NRC-14-0051, License Renewal Application - Supplement for LR-ISG-2012-02

License Renewal Application - Supplement for LR-ISG-2012-02

ML14213A061
Person / Time
Site:	Fermi
Issue date:	07/30/2014
From:	Kaminskas V DTE Electric Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-ISG-2012-02, NRC-14-0051
Download: ML14213A061 (77)

Text

Vito Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasv@dteenergy.com DTE Energy-July 30, 2014 10 CFR 54 NRC-14-0051 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) DTE Electric Company Letter to NRC, "Fermi 2 License Renewal Application," NRC-14-0028, dated April 24, 2014, Accession No. ML14121A554

Subject:

Fermi 2 License Renewal Application - Supplement for LR-ISG-2012-02 In Reference 2, DTE Electric Company submitted an application for a renewed operating license for Fermi 2 pursuant to 10 CFR 51 and 10 CFR 54. Section 2.1.3, "Interim Staff Guidance Discussion," of the license renewal application (LRA) addressed relevant Interim Staff Guidance (ISG). In the discussion of LR-ISG-2012-02, it is stated that the guidance from Sections B, D, F, G, and H of the ISG were included in the LRA. However, due to the timing of the ISG issuance, it was not feasible to address Sections A, C, and E of the ISG in the LRA.

In the enclosed documents, DTE Electric Company is providing a supplement to the LRA to address Sections A, C, and E of LR-ISG-2012-02. Enclosure 1 provides a general description of the supplement to the LRA. Enclosure 2 provides the actual revisions to the LRA, with changes indicated in strike-through and underline. The affected sections of the LRA are 2.1.3, 2.3, 3.0, 3.2, 3.3, 3.4, Appendix A, and Appendix B. As described in Enclosure 1, some other minor revisions to the LRA are being made at this time in addition to those due to LR-ISG-2012-02. The LRA in Reference 2 as supplemented by this submittal now addresses all of the relevant ISGs issued as final.

USNRC NRC-14-0051 Page 2 No new commitments are being made in this submittal. However, commitments previously identified in Section A.4 of the LRA have been modified as indicated in.

Should you have any questions or require additional information, please contact Lynne Goodman at 734-586-1205.

Sinc rely Vito Kaminskas Site Vice President Nuclear Generation

Enclosures:

1. Fermi 2 LRA Supplement for LR-ISG-2012 General Description

2. Fermi 2 LRA Supplement for LR-ISG-2012 LRA Revisions 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)

USNRC NRC-14-0051 Page 3 I, Vito Kaminskas, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

Vito Kaminskas Site Vice President Nuclear Generation On this day of A.

, 2014 before me personally appeared Vito Kaminskas, being first duly sw n and says that he executed the foregoing as his free act and deed.

ANGELA R. CRONE NOTARY PUBLIC, STATE OF MI COUNTY OF LENAWEE MY COMMISSION EXPIRES Apt 4, 2020 ACTING IN COUNTY OF fn6y W l}

Notv Public

ENCLOSURE 1 TO NRC-14-0051 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Fermi 2 LRA Supplement for LR-ISG-2012 General Description to NRC-14-0051 Page 1 of 1 BACKGROUND As stated in LRA Section 2.1.3, due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance from all parts of this ISG into the development of the Fermi 2 LRA as originally submitted. Further review has now been completed, and revised LRA Sections have been developed to reflect the guidance of LR-ISG-2012-02 Sections A, C, E. All aspects of this ISG have now been addressed in the LRA.

Supplement based on LR-ISG-2012-02 Section A, Recurring Internal Corrosion Based on a review of operating experience to identify recurring internal corrosion aging mechanisms using the guidance of LR-ISG-2012-02 Section A, loss of material due to multiple corrosion mechanisms was found to be an aging effect requiring management for affected components. The results of the associated aging management review are documented in the revised LRA sections provided in Enclosure 2 of this letter.

Supplement based on LR-ISG Section C, Flow Blockage of Water-Based Fire Protection System Piping DTE will perform the tests and inspections for fire water system blockage at Fermi 2 as recommended by LR-ISG-2012-02 Section C, with exceptions listed in the revised LRA Section B.1.19 provided in Enclosure 2 of this letter.

Supplement based on LR-ISG Section E, Corrosion Under Insulation Based on a review of operating experience, system configuration, and environmental factors, using the guidance of LR-ISG-2012-02 Section E, aging effects related to the phenomenon of corrosion under insulation have been conservatively assumed for affected components at Fermi 2. The results of the associated aging management review are documented in the revised LRA sections provided in Enclosure 2 of this letter.

Supplement based on further review of LRA Based on a further review, it was noted that one line item for LRA Table 2.3.3-17-14 and two line items for LRA Table 3.3.2-17-14 had been inadvertently left out of the Fermi 2 LRA as originally submitted. These line items for piping are included in the revised LRA sections provided in Enclosure 2 of this letter.

ENCLOSURE 2 TO NRC-14-0051 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Fermi 2 LRA Supplement for LR-ISG-2012 LRA Revisions to NRC-14-0051 Page 1 of 71 Revisions to text and tables in LRA Sections 2.1.3, 2.3, 3.0, 3.2, 3.3 and 3.4 are provided below with additions underlined and deletions in strike-through.

Revise Section 2.1.3 discussion of LR-ISG-2012-02 as follows:

LR-ISG-2012-02 Aging Management of Internal Surfaces, Fire Water Systems, Service Level III and Other Coatings, Atmospheric Storage Tanks, and Corrosion under Insulation This ISG provides proposed guidance on a variety of topics as indicated by the title. The revised guidance has been considered in the integrated plant assessment and is reflected in the aging management results presented in Section 3 and the aging management program descriptions presented in Appendix B. Due to the timing of the ISG issuance, it was not feasible to include guidance from all parts of this ISG into the development of the Fermi 2 LRA. Guidance from the following sections of this ISG was included.

Section B: Representative Minimum Sample Size for XI.M38.

Section D: Revisions to the Scope and Inspection Recommendations of XI.M29.

Section F: External Volumetric Examination of Internal Piping Surfaces of Underground Piping Removed from XI.M41.

Section G: Specific Guidance for Use of the Pressurization Option for Inspecting Elastomers in XI.M38.

Section H: Key Miscellaneous Changes.

to NRC-14-0051 Page 2 of 71 Add the following line to Table 2.3.3-17-14, Reactor Building Closed Cooling Water System, Nonsafety-Related Components Affecting Safety-Related Systems, Components Subject to Aging Management Review.

Component Type Intended Functiona Piping Pressure Boundary to NRC-14-0051 Page 3 of 71 Revise Table 3.0-1 definition of condensation as follows:

Table 3.0-1 Service Environments for Mechanical Aging Management Reviews Environment Description Corresponding NUREG-1801 Environments Condensation Air and condensation on surfaces of indoor systems with temperatures below dew point; condensation is considered untreated water due to potential for surface contamination.

For compressed air systems with dryers, condensation may be conservatively identified as the internal environment. Because of air in-leakage through minor gaps in insulation, condensation can occur underneath the insulation on components when the operating temperature of the component is below the dew point of the air on the external surfaces of the insulation.

Condensation to NRC-14-0051 Page 4 of 71 In Section 3.2.2.1.8, Miscellaneous ESF Systems in Scope for 10 CFR 54.4(a)(2), add the following line items:

Aging Effects Requiring Management

Loss of material - recurring internal corrosion Aging Management Programs

Periodic Surveillance and Preventive Maintenance Revise Section 3.2.2.2.9 as shown:

3.2.2.2.9 Loss of Material due to Recurring Internal Corrosion Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on recurring internal corrosion in the development of the license renewal application. A review of plant operating experience identified recurring internal corrosion (RIC) as defined in LR-ISG-2012-02, Section A, in carbon steel piping components exposed to raw water due to multiple corrosion mechanisms. The Periodic Surveillance and Preventive Maintenance Program will manage loss of material for these piping components by monitoring degradation and replacing pipe where necessary.

The Periodic Surveillance and Preventive Maintenance Program will monitor piping degradation using wall thickness measurements at selected locations to determine the rate of corrosion. The thickness measurements and rate of corrosion will determine the frequency of subsequent inspections. Piping will be replaced as necessary to assure the piping intended function is maintained.

to NRC-14-0051 Page 5 of 71 Revise the following lines of Table 3.2.1, Summary of Aging Management Programs for Engineered Safety Features Evaluated in Chapter V of NUREG-1801:

Table 3.2.1: Engineered Safety Features Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.2.1-66 Metallic piping, piping components, and tanks exposed to raw water or waste water Loss of material due to recurring internal corrosion A plant-specific aging management program is to be evaluated to address recurring internal corrosion Yes, plant-specific Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on recurring internal corrosion in the development of the license renewal application.Consistent with NUREG-1801.

Recurring internal corrosion (RIC) as defined in LR-ISG-2012-02, Section A, was identified in carbon steel piping components exposed to raw water due to multiple corrosion mechanisms. The Periodic Surveillance and Preventive Maintenance Program will manage loss of material for these piping components.

(See Section 3.2.2.2.9.)

to NRC-14-0051 Page 6 of 71 Table 3.2.1: Engineered Safety Features Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.2.1-67 Stainless steel or aluminum tanks (within the scope of Chapter XI.M29, Aboveground Metallic Tanks) exposed to soil or concrete, or the following external environments air-outdoor, air-indoor uncontrolled, moist air, condensation Cracking due to stress corrosion cracking Chapter XI.M29, Aboveground Metallic Tanks No This item was not used. There are no stainless steel or aluminum tanks (consistent with the scope of NUREG-1801, Chapter XI.M29, Aboveground Metallic Tanks) in the engineered safety features systems.

3.2.1-68 Steel, stainless steel, or aluminum tanks (within the scope of Chapter XI.M29, Aboveground Metallic Tanks) exposed to soil or concrete, or the following external environments air-outdoor, air-indoor uncontrolled, moist air, condensation Loss of material due to general (steel only), pitting, and crevice corrosion Chapter XI.M29, Aboveground Metallic Tanks No This item was not used. There are no steel, stainless steel or aluminum tanks (consistent with the scope of NUREG-1801, Chapter XI.M29, Aboveground Metallic Tanks) in the engineered safety features systems.

to NRC-14-0051 Page 7 of 71 Table 3.2.1: Engineered Safety Features Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.2.1-69 Insulated steel, stainless steel, copper alloy, or aluminum, piping, piping components, and tanks exposed to condensation, air-outdoor Loss of material due to general (steel, and copper alloy only), pitting, and crevice corrosion Chapter XI.M36, "External Surfaces Monitoring of Mechanical Components" or Chapter XI.M29, Aboveground Metallic Tanks, (for tanks only)

No Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on corrosion under insulation in the development of the license renewal application. Consistent with NUREG-1801.

Loss of material for steel insulated piping components exposed to outdoor air is managed by the External Surfaces Monitoring Program.

3.2.1-70 Steel, stainless steel or aluminum tanks (within the scope of Chapter XI.M29, Aboveground Metallic Tanks) exposed to treated water, treated borated water Loss of material due to general (steel only), pitting and crevice corrosion Chapter XI.M29, Aboveground Metallic Tanks No This item was not used. There are no steel, stainless steel or aluminum tanks (consistent with the scope of NUREG-1801, Chapter XI.M29, Aboveground Metallic Tanks) in the engineered safety features systems.

3.2.1-71 Insulated stainless steel, aluminum, or copper alloy (> 15%

Zn) piping, piping components, and tanks exposed to condensation, air-outdoor Cracking due to stress corrosion cracking Chapter XI.M36, "External Surfaces Monitoring of Mechanical Components" or Chapter XI.M29, Aboveground Metallic Tanks (for tanks only)

No Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on corrosion under insulation in the development of the license renewal application. This item was not used. There are no stainless steel, aluminum or copper alloy insulated piping components or tanks exposed to condensation or outdoor air in the engineered safety features systems.

to NRC-14-0051 Page 8 of 71 Add the following Plant-Specific Note 205 at the end of LRA Table 3.2.1, Summary of Aging Management Programs for Engineered Safety Features Evaluated in Chapter V of NUREG-1801, in Notes for Tables 3.2.2-1 through 3.2.2-8-6.

