ML16230A508

Fermi, Unit 2 - Revised Relief Request No. PRR-007 for the Inservice Testing Program Third10-year Interval (CAC No. Mf7573)

ML16230A508
Person / Time
Site:	Fermi
Issue date:	09/23/2016
From:	Wrona D J Plant Licensing Branch III
To:	Fessler P DTE Electric Company
Goetz S, DORL/LPL3-1
References
CAC MF7573
Download: ML16230A508 (9)

Text

Mr. Paul Fessler Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2 -210 NOC 6400 North Dixie Highway Newport, Ml 48166 September 23, 2016

SUBJECT: FERMI, UNIT NO. 2 -REVISED RELIEF REQUEST NO. PRR-007 FOR THE INSERVICE TESTING PROGRAM THIRD 10-YEAR INTERVAL (CAC NO. MF7573)

Dear Mr. Fessler:

By letter dated April 5, 2016 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML 16097A172), as supplemented by letter dated June 23, 2016 (ADAMS Accession No. ML 16179A 150), DTE Electric Company (DTE, the licensee) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for the use of an alternative to certain American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) requirements associated with pump inservice testing (IST) program at Fermi 2. Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 O CFR) 50.55a(z)(1 ), the licensee requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety. The NRC staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that DTE has adequately addressed all of the regulatory requirements set forth in 1 O CFR 50.55a(z)(1) and provides an acceptable level of quality and safety. Therefore, the NRC staff authorizes the use of the alternative request PRR-007, Revision 1, for Fermi for the third 10-year IST program interval, which began on February 17, 2010, and is scheduled to end on February 16, 2020. All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable. If you have any questions, please contact the NRC Project Manager, Sujata Goetz, at 301-415-8004, or via e-mail at Sujata.Goetz@nrc.gov. Docket No. 50-341

Enclosure:

Safety Evaluation cc w/encls: Distribution via ListServ

Sincerely,Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING REQUEST NO. PRR-007 FOR THE THIRD 10-YEAR INTERVAL INSERVICE TESTING PROGRAM DTE ELECTRIC COMPANY FERMI 2 POWER PLANT DOCKET NO. 50-341 1.0 INTRODUCTION By letter dated April 5, 2016 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML 16097A172), as supplemented by letter dated June 23, 2016 (ADAMS Accession Number ML 16179A 150), DTE Electric Company (DTE, the licensee) submitted a request to the U.S. Nuclear Regulatory Commission (NRC or Commission) for the use of an alternative to certain American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) requirements associated with pump inservice testing (IST) program. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1 ), the licensee requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety. 2.0 REGULATORY EVALUATION The regulation at 1 O CFR 50.55a(f), "lnservice Testing Requirements," states, in part, that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with the specified ASME OM Code and applicable addenda incorporated by reference in the regulations. 1 O CFR 50.55a(z)( 1) states that alternatives to the requirements of paragraph (f) of 1 O CFR 50.55a may be used when authorized by the NRC, if the licensee demonstrates the proposed alternatives would provide an acceptable level of quality and safety. Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request and the Commission to authorize the alternative requested by the licensee. Enclosure

-2 -3.0 TECHNICAL EVALUATION 3.1 Licensee's Request for an Alternative. PRR-007, Revision 1 The applicable ASME Code requirements are as follows:

• ASME OM Code, 2004 Edition, ISTB-3400, "Frequency of lnservice Tests," refers to Table ISTB-3400-1, "lnservice Test Frequency," which specifies that a comprehensive test be performed biennially for Group A and Group B pumps.

• ASME OM Code, 2004 Edition, ISTB-5123, "Comprehensive Test Procedure," specifies the specific requirements for the comprehensive test for centrifugal pumps.

• ASME OM Code, 2004 Edition, ISTB-5223, "Comprehensive Test Procedure," specifies the specific requirements for the comprehensive test for vertical line shaft pumps. ASME OM Code Cases, Code Case OMN-18, "Alternate Testing Requirements for Pumps Tested Quarterly within +/-20% of Design Flow," states, in part, that " ... the Group A test may be performed quarterly within +/-20% of pump design flow rate, with instrumentation meeting the requirements of Table ISTB-3510-1 (Table ISTB-3500-1 in the 1998 Edition through the 2003 Addenda, Table ISTB 4.7.1-1 in the OMc-1994 Addenda through the OMb-1997 Addenda)for the Comprehensive and Preservice Tests, and no comprehensive test is required." The licensee requested to use a modified quarterly Group A test for the IST in lieu of a quarterly Group A and a biennial comprehensive pump test (CPT) for the pumps listed in Table 1, below. The Fermi third 10-year IST program interval began on February 17, 2010, and is scheduled to end on February 16, 2020. The applicable ASME OM Code edition and addenda for the Fermi third 10-year IST program interval is the 2004 Edition, no Addenda.

