L-14-114, Reply to Request for Additional Information for the Review of License Renewal Application (TAC No. ME4640) and Amendment No. 49

Reply to Request for Additional Information for the Review of License Renewal Application (TAC No. ME4640) and Amendment No. 49

ML14072A008
Person / Time
Site:	Davis Besse
Issue date:	03/11/2014
From:	Lieb R FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-14-114, TAC ME4640
Download: ML14072A008 (17)

Text

FENOCT F5501 North State Route 2 FirstEnergyNuclear OperatingCompany Oak Harbor, Ohio 43449 Raymond A. Lieb 419-321-7676 Vice President,Nuclear Fax: 419-321-7582 March 11,2014 L-14-114 10 CFR 54 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4640) and License Renewal Application Amendment No. 49 By letter dated August 27, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102450565), FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse). By letter dated February 11, 2014 (ML14029A201), the Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the License Renewal Application (LRA).

The Attachment provides the FENOC reply to the NRC request for additional information. The NRC request is shown in bold text followed by the FENOC response.

The Enclosure provides Amendment No. 49 to the Davis-Besse LRA.

There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March _L1, 2014.

Sincerely, Raym/nd A. Lieb

Davis-Besse Nuclear Power Station, Unit No. 1 L-14-114 Page 2

Attachment:

Reply to Requests for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse), License Renewal Application (LRA), Section B.2.7

Enclosure:

Amendment No. 49 to the Davis-Besse License Renewal Application cc: NRC DLR Project Manager NRC Region III Administrator cc: w/o Attachment or Enclosure NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board

Attachment L-14-114 Reply to Requests for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse),

License Renewal Application (LRA),

Section B.2.7 Page 1 of 4 Question RAI 2011-03-1

Background:

The License Renewal Annual Update letter, dated September 20, 2013, amended the acceptance criteria for cathodic protection ground surveys to address the changes in recommendations issued in License Renewal Interim Staff Guidance (LR-ISG)-2011-3, "Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program (AMP) XI.M41, 'Buried and Underground Piping and Tanks'." As amended, the cathodic protection acceptance criteria are negative 850 mV relative to a copper/copper sulfate reference electrode instant off or negative 100 mV minimum polarization, and limiting critical potential not more negative than 1200 mV.

LR-ISG-2011-3 Table 6a, "Cathodic Protection Acceptance Criteria," recommends that, [t]he 100 mV polarization criterion is limited to electrically isolated piping sections or areas of grounded piping where the effects of mixed potentials are shown to be minimal. When the 100 mV criterion is utilized in lieu of the -850 mV CSE criterion for steel piping, or where copper or aluminum components are protected, applicants must explain in the application why the effects of mixed potentials are minimal and why the most anodic metal in the system is adequately protected.

Issue:

A basis was not provided for the 100 mV polarization criterion to demonstrate that the effects of mixed potentials are minimal and the most anodic metal in the system is adequately protected.

Request:

State the basis for use of the negative 100 mV minimum polarization criterion, or revise the Buried Piping and Tanks Inspection Program to be consistent with the cathodic protection criteria stated in LR-ISG-2011-03.

RESPONSE RAI 2011-03-1 The cathodic protection system NACE International negative 100 mV minimum polarization criterion is applied to the manways and vents located at the top of the two

Attachment L-14-114 Page 2 of 4 emergency diesel generator fuel oil storage tanks (T-1 53-1 and T-1 53-2) because their polarization instant off values range from 15-150 mV below the -850 mV CSE criterion.

However, the 100mV minimum polarization criterion is being met at all locations on the fuel oil piping and tanks, including the tanks' manways and vents. The mixed potentials are minimal, and the tank is made of steel, so there are no other metals of concern.

Each steel emergency diesel generator fuel oil storage tank is 12 feet in diameter and 50 feet in length, and has a gross capacity of approximately 40,000 gallons. The tanks are installed above grade elevation with tornado missile protection provided by a truncated pyramid of structural backfill built around the tanks (i.e., mound-buried).

Corrosion of the tanks is prevented by protective coatings and by cathodic protection.

The original impressed current cathodic protection system was installed in 2008 to protect each underground emergency diesel generator fuel oil storage tank 1-Y2" diameter supply pipeline. The two pipelines run underground for approximately 442 feet, and extend from the diesel fuel oil storage tanks to the emergency diesel generators in the Auxiliary Building.