205. Program provisions for outdoor insulated components that operate below the dew point apply.

Add the following line to LRA Table 3.2.2-6, Containment Penetrations Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Air - outdoor (ext)

Loss of material External Surfaces Monitoring V.C.E-403 3.2.1-69 A, 205 Add the following line to Table 3.2.2-8-1, Residual Heat Removal System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Piping components Pressure boundary Carbon steel Raw water (int)

Loss of material

- recurring internal corrosion Periodic Surveillance and Preventive Maintenance V.D2.E-400 3.2.1-66 E

to NRC-14-0051 Page 9 of 71 In Section 3.3.2.1.3, Service Water Systems, add the following line items:

Aging Effects Requiring Management

Loss of material - recurring internal corrosion Aging Management Programs

Periodic Surveillance and Preventive Maintenance In Section 3.3.2.1.10, Emergency Diesel Generator System, add the following line item:

Aging Effects Requiring Management

Loss of material - recurring internal corrosion In Section 3.3.2.1.13, Containment Atmospheric Control System, add the following line item:

Environment

Condensation In Section 3.3.2.1.17, Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2), add the following line item:

Aging Effects Requiring Management

Loss of material - recurring internal corrosion to NRC-14-0051 Page 10 of 71 Revise Section 3.3.2.2.8 as follows:

3.3.2.2.8 Loss of Material due to Recurring Internal Corrosion Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on recurring internal corrosion in the development of the license renewal application. A review of plant operating experience identified recurring internal corrosion (RIC) as defined in LR-ISG-2012-02, Section A, in carbon steel piping components exposed to raw water due to multiple corrosion mechanisms. The Periodic Surveillance and Preventive Maintenance Program will manage loss of material for these piping components by monitoring degradation and replacing pipe where necessary.

The Periodic Surveillance and Preventive Maintenance Program will monitor piping degradation using wall thickness measurements at selected locations to determine the rate of corrosion. The thickness measurements and rate of corrosion will determine the frequency of subsequent inspections. Piping will be replaced as necessary to assure the piping intended function is maintained.

Revise the following line items in Table 3.3.1, Summary of Aging Management Programs for the Auxiliary Systems Evaluated in Chapter VII of NUREG-1801.

Table 3.3.1: Auxiliary Systems Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.3.1-64 Steel, copper alloy piping, piping components, and piping elements exposed to raw water Loss of material due to general, pitting, crevice, and microbiologically influenced corrosion; fouling that leads to corrosion; flow blockage due to fouling Chapter XI.M27, "Fire Water System" No Loss of material for steel and copper alloy fire protection system components exposed to raw water is managed by the Fire Water System Program. Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on flow blockage of water-based fire protection system piping in the development of the license renewal application.

to NRC-14-0051 Page 11 of 71 Table 3.3.1: Auxiliary Systems Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.3.1-66 Stainless steel piping, piping components, and piping elements exposed to raw water Loss of material due to pitting and crevice corrosion; fouling that leads to corrosion; flow blockage due to fouling Chapter XI.M27, "Fire Water System" No Loss of material for stainless steel fire protection system components exposed to raw water is managed by the Fire Water System Program. Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on flow blockage of water-based fire protection system piping in the development of the license renewal application.

3.3.1-127 Metallic piping, piping components, and tanks exposed to raw water or waste water Loss of material due to recurring internal corrosion A plant-specific aging management program is to be evaluated to address recurring internal corrosion

Yes, plant-specific Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on recurring internal corrosion in the development of the license renewal application.

Consistent with NUREG-1801.

Recurring internal corrosion (RIC) as defined in LR-ISG-2012-02, Section A, was identified in carbon steel piping components exposed to raw water due to multiple corrosion mechanisms. The Periodic Surveillance and Preventive Maintenance Program will manage loss of material for these piping components.

(See Section 3.3.2.2.8) to NRC-14-0051 Page 12 of 71 Table 3.3.1: Auxiliary Systems Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.3.1-130 Metallic sprinklers exposed to air-indoor controlled, air-indoor uncontrolled, air-outdoor, moist air, condensation, raw water, treated water Loss of material due to general (where applicable), pitting, crevice, and microbiologically-influenced corrosion, fouling that leads to corrosion; flow blockage due to fouling Chapter XI.M27, Fire Water System No This item was not used. Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on flow blockage of water-based fire protection system piping in the development of the license renewal application. Consistent with NUREG-1801. Loss of material and fouling of sprinklers internally exposed to indoor and outdoor air or raw water is managed by the Fire Water System Program.

3.3.1-131 Steel, stainless steel, copper alloy, or aluminum fire water system piping, piping components and piping elements exposed to air-indoor uncontrolled (internal), air-outdoor (internal), or condensation (internal)

Loss of material due to general (steel, and copper alloy only), pitting, crevice, and microbiologically-influenced corrosion, fouling that leads to corrosion; flow blockage due to fouling Chapter XI.M27, Fire Water System No This item was not used. Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on flow blockage of water-based fire protection system piping in the development of the license renewal application. Consistent with NUREG-1801. Loss of material for fire water system piping internally exposed to indoor or outdoor air is managed by the Fire Water System Program.

to NRC-14-0051 Page 13 of 71 Table 3.3.1: Auxiliary Systems Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.3.1-132 Insulated steel, stainless steel, copper alloy, aluminum, or copper alloy (> 15% Zn) piping, piping components, and tanks exposed to condensation, air-outdoor Loss of material due to general (steel, and copper alloy only), pitting, and crevice corrosion; cracking due to stress corrosion cracking (aluminum, stainless steel and copper alloy (>15%

Zn) only)

Chapter XI.M36, "External Surfaces Monitoring of Mechanical Components" or Chapter XI.M29, Aboveground Metallic Tanks (for tanks only)

No Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on corrosion under insulation in the development of the license renewal application.Consistent with NUREG-1801. Cracking of stainless steel and loss of material for steel and stainless steel insulated piping components exposed to condensation is managed by the External Surfaces Monitoring Program.

3.3.1-136 Steel, stainless steel or aluminum fire water storage tanks exposed to air-indoor uncontrolled, air-

outdoor, condensation, moist air, raw water, treated water Loss of material due to general (steel only), pitting, crevice, and microbiologically-influenced corrosion, fouling that leads to corrosion; cracking due to stress corrosion cracking (stainless steel and aluminum only)

Chapter XI.M27, "Fire Water System" No This item was not used. Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on flow blockage of water-based fire protection system piping in the development of the license renewal application.There are no fire water storage tanks in the auxiliary systems in the scope of license renewal.

to NRC-14-0051 Page 14 of 71 Add the following Plant-Specific Note 310 at the end of LRA Table 3.3.1, Summary of Aging Management Programs for the Auxiliary Systems Evaluated in Chapter VII of NUREG-1801, in Notes for Tables 3.3.2-1 through 3.3.2-17-36.

310.

Program provisions for indoor insulated components that operate below the dew point apply.

Add the following lines to Table 3.3.2-3, Service Water Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C1.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Stainless steel Condensation (ext)

Cracking External Surfaces Monitoring VII.C1.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Stainless steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C1.A-405 3.3.1-132 A, 310 Piping components Pressure boundary Carbon steel Raw water (int)

Loss of material

- recurring internal corrosion Periodic Surveillance and Preventive Maintenance VII.C1.A-400 3.3.1-127 E

to NRC-14-0051 Page 15 of 71 Add the following lines to LRA Table 3.3.2-5, Emergency Equipment Cooling Water System, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C2.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Stainless steel Condensation (ext)

Cracking External Surfaces Monitoring VII.C2.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Stainless steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C2.A-405 3.3.1-132 A, 310 to NRC-14-0051 Page 16 of 71 Revise the following lines in LRA Table 3.3.2-7, Fire Protection - Water System, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Note s

Piping Pressure boundary Carbon steel Air - indoor (int)

Loss of material Internal Surfaces In Miscellaneous Piping and Ducting ComponentsFire Water System V.D2.E-29 VII.G.A-404 3.2.1-44 3.3.1-131 CA Piping Pressure boundary Carbon steel Air - outdoor (int)

Loss of material Internal Surfaces In Miscellaneous Piping and Ducting ComponentsFire Water System

- VII.G.A-404

- 3.3.1-131 GA Sprinkler Pressure boundary Flow control Copper alloy

> 15% Zn or

> 8% Al Air - indoor (int)

NoneLoss of material NoneFire Water System VII.J.AP-144 VII.G.A-403 3.3.1-114 3.3.1-130 A

Sprinkler Pressure boundary Flow control Copper alloy

> 15% Zn or

> 8% Al Air - outdoor (int)

Loss of material External Surfaces MonitoringFire Water System

- VII.G.A-403

- 3.3.1-130 GA Sprinkler Pressure boundary Flow control Copper alloy

> 15% Zn or

> 8% Al Raw water (int)

Loss of material Fire Water System VII.G.AP-197 VII.G.A-403 3.3.1-64 3.3.1-130 A

to NRC-14-0051 Page 17 of 71 Add the following line to LRA Table 3.3.2-10, Emergency Diesel Generator System, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Piping components Pressure boundary Carbon steel Raw water (int)

Loss of material -

recurring internal corrosion Periodic Surveillance and Preventive Maintenance VII.H2.A-400 3.3.1-127 E

Add the following line to LRA Table 3.3.2-12, Control Center Heating, Ventilation and Air Conditioning System, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.F1.A-405 3.3.1-132 A, 310 to NRC-14-0051 Page 18 of 71 Add the following line to LRA Table 3.3.2-13, Containment Atmospheric Control Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.D.A-405 3.3.1-132 C, 310 Add the following lines to Table 3.3.2-17-9, Off-Gas Process and Vacuum System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C1.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Stainless steel Condensation (ext)

Cracking External Surfaces Monitoring VII.C1.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Stainless steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C1.A-405 3.3.1-132 A, 310 to NRC-14-0051 Page 19 of 71 Add the following lines to Table 3.3.2-17-13, General Service Water System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C1.A-405 3.3.1-132 A, 310 Piping components Pressure boundary Carbon steel Raw water (int)

Loss of material

- recurring internal corrosion Periodic Surveillance and Preventive Maintenance VII.C1.A-400 3.3.1-127 E

to NRC-14-0051 Page 20 of 71 Delete a line and add the following lines to Table 3.3.2-17-14, Reactor Building Closed Cooling Water System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Heat exchanger (shell)

Pressure boundary Carbon steel Air - indoor (ext)

Loss of material External Surfaces Monitoring VII.IA-77 3.3.1-78 A

Insulated heat exchanger (shell)

Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C2.A-405 3.3.1-132 C, 310 Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C2.A-405 3.3.1-132 A, 310 Piping Pressure boundary Carbon steel Air - indoor (ext)

Loss of material External Surfaces Monitoring VII.I.A-77 3.3.1-78 A

Piping Pressure boundary Carbon steel Treated water (int)

Loss of material Water Chemistry Control - Closed Treated Water Systems VII.C2.AP-202 3.3.1-45 A

to NRC-14-0051 Page 21 of 71 Delete a line and add the following lines to Table 3.3.2-17-15, Turbine Building Closed Cooling Water System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Heat exchanger (shell)

Pressure boundary Stainless steel Air - indoor (ext)

None None VII.J.AP-123 3.3.1-120 C

Insulated heat exchanger (shell)

Pressure boundary Stainless steel Condensation (ext)

Cracking External Surfaces Monitoring VII.C2.A-405 3.3.1-132 C, 310 Insulated heat exchanger (shell)

