inservice testing which verifies that the pump has operated at this vibration level for a significant amount of time, with any spikes in the data justified.

II. The licensee should have consulted with the pump manufacturer or vibration expert about the level of vibration the pump is experiencing to determine if pump operation is acceptable.

III. The licensee should describe attempts to lower the vibration below the defined code absolute levels through modifications to the pump.

to NRC-19-0015 Page 3 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits IV. The licensee should perform a spectral analysis of the pump-driver system to identify all contributors to the vibration levels.

The following is a discussion of how each of these four key components are addressed for this relief request.

I. Vibration History (Key Component No. 1)

A. Testing Methods and Code Requirements Inconsistent and high vibration levels on the RHR pump motors has been a condition that has existed since original installation of these pumps in the 1970s. During preoperational testing in 1984, vibrations were measured in both displacement (mils) and velocity (ips) at three locations (horizontal in line with flow path, horizontal perpendicular to flow path, and axial) on each motor bearing and on the pump bearing. The vibration signals were recorded at multiple pump flow velocities. The intention was to baseline the vibration data throughout the expected hydraulic use range and to see if hydraulic disturbances were responsible for the observed phenomena. The data showed conclusively that the motor was vibrating with randomly distributed bursts of energy at the natural frequency of the system, in the range of 9-14 Hz. Therefore, it was determined that the hydraulic disturbances found in the piping were the source of the energy.

The monitoring of multiple vibration points was not a requirement of Section XI of the ASME Code until the adoption of the O&M Standards/Codes. The Fermi 2 first 10-year interval IST Program (which began in 1983) was committed to the 1980 Edition, Winter 1981 Addenda of Section XI. Paragraph IWP-4510 of this code required that at least one displacement vibration amplitude, shall be read during each inservice test. This code was in effect at Fermi 2 until the start of the second 10-year interval, which began in February 2000.

The Fermi 2 second 10-year interval IST Program was committed to the 1989 Edition of Section XI, which required multiple vibration points to be recorded during IST pump testing in accordance with the ASME/ANSI Operations and Maintenance Standard, Part 6, 1987 Edition with the 1988 Addenda.

However, at Fermi 2, the first and second 10-year interval IST Program Plans did include both vibration monitoring of multiple points and use of velocity measurement instead of displacement. This was a conservative testing regime based on expectations that this level of vibration monitoring would be beneficial in terms of early identification of degradation.

Vibration monitoring for the third 10-year interval was performed in accordance with the ASME OM Code 2004 Edition. Because of this, readily available data exists for two vibration points on each RHR pump from July 1984 to the present and on three motor to NRC-19-0015 Page 4 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits vibration points from October 1996 to the present. Various analyses of this data are included in the figures provided with this relief request.

B. Review of Vibration History Data RHR pump IST vibration trend graphs (Figures 1 through 4 in this relief request), which include data from 2002 through the present, show essentially flat trends. All vibration data shown on Figures 1 through 6 are the measurements of Peak Total Amplitude and all are in the units of ips. These measurements are in accordance with the requirements of ISTB-5123(d). These figures also show that vibration readings for all four pumps occasionally exceed the ISTB Table ISTB-5121-1 alert range criteria of 0.325 ips.

Differential pressure trend graphs (Figures 7 through 10) illustrate differential pressure data dating back to 1990 for all four RHR pumps. This data clearly shows no discernible evidence of hydraulic degradation. Average run hours for each RHR pump per cycle is approximately 300 to 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br />. There is low likelihood that motors and pumps built and maintained to exacting nuclear quality standards will suffer significant wear-related degradation over their design life with such low average run times.

C. Review of Spikes in Vibration Data In reviewing the long-term trend data for vibration, which includes the code-required frequency ranges (one-third pump running speed to 1000 Hz), random spikes were observed throughout the data that resulted in values above the alert range. Most of the vibration that is measured on the motor casing is due to excitation of the structural resonances of the motor/pump by turbulent flow. These structural resonances are poorly damped and can be easily excited. Many vertical pumps exhibit similar characteristics, and it is not necessarily problematic by itself. A problem occurs when a pump has a continuous forcing function whose frequency coincides with a resonance (i.e., running speed). The forcing function in this case is flow turbulence caused in large part by the 90° elbow in the piping just off the pump discharge. The flow through this area generates lateral broadband forces that excite the resonances in a non-continuous fashion.

This is why the amplitude swings so dramatically on the motor and to some degree on the pump casing. Figure 5 provides an example of a single point on RHR Pump C motor that clearly shows significant variation / spiking about a fairly constant mean. Figures 12 through 14 show frequency spectrum results, for 3 recorded measurements, of a single location (RHR Pump A motor point EA1), taken approximately 45 seconds apart from the most recent available surveillances. The total peak values which would be recorded for IST purposes were 0.213, 0.225 and 0.239. The system goes from brief periods of excitation to brief periods of no excitation. The discharge riser is also moving side to side from the same to NRC-19-0015 Page 5 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits forces. Although the discharge piping configuration is less than optimum for this application, the design poses no threat to the long-term reliability of the pump, motor or the system piping.

As illustrated previously, there have been no significant degrading trends associated with vibration data for the past seventeen years. By analyzing this data using a moving average function (averaging of the last 8 data points), the trends are relatively steady, and without the spikes that the code-required data contains. This further supports the fact that the spikes in the original code data are due to the piping-induced, non-detrimental broadband vibration occurring in the one-third to one-half pump running speed range. These spikes may exceed Code (i.e., ISTB Table ISTB-5121-1) alert criteria, which triggers the corrective action process and the need to increase the testing frequency. These Code compliance actions are not appropriate or necessary because the true nominal average of the particular vibration point may be anywhere from 40-60% below the individual spike value. The Code alert triggered response is not because of true degradation that warrants remedial action, but merely data fluctuation as illustrated in Figures 12 through 14.

II. Consultation - Pump Manufacturer/Vibration Expert (Key Component No. 2)

Each RHR pump motor is vertically mounted to the pump casing, with the piping entering/exiting the pump casing horizontally. Each 2000 horsepower motor is 8 feet tall and 42 inches diameter, weighing approximately 14,000 lbs. The vendor describes the upper motor thrust bearing as having a minimum expected life of 5 years [operation]. With a conservative assumption of 500 run hours per year and appropriate lubrication activities, these bearings should last over 80 years. The pump casing is mounted on a reinforced floor pad and is approximately 4 feet high and 6 feet diameter. The 24 inch suction piping enters the room level with the pump centerline but elbows horizontally 45 degrees 10 feet from the pump center and then another 45 degrees 6 feet from the pump. The 20 inch discharge pipe leaves the pump on nearly the same plane as the suction pipe but then elbows vertically 90 degrees at 6 feet from pump center. Six feet up from this elbow is the pump discharge check valve and 3 feet from the elbow is the 3 inch minimum flow piping connection. Figures 15 and 16 show the pump suction and discharge piping isometrics.

Figure 17 shows the vibration monitoring points on the RHR motor/pump assembly.

Points A1, A2, A3, C1 and C2 are the specified locations for IST data. The physical locations are as follows:

A1 - Radial 0° measurement on top portion of motor in line with upper bearing housing A2 - Radial 90° measurement on top portion of motor in line with upper bearing housing A3 - Axial at 0° measurement on top of motor upper end bell C1 - Radial 0° measurement on top portion of pump casing C2 - Radial 90° measurement on top portion of pump casing to NRC-19-0015 Page 6 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits ASME OM Code 2012 Section ISTB-6400 states If the reference value of a particular parameter being measured or determined can be significantly influenced by other related conditions, then these conditions shall be analyzed* and documented in the record of tests (see section ISTB-9000). The footnote to analyzed, states Vibration measurements of pumps may be foundation, driver, and piping dependent. Therefore, if initial readings are high and have no obvious relationship to the pump, then vibration measurements should be taken at the driver, at the foundation, and on the piping and analyzed to ensure that the reference vibration measurements are representative of the pump and the measured vibration levels will not prevent the pump from fulfilling its function. This is exactly the case with the RHR pumps, where the flow noise significantly influences the vibration measurements of the pump and motor. The data for RHR Pump C was extensively analyzed and documented in IST Evaluation 97-042 by the on-site Level 3 Vibration Expert. Additionally, Engineering Research Reports 85D15-5, Rev. 1, (dated 1984) and 84C97 (dated 1984) had identified the same resonant peaks in the other three RHR pumps.

