NRC-12-0068, Notification of Deviation from BWRVIP-205 Guidelines
| ML12296A082 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/19/2012 |
| From: | Conner J Detroit Edison, Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| BWRVIP-205, NRC-12-0068 | |
| Download: ML12296A082 (2) | |
Text
J. Todd CoRner Director, Nuclear Production DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5325 Fax: 734.586.5295 Email: connert@dteenergycom DTE Energy-October 19, 2012 NRC-12-0068 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) BWRVIP-205, "BWR Vessel and Internals Project, Bottom Head Drain Line Inspection and Evaluation Guidelines,"
EPRI Report TR-1018428, November 2008
- 3) BWRVIP-94, "BWR Vessel and Internals Project Program Implementation Guide," Revision 2, September 2011
Subject:
Notification of Deviation from BWRVIP-205 Guidelines Reference 3 requires notifying the Nuclear Regulatory Commission (NRC) anytime a utility does not implement any portion of an applicable "mandatory" or "needed" BWR Vessel and Internals Project (BWRVIP) guideline that has been approved by the BWRVIP Executive Committee and transmitted to the NRC. Reference 3 further states that the notification shall be sent to the NRC within 45 days of the utility executive concurrence with the Deviation Disposition.
A Deviation Disposition for the Reactor Water Clean Up (RWCU) bottom head drain line was signed by the Fermi 2 Site Vice President on September 17, 2012. The deviation is from a guideline that is designated as "needed" by the BWRVIP. The guidance requires that inspections of the RWCU bottom head drain line be performed using methods such as ultrasonic testing or radiography. Due to the location of the drain line nozzle, remote methods and specialized tooling must be utilized. This requirement is applicable to plants ranked as Category C by EPRI in Reference 2. The
USNRC NRC-12-0068 Page 2 deadline for completion of this piping wall thickness examination at Fermi 2 was the fifteenth refueling outage (RF15). RF15 was completed on May 5, 2012.
Detroit Edison attempted a radiography inspection of the RWCU bottom drain per the requirements in BWRVIP-205 (Reference 2). This inspection was not successfully completed during RF15 due to physical plant configuration and technical difficulties encountered with the selected radiography equipment.
The analysis included in the Deviation Disposition submitted to the BWRVIP concluded that there is reasonable assurance that the RWCU bottom drain piping at Fermi 2 has not experienced significant wall thickness thinning due to Flow Accelerated Corrosion (FAC). This is based on inspections at other Category C plants where successful inspections of the RWCU bottom drain found no FAC wear. In addition, examinations were performed during RF15 at Fermi 2 on similar RWCU under vessel piping and other RWCU piping considered to be more susceptible to FAC compared to the bottom drain. These examinations did not find any significant wear.
The RWCU bottom head drain line inspection is currently planned to be performed in the upcoming sixteenth refueling outage (RF16). The use of modified radiography equipment and improved mockup of the physical plant configuration demonstrated that this inspection can be successfully performed in RF16.
This letter is being transmitted for NRC information only, based on the requirement in Reference 3. No regulatory action is being requested.
No regulatory commitments are included in this letter.
Should you have any questions or require additional information, please contact Mr.
Zackary W. Rad of my staff at (734) 586-5076.
Sincerely, 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