Pressure boundary Stainless steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C2.A-405 3.3.1-132 C, 310 Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C2.A-405 3.3.1-132 A, 310 Add the following line to Table 3.3.2-17-16, Emergency Equipment Cooling Water System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C2.A-405 3.3.1-132 A, 310 to NRC-14-0051 Page 22 of 71 Add the following lines to Table 3.3.2-17-17, Emergency Equipment Service Water System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C1.A-405 3.3.1-132 A, 310 Piping components Pressure boundary Carbon steel Raw water (int)

Loss of material

- recurring internal corrosion Periodic Surveillance and Preventive Maintenance VII.C1.A-400 3.3.1-127 E

Add the following lines to Table 3.3.2-17-18, Supplemental Cooling Chilled Water System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.C2.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Copper alloy Condensation (ext)

Cracking External Surfaces Monitoring VII.C2.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Copper alloy Condensation (ext)

Loss of material External Surfaces Monitoring VII.C2.A-405 3.3.1-132 A, 310 to NRC-14-0051 Page 23 of 71 Revise the following lines in Table 3.3.2-17-23, Fire Protection System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Piping Pressure boundary Carbon steel Raw water (int)

Loss of material Fire Water SystemInternal Surfaces In Miscellaneous Piping and Ducting Components VII.G.A-33 VII.C1.A-408 3.3.1-64 3.3.1-134 AC Valve body Pressure boundary Carbon steel Raw water (int)

Loss of material Fire Water SystemInternal Surfaces In Miscellaneous Piping and Ducting Components VII.G.A-33 VII.C1.A-408 3.3.1-64 3.3.1-134 AC Valve body Pressure boundary Copper alloy

> 15% Zn or

> 8% Al Raw water (int)

Loss of material Fire Water SystemInternal Surfaces In Miscellaneous Piping and Ducting Components VII.G.AP-197 VII.C1.A-408 3.3.1-64 3.3.1-134 AC to NRC-14-0051 Page 24 of 71 Add the following line to Table 3.3.2-17-25, Emergency Diesel Generator System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Piping components Pressure boundary Carbon steel Raw water (int)

Loss of material

- recurring internal corrosion Periodic Surveillance and Preventive Maintenance VII.H2.A-400 3.3.1-127 E

to NRC-14-0051 Page 25 of 71 Add the following lines to Table 3.3.2-17-28, Reactor/Auxiliary Building HVAC System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated cooler housing Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.F2.A-405 3.3.1-132 C, 310 Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.F2.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Copper alloy Condensation (ext)

Cracking External Surfaces Monitoring VII.F2.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Copper alloy Condensation (ext)

Loss of material External Surfaces Monitoring VII.F2.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Stainless steel Condensation (ext)

Cracking External Surfaces Monitoring VII.F2.A-405 3.3.1-132 A, 310 Insulated piping components Pressure boundary Stainless steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.F2.A-405 3.3.1-132 A, 310 to NRC-14-0051 Page 26 of 71 Add the following line to Table 3.3.2-17-30, Containment Atmospheric Control System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VII.F2.A-405 3.3.1-132 C, 310 Revise Section 3.4.2.1.3 as shown:

Environments

Condensation Revise Section 3.4.2.2.6 as shown:

3.4.2.2.6 Loss of Material due to Recurring Internal Corrosion Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on recurring internal corrosion in the development of the license renewal application.A review of plant operating experience identified no conditions of recurring internal corrosion (RIC) as defined in LR-ISG-2012-02, Section A, in the piping components of the steam and power conversion systems.

to NRC-14-0051 Page 27 of 71 Revise the following lines in Table 3.4.1, Summary of Aging Management Programs for the Steam and Power Conversion System Evaluated in Chapter VIII of NUREG-1801:

Table 3.4.1: Steam and Power Conversion Systems Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.4.1-61 Metallic piping, piping components, and tanks exposed to raw water or waste water Loss of material due to recurring internal corrosion A plant-specific aging management program is to be evaluated to address recurring internal corrosion Yes, plant-specific Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on recurring internal corrosion in the development of the license renewal application. This item was not used. No conditions of recurring internal corrosion (RIC) as defined in LR-ISG-2012-02, Section A, were identified in piping components of the steam and power conversion systems.

(See Section 3.4.2.2.6) to NRC-14-0051 Page 28 of 71 Table 3.4.1: Steam and Power Conversion Systems Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.4.1-63 Insulated steel, stainless steel, copper alloy, aluminum, or copper alloy (> 15%

Zn) piping, piping components, and tanks exposed to condensation, air-outdoor Loss of material due to general (steel, and copper alloy), pitting, or crevice corrosion, and cracking due to stress corrosion cracking (aluminum, stainless steel and copper alloy (>15%

Zn) only)

Chapter XI.M36, "External Surfaces Monitoring of Mechanical Components" or Chapter XI.M29, Aboveground Metallic Tanks (for tanks only)

No Due to the timing of the issuance of LR-ISG-2012-02, it was not feasible to include guidance on corrosion under insulation in the development of the license renewal application. Consistent with NUREG-1801.

Loss of material for steel insulated piping components exposed to condensation is managed by the External Surfaces Monitoring Program. Loss of material and cracking of aluminum insulated tanks exposed to outdoor air is managed by the Aboveground Metallic Tanks Program.

Add the following Plant-Specific Note 404 at the end of Table 3.4.1, Summary of Aging Management Programs for the Steam and Power Conversion System Evaluated in Chapter VIII of NUREG-1801, in Notes for Tables 3.4.2-1 through 3.4.2-3-9.

404. Program provisions for outdoor insulated components or indoor insulated components that operate below the dew point apply.

to NRC-14-0051 Page 29 of 71 Add and delete the following lines to LRA Table 3.4.2-1, Condensate Storage and Transfer System, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated tank Pressure boundary Aluminum Air - outdoor (ext)

Cracking Aboveground Metallic Tanks VIII.E.S-402 3.4.1-63 A, 404 Insulated tank Pressure boundary Aluminum Air - outdoor (ext)

Loss of material Aboveground Metallic Tanks VIII.E.S-402 3.4.1-63 A, 404 Tank Pressure boundary Aluminum Air - outdoor (ext)

Cracking Aboveground Metallic Tanks VIII.E.SP-139 3.4.1-31 A

Tank Pressure boundary Aluminum Air - outdoor (ext)

Loss of material Aboveground Metallic Tanks VIII.E.SP-139 3.4.1-31 A

Add the following line to Table 3.4.2-3-7, Circulating Water System, Nonsafety-Related Components Affecting Safety-Related Systems, Summary of Aging Management Evaluation.

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Insulated (tightly adhering) piping components Pressure boundary Carbon steel Condensation (ext)

Loss of material External Surfaces Monitoring VIII.H.S-402 3.4.1-63 A, 404 to NRC-14-0051 Page 30 of 71 Revisions to LRA Sections A.1.16 are provided below with additions underlined and deletions in strike-through.

A.1.16 External Surfaces Monitoring Program The External Surfaces Monitoring Program manages aging effects of components fabricated from metallic, elastomeric, and polymeric materials through periodic visual inspection of external surfaces during system inspections and walkdowns for evidence of leakage, loss of material (including loss of material due to wear), cracking, fouling, and change in material properties.

When appropriate for the component and material, physical manipulation, such as touching, pressing, flexing, and bending, is used to augment visual inspections to confirm the absence of hardening and loss of strength in non-metallic materials. The External Surfaces Monitoring Program is also credited for situations where the material and environment combinations are the same for the internal and external surfaces such that the external surfaces are representative of the internal surfaces.

Inspections are performed at a frequency of at least once per refueling cycle by personnel qualified through plant-specific programs. Deficiencies are documented and evaluated under the Corrective Action Program. Surfaces that are not readily visible during plant operations and refueling outages are inspected when they are made accessible and at such intervals that would ensure the components' intended functions are maintained.

Periodic representative surface condition inspections of the in-scope mechanical indoor components under insulation (with process fluid temperature below the dew point) and outdoor components under insulation will be performed. Surfaces that are insulated are inspected when exposed at such intervals to ensure the components intended functions are maintained.

For polymeric materials, the visual inspection will include 100 percent of the accessible components. The sample size of polymeric components that receive physical manipulation is at least 10 percent of the available surface area.

Acceptance criteria are defined to ensure that the need for corrective action is identified before a loss of intended function. For stainless steel, a clean shiny surface is expected. For flexible polymers, a uniform surface texture (no cracks) and no change in material properties (e.g.,

hardness, flexibility, physical dimensions, color unchanged from when the material was new) are expected. For rigid polymers, no surface changes affecting performance, such as erosion, cracking, crazing, checking, and chalking, are acceptable.

The External Surfaces Monitoring Program will be enhanced as follows.

Revise External Surfaces Monitoring Program procedures to clarify that periodic inspections will be performed of systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(1) and (a)(3).

Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

to NRC-14-0051 Page 31 of 71 Revise External Surfaces Monitoring Program procedures to inspect 100 percent of accessible components at least once per refueling cycle and to ensure required walkdowns include instructions to inspect for the following related to metallic components:

Corrosion (loss of material).

Leakage from or onto external surfaces (loss of material).

Worn, flaking, or oxide-coated surfaces (loss of material).

Corrosion stains on thermal insulation (loss of material).

Protective coating degradation (cracking, flaking, and blistering).

Leakage for detection of cracks on the external surfaces of stainless steel components exposed to an air environment containing halides (cracking).

Revise External Surfaces Monitoring Program procedures to include instructions for monitoring aging effects for flexible polymeric components through physical manipulations of the material, with a sample size for manipulation of at least ten percent of the available surface area. Inspect accessible surfaces for the following:

Surface cracking, crazing, scuffing, dimensional changes (e.g., ballooning and necking).

Discoloration.

Exposure of internal reinforcement for reinforced elastomers.

Hardening as evidence by loss of suppleness during manipulation where the component and material are appropriate to manipulation.

Shrinkage, loss of strength.

Revise External Surfaces Monitoring Program procedures to specify the following for insulated components: Revise External Surfaces Monitoring Program procedures to ensure surfaces that are insulated will be inspected when the external surface is exposed (i.e., during maintenance).

Periodic representative inspections will be conducted during each 10-year period.

For a representative sample of insulated indoor components exposed to condensation (because the component is operated below the dew point) and insulated outdoor components, insulation will be removed for visual inspection of the component surface. Inspections include a minimum of 20 percent of the in-scope piping length for each material type (e.g., steel, stainless steel, copper alloy, aluminum), or for components with a configuration which does not conform to a 1-foot axial length determination (e.g., valve, accumulator), 20 percent of the surface area. Alternatively, insulation will be removed and a minimum of 25 inspections performed that can be a combination of 1 foot axial length sections and individual components for each material type.

Inspection locations are based on the likelihood of corrosion under insulation (CUI).

For example, CUI is more likely for components experiencing alternate wetting and to NRC-14-0051 Page 32 of 71 drying in environments where trace contaminants could be present and for components that operate for long periods of time below the dew point.

Subsequent inspections will consist of an examination of the exterior surface of the insulation for indications of damage to the jacketing or protective outer layer of the insulation, if the following conditions are verified in the initial inspection:

No loss of material due to general, pitting or crevice corrosion, beyond that which could have been present during initial construction, and

No evidence of cracking.

If the external visual inspections of the insulation reveal damage to the exterior surface of the insulation or there is evidence of water intrusion through the insulation (e.g. water seepage through insulation seams/joints), periodic inspections under the insulation will continue as described above.

Removal of tightly adhering insulation that is impermeable to moisture is not required unless there is evidence of damage to the moisture barrier. If the moisture barrier is intact, the likelihood of CUI is low for tightly adhering insulation. Tightly adhering insulation is considered to be a separate population from the remainder of insulation installed on in-scope components. The entire population of in-scope accessible piping component surfaces that have tightly adhering insulation will be visually inspected for damage to the moisture barrier with the same frequency as for other types of insulation inspections. These inspections will not be credited towards the inspection quantities for other types of insulation.

Revise External Surfaces Monitoring Program procedures to include acceptance criteria for the parameters observed.

Metals should not have any indications of relevant degradation.

Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

Rigid polymers should have no erosion, cracking, crazing, or chalking.

Revise External Surfaces Monitoring Program procedures to stipulate that administrative controls are in accordance with the Fermi 2 10 CFR 50 Appendix B Quality Assurance Program.

Enhancements will be implemented prior to the period of extended operation.

to NRC-14-0051 Page 33 of 71 Revisions to LRA Section A.1.19 are provided below with additions underlined and deletions in strike-through.

A.1.19 Fire Water System Program The Fire Water System Program manages loss of material and biofouling for components in fire water systems using preventive, inspection, and monitoring activities, including periodic flush tests, and testing or replacement of sprinkler heads. Applicable industry standards and guidance documents are used to delineate the program.

Consistent with NFPA 25, the Fermi 2 program includes system performance testing in accordance with the UFSAR and TRM. The periodic flow testing includes monitoring the pressure of tested pipe segments, which verifies that system pressure remains adequate for system intended functions. Results are trended. Periodic flushing is also performed in accordance with the TRM.

The Fire Water System Program manages loss of material for in-scope long-lived passive water-based fire suppression system components using periodic flow testing and visual inspections. When visual inspections are used to detect loss of material, the inspection technique is capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling.

Testing or replacement of sprinkler heads that have been in service for 50 years is performed in accordance with the 2011 Edition of NFPA 25. Portions of the water-based fire water system that a) are normally dry, but periodically subject to flow (e.g., dry-pipe or downstream of deluge valve in a deluge system) and b) cannot be drained or allow water to collect are subject to augmented testing beyond that specified in NFPA 25. These augmented inspections include a) periodic full flow tests at the design pressure and flow rate, or internal inspections, and b) volumetric wall thickness evaluations. Applicable industry standards and guidance documents are also used to delineate the program (e.g., insurance loss control manual and INPO operating experience issuances).

Wall thickness is evaluated to ensure minimum wall thickness is maintained. Wall thickness measurements are determined by volumetric testing, or as an alternative to nonintrusive testing, by visually monitoring internal surface condition upon each entry into the system for routine or corrective maintenance. The use of internal visual inspections is acceptable when inspections can be performed (based on past maintenance history) on a representative number of locations.

These inspections will be performed before the period of extended operation and at plant-specific intervals, based on the initial test results, during the period of extended operation.

Periodic visual inspections of fire water system internals monitor surface condition for indication of loss of material or biofouling.

Other requirements of the program include testing and maintaining fire detectors and visually inspecting fire hydrants to detect signs of corrosion. Fire hydrant flow tests are performed annually to ensure fire hydrants can perform their intended function. Water system pressure is continuously monitored such that loss of pressure is immediately detected and corrective action to NRC-14-0051 Page 34 of 71 initiated. If not replaced, sprinkler heads are tested before the end of 50-year sprinkler service life and every ten years thereafter during the period of extended operation.

Program acceptance criteria includeare (a) the water based fire protection system can maintain required pressure, (b) no unacceptable signs of degradation or fouling are observed during nonintrusive or visual inspections, and (c) in the event surface irregularities are identified, testing is performed to ensure minimum design pipe wall thickness is maintained, and (d) no biofouling exists in the sprinkler systems that could cause corrosion in the sprinklers.

The Fire Water System Program will be enhanced as follows.

Revise Fire Water System Program procedures to ensure sprinkler heads are tested or replaced in accordance with NFPA 25 (2011 Edition), Section 5.3.1include periodic visual inspection of fire water system internals surface condition for evidence of loss of material.

Revise Fire Water System Program procedures to perform an inspection of wet fire water system piping condition at least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic or inorganic material that could result in flow obstructions or blockage of a sprinkler head. (Refer to NFPA 25 (2011 Edition) Section 14.2.1) The inspection method used shall be capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling. Ensure procedures require a follow-up volumetric wall thickness evaluation where irregularities are detected.

Revise Fire Water System Program procedures to ensure a) sprinkler heads are tested or replaced in accordance with NFPA 25 (2011 Edition) Section 5.3.1 and b) the fire protection engineer approves the sprinkler testing laboratory.

Revise Fire Water System Program procedures to a) address a 10% decrease in pressure from one main drain test to the previous main drain test results, b) note the time to return to static pressure after performing a main drain test, and c) develop a basis for the acceptance criteria of 25 psig and 10 psig that currently exists in the main drain test procedures.

Revise Fire Water System Program procedures to notify the fire protection engineer of test results and deficiencies identified or detected during testing.

Revise Fire Water System Program procedures to ensure piping and sprinklers are cleaned if obstructions are identified during internal inspections.

Revise Fire Water System Program procedures to perform an internal inspection of wet fire water system piping conditions at least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of the branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinkler heads.

to NRC-14-0051 Page 35 of 71

Revise Fire Water System Program procedures to perform, prior to the PEO, a one-time internal inspection of the dry portion of the manual wet pipe system associated with the cable spreading room by removing a sprinkler toward the end of one branch line for the purpose of inspecting for loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinkler heads.

Revise Fire Water System Program procedures to perform at least once every five years either an internal inspection of the dry components downstream of the deluge valves for the hydrogen seal oil unit by removing a sprinkler toward the end of one branch line and inspecting for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinklers, or Revise Fire Water System Program procedures to perform at least once every five years an air or smoke test to verify there is no flow obstruction or blockage of sprinklers.

Revise Fire Water System Program procedures to perform an inspection of the sprinklers associated with charcoal filters for loss of material and foreign organic or inorganic material when the charcoal beds are replaced.

Revise Fire Water System Program procedures to perform an obstruction investigation after an extended shutdown of more than one year.

Perform a fire water system walkdown of the piping and components that are designed to be dry (e.g., downstream of deluge valves or manual isolations of dry fire water piping), but are periodically wetted, to determine if any piping sections are collecting water and are subject to both of the following augmented inspections:

In each five year interval, beginning five years prior to the period of extended operation, either a) conduct a flow test or flush sufficient to detect potential flow blockage, or b) conduct a visual inspection of 100 percent of the internal surface of piping segments that cannot be drained or piping segments that allow water to collect.

In each five year interval of the period of extended operation, inspect 20 percent of the length of piping segments that cannot be drained or piping segments that allow water to collect using volumetric techniques to measure wall thickness.

Measurement points will be obtained so that each potential degraded condition can be identified (e.g., general corrosion, MIC). The 20 percent of piping that will be inspected in each five year interval will be in different locations than previously inspected piping.

Revise Fire Water System Program procedures to include acceptance criteria that any indication of fouling is evaluated.

Revise Fire Water System Program procedures to specify that if the presence of sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected to NRC-14-0051 Page 36 of 71 during pipe inspections, the material is removed and the source and extent of condition determined, corrected, and the condition entered into the Corrective Action Program.

Revise Fire Water System Program procedures to replace sprinklers associated with representative tested sprinkler, if the representative test sprinkler fails to meet the test requirements.

Revise Fire Water System Program procedures to include one of the following inspection options.

(1) Wall thickness evaluations of fire protection piping using nonintrusive techniques (e.g., volumetric testing) to identify evidence of loss of material will be performed prior to the period of extended operation and periodically thereafter. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.

OR (2) A visual inspection of the internal surface condition of a representative sample of fire protection piping will be performed. The visual inspections can be opportunistic or planned as needed to obtain a representative sample prior to the period of extended operation. The frequency of inspections during the period of extended operation will be determined through an engineering evaluation of the results of previous inspections of fire water piping.

Revise Fire Water System Program procedures to include testing or replacement of sprinkler heads. If testing is chosen, a representative sample of sprinkler heads will be tested before the end of the 50-year sprinkler head service life and at ten-year intervals thereafter during the period of extended operation.

NFPA-25 defines a representative sample of sprinklers. If replacement of the sprinkler heads is chosen, all sprinklers that have been in service for 50 years will be replaced.

Revise Fire Water System Program procedures to include inspection of fire water system internals for no unacceptable signs of degradation observed during nonintrusive or visual inspection of components and no biofouling found in the sprinkler systems that could cause corrosion in the sprinklers.

Enhancements will be implemented prior to the period of extended operation.

to NRC-14-0051 Page 37 of 71 Revisions to LRA Section A.1.35 are provided below with additions underlined.

A.1.35 Periodic Surveillance and Preventive Maintenance Program There is no corresponding NUREG-1801 program.

The Periodic Surveillance and Preventive Maintenance Program manages aging effects not managed by other aging management programs, including loss of material, fouling, loss of material due to wear, and loss of sealing. Any indication or relevant condition of degradation detected is evaluated. Inspections occur at least once every five years during the period of extended operation.

The Periodic Surveillance and Preventive Maintenance Program also manages loss of material in carbon steel components exposed to raw water due to the recurring internal corrosion aging mechanism collectively referred to as multiple corrosion mechanisms (MCM). MCM was identified as a recurring internal corrosion aging mechanism (RICAM) in an operating experience review conducted by DTE in accordance with LR-ISG 2012-02 Section A.

The Fermi 2 aging management review credits the following inspection activities.

Visually inspect and manually flex the rubber gasket/seal for reactor building spent fuel storage pool gates to verify no loss of sealing.

Determine wall thickness of selected service water system piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Visually inspect a representative sample of EDG system air coolant, lube oil, and jacket water heat exchanger tubes to manage loss of material due to wear.

Determine wall thickness of selected EDG system piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Use visual or other NDE techniques to inspect internal surfaces to manage fouling of the fire water system heat exchanger tubes exposed to raw water.

Visually inspect a representative sample of CTG system lube oil heat exchanger tubes to manage loss of material due to wear.

Visually inspect a representative sample of CTG system atomizing air precooler heat exchanger tubes to manage fouling and loss of material due to wear.

Visually inspect and clean CTG system atomizing air booster compressor suction filter to manage fouling.

Visually inspect and clean CTG system compressor extraction air filter to manage fouling.

to NRC-14-0051 Page 38 of 71 Use visual or other NDE techniques to inspect containment atmospheric control system recombiner components' internal surfaces to manage loss of material.

Nonsafety-related systems, structures, and components affecting safety-related systems, structures, and components Visually inspect the internal surface of a representative sample of nuclear boiler system (B21) piping and valve bodies to manage loss of material.

Determine wall thickness of selected RHR service water system (E11) piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Perform visual or ultrasonic inspection of a representative sample of the internal surface of fuel pool cooling and cleanup system (G41) abandoned piping to manage loss of material.

Visually inspect the internal surface of a representative sample of condensate system (N20) piping, pump casing, tanks, and valve bodies to manage loss of material.

Visually inspect the internal surface of a representative sample of heater drains system (N22) piping, thermowells, and valve bodies to manage loss of material.

Visually inspect the internal surface of a representative sample of main turbine generator and auxiliaries system (N30) piping, tanks, and valve bodies to manage loss of material.

Visually inspect the internal surface of a representative sample of condenser and auxiliaries system (N61) piping and valve bodies to manage loss of material.

Visually inspect the internal surface of process sampling system (P33) chiller and cooler housing to manage loss of material.

Determine wall thickness of selected general service water system (P41) piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Determine wall thickness of selected emergency equipment service water system (P45) piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Visually inspect the internal surface of a representative sample of drips, drains and vents system (P95) piping and valve bodies to manage loss of material.

Determine wall thickness of selected EDG system (R30) piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Visually inspect the internal surface of a representative sample of reactor/ auxiliary building HVAC system (T41) piping, strainer housing, tubing, and valve bodies to manage loss of material.

Visually inspect the internal surface of a representative sample of containment atmospheric control system (T48) piping and valve bodies to manage loss of material.

to NRC-14-0051 Page 39 of 71 The Periodic Surveillance and Preventive Maintenance Program will be enhanced as follows.

Revise the Periodic Surveillance and Preventive Maintenance Program procedures as necessary to incorporate the identified activities.

