ML14267A267

Scoping and Screening Audit Report

ML14267A267
Person / Time
Site:	Fermi
Issue date:	10/21/2014
From:	Melendez-Colon D License Renewal Projects Branch 1
To:	Kaminskas V DTE Electric Company
Melendez-Colon D, 301-415-3301
References
TAC MF4222
Download: ML14267A267 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 21, 2014 Mr. Vito Kaminskas Site Vice President - Nuclear Generation DTE Electric Company Fermi 2 - 280 OBA 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

SCOPING AND SCREENING METHODOLOGY AUDIT REPORT REGARDING THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)

Dear Mr. Kaminskas:

By letter dated April 24, 2014, DTE Electric Company submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating license NPF-43 for Fermi 2 Nuclear Power Plant for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff completed the on-site audit of the license renewal scoping and screening methodology from August 4 through August 7, 2014, at the Fermi 2 facility located in Newport, MI.

If you have any questions, please contact me at 301-415-3301 or e-mail Daneira.Melendez-Colon@nrc.gov.

Sincerely,

/RA/

Daneira Meléndez-Colón, Project Manager Reactor Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

Audit Report cc: Listserv

ML14267A267

• Concurred via e-mail OFFICE LA:RPB1:DLR PM:RPB1:DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME

• YEdmonds DMelendez-Colon *JDaily YDiaz-Sanabria DMelendez-Colon DATE 10/15/14 10/21/14 10/17/14 10/21/14 10/21/14 Letter to V. Kaminskas from Daneira Meléndez-Colón dated October 21, 2014

SUBJECT:

SCOPING AND SCREENING METHODOLOGY AUDIT REPORT REGARDING THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)

DISTRIBUTION EMAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRsrg Resource RidsNrrPMFermi2 Resource DMelendez-Colon LPerkins YDiaz-Sanabria BWittick D.McIntyre, OPA C. Kanatas, OGC D. Roth, OGC M. Kunowski, RIII B. Kemker, RIII V. Mitlyng, RIII P. Chandrathil, RIII A. Stone, RIII S. Sheldon, RIII

ENCLOSURE SCOPING AND SCREENING METHODOLOGY TRIP REPORT FOR THE FERMI 2 LICENSE RENEWAL APPLICATION I.

Introduction The Division of License Renewal performed an audit of the DTE Electric Company (DTE, the applicant), Fermi 2, license renewal scoping and screening methodology, developed to support the Fermi 2 license renewal application (LRA). The audit was performed during the week of August 4 through 7, 2014, at the applicants Fermi 2 power plant located in Monroe County, Michigan. The purpose of the audit was to review the applicants administrative controls governing implementation of the scoping and screening methodology and the technical basis for selected scoping and screening results for various plant systems, structures, and components (SSCs). The audit team also reviewed selected examples of component material types, information contained in the applicants corrective action database relevant to plant-specific age related degradation, quality practices applied during development of the LRA, and the training of personnel that participated in the development of the LRA.

The regulatory bases for the audit are Title 10 of the Code of Federal Regulations, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, (10 CFR Part 54) and NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Revision 2 (SRP-LR). In addition, the applicant developed the LRA in accordance with the guidance contained in Nuclear Energy Institute (NEI) 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, Revision 6 (NEI 95-10), which the NRC has endorsed via Regulatory Guide 1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, (RG 1.188).

II.

Background

The requirements of 10 CFR 54.21, Contents of Application - Technical Information, requires that each application for license renewal contain an integrated plant assessment (IPA). The IPA must list, for SSCs within the scope of license renewal, the structures and components (SCs) that are subject to an aging management review (AMR). Title 10 of the Code of Federal Regulations, Paragraph 54.4(a), Scope, provides the criteria for inclusion of SSCs within the scope of license renewal, and 10 CFR 54.21(a)(1) requires that SCs within the scope of license renewal that are determined to be passive and not periodically replaced are subject to an AMR.

III.

Scoping Methodology The scoping evaluations for the LRA were performed by the applicants license renewal project personnel. The audit team conducted detailed discussions with the applicants management and staff. In addition, the audit team reviewed documentation pertinent to the scoping process.

The audit team assessed whether the scoping methodology outlined in the LRA and implementing procedures was appropriately implemented and consistent with 10 CFR Part 54.

Verification of Scoping and Screening Results for Sampled Systems and Components The audit team reviewed a sample of the scoping and screening implementation for portions of the emergency equipment service water system and residual heat removal (RHR) complex support equipment system and corresponding structures. The staff reviewed applicable portions of the Updated Final Safety Analysis Report (UFSAR), scoping and screening reports, and license renewal drawings and performed a walkdown to confirm information contained in the LRA.

In addition, the audit team conducted a review of selected components from the applicants controlled plant equipment database (Fermi 2 Central Component database (CECO)) to confirm the results of the applicants determination of whether the components were within the scope of license renewal and subject to an AMR. The audit team reviewed the selected components, which included mechanical, electrical and structural components, using the UFSAR, system information, and piping and instrumentation drawings to perform its review. The controlled plant component database, which provided a list of components, was a primary source of information used during the license renewal scoping and screening process, including scoping and screening reviews, AMR, and assignment of aging management programs (AMP).

The NRC staff independently selected a random sample of 85 components from the 62,227 components listed in the plant equipment database and reviewed the component information to determine whether the components were appropriately included within the scope of license renewal and determined to be subject to an AMR. The staff reviewed the component information including the component name, system, function, tag number, location and other documentation. The applicant included 38 of the 85 randomly selected components within the scope of license renewal and determined the components to be subject to an AMR. The applicant had determined 47 components were either not within the scope of license renewal or not subject to an AMR (because the component was active or replaced on a periodic basis).