This analysis identified a resonant frequency between 9 and 14 Hz. An impact test was also conducted with the pumps not running which again confirmed the 9 to 14 Hz resonant frequencies on the pumps. This resonance frequency, either alone or in combination with the running speed peak, occasionally results in the overall vibration amplitude exceeding the 0.325 ips Alert Range limit. Each structure has its own resonance frequency based on the mass and stiffness of the system. Minor changes in either of these two components will change the resonance frequency. A difference in piping and hanger design between the four RHR pumps is the cause for slight differences in the resonance frequency and therefore the vibration levels. The reason that the vibration levels change from run to run is that for a resonance frequency to ring it must be excited by some forcing function. In the RHR pumps this forcing function is flow noise, which causes a broad band forcing frequency that varies slightly during each run.

III. Attempts to Lower Vibration (Key Component No. 3)

As stated earlier, Engineering Research Reports 85D15-5, Rev. 1, (dated 1984), and 84C97 (dated 1984) had identified these frequencies. At that time several attempts were made to stiffen the pump structure. These attempts only succeeded in transferring the energy to the piping. These supports were removed and the system returned to the previous configuration.

When the upper motor bearing vibration data was added to the IST program and the data was found to be high, the shaft locking nut was checked along with the mounting bolts and hangers. No problems were identified. Additional vibration data was also collected and entered into a three-dimensional model (Figure 11) program. This program did not indicate any problems in either the pump or motor. Analysis of a high-resolution vibration spectrum shows the structural resonance and running speed peaks. These analyses indicate that the to NRC-19-0015 Page 7 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits running speed spectral peaks remained unchanged while the resonant peak can change with each run. With the resonant frequency being a significant contributor in exceeding the alert vibration range there is little that can be done to the pump or rotating assembly (such as balancing or alignment) that will reduce this resonant vibration peak.

IV. Spectral Analysis (Key Component No. 4)

Spectral data indicates that the overall vibration levels (IST data) are primarily made up of the broad spectrum from 30 Hz up to 100 Hz which undergoes random amplitudinal increases as a function of flow noise excitation. Spectral data does not indicate any problem with bearings or the rotating elements such as imbalance or misalignment. Uncoupled runs of the motors have shown very low vibration levels compared to pump running conditions.

Historically, the overall peak amplitude value recorded for IST can vary by as much as 0.150 to 0.200 ips peak on readings taken a few seconds apart. Figures 12, 13 and 14 show the variance from the most recent test. These noise-induced oscillations are neither consistent in amplitude or duration and are still present.

Basis for Code Alternative Alert Values By this relief request Fermi 2 is proposing to increase the absolute alert limit for vibration from 0.325 ips to 0.415 ips for all four RHR pumps. The flow-induced broadband vibration occasionally causes the overall vibration value for these points to exceed 0.325 ips, resulting in the pumps being placed on increased test frequency. In late 2005 a single reading on RHR Pump A exceeded alert criteria. RHR Pump A was placed on increased frequency and planning begun for motor replacement. The motor for RHR Pump A was replaced during the RF12 refueling outage as a corrective action due to exceeding the vibration alert. Initial examination of the replaced motor identified no evidence of degradation, and initial average vibration data for the new motor showed only a slight reduction compared to recent data on the old motor (Figure 6). This motor replacement was a high impact work item in the RF12 refueling outage, incurring significant cost and dose. Expert analyses and maintenance history reviews have shown that this flow-induced vibration has not resulted in noticeable degradation to the pump or motor. Additionally, the overall vibration levels, when dampened using moving-average technique, have remained essentially steady over the past 17 years.

Therefore, it has been demonstrated that doubling the test frequency and initiating corrective actions such as motor replacement under the current conditions does not provide additional assurance as to the condition of the pump and its ability to perform its safety function.

The proposed alternative alert criteria values are reasonable as they represent an alternative method that still meets the intended function of monitoring the pump for degradation over time while keeping the required action level unchanged. The proposed values encompass all of the historical spiking values, which would eliminate the unnecessary actions associated to NRC-19-0015 Page 8 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits with exceeding Code Alert limits due to spiking. However, the more accurate moving average value for these pumps would typically still be within the original Code alert value of 0.325 ips at a point where any spiking in the data due to the high flow-induced broadband noise would exceed the proposed 0.415 ips alert limit. Therefore, corrective actions triggered by exceeding the 0.415 ips alert value would be taken at a point commensurate with the intent of the Code guidance.

The Fermi 2 Vibration Specialist routinely performs a spectral analysis on all data recorded during RHR pump inservice testing per procedure 47.000.02 Mechanical Vibration Measurements for Trending. This analysis is in addition to the quantitative rendering of total vibration values recorded in the IST test procedures. The routine spectral analysis provides additional confidence in the ability to detect degradation at an early stage.

Each RHR pump motor is also covered by various Preventive and Predictive Maintenance (PM and PdM) activities. These include:

10 year detailed motor condition inspection / refurbishment PM Oil sampling and analysis every 92 days Annual motor PM including phase to phase winding tests, insulation checks and exterior cleaning (PDMA) every 3 years This maintenance and testing regime in addition to trending of inservice test data provides for early identification and analysis of any degradation.

Conclusions Several expert evaluations have documented that no internal pump or motor degradation is occurring due to the piping-induced vibration, which has been present since the pre-operational testing time period. The available vibration data over the past seventeen years and differential pressure data over nearly the past 29 years supports this fact. A maintenance history review and a review of thermography and oil analyses results further supports these conclusions.

Vibration data analysis clearly shows significant variations which are attributable to the external influence of the flow noise. These variations have frequently crossed the ASME Code alert threshold of 0.325 ips and triggered unnecessary responses.

Based on this information, Fermi 2 concludes that doubling the test frequency and initiating costly corrective actions for the RHR pump motors at the 0.325 ips Code alert limit does not provide additional information nor does it provide additional assurance as to the condition of the pumps and their ability to perform their safety function. Testing of these pumps on an increased frequency and performing the associated corrective actions places an unnecessary to NRC-19-0015 Page 9 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits burden on Fermi 2 resources. Establishing an alert limit of 0.415 ips provides for necessary margin above the normal and expected vibration levels encountered with these components to prevent exceeding the alert limit due to the data fluctuations caused by the system flow induced noise.

6. Duration of Proposed Alternative This proposed alternative will be utilized for the entire fourth 10-year interval. The fourth interval begins on February 17, 2020.
7. Precedent Fermi 2 currently has an approved relief request for RHR pump vibration alert limits for the third 10-year interval. The current relief request is identified as PRR-004 in the approval document listed below:

Fermi 2 - Evaluation of Relief Request Nos: PRR-004, PRR-005, PRR-007, and PRR-010 for the Third 10-Year Interval Inservice Program, dated July 6, 2010, Accession No. ML101670372.

to NRC-19-0015 Page 10 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 1 0.4 RHR A Vibration Data 0.35 0.3 0.25 0.2 0.15 0.1 EA1 EA2 EA3 EC1 EC2 8 per. Mov. Avg. (EA1) 8 per. Mov. Avg. (EA2) 8 per. Mov. Avg. (EA3) 8 per. Mov. Avg. (EC1) 8 per. Mov. Avg. (EC2) to NRC-19-0015 Page 11 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 2 RHR Pump B Vibration Data 0.4 0.35 0.3 0.25 0.2 0.15 0.1 3/1/2002 11/1/2002 7/1/2003 3/1/2004 11/1/2004 7/1/2005 3/1/2006 11/1/2006 7/1/2007 3/1/2008 11/1/2008 7/1/2009 3/1/2010 11/1/2010 7/1/2011 3/1/2012 11/1/2012 7/1/2013 3/1/2014 11/1/2014 7/1/2015 3/1/2016 11/1/2016 7/1/2017 3/1/2018 11/1/2018 EA1 EA2 EA3 EC1 EC2 8 per. Mov. Avg. (EA1) 8 per. Mov. Avg. (EA2) 8 per. Mov. Avg. (EA3) 8 per. Mov. Avg. (EC1) 8 per. Mov. Avg. (EC2) to NRC-19-0015 Page 12 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 3 0.4 RHR Pump C Vibration Data 0.35 0.3 0.25 0.2 0.15 0.1 EA1 EA2 EA3 EC1 EC2 8 per. Mov. Avg. (EA1) 8 per. Mov. Avg. (EA2) 8 per. Mov. Avg. (EA3) 8 per. Mov. Avg. (EC1) 8 per. Mov. Avg. (EC2) to NRC-19-0015 Page 13 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 4 0.4 RHR Pump D Vibration Data 0.35 0.3 0.25 0.2 0.15 0.1 6/1/2002 2/1/2003 10/1/2003 6/1/2004 2/1/2005 10/1/2005 6/1/2006 2/1/2007 10/1/2007 6/1/2008 2/1/2009 10/1/2009 6/1/2010 2/1/2011 10/1/2011 6/1/2012 2/1/2013 10/1/2013 6/1/2014 2/1/2015 10/1/2015 6/1/2016 2/1/2017 10/1/2017 6/1/2018 EA1 EA2 EA3 EC1 EC2 8 per. Mov. Avg. (EA1) 8 per. Mov. Avg. (EA2) 8 per. Mov. Avg. (EA3) 8 per. Mov. Avg. (EC1) 8 per. Mov. Avg. (EC2)