Revise Periodic Surveillance and Preventive Maintenance Program procedures to require periodic determination of wall thickness for selected piping components.

Revise Periodic Surveillance and Preventive Maintenance Program procedures to require wall thickness measurements using UT or other suitable techniques at selected locations be periodically performed to identify loss of material due to MCM in system piping components. The selected locations are based on pipe configuration, flow conditions and operating history to represent a cross-section of potential MCM sites.

The selected locations are periodically reviewed to validate their relevance and usefulness, and are modified accordingly. Prior to the period of extended operation, select a method (or methods) from available technologies for inspecting internal surfaces of buried piping that provides suitable indication of piping wall thickness for a representative set of buried piping locations.

Revise Periodic Surveillance and Preventive Maintenance Program procedures to compare wall thickness measurements to nominal wall thickness or previous measurements to determine rates of corrosion degradation. Compare wall thickness measurements to code minimum wall thickness plus margin for corrosion during the refueling cycle (Tmarg) to determine acceptability of the component for continued use.

Perform subsequent wall thickness measurements as needed for each selected location based on the rate of corrosion and expected time to reach Tmarg. Perform a minimum of five MCM degradation inspections per year until the rate of MCM corrosion occurrences no longer meets the criteria for recurring internal corrosion.

Revise the Periodic Surveillance and Preventive Maintenance Program procedures to state that the acceptance criterion is no indication of relevant degradation and to incorporate the following:

Examples of acceptance criteria for metallic components No excessive corrosion (loss of material).

No leakage from or onto internal surfaces (loss of material).

No excessive wear (loss of material).

No loss of piping component structural integrity.

Examples of acceptance criteria for elastomeric components Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

Enhancements will be implemented prior to the period of extended operation.

to NRC-14-0051 Page 40 of 71 Revisions to LRA Section A.4 are provided below with additions underlined and deletions in strike-through.

No.

Program or Activity Commitment Implementation Schedule Source 11 External Surfaces Monitoring Enhance External Surfaces Monitoring Program as follows:

a. Revise External Surfaces Monitoring Program procedures to clarify that periodic inspections will be performed of systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to those systems.

Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

b. Revise External Surfaces Monitoring Program procedures to inspect 100 percent of accessible components at least once per refueling cycle and to ensure required walkdowns include instructions to inspect for the following related to metallic components:

• Corrosion (loss of material).

• Leakage from or onto external surfaces (loss of material).

• Worn, flaking, or oxide-coated surfaces (loss of material).

• Corrosion stains on thermal insulation (loss of material).

• Protective coating degradation (cracking, flaking, and blistering).

• Leakage for detection of cracks on the external surfaces of stainless steel components exposed to an air environment containing halides (cracking).

c. Revise External Surfaces Monitoring Program procedures to include instructions for monitoring aging effects for flexible polymeric components through physical manipulations of the material, with a sample size for manipulation of at least ten percent of the available surface area. Inspect accessible surfaces for the following:

• Surface cracking, crazing, scuffing, dimensional changes (e.g.,

ballooning and necking).

• Discoloration.

• Exposure of internal reinforcement for reinforced elastomers.

• Hardening as evidence by loss of suppleness during manipulation Prior to September 20, 2024.

A.1.16 to NRC-14-0051 Page 41 of 71 No.

Program or Activity Commitment Implementation Schedule Source where the component and material are appropriate to manipulation.

• Shrinkage, loss of strength.

d. Revise External Surfaces Monitoring Program procedures to ensure surfaces that are insulated will be inspected when the external surface is exposed (i.e., during maintenance).Revise External Surfaces Monitoring Program procedures to specify the following for insulated components:

• Periodic representative inspections will be conducted during each 10-year period.

• For a representative sample of insulated indoor components exposed to condensation (because the component is operated below the dew point) and insulated outdoor components, insulation will be removed for visual inspection of the component surface. Inspections include a minimum of 20 percent of the in-scope piping length for each material type (e.g., steel, stainless steel, copper alloy, aluminum), or for components with a configuration which does not conform to a 1-foot axial length determination (e.g., valve, accumulator), 20 percent of the surface area. Alternatively, insulation will be removed and a minimum of 25 inspections performed that can be a combination of 1 foot axial length sections and individual components for each material type.

• Inspection locations are based on the likelihood of corrosion under insulation (CUI). For example, CUI is more likely for components experiencing alternate wetting and drying in environments where trace contaminants could be present and for components that operate for long periods of time below the dew point.

Subsequent inspections will consist of an examination of the exterior surface of the insulation for indications of damage to the jacketing or protective outer layer of the insulation, if the following conditions are verified in the initial inspection:

• No loss of material due to general, pitting or crevice corrosion, to NRC-14-0051 Page 42 of 71 No.

Program or Activity Commitment Implementation Schedule Source beyond that which could have been present during initial construction, and

• No evidence of cracking.

If the external visual inspections of the insulation reveal damage to the exterior surface of the insulation or there is evidence of water intrusion through the insulation (e.g. water seepage through insulation seams/joints), periodic inspections under the insulation will continue as described above.

• Removal of tightly adhering insulation that is impermeable to moisture is not required unless there is evidence of damage to the moisture barrier. If the moisture barrier is intact, the likelihood of CUI is low for tightly adhering insulation. Tightly adhering insulation is considered to be a separate population from the remainder of insulation installed on in-scope components. The entire population of in-scope accessible piping component surfaces that have tightly adhering insulation will be visually inspected for damage to the moisture barrier with the same frequency as for other types of insulation inspections. These inspections will not be credited towards the inspection quantities for other types of insulation.

e. Revise External Surfaces Monitoring Program procedures to include acceptance criteria for the parameters observed.

• Metals should not have any indications of relevant degradation.

• Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

• Rigid polymers should have no erosion, cracking, crazing or chalking.

f. Revise External Surfaces Monitoring Program procedures to stipulate that administrative controls are in accordance with the Fermi 2 10 CFR 50 Appendix B Quality Assurance Program.

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Program or Activity Commitment Implementation Schedule Source 14 Fire Water System Enhance Fire Water System Program as follows:

a. Revise Fire Water System Program procedures to ensure sprinkler heads are tested or replaced in accordance with NFPA 25 (2011 Edition), Section 5.3.1include periodic visual inspection of fire water system internals surface condition for evidence of loss of material.

b. Revise Fire Water System Program procedures to include one of the following inspection options.

(1) Wall thickness evaluations of fire protection piping using nonintrusive techniques (e.g., volumetric testing) to identify evidence of loss of material will be performed prior to the period of extended operation and periodically thereafter. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.

OR (2) A visual inspection of the internal surface condition of a representative sample of fire protection piping will be performed. The visual inspections can be opportunistic or planned as needed to obtain a representative sample prior to the period of extended operation. The frequency of inspections during the period of extended operation will be determined through an engineering evaluation of the results of previous inspections of fire water piping.

c. Revise Fire Water System Program procedures to include testing or replacement of sprinkler heads. If testing is chosen, a representative sample of sprinkler heads will be tested before the end of the 50-year sprinkler head service life and at ten-year intervals thereafter during the extended period of operation. NFPA-25 defines a representative sample of sprinklers. If replacement of the sprinkler heads is chosen, all sprinklers that have been in service for 50 years will be replaced.

d. Revise Fire Water System Program procedures to include inspection of fire water system internals for no unacceptable signs of degradation observed during non-intrusive or visual inspection of Prior to September 20, 2024, or the end of the last refueling outage prior to March 20, 2025, whichever is later, with the exception that the activities described in this commitment for piping segments designed to be dry but determined to be collecting water shall be conducted within five years prior to March 20, 2025.

A.1.19 to NRC-14-0051 Page 44 of 71 No.

Program or Activity Commitment Implementation Schedule Source components and no biofouling found in the sprinkler systems that could cause corrosion in the sprinklers.

b. Revise Fire Water System Program procedures to perform an inspection of wet fire water system piping condition at least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic or inorganic material that could result in flow obstructions or blockage of a sprinkler head.

(Refer to NFPA 25 (2011 Edition) Section 14.2.1) The inspection method used shall be capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling. Ensure procedures require a follow-up volumetric wall thickness evaluation where irregularities are detected.

c. Revise Fire Water System Program procedures to a) ensure sprinkler heads are tested or replaced in accordance with NFPA 25 (2011 Edition) Section 5.3.1 and b) the fire protection engineer approves the sprinkler testing laboratory.

d. Revise Fire Water System Program procedures to a) address a 10% decrease in pressure from one main drain test to the previous main drain test results, b) note the time to return to static pressure after performing a main drain test, and c) develop a basis for the acceptance criteria of 25 psig and 10 psig that currently exists in the main drain test procedures.

e. Revise Fire Water System Program procedures to notify the fire protection engineer of test results and deficiencies identified or detected during testing.

f. Revise Fire Water System Program procedures to ensure piping and sprinklers are cleaned if obstructions are identified during internal inspections.

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Program or Activity Commitment Implementation Schedule Source

g. Revise Fire Water System Program procedures to perform an internal inspection of wet fire water system piping conditions at least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of the branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinkler heads.

h. Revise Fire Water System Program procedures to perform, prior to the PEO, a one-time internal inspection of the dry portion of the manual wet pipe system associated with the cable spreading room by removing a sprinkler toward the end of one branch line for the purpose of inspecting for loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinkler heads.

i. Revise Fire Water System Program procedures to perform at least once every five years either an internal inspection of the dry components downstream of the deluge valves for the hydrogen seal oil unit by removing a sprinkler toward the end of one branch line and inspecting for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinklers, or Revise Fire Water System Program procedures to perform at least once every five years an air or smoke test to verify there is no flow obstruction or blockage of sprinklers.

j. Revise Fire Water System Program procedures to perform an inspection of the sprinklers associated with charcoal filters for loss of material and foreign organic or inorganic material when the charcoal beds are replaced.

k. Revise Fire Water System Program procedures to perform an obstruction investigation after an extended shutdown of more than one year.

to NRC-14-0051 Page 46 of 71 No.

Program or Activity Commitment Implementation Schedule Source

l. Perform a fire water system walkdown of the piping and components that are designed to be dry (e.g., downstream of deluge valves or manual isolations of dry fire water piping), but are periodically wetted, to determine if any piping sections are collecting water and are subject to both of the following augmented inspections:

• In each five year interval, beginning five years prior to the period of extended operation, either a) conduct a flow test or flush sufficient to detect potential flow blockage, or b) conduct a visual inspection of 100 percent of the internal surface of piping segments that cannot be drained or piping segments that allow water to collect.

• In each five year interval of the period of extended operation, inspect 20 percent of the length of piping segments that cannot be drained or piping segments that allow water to collect using volumetric techniques to measure wall thickness. Measurement points will be obtained so that each potential degraded condition can be identified (e.g., general corrosion, MIC). The 20 percent of piping that will be inspected in each five year interval will be in different locations than previously inspected piping.

m. Revise Fire Water System Program procedures to include acceptance criteria that any indication of fouling is evaluated.

n. Revise Fire Water System Program procedures to specify that if the presence of sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected during pipe inspections, the material is removed and the source and extent of condition determined, corrected, and the condition entered into the Corrective Action Program.

o. Revise Fire Water System Program procedures to replace sprinklers associated with representative tested sprinkler, if the representative test sprinkler fails to meet the test requirements.