The cathodic protection system was upgraded in April 2012 to provide cathodic protection for the mound-buried emergency diesel generator fuel oil storage tanks. The upgraded cathodic protection system was installed as designed and is operating properly. However, the NACE -850 mV polarized potential criterion is being met at all locations except the top of the mound, which is approximately 13 feet above grade. For the purposes of the Davis-Besse Buried Piping and Tanks Inspection Program, the NACE 1 OOmV minimum polarization criterion will be used as the acceptance criterion for the manways and vents at the top of the mound over the emergency diesel generator fuel oil storage tanks, as these locations have polarization values less than -850 mV. At all other locations that are cathodically protected, the -850 mV polarized potential instant off acceptance criterion will be applied.

To ensure that the manways and vents at the top of the mound over the emergency diesel generator fuel oil storage tanks are not degrading due to the lower polarization criterion, ultrasonic testing (UT) thickness measurements of the manways and vents for emergency diesel generator fuel oil storage tanks T1 53-1 and T1 53-2 will be performed prior to entering the period of extended operation and every 10 years during the period of extended operation to ensure that the metal thickness in those areas remains satisfactory.

Davis-Besse License Renewal Application, Table A-I, "Davis-Besse License Renewal Commitments," Commitment No. 3, and Section B.2.7, "Buried Piping and Tanks Inspection Program," are revised to clarify the cathodic protection system acceptance criteria.

See the Enclosure to this letter for the revision to the Davis-Besse LRA.

Attachment L-14-114 Page 3 of 4 Question RAI 2011-03-2

Background:

Commitment No. 44 states that cathodic protection will be provided for the emergency diesel fuel oil storage tanks prior to entering the period of extended operation. In reference to tank inspections, Commitment No. 3, and the associated enhancement, state, "[t]hese inspections are not required if it is demonstrated that the tanks are cathodically protected in accordance with NACE International (NACE) Standard Practice SP0169-2007, "Control of External Corrosion on Underground or Submerged Metallic Piping Systems," or NACE Standard Recommended Practice RP0285-2002, "Corrosion Control of Underground Storage Tank Systems by Cathodic Protection."

LR-ISG-2011-3, Table 4c, "Inspections of Buried Tanks for all Inspection Periods,"

recommends that tank inspections are not required if the tank is cathodically protected in accordance with the provisions of footnote 3 of the Table. If the tanks are not cathodically protected or the cathodic protection does not meet the availability and effectiveness goals in footnote 3, they should be inspected in accordance with Table 4c.

Issue:

The staff noted that, in the event that the emergency diesel fuel oil storage tanks are not cathodically protected (due to a future commitment change), the corrective action process will not necessarily lead to the tank inspections in Table 4c. In addition, if the cathodic protection system does not meet availability or effectiveness goals, it is not clear to the staff that tank inspections will be conducted. The staff considers the incorporation of these inspections into Commitment No. 3 and No. 44, as necessary to ensure that aging can be managed throughout the period of extended operation.

Request:

State the basis for not including the recommended fuel oil storage tank inspections into the Buried Piping and Tanks Inspection Program in the event that the tanks are not cathodically protected, or the cathodic protection system does not meet availability or effectiveness goals. Alternatively, revise Commitment No. 3 and No. 44, and the associated enhancements to require that tank inspections meet the recommendations of Table 4c.

Attachment L-14-114 Page 4 of 4 RESPONSE RAI 2011-03-2 Cathodic protection was installed and operational for the in-scope buried emergency diesel generator fuel oil storage tanks and associated fuel oil supply piping from the storage tanks to the emergency diesel generators in the Auxiliary Building on April 10, 2012, greater than five years prior to entering the period of extended operation. Also, the buried Service Water System piping and buried diesel fuel oil piping from the aboveground diesel oil storage tank to the Auxiliary Building have been cathodically protected. Therefore, License Renewal Application Table A-I, "Davis-Besse License Renewal Commitments," Commitment No. 44, is revised to state "Complete".

The Davis-Besse license renewal Buried and Underground Piping and Tanks Program will be enhanced to include the following statement regarding fuel oil storage tank inspections:

Add a requirement that, IF the cathodicprotection system for the emergency diesel generatorfuel oil storage tanks (DB-T153-1 and DB-TI53-2) meets the availabilitycriteria of Table 4c "Inspectionsof Buried Tanks for all Inspection Periods," (i.e., footnotes 3.i, 3.ii and 3.iii) of LR-ISG-2011-03, Appendix A, "Revised GALL Report AMP XI.M4 1,"

THEN no Table 4c inspections of tanks DB-T153-1 and DB-T153-2 are required. Otherwise, perform inspections of tanks DB-T153-1 and DB-T153-2 in accordance with Table 4c of LR-ISG-2011-03.