0.2 0.22 0.24 0.26 0.28 0.3 0.32 0.34 0.36 0.38 0.4 Enclosure 1 to 2/7/2002 NRC-19-0015 8/7/2002 2/7/2003 Page 14 8/7/2003 2/7/2004 8/7/2004 2/7/2005 8/7/2005 2/7/2006 8/7/2006 2/7/2007 8/7/2007 2/7/2008 8/7/2008 2/7/2009 8/7/2009 2/7/2010 8/7/2010 2/7/2011 8/7/2011 2/7/2012 Figure 5 8/7/2012 RHR Pump C EA3 Data 2/7/2013 8/7/2013 2/7/2014 8/7/2014 2/7/2015 10 CFR 50.55a Relief Request PRR-001 8/7/2015 EA3 2/7/2016 8/7/2016 2/7/2017 8/7/2017 2/7/2018 Alternative for Residual Heat Removal Pump Vibration Alert Limits 8/7/2018 Average value for this dataset = 0.289 to NRC-19-0015 Page 15 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 6 0.4 RHR A Vibration Data Motor replaced 2007 due to exceeding Alert threshold several times little change in data and already have another spike on EA2 exceeding Alert threshold again. Additional data up to 2018 was added to show similar results.

0.35 0.3 0.25 0.2 0.15 5/7/2006 11/7/2006 5/7/2007 11/7/2007 5/7/2008 11/7/2008 5/7/2009 11/7/2009 5/7/2010 11/7/2010 5/7/2011 11/7/2011 5/7/2012 11/7/2012 5/7/2013 11/7/2013 5/7/2014 11/7/2014 5/7/2015 11/7/2015 5/7/2016 11/7/2016 5/7/2017 11/7/2017 5/7/2018 11/7/2018 EA1 EA2 EA3 EC1 EC2 to NRC-19-0015 Page 16 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 7 RHR PUMP A DP 275 Changed test procedure to add 9.4 PSIG to discharge pressure to account for elevation bias.

270 265 260 255 DP 250 245 240 DP 235 8 per. Mov.

Avg. (DP) 230 3/20/1990 3/20/1991 3/20/1992 3/20/1993 3/20/1994 3/20/1995 3/20/1996 3/20/1997 3/20/1998 3/20/1999 3/20/2000 3/20/2001 3/20/2002 3/20/2003 3/20/2004 3/20/2005 3/20/2006 3/20/2007 3/20/2008 3/20/2009 3/20/2010 3/20/2011 3/20/2012 3/20/2013 3/20/2014 3/20/2015 3/20/2016 3/20/2017 3/20/2018 DATE to NRC-19-0015 Page 17 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 8 RHR PUMP B DP 260 Changed test procedure to add 9.4 PISG to discharge 255 pressure to account for elevation bias.

250 DP245 240 235 DP 8 per. Mov.

Avg. (DP) 230 1/24/1990 1/24/1991 1/24/1992 1/24/1993 1/24/1994 1/24/1995 1/24/1996 1/24/1997 1/24/1998 1/24/1999 1/24/2000 1/24/2001 1/24/2002 1/24/2003 1/24/2004 1/24/2005 1/24/2006 1/24/2007 1/24/2008 1/24/2009 1/24/2010 1/24/2011 1/24/2012 1/24/2013 1/24/2014 1/24/2015 1/24/2016 1/24/2017 1/24/2018 DATE to NRC-19-0015 Page 18 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 9 RHR PUMP C DP 270 Changed test procedure to add 265 9.4 PSIG to discharge pressure to account for elevation bias.

260 255 250 DP 245 240 DP 235 8 per. Mov.

Avg. (DP) 230 3/20/1990 3/20/1991 3/20/1992 3/20/1993 3/20/1994 3/20/1995 3/20/1996 3/20/1997 3/20/1998 3/20/1999 3/20/2000 3/20/2001 3/20/2002 3/20/2003 3/20/2004 3/20/2005 3/20/2006 3/20/2007 3/20/2008 3/20/2009 3/20/2010 3/20/2011 3/20/2012 3/20/2013 3/20/2014 3/20/2015 3/20/2016 3/20/2017 3/20/2018 DATE to NRC-19-0015 Page 19 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 10 RHR PUMP D DP 260 Changed test procedure to add 9.4 PSIG to discharge pressure to account for elevation bias.

255 250 245 DP 240 DP 235 8 per. Mov.

Avg. (DP) 230 1/24/1990 1/24/1991 1/24/1992 1/24/1993 1/24/1994 1/24/1995 1/24/1996 1/24/1997 1/24/1998 1/24/1999 1/24/2000 1/24/2001 1/24/2002 1/24/2003 1/24/2004 1/24/2005 1/24/2006 1/24/2007 1/24/2008 1/24/2009 1/24/2010 1/24/2011 1/24/2012 1/24/2013 1/24/2014 1/24/2015 1/24/2016 1/24/2017 1/24/2018 DATE to NRC-19-0015 Page 20 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 11 3-Dimensional Model to NRC-19-0015 Page 21 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 12 RHR Pump A Point EA1 - overall value recorded as 0.213 ips on 1/17/19 at 12:50:27 PM Time 0 - The overall flow noise is low during this data collection but the 9-10 Hz resonance peaks and its multiples are still present. The running speed vibration is extremely low (0.061 ips).

to NRC-19-0015 Page 22 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 13 RHR Pump A Point EA1 - overall value recorded as 0.225 ips on 1/17/19 at 12:51:13 PM Time 0 + 45 sec - The overall flow noise is higher during this data collection. The 9-10 Hz resonance peaks and its multiples are still present. The running speed vibration is still extremely low (0.058 ips).

to NRC-19-0015 Page 23 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 14 RHR Pump A Point EA1 - overall value recorded as 0.239 ips on 1/17/19 at 12:51:48 PM.

Time 0 + 80 sec - The overall flow noise is highest during this data collection. The 9-10 Hz resonance peaks and its multiples are still present. The running speed vibration is still extremely low (0.059 ips) and its change is not the contributor to the change in overall vibration level.

to NRC-19-0015 Page 24 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 15 RHR Pump A Suction Piping Isometric to NRC-19-0015 Page 25 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 16 RHR Pump C Discharge Piping Isometric to NRC-19-0015 Page 26 10 CFR 50.55a Relief Request PRR-001 Alternative for Residual Heat Removal Pump Vibration Alert Limits Figure 17 RHR Pump and Motor Vibration Monitoring Points

Enclosure 2 to NRC-19-0015 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request PRR-002 for the IST Fourth 10-Year Interval to NRC-19-0015 Page 1 10 CFR 50.55a Relief Request PRR-002 Alternative Vibration Acceptance Criteria for 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 Component(s) Affected Pump ASME OM Speed(3)

Identification Pump Description Code Type(2)

Group(1) (RPM)

(PIS) No. Class Residual Heat Removal (RHR)