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Program or Activity Commitment Implementation Schedule Source 28 Periodic Surveillance and Preventive Maintenance Enhance Periodic Surveillance and Preventive Maintenance Program as follows:

a. Revise the Periodic Surveillance and Preventive Maintenance Program procedures as necessary to incorporate the identified activities in LRA Section A.1.35.

b. Revise the Periodic Surveillance and Preventive Maintenance Program procedures to state that acceptance criterion is no indication of relevant degradation and to incorporate the following:

• Examples of acceptance criteria for metallic components

-No excessive corrosion (loss of material)

-No leakage from or onto internal surfaces (loss of material)

-No excessive wear (loss of material)

-No loss of piping component structural integrity

• Examples of acceptance criteria for elastomeric components

-Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

c. Revise Periodic Surveillance and Preventive Maintenance Program procedures to require periodic determination of wall thickness for selected piping components.

d. Revise Periodic Surveillance and Preventive Maintenance Program procedures to require wall thickness measurements using UT or other suitable techniques at selected locations be periodically performed to identify loss of material due to MCM in system piping components. The selected locations are based on pipe configuration, flow conditions and operating history to represent a cross-section of potential MCM sites. The selected locations are periodically reviewed to validate their relevance and usefulness, and are modified accordingly. Prior to the period of extended operation, select a method (or methods) from available technologies for inspecting internal surfaces of buried piping that provides suitable indication of piping wall thickness for a representative set of buried Prior to September 20, 2024.

A.1.35 to NRC-14-0051 Page 48 of 71 No.

Program or Activity Commitment Implementation Schedule Source piping locations.

e. Revise Periodic Surveillance and Preventive Maintenance Program procedures to compare wall thickness measurements to nominal wall thickness or previous measurements to determine rates of corrosion degradation. Compare wall thickness measurements to code minimum wall thickness plus margin for corrosion during the refueling cycle (Tmarg) to determine acceptability of the component for continued use. Perform subsequent wall thickness measurements as needed for each selected location based on the rate of corrosion and expected time to reach Tmarg. Perform a minimum of five MCM degradation inspections per year until the rate of MCM corrosion occurrences no longer meets the criteria for recurring internal corrosion.

to NRC-14-0051 Page 49 of 71 Revisions to LRA Table B-3 are provided below with additions underlined and deletions in strike-through.

Table B-3 Fermi 2 Program Consistency with NUREG-1801 Program Name NUREG-1801 Comparison Consistent with NUREG-1801 Programs with Enhancements Programs with Exceptions to NUREG-1801 Plant-Specific Fire Water System X

X X

Revisions to LRA Section B.1.16 are provided below with additions underlined and deletions in strike-through.

to NRC-14-0051 Page 50 of 71 B.1.16 EXTERNAL SURFACES MONITORING Program Description The External Surfaces Monitoring Program manages aging effects of components fabricated from metallic, elastomeric, and polymeric materials through periodic visual inspection of external surfaces during system inspections and walkdowns for evidence of leakage, loss of material (including loss of material due to wear), cracking, fouling, and change in material properties.

When appropriate for the component and material, physical manipulation, such as touching, pressing, flexing, and bending, is used to augment visual inspections to confirm the absence of hardening and loss of strength in non-metallic materials. The External Surfaces Monitoring Program is also credited in an air - indoor and air - outdoor environment where the material and environment combinations are the same for the internal and external surfaces such that the external surfaces are representative of the internal surfaces.

Inspections are performed at a frequency of at least once per refueling cycle by personnel qualified through plant-specific programs. Deficiencies are documented and evaluated under the Corrective Action Program. Surfaces that are not readily visible during plant operations and refueling outages are inspected when they are made accessible and at such intervals that would ensure the components' intended functions are maintained.

Periodic representative surface condition inspections of the in-scope mechanical indoor components under insulation (with process fluid temperature below the dew point) and outdoor components under insulation will be performed. Surfaces that are insulated are inspected when exposed at such intervals to ensure the components intended functions are maintained.

Examples of inspection parameters for metallic components include the following:

Corrosion (loss of material).

Leakage from or onto external surfaces (loss of material).

Worn, flaking, oxide-coated surfaces (loss of material).

Corrosion stains on thermal insulation (loss of material).

Protective coating degradation (cracking, flaking, and blistering).

Leakage for detection of cracks on the external surfaces of stainless steel components exposed to an air environment containing halides (cracking).

Examples of inspection parameters for non-metallics include the following:

Surface cracking, crazing, scuffing, and dimensional change (e.g., ballooning and necking).

Discoloration.

Exposure of internal reinforcement for reinforced elastomers.

Hardening as evidenced by a loss of suppleness during manipulation where the component and material are appropriate for manipulation.

Shrinkage, loss of strength.

For polymeric materials, the visual inspection will include 100 percent of the accessible components. The sample size of polymeric components that receive physical manipulation is at least 10 percent of the available surface area.

to NRC-14-0051 Page 51 of 71 Acceptance criteria are defined to ensure that the need for corrective action is identified before a loss of intended function. For stainless steel, a clean shiny surface is expected. For flexible polymers, a uniform surface texture (no cracks) and no change in material properties (e.g.,

hardness, flexibility, physical dimensions, color unchanged from when the material was new) are expected. For rigid polymers, no surface changes affecting performance, such as erosion, cracking, crazing, checking, and chalking, are acceptable.

NUREG-1801 Consistency The External Surfaces Monitoring Program, with enhancements, is consistent with the program described in NUREG-1801,Section XI.M36, External Surfaces Monitoring of Mechanical Components, as modified by LR-ISG-2011-03 and LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation."

Exceptions to NUREG-1801 None Enhancements The following enhancements will be implemented prior to the period of extended operation.

Element Affected Enhancement

1. Scope of Program Revise External Surfaces Monitoring Program procedures to clarify that periodic inspections will be performed of systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(1) and (a)(3).

Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

to NRC-14-0051 Page 52 of 71

3. Parameters Monitored or Inspected

4. Detection of Aging Effects Revise External Surfaces Monitoring Program procedures to inspect 100 percent of accessible components at least once per refueling cycle and to ensure required walkdowns include instructions to inspect for the following related to metallic components:

• Corrosion (loss of material and fouling).

• Leakage from or onto external surfaces (loss of material).

• Worn, flaking, or oxide-coated surfaces (loss of material).

• Corrosion stains on thermal insulation (loss of material).

• Protective coating degradation (cracking, flaking, and blistering).

• Leakage for detection of cracks on the external surfaces of stainless steel components exposed to an air environment containing halides (cracking).

3. Parameters Monitored or Inspected

4. Detection of Aging Effects Revise External Surfaces Monitoring Program procedures to include instructions for monitoring aging effects for flexible polymeric components through physical manipulations of the material, with a sample size for manipulation of at least ten percent of the available surface area. Inspect accessible surfaces for the following:

• Surface cracking, crazing, scuffing, dimension changes (e.g., ballooning and necking).

• Discoloration.

• Exposure of internal reinforcement for reinforced elastomers.

• Hardening as evidenced by loss of suppleness during manipulation where the component and material are appropriate to manipulation.

• Shrinkage, loss of strength.

4. Detection of Aging Effects Revise External Surfaces Monitoring Program procedures to ensure surfaces that are insulated will be inspected when the external surface is exposed (i.e., during maintenance).Revise External Surfaces Monitoring Program procedures to specify the following for insulated components:

Periodic representative inspections will be conducted during each 10-year period.

For a representative sample of insulated indoor components exposed to condensation (because the component is to NRC-14-0051 Page 53 of 71 operated below the dew point) and insulated outdoor components, insulation will be removed for visual inspection of the component surface. Inspections include a minimum of 20 percent of the in-scope piping length for each material type (e.g.,

steel, stainless steel, copper alloy, aluminum), or for components with a configuration which does not conform to a 1-foot axial length determination (e.g., valve, accumulator), 20 percent of the surface area. Alternatively, insulation will be removed and a minimum of 25 inspections performed that can be a combination of 1 foot axial length sections and individual components for each material type.

Inspection locations are based on the likelihood of corrosion under insulation (CUI). For example, CUI is more likely for components experiencing alternate wetting and drying in environments where trace contaminants could be present and for components that operate for long periods of time below the dew point.

Subsequent inspections will consist of an examination of the exterior surface of the insulation for indications of damage to the jacketing or protective outer layer of the insulation, if the following conditions are verified in the initial inspection:

No loss of material due to general, pitting or crevice corrosion, beyond that which could have been present during initial construction, and No evidence of cracking If the external visual inspections of the insulation reveal damage to the exterior surface of the insulation or there is evidence of water intrusion through the insulation (e.g.

water seepage through insulation seams/joints), periodic inspections under the insulation will continue as described above.

Removal of tightly adhering insulation that is impermeable to moisture is not required unless there is evidence of damage to the moisture barrier. If the moisture barrier is to NRC-14-0051 Page 54 of 71 intact, the likelihood of CUI is low for tightly adhering insulation. Tightly adhering insulation is considered to be a separate population from the remainder of insulation installed on in-scope components. The entire population of in-scope accessible piping component surfaces that have tightly adhering insulation will be visually inspected for damage to the moisture barrier with the same frequency as for other types of insulation inspections. These inspections will not be credited towards the inspection quantities for other types of insulation.

6. Acceptance Criteria Revise External Surfaces Monitoring Program procedures to include acceptance criteria for the parameters observed.

• Metals should not have any indications of relevant degradation.

• Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

• Rigid polymers should have no erosion, cracking, crazing, or chalking.

9. Administrative Controls Revise External Surfaces Monitoring Program procedures to stipulate that administrative controls are in accordance with the Fermi 2 10 CFR 50 Appendix B Quality Assurance Program.

Revisions to LRA Section B.1.19 are provided below with additions underlined and deletions in strike-through.

to NRC-14-0051 Page 55 of 71 B.1.19 FIRE WATER SYSTEM Program Description The Fire Water System Program manages loss of material and biofouling for components in fire water systems using preventive, inspection, and monitoring activities, including periodic flush tests, and testing or replacement of sprinkler heads. Applicable industry standards and guidance documents are used to delineate the program.

Consistent with NFPA 25, the Fermi 2 program includes system performance testing in accordance with the UFSAR and TRM. The periodic flow testing includes monitoring the pressure of tested pipe segments, which verifies that system pressure remains adequate for system intended functions. Results are trended. Periodic flushing is also performed in accordance with the TRM.

The Fire Water System Program manages loss of material for in-scope long-lived passive water-based fire suppression system components using periodic flow testing and visual inspections. When visual inspections are used to detect loss of material, the inspection technique is capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling.

Testing or replacement of sprinkler heads that have been in service for 50 years is performed in accordance with the 2011 Edition of NFPA 25. Portions of the water-based fire water system that a) are normally dry, but periodically subject to flow (e.g., dry-pipe or downstream of deluge valve in a deluge system) and b) cannot be drained or allow water to collect are subject to augmented testing beyond that specified in NFPA 25. These augmented inspections include a) periodic full flow tests at the design pressure and flow rate, or internal inspections, and b) volumetric wall thickness evaluations. Applicable industry standards and guidance documents are also used to delineate the program (e.g., insurance loss control manual and INPO operating experience issuances).

Wall thickness is evaluated to ensure minimum wall thickness is maintained. Wall thickness measurements are determined by volumetric testing, or as an alternative to nonintrusive testing, by visually monitoring internal surface condition upon each entry into the system for routine or corrective maintenance. The use of internal visual inspections is acceptable when inspections can be performed (based on past maintenance history) on a representative number of locations.

These inspections will be performed before the period of extended operation and at plant-specific intervals, based on the initial test results, during the period of extended operation.

Periodic visual inspections of fire water system internals monitor surface condition for indication of loss of material or biofouling.

Other requirements of the program include testing and maintaining fire detectors and visually inspecting fire hydrants to detect signs of corrosion. Fire hydrant flow tests are performed annually to ensure fire hydrants can perform their intended function. Water system pressure is continuously monitored such that loss of pressure is immediately detected and corrective action initiated. If not replaced, sprinkler heads are tested before the end of 50-year sprinkler service life and every ten years thereafter during the period of extended operation.

Program acceptance criteria includeare (a) the water based fire protection system can maintain required pressure, (b) no unacceptable signs of degradation or fouling are observed during to NRC-14-0051 Page 56 of 71 nonintrusive or visual inspections, and (c) in the event surface irregularities are identified, testing is performed to ensure minimum design pipe wall thickness is maintained, and (d) no biofouling exists in the sprinkler systems that could cause corrosion in the sprinklers.