License Renewal Application Table A-I, "Davis-Besse License Renewal Commitments,"

Commitment No. 3, and Section B.2.7, "Buried Piping and Tanks Inspection Program,"

are revised to include the tank inspection recommendations of LR-ISG-2011-03, Table 4c, as described above.

See the Enclosure to this letter for the revision to the Davis-Besse LRA.

Enclosure Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse)

Letter L-14-114 Amendment No. 49 to the Davis-Besse License Renewal Application Page 1 of 11 License Renewal Application Sections Affected Table A-1 Section B.2.7 The Enclosure identifies the change to the License Renewal Application (LRA) by Affected LRA Section, LRA Page No., and Affected Paragraph and Sentence. The count for the affected paragraph, sentence, bullet, etc. starts at the beginning of the affected Section or at the top of the affected page, as appropriate. Below each section the reason for the change is identified, and the sentence affected is printed in italics with deleted text #ned eu and added text underlined.

Enclosure L-14-114 Page 2 of 11 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Pages A-55 Commitment No. 3, thru A-57 Based on the responses to NRC requests for additional information (RAI) 2011-03-1 and 2011-03-2, license renewal future Commitment No. 3 of LRA Table A-i, "Davis-Besse License Renewal Commitments," previously revised by FENOC letter dated September 20, 2013 (ML13269A027), is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Cmet Comments 3 Enhance the Buried Piping and Tanks Inspection Program to: Prior to LRA A. 1.7

" Add 1) bolting for buried Fire Protection System piping, and April 22, 2017 and B.2.7

2) the emergency diesel fuel oil storage tanks (DB-T153-1, FENOC and DB-T1 53-2) to the scope of the program. Letters

" Conduct annual ground potential surveys of the cathodic L-11-153, NRC RAes protection system. Monitor cathodic protection voltage and L-13-160, B.2. 7-1 from current monthly to determine the effectiveness of cathodic and NRC Letter protection systems and, thereby, the effectiveness of corrosion L-13-304 dated mitigation. Trend voltage, current, and ground potential readings and April 20, 2011, and evaluate for adverse changes. L-14-114

• Require that the activity of the jockey fire pump or equivalent A. 1-1 from parameter be monitored on at least a monthly interval. NRC Letter

Enclosure L-14-114 Page 3 of 11 Table A-1 Davis-Besse License Renewal Commitments Item Item Commitment IRelated ImplementationRead A LRA Imple Source Section No./

Number ScheduleComments Conduct a flow test by the end of the next refueling outage dated when unexplained changes in jockey pump activity are March 26, observed. 2013,

• Require that the directed buried pipe inspection locations be and selected based on risk. 2011-03-1 and 2011-03-2

• Require that the minimum number of buried in-scope piping from inspections during the 30-40, 40-50, and 50-60 year operating NRC Letter period is one steel-piping segment. Perform the directed buried dated steel pipe and-tank-inspectionseach ten year interval based February 11, upon table 4a, "Inspectionsof Buried Pipe," in the XI.M41 aging 2014 managementprogram describedin LR-ISG-2011-03. Each inspection will have a minimum of 10 feet of piping inspected.

" Require that, IF the cathodicprotection system for the emergency diesel generatorfuel oil storage tanks (DB-T153-1 and DB-T153-2) meets the availabilitycriteriaof Table 4c "Inspectionsof Buried Tanks for all Inspection Periods," "iJe.,

footnotes 3.i, 3.ii and 3.iii) of LR-ISG-2011-03, Appendix A.

"Revised GALL Report AMP XI.M4 1." THEN no Table 4c inspectionsof tanks DB-T153-1 and DB-T153-2 are required.

Otherwise, perform inspections of tanks DB- T153-1 and DB-T153-2 in accordancewith Table 4c of LR-ISG-2011-03.4-he EDG Fuel OilStorage Tank-s(DB T153I anI;d DB T153 2)be in..e.t,-d per-to entoing the period of extended opertion,.

The ;4SPeNcti '-i' 1on11 ;thera visual in;petion of at least 25%

Enclosure L-14-114 Page 4 of 11 Table A-1 Davis-Besse License Renewal Commitments Item Iter Commitment Implementation Sheme IRelated Source LRA Section No./

Number ScheduleComments of each tank and inclUde at l-a-St cornoM portion of the tank top and boefo, or, an intorntal inpoction con.iting of U) roaswenomnts with at least one moasuro*Vnt pr*r square fool of the sufaco o9f thio tanksA. ThosoA inpectionS arc not reqUired i accordanGo wthýNACE Intornationa! (4A CE Standard PrFactico SP 166920_07, "Control of EWornal Corro4ion on Und, rgroud or-Submorgod Motal.. P-ping Systems," or NACE Standar Reommndod Pra-cdieRP0285 _21002L, .... qon C.ontrol o Undorground Storage Tank Syetems by Cathodic Protetion-."