E1151C001A 3 A VLSC 1800 Service Water Pump A E1151C001B RHR Service Water Pump B 3 A VLSC 1800 E1151C001C RHR Service Water Pump C 3 A VLSC 1800 E1151C001D RHR Service Water Pump D 3 A VLSC 1800 Emergency Equipment Cooling P4400C001A 3 B CENT 1800 Water (EECW) Division 1 Pump P4400C001B EECW Division 2 Pump 3 B CENT 1800 P4400C002A EECW Makeup Division 1 Pump 3 B CENT 1800 P4400C002B EECW Makeup Division 2 Pump 3 B CENT 1800 Emergency Equipment Service P4500C002A 3 A VLSC 1800 Water (EESW) South Pump P4500C002B EESW North Pump 3 A VLSC 1800 Emergency Diesel Generator R3000C001 (EDG) 11 Diesel Fuel Oil 3 B PD 1200 Transfer Pump A EDG 12 Diesel Fuel Oil Transfer R3000C002 3 B PD 1200 Pump A EDG 11 Diesel Fuel Oil Transfer R3000C003 3 B PD 1200 Pump B EDG 12 Diesel Fuel Oil Transfer R3000C004 3 B PD 1200 Pump B EDG 13 Diesel Fuel Oil Transfer R3000C009 3 B PD 1200 Pump A EDG 14 Diesel Fuel Oil Transfer R3000C010 3 B PD 1200 Pump A EDG 13 Diesel Fuel Oil Transfer R3000C011 3 B PD 1200 Pump B EDG 14 Diesel Fuel Oil Transfer R3000C012 3 B PD 1200 Pump B to NRC-19-0015 Page 2 10 CFR 50.55a Relief Request PRR-002 Alternative Vibration Acceptance Criteria for Smooth Running Pumps Pump ASME OM Speed(3)

Identification Pump Description Code Type(2)

Group(1) (RPM)

(PIS) No. Class R3001C005 EDG 11 DG Service Water Pump 3 A VLSC 1800 R3001C006 EDG 12 DG Service Water Pump 3 A VLSC 1800 R3001C007 EDG 13 DG Service Water Pump 3 A VLSC 1800 R3001C008 EDG 14 DG Service Water Pump 3 A VLSC 1800 Control Center Heating Ventilating and Air Conditioning T4100C040 3 A CENT 1800 (CCHVAC) South Chilled Water Pump CCHVAC North Chilled Water T4100C041 3 A CENT 1800 Pump (1) All pumps on list are vibration tested quarterly (2) VLSC = vertical line shaft centrifugal, CENT = centrifugal, PD = positive displacement (3) Pump speed is synchronous motor speed

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda

3. Applicable Code Requirement

This request for relief applies only to vibration testing. ISTB-3300 requires that vibration reference values be determined from the results of preservice testing or from the results of the first inservice test. Tables ISTB-5121-1, ISTB-5221-1, and ISTB-5321-1 establish ranges of acceptability of reference values. Specifically, the tables require the use of 2.5 and 6 times the reference values in determining acceptable ranges of vibration unless those calculated values exceed the absolute limits specified in the Tables. ISTB-6200 requires action to be taken based upon exceeding the ranges established in Tables ISTB-5121-1, ISTB-5221-1, and ISTB-5321-1.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(1), relief is requested from the requirements of ASME OM Code ISTB-3300, Tables ISTB-5121-1, ISTB-5221-1, and ISTB-5321-1, and ISTB-6200. The basis of the relief request is that the proposed alternative will provide an acceptable level of quality and safety.

Vibration monitoring point locations are shown on Figures 1 and 2. The listed pumps have at least one vibration reference value (Vr) that is currently less than or equal to 0.04 inches per to NRC-19-0015 Page 3 10 CFR 50.55a Relief Request PRR-002 Alternative Vibration Acceptance Criteria for Smooth Running Pumps second (ips). Small values for Vr result in very small acceptable ranges for pump operation.

The acceptable ranges are defined in Tables ISTB-5121-1, ISTB-5221-1, and ISTB-5321-1, as less than or equal to 2.5Vr. Based on such a small acceptable range, a smooth running pump could be subject to unnecessary corrective action.

5. Proposed Alternative and Basis for Use To avoid unnecessary increased frequency testing or corrective actions on pumps which are performing satisfactorily and with very low baseline vibration, a minimum velocity measurement value (Vr) of 0.04 ips will be established for velocity reference values. This minimum value will be applied to individual vibration locations where the measured reference value is less than or equal to 0.04 ips and utilized in the calculation of acceptable ranges specified in Tables ISTB-5121-1, ISTB-5221-1, and ISTB-5321-1. Therefore, the acceptance range as specified in Tables ISTB-5121-1, ISTB-5221-1, and ISTB-5321-1, will be less than or equal to 0.100 ips, the alert range will be greater than 0.100 to 0.240 ips, and the required action range will be greater than 0.240 ips.

For very small reference values, hydraulic noise and instrumentation error can be a significant portion of the reading and therefore affect the repeatability of subsequent measurements. Also, experience gathered from the predictive maintenance program has shown that changes in vibration levels in the range of 0.04 ips are not typically indicative of degradation in pump or motor condition.

When new reference values are established per ISTB-3310, ISTB-3320 or ISTB-6200(c), the measured parameters will be evaluated for each location to determine if the provisions of this relief request remain applicable. If the measured Vr is greater than 0.04 ips, the requirements of ISTB-3300 will be applied. Conversely, if a measured Vr is less than or equal to 0.04 ips, a minimum value of 0.04 ips will be used for Vr for the pumps included in the list of pumps.

In addition to the requirements of ISTB, the pumps in the ASME Inservice Testing Program are included in the Fermi 2 Vibration Monitoring Program scope. The Vibration Monitoring Program currently employs vibration monitoring and analysis beyond that required by ISTB when the pumps are tested quarterly.

All data is collected currently utilizing an accurate data acquisition system, downloaded into the Vibration Monitoring Program software and then analyzed for vibration magnitude and discrete frequencies. Components exhibiting abnormal vibration trends would be subjected to more advanced diagnostics.

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:

to NRC-19-0015 Page 4 10 CFR 50.55a Relief Request PRR-002 Alternative Vibration Acceptance Criteria for Smooth Running Pumps Increased monitoring to establish rate of change, Review of component specific information to identify cause, and Removal of the pump from service to perform maintenance.

Preventive Maintenance (PM) Program coverage typically entails, depending on the specific pump, oil sampling, lubrication, PDMA motor testing, cleaning, and inspections.

All of the pumps in the IST Program will remain in the PM and Vibration Monitoring Program scope even if certain pumps have very low vibration readings and are considered to be smooth running pumps.

6. Duration of Proposed Alternative This proposed alternative will be utilized for the entire fourth 10-year interval. The fourth interval begins on February 17, 2020.
7. Precedent Fermi 2 currently has approved relief requests for smooth running pumps for the third 10-year interval. The current relief requests are identified as PRR-005 and PRR-011 in the approval documents listed below:

Fermi 2 - Evaluation of Relief Request Nos: PRR-004, PRR-005, PRR-007, and PRR-010 for the Third 10-Year Interval Inservice Program, dated July 6, 2010, Accession No. ML101670372.

Fermi 2 - Alternative Request PRR-011 Concerning the Third 10-Year Inservice Testing Program, dated May 14, 2014, Accession No. ML14128A299.

to NRC-19-0015 Page 5 10 CFR 50.55a Relief Request PRR-002 Alternative Vibration Acceptance Criteria for Smooth Running Pumps Figure 1 - Vertical Line Shaft Centrifugal Vibration Monitoring Points Figure 2 - Centrifugal Horizontal / Positive Displacement Vibration Monitoring Points

Enclosure 3 to NRC-19-0015 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request PRR-003 for the IST Fourth 10-Year Interval to NRC-19-0015 Page 1 10 CFR 50.55a Relief Request PRR-003 Relief for Service Water Pump Suction Pressure Accuracy Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected Pump ASME OM Speed(2)

Identification Pump Description Code Type(1)

Group (RPM)

(PIS) No. Class Residual Heat Removal (RHR)

E1151C001A 3 A VLSC 1800 Service Water Pump A E1151C001B RHR Service Water Pump B 3 A VLSC 1800 E1151C001C RHR Service Water Pump C 3 A VLSC 1800 E1151C001D RHR Service Water Pump D 3 A VLSC 1800 Emergency Equipment Service P4500C002A 3 A VLSC 1800 Water (EESW) South Pump P4500C002B EESW North Pump 3 A VLSC 1800 Emergency Diesel Generator R3001C005 (EDG) 11 DG Service Water 3 A VLSC 1800 Pump R3001C006 EDG 12 DG Service Water Pump 3 A VLSC 1800 R3001C007 EDG 13 DG Service Water Pump 3 A VLSC 1800 R3001C008 EDG 14 DG Service Water Pump 3 A VLSC 1800 (1) VLSC = vertical line shaft centrifugal (2) Pump speed is synchronous motor speed

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda

3. Applicable Code Requirement

ISTB Table ISTB-3510-1, Required Instrument Accuracy

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(1), relief is requested from the requirement of ASME OM Code ISTB Table ISTB-3510-1. The basis of the relief request is that the proposed alternative will provide an acceptable level of quality and safety.

to NRC-19-0015 Page 2 10 CFR 50.55a Relief Request PRR-003 Relief for Service Water Pump Suction Pressure Accuracy Table ISTB-3510-1 specifies the pressure instrument accuracy to be +/-0.5% during a comprehensive pump test. Due to the design of these service water pumps (vertical line shaft), the suction pressure (INLPR) is determined using measurement of RHR reservoir level and correlation to suction lift pressure. The ASME OM code does not specify accuracy requirements for level instrumentation when used as a method to obtain suction lift pressure.