NUREG-1801 Consistency The Fire Water System Program, with enhancements, is consistent with the program described in NUREG-1801,Section XI.M27, Fire Water System, as modified by LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation", with the following exceptions.

Exceptions to NUREG-1801 None Element Affected Exception

4. Detection of Aging Effects NFPA 25, Section 5.2.1 specifies annual sprinkler inspections. Fermi 2 performs the sprinkler inspections every refueling cycle interval.1 Exception Notes

1. As indicated by the note in Table 4a of LR-ISG-2012-02, access for some inspections is feasible only during refueling outages, which are scheduled every 18 months. Inspections performed at least once every refueling cycle interval have been effective at maintaining component intended functions.

Element Affected Exception

4. Detection of Aging Effects NFPA 25, Section 5.2.1.1 specifies inspections for sprinkler orientation, foreign material, physical damage, and loading due to dust or debris. The effects of aging are not causes of discrepancies involving sprinkler orientation, foreign material, physical damage, and loading due to dust or debris. Therefore, inspections for these conditions are not included in the aging management programs for the Fermi 2 fire water system.2 Exception Notes

2. Fermi 2 addresses the identified conditions during design, installation, and operation of the fire water system rather than in the fire water system aging management program because these conditions are not attributable to the effects of aging.

to NRC-14-0051 Page 57 of 71 Element Affected Exception

4. Detection of Aging Effects NFPA 25, Section 6.3.1 specifies flow testing every five years at the hydraulically most remote hose connections of each zone of an automatic standpipe system to verify the water supply still provides the design pressure at the required flow.

Fermi 2 performs main header flow testing in the main headers that supply the standpipe system to verify the water supply provides the design pressure and required flow.3 Exception Notes

3. To flow test the hydraulically most remote hose connection of the automatic standpipe system in a manner that would provide sufficient information to verify design pressure and flow would generate a large quantity of liquid that is potentially radwaste and could create a risk of wetting components critical to normal and shutdown operations. By not performing additional flow testing, the potential for creating radwaste and increasing operational risk is reduced.

Fermi 2 tests the fire water hoses listed in the Technical Requirements Manual (TRM) every three years, performs a version of a main drain test in each building every 18 months on a portion of the deluge and sprinkler systems, and verifies the fire water system valve line-up monthly per the TRM. During the fire water hose tests, Fermi 2 flows several gallons of fire water into a pail or drain to ensure there is no flow blockage. The station flow tests approximately 15 fire water hose stations in the Auxiliary Building, 33 fire water hose stations in the Reactor Building, and 8 fire water hose stations in the RHR Complex. Acceptance criteria for the open flow paths consist of verifying a) valve operability and b) flow through valve and connection with no indication of obstruction or other undue restriction of water flow. Fermi 2 also flow tests the wet pipe sprinkler systems through 14 inspector test valves and 7 main drain valves in the Reactor Building, Auxiliary Building and RHR Complex. For 6 of those locations that are flowed through the inspector test valve and main drain valve, the difference between static and flowing pressure is recorded and two of those locations are flowed through a sample collection sock. Any debris found in the sample collection sock is representative of what is in the rest of the system. Similar tests are also performed for the balance of the plant.

In addition, Section 6.3.1 has been revised in the 2014 edition of NFPA 25 to indicate this testing provision is only applicable to Class I and Class III standpipe systems. The automatic standpipe system at Fermi 2 is a Class II system.

Element Affected Exception

4. Detection of Aging Effects NFPA 25, Sections 6.3.1.5 and 13.2.5 specify annual main drain testing on all standpipes and risers in the water-based fire suppression system with automatic water supplies. This is done to determine if there has been a change in the water supply piping and control valves. Fermi 2 does not perform main drain testing on all standpipes and risers; However Fermi 2 does perform 7 main drain tests throughout the plant to verify there has to NRC-14-0051 Page 58 of 71 not been a change in the water supply piping and control valves.4 Exception Notes

4. With the exception of the last paragraph of Exception Note 3, the basis for Fermi 2 taking an exception to performing main drain tests on all standpipe and riser systems is the same as that for not performing flow testing on the hydraulically most remote hose connections of each zone of an automatic standpipe system (i.e., additional testing increases the risk of wetting equipment critical to normal and shutdown operations and increases the generation of additional potential radwaste).

Element Affected Exception

4. Detection of Aging Effects NFPA 25, Section 6.3.1.5.2, which refers to Section 5.3.2, addresses the calibration of gauges used during flow testing. Gauges and their calibration are not addressed in the license renewal Fermi 2 Fire Water System Program.5 Exception Notes

5. Gauges are active components. Therefore, gauges are not subject to aging management review for license renewal and their calibration is not included in the aging management program.

Element Affected Exception

4. Detection of Aging Effects NFPA 25, Sections 8.3.3.7 and 14.3.1*(1) specify inspecting and cleaning the suction screens after the water flow portions of the annual tests or fire protection activation. Fermi 2 monitors the intake structure screens routinely, and both fire water pump suction screens that get inspected annually.6 Exception Notes

6. Fermi 2 performs a) routine inspections of the intake structure screens which are the water source for the fire water system, b) annually inspects the fire water pump suction screens, and c) inspects the diesel driven fire water pump discharge strainer every 18 months and the electric driven fire water pump discharge strainer every three years. These inspections are considered to be satisfactory in lieu of inspecting and cleaning the suction screens after the flow water testing portions of the annual tests or upon activation of the fire water system.

to NRC-14-0051 Page 59 of 71 Element Affected Exception

4. Detection of Aging Effects NFPA 25, Section 14.2 specifies performing at least every five years an internal inspection of the wet and dry fire water piping. Fermi 2 performs full flow testing of the piping downstream of the deluge valves for transformers, but does not perform an internal inspection on the dry piping downstream of the deluge valves for transformers.

Fermi 2 does not inspect the dry lines downstream of the manual isolation valves for the control center HVAC make-up filter charcoal filter absorber unit, control center HVAC recirculation filter charcoal absorber unit, and the manual wet pipe cable spreading room fire water supply.7 Exception Notes

7. Performing full flow testing downstream of the deluge valves associated with transformers at least once each refueling outage satisfactorily indicates organic or inorganic material within the system.

Performing an internal inspection or performing an air or smoke test of the piping downstream of the manual isolation valves for the control center HVAC make-up filter charcoal filter absorber unit and the control center HVAC recirculation filter charcoal absorber would require system modification. Therefore, this piping and the nozzles associated with the charcoal absorber unit will be internally inspected when the charcoal is replaced. The wet pipe system for the cable spreading room is isolated and is now the backup system for the Halon system that provides fire suppression for the cable spreading room. Performing a one-time inspection of the dry piping downstream of the manual isolation valve for the wet pipe system for the cable spreading room is sufficient to determine the material condition of this section of dry piping.

Enhancements The following enhancements will be implemented prior to the period of extended operation.

Element Affected Enhancement

3. Parameters Monitored or Inspected Revise Fire Water System Program procedures to ensure sprinkler heads are tested or replaced in accordance with NFPA 25 (2011 Edition), Section 5.3.1 include periodic visual inspection of fire water system internal surface condition for evidence of loss of material.

to NRC-14-0051 Page 60 of 71

3. Parameters Monitored or Inspected Revise Fire Water System Program procedures to perform an inspection of wet fire water system piping condition at least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic or inorganic material that could result in flow obstructions or blockage of a sprinkler head.

(Refer to NFPA 25 (2011 Edition) Section 14.2.1) The inspection method used shall be capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling. Ensure procedures require a follow-up volumetric wall thickness evaluation where irregularities are detected.

4. Detection of Aging Effects Revise Fire Water System Program procedures to ensure a) sprinkler heads are tested or replaced in accordance with NFPA 25 (2011 Edition) Section 5.3.1 and b) the fire protection engineer approves the sprinkler testing laboratory.

4. Detection of Aging Effects Revise Fire Water System Program procedures to a) address a 10% decrease in pressure from one main drain test to the previous main drain test results, b) note the time to return to static pressure after performing a main drain test, and c) develop a basis for the acceptance criteria of 25 psig and 10 psig that currently exists in the main drain test procedures.

4. Detection of Aging Effects Revise Fire Water System Program procedures to notify the fire protection engineer of test results and deficiencies identified or detected during testing.

4. Detection of Aging Effects Revise Fire Water System Program procedures to ensure piping and sprinklers are cleaned if obstructions are identified during internal inspections.

4. Detection of Aging Effects Revise Fire Water System Program procedures to perform an internal inspection of wet fire water system piping conditions at least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of the branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinkler heads.

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4. Detection of Aging Effects Revise Fire Water System Program procedures to perform, prior to the PEO, a one-time internal inspection of the dry portion of the manual wet pipe system associated with the cable spreading room by removing a sprinkler toward the end of one branch line for the purpose of inspecting for loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinkler heads.

4. Detection of Aging Effects Revise Fire Water System Program procedures to perform at least once every five years either an internal inspection of the dry components downstream of the deluge valves for the hydrogen seal oil unit by removing a sprinkler toward the end of one branch line and inspecting for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinklers, or Revise Fire Water System Program procedures to perform at least once every five years an air or smoke test to verify there is no flow obstruction or blockage of sprinklers.

4. Detection of Aging Effects Revise Fire Water System Program procedures to perform an inspection of the sprinklers associated with charcoal filters for loss of material and foreign organic or inorganic material when the charcoal beds are replaced.

4. Detection of Aging Effects Revise Fire Water System Program procedures to perform an obstruction investigation after an extended shutdown of more than one year.

4. Detection of Aging Effects Perform a fire water system walkdown of the piping and components that are designed to be dry (e.g.,

downstream of deluge valves or manual isolations of dry fire water piping), but are periodically wetted, to determine if any piping sections are collecting water and are subject to both of the following augmented inspections:

In each five year interval, beginning five years prior to the period of extended operation, either a) conduct a flow test or flush sufficient to detect potential flow blockage, or b) conduct a visual inspection of 100 percent of the internal surface of piping segments that cannot be drained or piping segments that allow water to collect.

In each five year interval of the period of extended operation, inspect 20 percent of the length of piping to NRC-14-0051 Page 62 of 71 segments that cannot be drained or piping segments that allow water to collect using volumetric techniques to measure wall thickness.

Measurement points will be obtained so that each potential degraded condition can be identified (e.g.,

general corrosion, MIC). The 20 percent of piping that will be inspected in each five year interval will be in different locations than previously inspected piping.

6. Acceptance Criteria Revise Fire Water System Program procedures to include acceptance criteria that any indication of fouling is evaluated.

6. Acceptance Criteria Revise Fire Water System Program procedures to specify that if the presence of sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected during pipe inspections, the material is removed and the source and extent of condition determined, corrected, and the condition entered into the Corrective Action Program.

7. Corrective Actions Revise Fire Water System Program procedures to replace sprinklers associated with representative tested sprinkler, if the representative test sprinkler fails to meet the test requirements.

4. Detection of Aging Effects Revise Fire Water System Program procedures to include one of the following inspection options.

Wall thickness evaluations of fire protection piping using nonintrusive techniques (e.g.,

volumetric testing) to identify evidence of loss of material will be performed prior to the period of extended operation and periodically thereafter. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.

OR

A visual inspection of the internal surface condition of a representative sample of fire protection piping will be performed. The visual inspections can be opportunistic or planned as needed to obtain a representative sample prior to the period of extended operation. The frequency of inspections during the period of extended operation will be determined through an engineering evaluation of the results of previous inspections of fire water piping.

to NRC-14-0051 Page 63 of 71

4. Detection of Aging Effects Revise Fire Water System Program procedures to include testing or replacement of sprinkler heads. If testing is chosen, a representative sample of sprinkler heads will be tested before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the period of extended operation.

NFPA-25 defines a representative sample of sprinklers. If replacement of the sprinkler heads is chosen, all sprinklers that have been in service for 50 years will be replaced.