• Require that ultrasonictesting (UT) thickness measurements of the manways and vents for emergency diesel generatorfuel oil storagetanks T153-1 and T153-2 will be performed prior to entering the period of extended operation and every 10 years during the period of extended operation to ensure that the metal thickness in those areasremains satisfactory.

• Add a mq..... Require that undergroundpiping in the decay heat removal and low pressure injection system located in the boratedwater piping trench will be visually inspected during the 30-40, 40-50, and 50-60 year operatingperiods to confirm the absence of aging effects.

• Require that if adverse indications are detected, the inspection sample sizes, within the affected piping categories, are initially doubled and if adverse conditions are discovered in the

Enclosure L-14-114 Page 5 of 11 Table A-1 Davis-Besse License Renewal Commitments Item Ii Related LRA Iter Commitment Implementation Source Section No./

Number ScheduleComments expanded sample, the size of the follow-on inspections is determined by establishing the extent of condition and extent of cause, consistent with the FENOC Corrective Action Program.

Scheduling of additional examinations is based on the severity of the degradation identified and commensurate with the consequences of a leak or loss of function, but in all cases, the expanded sample inspection should be completed within the 10-year interval in which the original adverse indication was identified. Further inspections are conducted in locations with similar materials and environment, or the piping is replaced on a schedule based upon either the station's need to return the system to service for non-Technical Specification-related systems or the allowed outage time for Technical Specification-related systems.

• Require that an inspection of buried Fire Protection System bolting will be performed when the bolting becomes accessible during opportunistic or focused inspections.

• Require that the inspections of buried piping be conducted using visual (VT-3 or equivalent) inspection methods. Excavation shall be a minimum of 10 linear feet of piping, with all surfaces of the pipe exposed.

Enclosure L-14-114 Page 6 of 11 Table A-1 Davis-Besse License Renewal Commitments Item IImplementation Related LRA Iter Number Commitment j ISheme Schedule Source Section CmetNo./

Comments

• Include the following acceptance criteria in the program procedure:

o The cathodic protection survey acceptance criteria for protected piping and tanks, with the exception of the manways and vents at the top of the mound over emergency diesel generatorfuel oil storage tanks T153-1 and T153-2, are the -850 m V relative to a copper/coppersulfate reference electrode (CSE), instant off and limiting critical potential not more negative than 1200 miV. For the manways and vents at the top of the mound over tanks T153-1 and T153-2, the acceptance criterion is the 100 mV minimum polarizationtesting criterialisted in NACE SP0169 2007, The eathedic proetotion cw~,'ay aGcaptanco criteriai -garctho 950 mY realaiv to a coppor/copP9 parcfate roforonco oloctFodo (CSE,, instant eff or 1600 mV mginimum pelaFration 'in" _c "itoia Aisted in NAI =SP 160 2007 and limitig critial potonta no mon oativo than 1200 rnV o For coated piping or tanks, there should be either no evidence of coating degradation or the type and extent of coating degradation should be insignificant as evaluated by an individual possessing a NACE Coating Inspector Program Level 2 or 3 inspector qualification or an individual has attended the Electric Power Research Institute (EPRI)

Comprehensive Coatings Course and completed the EPRI

Enclosure L-14-114 Page 7 of 11 Table A-1 Davis-Besse License Renewal Commitments ItemImplmenttionRelated LRA Item Commitment Implementation Source Section No./

Number Schedule Cmet Comments Buried Pipe Condition Assessment and Repair Training Computer-Based Training Course. Where damage to the coating has been evaluated as significant and the damage was caused by nonconforming backfill, an extent of condition evaluation should be conducted to ensure that the as-left condition of backfill in the vicinity of observed damage will not lead to further degradation; o If metallic piping or tanks show evidence of corrosion, the remaining wall thickness in the affected area is determined to ensure that the minimum wall thickness is maintained; and, o Changes in jockey pump activity or equivalent parameter that cannot be attributed to causes other than leakage from buried piping are not occurring.