5. Proposed Alternative and Basis for Use Fermi 2 proposes to perform the quarterly testing of these pumps using the existing +/-0.92%

accurate level instrumentation for determining suction pressure.

The instrumentation for level measurement of the RHR reservoir is calibrated to +/-0.73% at full scale (+/-0.22 ft @ 30 ft). The calibration cardinal point of 24 feet bounds readings obtained for pump surveillance testing which range between 4.8 psi and 5.4 psi based on a review of pump testing data obtained in approximately the last five years. The corresponding reservoir level is 27.0 ft (5.4 psi) to 28.4 ft (4.8 psi). The accuracy at that cardinal point is

+/-0.92% (+/-0.22 ft @ 24 ft).

Differential pressure is determined by adding the suction lift pressure derived from RHR reservoir level to the pump discharge pressure. Suction lift pressure is determined using a table relating RHR reservoir level to suction lift in psi (a copy of this table is in each surveillance procedure).

The critical point accuracy of the existing level instrument is +/-0.92% (for the 24 ft cardinal point). For the nominal INLPR pressure reading of 5.4 psi this equates to a maximum possible error of 5.4 x 0.0092 = 0.050 psi which is the conservative side of the INLPR pressure testing range with respect to accuracy. For the comprehensive test of these pumps, the Code required accuracy for pressure is 0.5 %, or 0.027 psi at a measured INLPR of 5.4 psi. The difference between the permanently installed instrument accuracy and the Code required 0.5% accuracy amounts to 0.023 psi.

Temporary digital instrumentation is used to measure the discharge pressure (DISPR) of these pumps. The accuracy of the DISPR measurements is 0.5% of reading or better. The discharge pressure of the subject service water pumps has a range of between 35.8 and 59.6 psi based on recent data depending on the specific pump. To illustrate the discharge pressure accuracy, the high DISPR reading of 59.6 psi will be used. This discharge pressure has an error of 59.6 x 0.005 = 0.30 psi based on an accuracy requirement of +/-0.5%. This is conservative as most modern pressure gauges, such as a Crystal XP2i, are more accurate compared to the ASME OM Code requirement of +/-0.5%. Also, the higher discharge pressure is more conservative in comparison to a lower discharge pressure in terms of full scale instrument accuracy. Combining the INLPR error of 0.050 psi and the DISPR error of to NRC-19-0015 Page 3 10 CFR 50.55a Relief Request PRR-003 Relief for Service Water Pump Suction Pressure Accuracy 0.30 psi using square root sum of the squares gives an overall error of +/-0.30 psi for the P value of 65 psid. This represents a +/-0.47% accuracy of the P measurement.

The differential pressure parameter is affected primarily by the accuracy of the discharge pressure of the pumps. The suction lift pressure derived from RHR reservoir level has lower impact on the overall calculation of pump differential pressure.

The RHR reservoir level transmitter is manufactured by Rosemount, with Model number 1151DP5E12. This instrument is a steel diaphragm style level instrument. The instrument loop calibration includes the transmitter, power supply and digital level indicator / recorder.

In conclusion, Fermi 2 proposes to perform the quarterly testing of these pumps using the existing +/-0.92% accurate level instrument for determining suction pressure. All other measurements and methods will meet the 0.5 % accuracy requirements for determining pump differential pressure. Use of this instrumentation and accuracy during quarterly testing supports Comprehensive Pump Testing instrument requirements.

Using the provisions of this Relief Request as an alternative to the specific requirements of Table ISTB-3510-1 identified above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(z)(1) Fermi 2 requests relief from the specific ISTB requirements identified in this request.

6. Duration of Proposed Alternative This proposed alternative will be utilized for the entire fourth 10-year interval. The fourth interval begins on February 17, 2020.
7. Precedent Fermi 2 currently has an approved relief request for pressure accuracy for the third 10-year interval. The current relief request is identified as PRR-006 in the approval document listed below:

Fermi 2 - Evaluation of Relief Request Nos: PRR-002, PRR-003, and PRR-006 for the Third 10-Year Interval Inservice Program, dated July 6, 2010, Accession No. ML101670351.

Enclosure 4 to NRC-19-0015 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request PRR-004 for the IST Fourth 10-Year Interval to NRC-19-0015 Page 1 10 CFR 50.55a Relief Request PRR-004 Relief from Quarterly Test of Core Spray Pumps Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected Pump ASME OM Speed(2)

Identification Pump Description Code Type(1)

Group (RPM)

(PIS) No. Class E2101C001A Division 1 Core Spray Pump A 2 B CENT 3600 E2101C001B Division 2 Core Spray Pump B 2 B CENT 3600 E2101C001C Division 1 Core Spray Pump C 2 B CENT 3600 E2101C001D Division 2 Core Spray Pump D 2 B CENT 3600 (1) CENT = centrifugal (2) Pump speed is synchronous motor speed

2. Applicable Code Edition and Addenda

ASME OM Code 2012 Edition, No Addenda

3. Applicable Code Requirement

ISTB-3300 (Reference Values)

ISTB-5122 (Group B Test Procedure)

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(1), relief is requested to deviate from the Group B (stand-by) pump testing requirements in ASME Operation and Maintenance (OM) Code sections ISTB-3300 and ISTB-5122. The basis of the relief request is that the proposed alternative will provide an acceptable level of quality and safety.

The ASME OM Code is considered applicable to component testing rather than system level testing. Therefore, the general ASME OM Code requirements for Group B pumps are interpreted to be performed on individual pumps. Historically, the Group B test for the Core Spray (CS) system at Fermi 2 has been performed on two pumps running in parallel due to test system design limitations. For example, Division 1 CS Pumps A and C are operated in parallel during the quarterly pump surveillance. DTE is requesting permission to continue performing the Group B CS test with the pumps operated in parallel for the fourth 10-year interval. Previously in the third 10-year interval, divisional testing was performed under relief request PRR-002. Relief request PRR-002 allowed for divisional testing of the A/C to NRC-19-0015 Page 2 10 CFR 50.55a Relief Request PRR-004 Relief from Quarterly Test of Core Spray Pumps and B/D pumps, and described a planned design modification to allow for individual testing of the pumps. Relief request PRR-002 expired and relief request PRR-012 was approved to continue divisional testing quarterly and perform individual pump testing as part of the Comprehensive Test, performed every two years, through the end of the third 10-year interval. This new relief request PRR-0004 would allow for Fermi to continue testing CS pumps with two pumps running in parallel during the fourth 10-year interval of the IST program for the quarterly Group B test. The Comprehensive Pump Test (CPT) would be performed in accordance with the requirements of the 2012 OM Code.

Background

The CS system protects the reactor core in the event of a large break loss of coolant accident (LOCA) if the Feedwater, Control Rod Drive (CRD), Reactor Core Isolation Cooling (RCIC), High Pressure Coolant Injection (HPCI), or Residual Heat Removal (RHR) systems are unable to maintain Reactor Pressure Vessel (RPV) water level. At Fermi 2, the CS system is divided into two divisions, 1 and 2, with two pumps in each division since each pump is capable of providing only 50% of the desired system flow. If one CS pump is determined to be inoperable, then that CS division is declared inoperable.