4. Detection of Aging Effects Revise Fire Water System Program procedures to include inspection of fire water system internals for no unacceptable signs of degradation observed during non-intrusive or visual inspection of components and no biofouling found in the sprinkler systems that could cause corrosion in the sprinklers.

Revisions to LRA Section B.1.35 are provided below with additions underlined.

to NRC-14-0051 Page 64 of 71 B.1.35 PERIODIC SURVEILLANCE AND PREVENTIVE MAINTENANCE Program Description There is no corresponding NUREG-1801 program.

The Periodic Surveillance and Preventive Maintenance (PSPM) Program manages aging effects not managed by other aging management programs, including loss of material, fouling, loss of material due to wear, and loss of sealing. Any indication or relevant condition of degradation detected is evaluated. Inspections occur at least once every five years during the period of extended operation.

The Periodic Surveillance and Preventive Maintenance Program also manages loss of material in carbon steel components exposed to raw water due to the recurring internal corrosion aging mechanism collectively referred to as multiple corrosion mechanisms (MCM). MCM was identified as a recurring internal corrosion aging mechanism (RICAM) in an operating experience review conducted by DTE in accordance with LR-ISG 2012-02 Section A.

The Fermi 2 aging management review credits the following inspection activities.

Reactor building Visually inspect and manually flex the rubber gasket/seal for spent fuel storage pool gates to verify no loss of sealing.

Service water system Determine wall thickness of selected piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Emergency diesel generator system Visually inspect a representative sample of air coolant, lube oil, and jacket water heat exchanger tubes to manage loss of material due to wear.

Determine wall thickness of selected piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Fire water system Use visual or other NDE techniques to inspect internal surfaces to manage fouling of the heat exchanger tubes exposed to raw water.

Combustion turbine generator system Visually inspect a representative sample of lube oil heat exchanger tubes to manage loss of material due to wear.

Visually inspect a representative sample of atomizing air precooler heat exchanger tubes to manage fouling and loss of material due to wear.

Visually inspect and clean atomizing air booster compressor suction filter to manage fouling.

Visually inspect and clean compressor extraction air filter to manage fouling.

to NRC-14-0051 Page 65 of 71 Containment atmospheric control system Use visual or other NDE techniques to inspect recombiner system component internal surfaces to manage loss of material.

Nonsafety-related systems, structures, and components affecting safety-related systems, structures, and components Visually inspect the internal surface of a representative sample of nuclear boiler system (B21) piping and valve bodies to manage loss of material.

Determine wall thickness of selected RHR service water system (E11) piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Perform visual or ultrasonic inspection of a representative sample of the internal surface of fuel pool cooling and cleanup system (G41) abandoned piping to manage loss of material.

Visually inspect the internal surface of a representative sample of condensate system (N20) piping, pump casing, tanks, and valve bodies to manage loss of material.

Visually inspect the internal surface of a representative sample of heater drains system (N22) piping, thermowells, and valve bodies to manage loss of material.

Visually inspect the internal surface of a representative sample of main turbine generator and auxiliaries system (N30) piping, tanks, and valve bodies to manage loss of material.

Visually inspect the internal surface of a representative sample of condenser and auxiliaries system (N61) piping and valve bodies to manage loss of material.

Visually inspect the internal surface of process sampling system (P33) chiller and cooler housing to manage loss of material.

Determine wall thickness of selected general service water system (P41) piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Determine wall thickness of selected emergency equipment service water system (P45) piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

to NRC-14-0051 Page 66 of 71 Nonsafety-related systems, structures, and components affecting safety-related systems, structures, and components (cont.)

Visually inspect the internal surface of a representative sample of drips, drains and vents system (P95) piping and valve bodies to manage loss of material.

Determine wall thickness of selected EDG system (R30) piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

Visually inspect the internal surface of a representative sample of reactor/auxiliary building HVAC system (T41) piping, strainer housing, tubing, and valve bodies to manage loss of material.

Visually inspect the internal surface of a representative sample of containment atmospheric control system (T48) piping and valve bodies to manage loss of material.

Evaluation 1.

Scope of Program The PSPM Program, with regard to license renewal, includes the specific structures and components identified in the aging management reviews as listed in the table above.

2.

Preventive Actions Similar to other condition monitoring programs described in NUREG-1801, the PSPM Program does not include preventive actions.

3.

Parameters Monitored/Inspected The PSPM Program monitors and inspects surface condition to identify degradation of the particular structure or component. This program monitors for degradation by (a) inspecting surface condition and flexibility for elastomeric components and (b) inspecting the surface condition of internal and external surfaces of metallic components. For selected piping components, wall thickness is measured to determine the extent of corrosion caused by MCM.

4.

Detection of Aging Effects Periodic surveillances and preventive maintenance activities provide for component inspections to detect aging effects. Inspection intervals are established such that they provide timely detection of degradation prior to loss of intended functions. Inspection intervals, sample sizes, to NRC-14-0051 Page 67 of 71 and data collection methods are dependent on component material and environment and take into consideration industry and plant-specific operating experience and manufacturers' recommendations.

Each inspection occurs at least once every five years. The selection of components to be inspected will focus on locations which are most susceptible to aging, where practical.

Established inspection methods to detect aging effects of loss of material, loss of material due to wear, and fouling include visual inspections for metallic and glass-like components.

Inspection of elastomeric materials to detect loss of sealing includes visual inspections for conditions such as flexibility by manually flexing the component. Inspections are performed by personnel qualified to perform the inspections.

For each activity that refers to a representative sample, a representative sample is 20 percent of the population (defined as components having the same material, environment, and aging effect combination) with a maximum of 25 components.

For the RICAM of MCM, wall thickness measurements using UT or other suitable techniques at selected locations will be periodically performed to identify loss of material in system piping components. The selected locations will be based on pipe configuration, flow conditions, and operating history to represent a cross-section of potential MCM sites. The selected locations will be periodically reviewed to validate their relevance and usefulness, and are modified accordingly.

Prior to the period of extended operation, a method (or methods) will be selected from available technologies for inspecting internal surfaces of buried piping that provides suitable indication of piping wall thickness for a representative set of buried piping locations.

5.

Monitoring and Trending Periodic surveillance and preventive maintenance activities provide for monitoring and trending of aging degradation. Inspection intervals are established such that they provide for timely detection of component degradation.

For the RICAM of MCM, wall thickness measurements will be compared to nominal wall thickness or previous measurements to determine rates of corrosion degradation. Wall thickness measurements will be compared to code minimum wall thickness plus margin for corrosion during the refueling cycle (Tmarg) to determine acceptability of the component for continued use. Subsequent wall thickness measurements will be performed as needed for each selected location based on the rate of corrosion and expected time to reach Tmarg. A minimum to NRC-14-0051 Page 68 of 71 of five MCM degradation inspections will be performed each year until the rate of MCM corrosion occurrences no longer meets the criteria for recurring internal corrosion.

6.

Acceptance Criteria PSPM Program acceptance criteria are defined in specific inspection procedures. The acceptance criterion is no indication of relevant degradation. For example, if the specific inspection is monitoring the surface condition for excessive corrosion, excessive wear, etc., then the acceptance criterion is the absence of excessive corrosion, excessive wear, etc.

7.

Corrective Actions Unacceptable conditions are evaluated. Corrective actions, including root cause determination and prevention of recurrence, are implemented as discussed in Section B.0.3.

8.

Confirmation Process This element is discussed in Section B.0.3.

9.

Administrative Controls This element is discussed in Section B.0.3.

10.

Operating Experience The following examples of operating experience provide objective evidence that the PSPM Program will be effective in managing the effects of aging by identifying problems, initiating corrective action and implementing program improvements.

• A major upgrade of the PSPM program was performed to reclassify component criticality.

Starting in 2009, Fermi 2 reclassified previously classified critical components by applying industry standard definitions of component criticality. The result was a reduction in the number of components classified critical. The number of critical components is now in line with industry benchmarking for a single unit BWR. The reclassification had an immediate benefit in an increased respect for preventive maintenance activities on critical components and more economic maintenance strategies on the remaining components. While the new aging management activities will increase the number of PM activities, the increase is not significant.

to NRC-14-0051 Page 69 of 71

• Following an INPO assessment in 2011, Fermi created plant-specific templates for selected PM activities, validated PM classifications, instituted a risk-based approach for first time PMs, and adopted a living PM program philosophy. Implementation of the templates into individual maintenance strategies is ongoing. In 2013, a self-assessment looked at new templates and implementation of maintenance strategies for the new templates. One corrective action was initiated to modify a template, and several improvement items were identified. The template was modified.

The following are recent examples of activities that demonstrate effectiveness of the PSPM Program.

• The PSPM Program is credited to manage loss of material due to wear of heat exchanger tubes in the emergency diesel generator (EDG) system. The air coolant heat exchanger, lube oil heat exchanger, and jacket cooling heat exchanger for EDG 12 were inspected and cleaned in July 2013. Visual inspection, eddy current testing and ultrasonic thickness testing were performed. In the air coolant and lube oil heat exchangers, though some pitting was observed, no tubes met the plugging criteria. Two tubes exceeded the plugging criteria in the jacket cooling heat exchanger and were plugged.

• For the last six years, the as-found condition for CTG 11-1 during the semi-annual and annual PMs has been rated as component condition satisfactory or measured parameter within tolerance but minor adjustment required.

The history of identification of degradation and initiation of corrective action prior to loss of intended function, along with identification of program deficiencies and subsequent corrective actions, provide assurance that the PSPM Program will remain effective. The continued application of proven monitoring methods provides assurance that the effects of aging will be managed such that components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.

The process for review of future plant-specific and industry operating experience for aging management programs is discussed in Section B.0.4.

Enhancements The following enhancements will be implemented prior to the period of extended operation.

Element Affected Enhancement

1. Scope of Program Revise the PSPM Program procedures as necessary to incorporate the identified activities.

to NRC-14-0051 Page 70 of 71

3. Parameters Monitored or Inspected Revise Periodic Surveillance and Preventive Maintenance Program procedures to require periodic determination of wall thickness for selected piping components.

4. Detection of Aging Effects Revise Periodic Surveillance and Preventive Maintenance Program procedures to require wall thickness measurements using UT or other suitable techniques at selected locations be periodically performed to identify loss of material due to MCM in system piping components. The selected locations are based on pipe configuration, flow conditions and operating history to represent a cross-section of potential MCM sites. The selected locations are periodically reviewed to validate their relevance and usefulness, and are modified accordingly. Prior to the period of extended operation, select a method (or methods) from available technologies for inspecting internal surfaces of buried piping that provides suitable indication of piping wall thickness for a representative set of buried piping locations.

5. Monitoring and Trending Revise Periodic Surveillance and Preventive Maintenance Program procedures to compare wall thickness measurements to nominal wall thickness or previous measurements to determine rates of corrosion degradation.

Compare wall thickness measurements to code minimum wall thickness plus margin for corrosion during the refueling cycle (Tmarg) to determine acceptability of the component for continued use. Perform subsequent wall thickness measurements as needed for each selected location based on the rate of corrosion and expected time to reach Tmarg. Perform a minimum of five MCM degradation inspections per year until the rate of MCM corrosion occurrences no longer meets the criteria for recurring internal corrosion.

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6. Acceptance Criteria Revise the PSPM Program procedures to state that the acceptance criterion is no indication of relevant degradation and to incorporate the following:

Examples of acceptance criteria for metallic components:

- No excessive corrosion (loss of material).

- No leakage from or onto internal surfaces (loss of material).

- No excessive wear (loss of material).

- No loss of piping component structural integrity.

• Examples of acceptance criteria for elastomeric components:

- Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

Conclusion The PSPM Program has been effective at identifying and managing aging effects of loss of material, fouling, loss of material - wear, and loss of sealing, since it consists of proven industry standard monitoring techniques, acceptance criteria, corrective actions, and administrative controls. The PSPM Program provides reasonable assurance that effects of aging are managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.