-3 -Table 1 Pump Description Current ASME Classification Class PumcType E1102C002A RHR Pump A Group A 2 Centrifuaal E1102C002B RHR Pump B Grouo A 2 Centrifuaal E1102C002C RHR Pump C Group A 2 Centrifuaal E1102C002D RHR Pump D Grouo A 2 Centrifuaal E1151C001A RHR Service Water Pump A Group A 3 Vertical Line Shaft E1151C001 B RHR Service Water Pump B Grouo A 3 Vertical Line Shaft E1151C001C RHR Service Water Pump C Group A 3 Vertical Line Shaft E1151C001D RHR Service Water Pump D Grouo A 3 Vertical Line Shaft E4101C001 Hiqh Pressure Coolant Injection Pump Group A 2 Centrifuaal P4400C001A Emeraencv EauiP. Coolina Water Div. 1 Pump Grouo A 3 Centrifuaal P4400C001B Emerqency Equip. Coolinq Water Div. 2 Pump Group A 3 Centrifuqal P4500C002A Emerqencv Eauip. Service Water South Pump Grouo A 3 Vertical Line Shaft P4500C002B Emeraencv Eauip. Service Water North Pump Grouo A 3 Vertical Line Shaft R3001C005 EDG 11 DG Service Water Pump Group A 3 Vertical Line Shaft R3001C006 EDG 12 DG Service Water Pump Grouo A 3 Vertical Line Shaft R3001C007 EOG 13 DG Service Water Pump Group A 3 Vertical Line Shaft R3001C008 EDG 14 DG Service Water Pumo Grouo A 3 Vertical Line Shaft T4100C040 South CCHVAC Chilled Water Pump Group A 3 Centrifuaal T4100C041 North CCHVAC Chilled Water Pump Grouo A 3 Centrifuaal By letter dated April 5, 2016, the licensee stated in part, the following reason for the request: Table ISTB-3400-1 specifies a biennial frequency for the CPT for Group A and Group B pumps. ISTB-5123 describes the specific requirements for performance of CPT for centrifugal pumps. Performance of the biennial CPT on the identified pumps are unnecessary since the existing quarterly pump tests are performed at sufficient flow rate to adequately monitor for pump degradation. Proposed Alternative The licensee proposes that in lieu of the requirements of ISTB-5123 and ISTB-5223, modified Group A tests will be performed quarterly, with instrumentation meeting the instrument accuracy requirements of Table ISTB-3510-1 for the biennial CPT. For the centrifugal pumps, the acceptable range for differential pressure would be 0.90 to 1.06 of the reference value. For the vertical line shaft pumps, the acceptable range for differential pressure would be 0.95 to 1.06 of the reference value, and the alert range would be 0.93 to <0.95 of the reference value. The licensee is proposing this alternative for the pumps listed in Table 1. All of the pumps in Table 1 are currently classified as Group A, and will remain classified as Group A. These acceptable ranges are more conservative than the acceptable ranges in Code Case OMN-18. Section ISTB-3300 requires that the CPT be performed within +/-20 percent of the pump design flow rate. This can be interpreted as either the design accident flow rate, design point, or the best efficiency point, provided that the testing is performed in a region of the pump curve where there is a linear flow to head relationship. This allows the test to properly monitor for pump