DTE has previously requested relief from the NRC to allow the Core Spray pump tests to be conducted with two pumps running in parallel during the first, second, and third 10-year intervals of the IST program. This relief was necessary because the existing flow control valves were not capable of throttling low enough to accommodate single pump operation without experiencing unstable operation, cavitation, and severe vibration. Additionally, the test system configuration and use of dual pumps required relief to allow DTE to use a pump curve methodology for the acceptance criteria.

Prior to the third ten-year interval, DTE submitted relief request PRR-002, Revision 0 (Reference 8.1). This relief was similar to the previous relief granted during the first and second 10-year intervals to allow dual pump operation during the quarterly Group B test and use of a pump curve as acceptance criteria. In this request, DTE also described a planned modification to the CS test line to facilitate single pump operation for the quarterly Group B test and the new CPT (ISTB-5123) by changing test line isolation valve (E2150F015A & B) design on both divisions including the installation of flow restriction orifices. A subsequent relief request, PRR-002, Revision 1 (Reference 8.2) was granted to extend this relief through refueling outage RF-17 to allow additional time for planning and scoping the proposed modification.

As DTE continued to plan the modification described in Reference 8.1, the modification became cost prohibitive due to cost of new valves, reanalysis of the piping system, and the necessary implementation maintenance. The increased cost and risk associated with to NRC-19-0015 Page 3 10 CFR 50.55a Relief Request PRR-004 Relief from Quarterly Test of Core Spray Pumps implementing this modification would not substantially increase the safety benefit to the station; therefore, DTE decided to pursue a different strategy. An alternate modification to allow for single pump testing was planned for RF-17, which consisted of changing the valve internals and actuator gearing on the existing test line isolation valves (E2150F015A & B).

Relief request PRR-012 (Reference 8.3) was written for the third 10-year interval in order to request relief from testing the CS pumps individually for the quarterly Group B test following the expiration of PRR-002, Revision 1, after RF-17 and through the end of the third 10-year interval.

5. Proposed Alternative and Basis for Use The proposed alternative is to perform the quarterly Group B pump test in the manner that it has historically been performed (dual pump testing method), as approved in previous relief request PRR-002 and current relief request PRR-012 for the third 10-year IST interval.

During the quarterly Group B test, both pumps in each division will be tested as a single unit.

This implies that differential pressure and developed head reference values represent a combined pump flow characteristic. Since both pumps are run in parallel, acceptance criteria for differential pressure have been established (Attachments 1 and 2 to this Enclosure), which are more restrictive than the criteria given in Table ISTB-5121-1 for centrifugal pumps. The following additional limitations on acceptance criteria are currently imposed and will be maintained for the duration of the relief request, to assure that any degradation in performance is detected and corrected in a timely manner:

1. In order to enhance the ability to detect the equivalent of one pumps degradation the following acceptance criteria will be utilized, which are more stringent than ISTB limits:

Acceptable P Range - 0.94 to 1.06 Alert Range - 0.92 to < 0.94 Required Action Range - Low < 0.92 and High > 1.06

2. If the hydraulic performance of a CS division enters the Alert Range for any reason other than instruments out of calibration, both pumps in that division will be individually evaluated (e.g., perform motor diagnostics, evaluate vibration data, etc.) in order to determine which pump(s) in the division has degraded. The testing frequency will be doubled until the cause of the deviation is determined and the condition is corrected.
3. If the hydraulic performance of a CS division exceeds the Required Action ranges for any reason, the CS division will be declared inoperable. Appropriate inspections, tests, and repairs will be completed prior to returning the division to service.

to NRC-19-0015 Page 4 10 CFR 50.55a Relief Request PRR-004 Relief from Quarterly Test of Core Spray Pumps

4. New reference curves will be established or the current curves verified after either pump in the division has been repaired, replaced, or serviced.
5. As noted above, the modification performed during RF-17 (i.e. fall 2015) changed the valve internals and gearing for the CS test line isolation valves (E2150F015 A & B). This allowed single pump testing during the CPT every 2 years. This test will also help detect small levels of degradation that may not be as easily noticed during the Quarterly Group B test. The current acceptance criteria for the CPT is based on Table ISTB 5121-1 (2004 OM Code). Although continued use of the 2004 OM Code for this acceptance criteria is conservative with respect to the 2012 OM Code, future revisions of the CPT acceptance criteria may use the 2012 OM Code.
6. Measuring and Test Equipment (M&TE) for pressure will meet the ASME OM Code requirements for a CPT (+/- 0.5%).
7. Vibration data will continue to be taken on each individual pump using the acceptance criteria established in ASME OM Code 2012 Edition (Table ISTB-5121-1). A single Alert criterion and a single Required Action criterion will be used over the range of the pump curve.
8. DTE will use normalization to a reference flow to improve the effectiveness of trending.

The use of flow reference curves (OMN-16 Revision 1) is now approved as described in Regulatory Guide 1.192, Revision 2, Operation and Maintenance Code Case Acceptability, ASME OM Code (Reference 8.4); therefore, no further relief is needed for the use of the flow reference curves.

Basis DTE requests relief to continue Group B quarterly testing of the CS pumps in parallel instead of individually. This is due to the additional time that will be required to perform the surveillance and resultant Limiting Condition for Operation (LCO) time, motor-operated valve (MOV) motor start limitations, loss of historical trend data, and potential valve cavitation. The current quarterly surveillance requires throttling E2150F015A & B while operating both pumps in parallel to achieve a flow of 6600 gallons per minute (gpm). This flow rate is used to meet both Technical Specification (TS) surveillance and IST testing using a pump curve based acceptance criteria. The TS surveillance requires both pumps in a division to be operated in parallel. If individual pump testing is required, one pump would be started and tested for IST, then the second pump would be started to conduct the TS surveillance in parallel, then the first pump would be shut off to test the second pump under IST. This would represent a significant time increase from conducting both tests in parallel to NRC-19-0015 Page 5 10 CFR 50.55a Relief Request PRR-004 Relief from Quarterly Test of Core Spray Pumps simultaneously and challenge the surveillance LCO time. This would also increase the time each division is temporarily inoperable while the testing is performed, which represents unnecessary reduction in defense in depth and introduces challenges to the operators. In addition, there is a limitation on how often a MOV can be cycled for throttling. The motor manufacturer, Limitorque (now owned by Flowserve), recommends a cooling period after 5 consecutive motor starts. Also, there would be a loss of trend data since DTE has obtained pump differential pressure and vibration for IST Group B testing with two pumps on a quarterly basis for many years. Finally, a modeling study for the system found that the valve cavitation index would be worse when testing with a single pump as compared to dual pumps. Therefore, it is preferable to limit how often the pumps are operated individually.

The CS pumps are standby system pumps and accumulate very few hours of run time per year. Degradation is unlikely for such pumps constructed to high quality standards, with periodic maintenance and lubrication activities. The fact that they do not operate frequently also increases the chance of detecting degradation before it reaches the IST Required Action and TS requirements. Charts showing the normalized historic performance trends for each division (pair of pumps) are attached to this relief request (Attachments 3 and 4 to this Enclosure). Historic performance data demonstrates the long-term stability of the CS pumps and the ability to trend the hydraulic performance by testing a pair of pumps for each division. In addition to the pump differential pressure (P), each pump is currently analyzed for vibration, and no adverse vibration trends have been detected. Finally, Attachments 5 through 8 to this Enclosure provide the CPT data acceptance criteria for individual pumps.

Attachment 9 to this Enclosure provides the differential pressure data collected following the RF-17 Comprehensive Pump Preservice Test.

In summary, continuing to perform the Group B pump test using two CS pumps in parallel combined with the single pump CPTs performed every two years is adequate to detect degradation. The quarterly Group B test will continue to use tighter P acceptance criteria compared to the ASME OM Code, individual pump vibration testing, pressure gauge accuracy requirements equivalent to CPT standards, and normalized pump trending. The CPT performed every two years will increase the likelihood of detecting any potential degradation occurring on an individual pump that may be masked during the dual pump test.

Finally, the attached P trend charts show a stable trend and a lack of apparent degradation over many years of service.

6. Duration of Proposed Alternative This proposed alternative will be utilized for the entire fourth 10-year interval. The fourth interval begins on February 17, 2020.

to NRC-19-0015 Page 6 10 CFR 50.55a Relief Request PRR-004 Relief from Quarterly Test of Core Spray Pumps

7. Precedent Fermi 2 currently has an approved relief request for CS pump test frequency for the third 10-year interval. The current relief request is identified as PRR-012 in the approval document listed below:

Fermi, Unit No. 2 - Inservice Testing Program Relief Request PRR-012 for Quarterly Test of Core Spray Pumps, dated August 24, 2015, Accession No. ML15218A360.