Enclosure L-14-114 Page 8 of 11 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-69 Commitment No. 44 The actions required by license renewal future Commitment No. 44 in LRA Table A-i, "Davis-Besse License Renewal Commitments," updated by FENOC Letter dated March 26, 2013 (ML13114A254), have been completed.

The Implementation Schedule is revised to read "COMPLETE", as follows:

Table A-1 Davis-Besse License Renewal Commitments Im Related LRA Item Commitment Implementation Source Section No./

Number Schedule Cmet Comments 44 Cathodically protect the EDG fuel oil storage tanks (DB-T153-1 PFerto FENOC Responses to and DB-T153-2) and the in-scope fuel oil and Service Water -,.÷othbor 22, 2016 Letters NRC RAIs buried piping in accordance with NACE SP0169-2007 or COMPLETE L-11-203, B.2.7-1 from NACE RP0285-2002. L-11-218, NRC Letter and dated L-13-160 April 20, 2011, and as modified per L-14-114 telecon with the NRC held on June 7, 2011, and A.1-1 from NRC Letter

Enclosure L-14-114 Page 9 of 11 Table A-1 Davis-Besse License Renewal Commitments Implementation Related LRA Item Number Commitment Schedule Source Section No.!

Comments dated March 26, 2013

Enclosure L-14-114 Page 10 of 11 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.7 Page B-41 Enhancements - bulleted items "Detection of Aging Effects" and "Acceptance Criteria" In response to RAIs 2011-03-1 and 2011-03-2, LRA Section B.2.7, "Buried Piping and Tanks Inspection Program," subsection titled "Enhancements," bulleted items "Detection of Aging Effects" (4 th and new 5 th paragraphs) and "Acceptance Criteria" (1st sub-bullet), previously revised by FENOC letter dated September 20, 2013 (ML13269A027), are revised to read as follows:

Detection of Aging Effects Add a requirement that, IF the cathodic protection system for the emergency diesel generator fuel oil storage tanks (DB-T153-1 and DB-T153-2) meets the availability criteria of Table 4c "Inspectionsof Buried Tanks for all Inspection Periods," (i.e., footnotes 3.i, 3.ii and 3.iii) of LR-ISG-2011-03, Appendix A, "Revised GALL Report AMP XI.M4 1," THEN no Table 4c inspections of tanks DB-T153-1 and DB-T153-2 are required.

Otherwise, perform inspections of tanks DB-T153-1 and DB-T153-2 in accordance with Table 4c of LR-ISG-2011-03. the emer.gency diee generator f4ei oil storage tanks (B T-153-I and D9 T-153-2) wil be inspected prior to the Per*iod f ePon*d-d operation. The npetion will ba either-a visual insec-tionP ofat least 25% of each tank and include; at feas; some porioen of the tank tp an boffoem or-, an internal inspectio consisting of UT measurements wit at least one moeasureenp;

,squarefoot of the sur-face of the tanks. These inspections arant euie if it is deosrtdthat the tank-s are cathodicaly protected in acco.__;rd-An ceWith NIACE- Ihternation-al ('NAGCE Standard Pr~actice SP 1!69 2007, "C~ontrol of External Corsino UndergroGund or Submerged Metalli Piping Systems;" or- NAC4E Stand-ardRoomone PrFactice RP0285 2002m, "Corrosion Control of Undergroeund Storage Tank Systm by Cathodic Protection."

Add a requirement that ultrasonic testing (UT) thickness measurements of the manways and vents for emergency diesel -generatorfuel oil stora-ge tanks T153-1 and TI153-2 will be performed prior to entering the period of extended operation and every 10 years during the period of extended operation to ensure that the metal thickness in those areas remains satisfactory.

Enclosure L-14-114 Page 11 of 11 Acceptance Criteria The program procedure will be enhanced to state that:

o The cathodic protection survey acceptance criteria for protected piping and tanks, with the exception of the manways and vents at the top of the mound over emergency diesel generator fuel oil storage tanks T153-1 and T153-2, are the -850 mV relative to a copper/copper sulfate reference electrode (CSE), instant off and limitinq critical potentialnot more negative than 1200 mV. For the manways and vents at the top of the mound over tanks T153-1 and T153-2, the acceptance criterion is the 100 mV minimum polarization testing criteria listed in NACE SP0169 2007. The cathodc p....c*"te n su.y ..c. ptanc

..

criteria ame the 85 e-lative to a GWppeFIWPper sulft Feference Fn

,lect,,de (CSE), instant off -or10 minimum p.,,,olrization testing crterfia listed in NAE SPQDI16 2007- and limtinWgcritical potential not more negativo than 1200 mgV-