-4 -degradation. Table 2 indicates where each pump is tested with respect to flow rate and the pump curve region. Table 2 Pump Description +/-20% Design :t20% Best Linear Region of Accident Flow Efficiency Point Pump Curve Rate Flow Rate E1102C002A RHR Pump A x x E1102C002B RHR Pump B x x E1102C002C RHR Pump C x x E1102C002D RHR Pump D x x E1151C001A RHR Service Water x x Pump A E1151C001B RHR Service Water x x Pump B E1151 C001 C RHR Service Water x x PumpC E1151C001D RHR Service Water x x PumpD E4101C001 High Pressure x x Coolant Injection Pump P4400C001A Emergency Equip. x x Cooling Water Div. 1 Pump P4400C001B Emergency Equip. x x Cooling Water Div. 2 Pump P4500C002A Emergency Equip. x x Service Water South Pump P4500C002B Emergency Equip. x x Service Water North Pump R3001C005 EDG 11 DG Service x x Water Pump R3001C006 EDG 12 DG Service x x Water Pump R3001C007 EDG 13 DG Service x x Water Pump R3001C008 EDG 14 DG Service x x Water Pump T4100C040 South CCHVAC x x Chilled Water Pump T4100C041 North CCHVAC x x Chilled Water Pump The use of ASME OM Code Case OMN-18 allows the performance of a Group A test in lieu of a CPT if the Group A test is conducted at the CPT flow rate using pressure instruments that meet the CPT accuracy requirements. Quarterly Group A pump testing performed at the CPT flow rate is more effective in assessing the pumps' operational readiness, through trending, than a

-5 -Group A test at lower flow rates in conjunction with a biennial CPT. The modified Group A test acceptance criteria (discussed above) will be used for pump IST rather than having to use the CPT criterion for one biennial test. The acceptance criteria for vibration tests would be the same as for Group A tests shown in Tables ISTB-5121-1 and ISTB-5221-1. 3.2 NRC Staff Evaluation The licensee is proposing to use ASME OM Code Case OMN-18, with a modified acceptance criteria, and perform IST for all the pumps listed in Table 1 in accordance with a modified Group A test procedure. The ASME OM Code requires that for Group A pumps, a Group A test is performed every quarter, and a CPT is performed biennially. The Group A test is performed within +/-20 percent of the pump design flow rate (if practicable), the pressure instrument accuracy is +/-2 percent, and the upper limit for the acceptable range for differential pressure is 11 O percent of the reference value. The CPT is performed within +/-20 percent of the pump design flow rate, the pressure instrument accuracy is +/-1/2 percent, and the upper limit of the acceptable range for differential pressure is 103 percent of the reference value. Vibration monitoring is performed during both the Group A test and the CPT. The licensee proposes that for the pumps listed in Table 1, which are classified as Group A, a modified Group A quarterly test be performed every quarter, and the biennial CPT is not required. The modified Group A quarterly test would be performed within +/-20 percent of the pump design accident flow rate for pumps indicated in Table 2. For the pumps indicated in Table 2 as being tested within +/-20 percent of pump best efficiency point flow rate, this is acceptable because the pumps will be operating on a sloped portion of the pump curve where degradation is more detectable. The more accurate pressure instrumentation that is required for a CPT (+/-1/2 percent versus +/-2 percent) will be used. This modified quarterly test would replace the CPT. The acceptable range for differential pressure for the modified Group A quarterly test is more conservative than the range for the Group A quarterly test. The licensee is proposing to perform a modified Group A pump test every quarter and not perform a CPT. The licensee will use a more limiting upper bound of 106 percent for the Acceptable Range for differential pressure in lieu of 110 percent that is required by the OM Code for Group A tests. This proposed upper bound of 106 percent is greater than the upper bound of 103 percent for the biennial CPT. All of the pump tests will be performed with pressure instruments with +/-1/2 percent accuracy. For the pumps that are currently classified as Group A, the elimination of the CPT (with its more limiting differential pressure Acceptable Range upper bound of 103 percent) is compensated for by using more accurate pressure gauges on every quarterly test. This will provide for better trending of pump performance. -Instead of performing seven tests with pressure instruments with +/-2 percent accuracy, and then performing the eighth test with pressure instruments with +/-1/2 percent accuracy, all eight tests will be performed with the same +/-1/2 percent accurate instruments. The proposed alternative would provide reasonable assurance of the operational readiness for the pumps listed in Table 1.

-6 -4.0 CONCLUSION As set forth above, the NRC staff determined that for alternative request PRR-007, Revision 1, for Fermi, the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1) for request PRR-007, Revision 1, and is in compliance with the ASME OM Code's requirement. Therefore, the NRC staff authorizes the use of the alternative request PRR-007, Revision 1, for Fermi for the third 10-year IST program interval, which began on February 17, 2010, and is scheduled to end on February 16, 2020. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests remain applicable. Principle Contributor: Robert Wolfgang, NRR/DE/EPNB Date of issuance: September 23, 2016