Note that although relief request PRR-0012 was submitted by DTE under 10 CFR 50.55a(z)(1), the relief request was reviewed by the NRC under 10 CFR 50.55a(f)(5)(iii) and granted by the NRC under 10 CFR 50.55a(f)(6)(i) as discussed in email captured by Accession No. ML15160A477. This change in review criteria was potentially related to the discussion of a future plant modification. Since the relevant plant modification is now complete, this relief request for the fourth 10-year interval (i.e. PRR-004) is being requested under 10 CFR 50.55a(z)(1).

8. References 8.1 DTE Electric Company letter to NRC, Submittal of Inservice Testing Program Relief Requests for Pumps and Valves - Third Ten-Year Interval, NRC-09-0064, dated November 3, 2009 (ML093140302).

8.2 DTE Electric Company letter to NRC, Submittal of Revised Relief Request No.

PRR-002 for the Inservice Testing Program Third 10-Year Interval, NRC-12-0015, dated February 20, 2012 (ML12052A043).

8.3 DTE Electric Company letter to NRC, Submittal of Inservice Testing Program Relief Request PRR-012 for Quarterly Test of Core Spray Pumps, NRC-15-0027, dated March 5, 2015 (ML15064A073).

8.4 U.S. Nuclear Regulatory Commission, Regulatory Guide 1.192, Revision 2, Operation and Maintenance Code Case Acceptability, ASME OM Code, dated March 2017 (ML16321A337)

9. Attachments Attachment 1, Division 1 Core Spray Pumps Performance Curve and Acceptance Criteria Table for Procedure 24.203.02 [1 page]

Attachment 2, Division 2 Core Spray Pumps Performance Curve and Acceptance Criteria Table for Procedure 24.203.03 [1 page]

to NRC-19-0015 Page 7 10 CFR 50.55a Relief Request PRR-004 Relief from Quarterly Test of Core Spray Pumps Attachment 3, Division 1 Core Spray Pump Differential Pressure Trend Chart

[1 page]

Attachment 4, Division 2 Core Spray Pump Differential Pressure Trend Chart

[1 page]

Attachment 5, Core Spray Pump A, Comprehensive Pump Test Differential Pressure Acceptance Criteria for Procedure 24.203.02 [1 page]

Attachment 6, Core Spray Pump B, Comprehensive Pump Test Differential Pressure Acceptance Criteria for Procedure 24.203.03 [1 page]

Attachment 7, Core Spray Pump C, Comprehensive Pump Test Differential Pressure Acceptance Criteria for Procedure 24.203.02 [1 page]

Attachment 8, Core Spray Pump D, Comprehensive Pump Test Differential Pressure Acceptance Criteria for Procedure 24.203.03 [1 page]

Attachment 9, Core Spray Pump A-D, Comprehensive Pump Test Differential Pressure Data Collected Since Refueling Outage 17 Preservice Testing [1 page]

ATTACHMENT 1 to ENCLOSURE 4 of NRC-19-0015 (PRR-004)

DIVISION 1 CORE SPRAY PUMPS PERFORMANCE CURVE AND ACCEPTANCE CRITERIA TABLE FOR PROCEDURE 24.203.02 Pr = 456.8592530 - 0.027306Qr where: Pr = Reference Differential Pressure, psi Qr = Reference Flow, gpm Acceptable Range: 0.94Pr P 1.06Pr Alert Range Low: 0.92Pr P < 0.94Pr Required Action Range: Low P < 0.92Pr High P > 1.06Pr Table 1 Core Spray Loop A E2101C001A & C Flow Flow Required Required Range Range Action Alert Range Low Acceptable Range Action Low High Range Low (psi) P (psi) Range High (gpm) (gpm) (psi) (psi) 6600 6650 < 254.6 254.6 to < 260.1 260.1 to 291.7 > 291.7 6650 6700 < 253.3 253.3 to < 258.8 258.8 to 290.3 > 290.3 6700 6750 < 252.0 252.0 to < 257.5 257.5 to 288.8 > 288.8 6750 6800 < 250.8 250.8 to < 256.2 256.2 to 287.4 > 287.4 6800 6850 < 249.5 249.5 to < 255.0 255.0 to 286.0 > 286.0 6850 6900 < 248.3 248.3 to < 253.7 253.7 to 284.5 > 284.5 6900 6950 < 247.0 247.0 to < 252.4 252.4 to 283.1 > 283.1 6950 7000 < 245.8 245.8 to < 251.1 251.1 to 281.6 > 281.6 7000 7050 < 244.5 244.5 to < 249.8 249.8 to 280.2 > 280.2 7050 7100 < 243.3 243.3 to < 248.5 248.5 to 278.7 > 278.7 7100 7150 < 242.0 242.0 to < 247.3 247.3 to 277.3 > 277.3 7150 7200 < 240.7 240.7 to < 246.0 246.0 to 275.8 > 275.8

ATTACHMENT 2 to ENCLOSURE 4 of NRC-19-0015 (PRR-004)

DIVISION 2 CORE SPRAY PUMPS PERFORMANCE CURVE AND ACCEPTANCE CRITERIA TABLE FOR PROCEDURE 24.203.03 Pr = 444.50000 - 0.02500Qr where: Pr = Reference Differential Pressure, psi Qr = Reference Flow, gpm Acceptable Range: 0.94Pr P 1.06Pr Alert Range Low: 0.92Pr P < 0.94Pr Required Action Range: Low P < 0.92Pr High P > 1.06Pr Table 1 Core Spray Loop B E2101C001B & D Flow Flow Required Required Range Range Action Alert Range Low Acceptable Range Action Low High Range Low (psi) P (psi) Range High (gpm) (gpm) (psi) (psi) 6600 6650 < 257.2 257.2 to < 262.8 262.8 to 294.9 > 294.9 6650 6700 < 256.0 256.0 to < 261.6 261.6 to 293.6 > 293.6 6700 6750 < 254.9 254.9 to < 260.4 260.4 to 292.2 > 292.2 6750 6800 < 253.7 253.7 to < 259.3 259.3 to 290.9 > 290.9 6800 6850 < 252.6 252.6 to < 258.1 258.1 to 289.6 > 289.6 6850 6900 < 251.4 251.4 to < 256.9 256.9 to 288.3 > 288.3 6900 6950 < 250.3 250.3 to < 255.7 255.7 to 286.9 > 286.9 6950 7000 < 249.1 249.1 to < 254.6 254.6 to 285.6 > 285.6 7000 7050 < 248.0 248.0 to < 253.4 253.4 to 284.3 > 284.3 7050 7100 < 246.8 246.8 to < 252.2 252.2 to 283.0 > 283.0 7100 7150 < 245.7 245.7 to < 251.0 251.0 to 281.6 > 281.6 7150 7200 < 244.5 244.5 to < 249.9 249.9 to 280.3 > 280.3

ATTACHMENT 3 to ENCLOSURE 4 of NRC-19-0015 (PRR-004)

Division 1 Core Spray Pump Differential Pressure Trend Chart Div 1 Core Spray Normalized DP Trend 290 285 280 275 270 265 260

ATTACHMENT 4 to ENCLOSURE 4 of NRC-19-0015 (PRR-004)

Division 2 Core Spray Pump Differential Pressure Trend Chart Div 2 Core Spray Normalized DP Trend 290 285 280 275 270 265 260

ATTACHMENT 5 to ENCLOSURE 4 of NRC-19-0015 (PRR-004)

Core Spray Pump A Comprehensive Pump Test Differential Pressure Acceptance Criteria for Procedure 24.203.02 Range Range Required Required Acceptable Range Alert Range Design Min Flow Low Flow High Action Range Action Range (psid) (psid) P (psid)

(gpm) (gpm) Low (psid) High (psid) 3200 3225 263.7 to < 291.9 258.4 to 263.7 < 258.4 > 291.9 < 258.42 3225 3250 262.5 to < 290.6 256.8 to 262.5 < 256.8 > 290.6 < 256.81 3250 3275 261.3 to < 289.3 255.2 to 261.3 < 255.2 > 289.3 < 255.18 3275 3300 260.1 to < 287.9 253.5 to 260.1 < 253.5 > 287.9 < 253.54 3300 3325 258.9 to < 286.6 251.9 to 258.9 < 251.9 > 286.6 < 251.88 3325 3350 257.6 to < 285.2 250.2 to 257.6 < 250.2 > 285.2 < 250.20 3350 3375 256.4 to < 283.9 248.5 to 256.4 < 248.5 > 283.9 < 248.50 3375 3400 255.2 to < 282.5 246.9 to 255.2 < 246.9 > 282.5 < 246.79 3400 3425 253.9 to < 281.1 245.7 to 253.9 < 245.7 > 281.1 < 245.06 3425 3450 252.7 to < 279.7 244.5 to 252.7 < 244.5 > 279.7 < 243.31 3450 3475 251.4 to < 278.3 243.3 to 251.4 < 243.3 > 278.3 < 241.55 3475 3500 250.1 to < 276.9 242.0 to 250.1 < 242.0 > 276.9 < 239.76 Pr = -8.5E-6 Qr2 + 3.6E-3 Qr + 358.8 where Pr = Reference Differential Pressure (psi) and Qr = Reference Flow (gpm)

Acceptable Range: 0.93 to 1.03Pr Alert Range Low: 0.90 to < 0.93Pr Required Action Range: Low < 0.90Pr High > 1.03Pr

ATTACHMENT 6 to ENCLOSURE 4 of NRC-19-0015 (PRR-004)

Core Spray Pump B Comprehensive Pump Test Differential Pressure Acceptance Criteria for Procedure 24.203.03 Range Range Required Required Acceptable Range Alert Range Design Min Flow Low Flow High Action Range Action Range (psid) (psid) P (psid)

(gpm) (gpm) Low (psid) High (psid) 3200 3225 259.1 to < 286.8 256.9 to 259.1 < 256.9 > 286.8 < 256.90 3225 3250 257.9 to < 285.5 255.2 to 257.9 < 255.2 > 285.5 < 255.22 3250 3275 256.6 to < 284.1 253.5 to 256.6 < 253.5 > 284.1 < 253.51 3275 3300 255.4 to < 282.8 251.8 to 255.4 < 251.8 > 282.8 < 251.78 3300 3325 254.2 to < 281.4 250.0 to 254.2 < 250.0 > 281.4 < 250.03 3325 3350 252.9 to < 280.0 248.3 to 252.9 < 248.3 > 280.0 < 248.25 3350 3375 251.7 to < 278.6 246.5 to 251.7 < 246.5 > 278.6 < 246.46 3375 3400 250.4 to < 277.2 244.7 to 250.4 < 244.7 > 277.2 < 244.65 3400 3425 249.1 to < 275.8 242.8 to 249.1 < 242.8 > 275.8 < 242.81 3425 3450 247.8 to < 274.3 241.0 to 247.8 < 241.0 > 274.3 < 240.95 3450 3475 246.5 to < 272.9 239.1 to 246.5 < 239.1 > 272.9 < 239.07 3475 3500 245.2 to < 271.5 237.3 to 245.2 < 237.3 > 271.5 < 237.16 Pr = -8.7E-6 Qr2 + 3.8E-3 Qr + 355.4 where Pr = Reference Differential Pressure (psi) and Qr = Reference Flow (gpm)

Acceptable Range: 0.93 to 1.03Pr Alert Range Low: 0.90 to < 0.93Pr Required Action Range: Low < 0.90Pr High > 1.03Pr

ATTACHMENT 7 to ENCLOSURE 4 of NRC-19-0015 (PRR-004)

Core Spray Pump C Comprehensive Pump Test Differential Pressure Acceptance Criteria for Procedure 24.203.02 Range Range Required Required Acceptable Range Alert Range Design Min Flow Low Flow High Action Range Action Range (psid) (psid) P (psid)

(gpm) (gpm) Low (psid) High (psid) 3200 3225 259.7 to < 287.5 258.4 to 259.7 < 258.4 > 287.5 < 258.42 3225 3250 258.4 to < 286.0 256.8 to 258.4 < 256.8 > 286.0 < 256.81 3250 3275 257.0 to < 284.5 255.2 to 257.0 < 255.2 > 284.5 < 255.18 3275 3300 255.6 to < 283.0 253.5 to 255.6 < 253.5 > 283.0 < 253.54 3300 3325 254.3 to < 281.5 251.9 to 254.3 < 251.9 > 281.5 < 251.88 3325 3350 252.9 to < 280.0 250.2 to 252.9 < 250.2 > 280.0 < 250.20 3350 3375 251.5 to < 278.4 248.5 to 251.5 < 248.5 > 278.4 < 248.50 3375 3400 250.1 to < 276.9 246.8 to 250.1 < 246.8 > 276.9 < 246.79 3400 3425 248.6 to < 275.3 245.1 to 248.6 < 245.1 > 275.3 < 245.06 3425 3450 247.2 to < 273.7 243.3 to 247.2 < 243.3 > 273.7 < 243.31 3450 3475 245.7 to < 272.1 241.6 to 245.7 < 241.6 > 272.1 < 241.55 3475 3500 244.3 to < 270.4 239.8 to 244.3 < 239.8 > 270.4 < 239.76 Pr = -1.1E-5 Qr2 + 1.1E-2 Qr + 352.0 where Pr = Reference Differential Pressure (psi) and Qr = Reference Flow (gpm)

Acceptable Range: 0.93 to 1.03Pr Alert Range Low: 0.90 to < 0.93Pr Required Action Range: Low < 0.90Pr High > 1.03Pr

ATTACHMENT 8 to ENCLOSURE 4 of NRC-19-0015 (PRR-004)

Core Spray Pump D Comprehensive Pump Test Differential Pressure Acceptance Criteria for Procedure 24.203.03 Range Range Required Required Acceptable Range Alert Range Design Min Flow Low Flow High Action Range Action Range (psid) (psid) P (psid)

(gpm) (gpm) Low (psid) High (psid) 3200 3225 262.1 to < 290.1 256.9 to 262.1 < 256.9 > 290.1 < 256.90 3225 3250 260.8 to < 288.7 255.2 to 260.8 < 255.2 > 288.7 < 255.22 3250 3275 259.5 to < 287.3 253.5 to 259.5 < 253.5 > 287.3 < 253.51 3275 3300 258.2 to < 285.9 251.8 to 258.2 < 251.8 > 285.9 < 251.78 3300 3325 256.9 to < 284.5 250.0 to 256.9 < 250.0 > 284.5 < 250.03 3325 3350 255.6 to < 283.0 248.3 to 255.6 < 248.3 > 283.0 < 248.25 3350 3375 254.3 to < 281.5 246.5 to 254.3 < 246.5 > 281.5 < 246.46 3375 3400 253.0 to < 280.1 244.8 to 253.0 < 244.8 > 280.1 < 244.65 3400 3425 251.6 to < 278.6 243.5 to 251.6 < 243.5 > 278.6 < 242.81 3425 3450 250.3 to < 277.1 242.2 to 250.3 < 242.2 > 277.1 < 240.95 3450 3475 248.9 to < 275.6 240.9 to 248.9 < 240.9 > 275.6 < 239.07 3475 3500 247.5 to < 274.1 239.6 to 247.5 < 239.6 > 274.1 < 237.16 Pr = -9.5E-6 Qr2 + 6.7E-3 Qr + 357.7 where Pr = Reference Differential Pressure (psi) and Qr = Reference Flow (gpm)

Acceptable Range: 0.93 to 1.03Pr Alert Range Low: 0.90 to < 0.93Pr Required Action Range: Low < 0.90Pr High > 1.03Pr

ATTACHMENT 9 to ENCLOSURE 4 of NRC-19-0015 (PRR-004)

Core Spray Pump A-D, Comprehensive Pump Test Differential Pressure Data Collected Since Refueling Outage 17 Preservice Testing Date Pump Flow (gpm) Differential Pressure (psid) Acceptable Range (psid) 12/16/17 E2101C001A 3260.9 280.9 261.3 to < 289.3 12/16/17 E2101C001C 3255.0 274.2 257.0 to < 284.5 12/28/17 E2101C001B 3234.0 277.9 257.9 to < 285.5 12/28/17 E2101C001D 3227.0 281.4 260.8 to < 288.7

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