The NRC staff reviewed the 47 components and confirmed the applicants conclusion that the 47 components were not required to be within the scope of license renewal or subject to an AMR, as applicable.

Areas Requiring Additional Information The audit team determined that the applicants scoping methodology was generally consistent with the requirements of 10 CFR Part 54 for the identification of SSCs that meet the scoping criteria of 10 CFR 54.4(a). However, the audit team determined that additional information was required in order for the staff to complete its review:

The staff confirmed fluid-filled, nonsafety-related pipe in the same space as safety-related SSCs had been included within the scope of license renewal due to the potential for spray or leakage. However, the staff was unable to confirm that if the fluid-filled pipe was also attached to safety-related SSCs (typically a safety-related/nonsafety-related piping interface) that the applicant had also verified that the portion of the nonsafety-related SSC up to the first anchor, equivalent anchor or bounding condition past the safety-related/nonsafety-related interface, was identified and included within the scope of license renewal. The staff requested a basis for not including the portion of nonsafety-related SSCs attached to safety-related SSCs up to and including an anchor, equivalent anchor or bounding condition, within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) to complete its review.

The staff determined that the nonsafety-related outage building, immediately adjacent to, and in contact with, the reactor building, in which personnel perform activities required prior to entry into the reactor building and following exit from the reactor building, was not included within the scope of license renewal. The staff requested a basis for not including the outage building within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) to complete its review.

IV.

Screening Methodology The audit team reviewed the methodology used by the applicant to determine if mechanical, structural, and electrical components within the scope of license renewal would be subject to an AMR (screening). The applicant provided the audit team with a detailed discussion of the processes used for each discipline. The audit team reviewed the applicable implementing procedures and reports and focused on a sample of the documentation for emergency equipment service water system and residual heat removal (RHR) complex support equipment system and corresponding structures. The audit team noted that the applicants screening process was performed in accordance with its written requirements and was consistent with the guidance provided in the SRP-LR and NEI 95-10. The audit team determined that the screening methodology was consistent with the requirements of 10 CFR Part 54 for the identification of SSCs that meet the screening criteria of 10 CFR 54.21(a)(1).

V.

Component Material The staff performed a review to confirm a sample of the component material information contained in the LRA. The staff reviewed the applicants documentation and performed walk-downs. The NRC staff independently selected a random sample of 35 components from the Summary of Aging Management Evaluation tables contained in Section 3 of the LRA. The staff verified the information either during a walkdown or through review of the applicants reference documents. These reference documents included the UFSAR; plant system and design drawings; and component vendor manuals. The staff was able to visually inspect 18 of the 35 selected components.

The staff confirmed that the material type of 34 of the 35 components was consistent with information contained in the LRA. However, prior to the audit, the applicant had determined through a review of plant documentation that one component, an orifice in the fuel oil system was incorrectly listed as aluminum in the LRA and the orifice material was actually stainless steel. The applicant had created a corrective action for this item in accordance with the Fermi 2 Corrective Action Program.

VI.

Site-Specific Operating Experience The SRP-LR provides guidance to the staff on the process to be followed when assessing the ten program elements for each AMP submitted in an LRA. Operating experience (OE) is one of the ten elements and is defined in the SRP-LR and the GALL Report. The site-specific and industry OE also relates to two other AMP elements: detection of aging effects and monitoring and trending. The SRP-LR addresses the importance of the applicants specific OE in relation to AMRs and time-limited aging analysis activities.

The staff performed an independent search of the applicant's corrective action report database, using staff selected keywords, to identify occurrences of age related degradation. The staff identified corrective action reports that contained information concerning age related degradation that would be used by the staff during the performance of the AMP audit.

VII. Aging Management Program Quality Assurance Attributes The audit team reviewed the AMPs quality assurance elements to verify consistency with the staffs guidance described in SRP-LR, Appendix A, Branch Technical Positions, Section A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1).

The AMP quality assurance elements are corrective action program, confirmation process, and administrative controls.

The applicant described the AMP quality assurance elements in LRA Appendix B, Section B.0.3, Quality Assurance Program and Administrative Controls, and the individual AMPs. LRA Appendix B states that the applicants existing 10 CFR Part 50 Appendix B Quality Assurance Program corrective action, confirmation process, and administrative controls requirements are applicable to all SSCs subject to AMPs and activities required during the period of extended operation. The applicants AMPs incorporate various Fermi 2 procedures required to ensure the elements of corrective action program, confirmation process, and administrative controls are compliant with 10 CFR Part 50, Appendix B. The audit team reviewed the AMPs and confirmed that the AMPs incorporate corrective action programs, confirmation processes, and administrative controls. The applicant has identified no exceptions to these program elements and has specified a variety of enhancements to them for specific AMPs.

Based on the audit teams evaluation, review of the AMPs and information contained in LRA Appendix B, the staff determined the AMP quality assurance elements to be consistent with the SRP-LR, Appendix A, Branch Technical Positions, Section A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1), regarding QA for aging management.

VIII. Quality Assurance Controls Applied to LRA Development The staff reviewed the quality controls used by the applicant during development of the LRA, which included:

The license renewal team coordinated and reviewed all license renewal activities Subject matter experts, supervisors and managers prepared and reviewed basis documents, reports and the LRA The Nuclear Quality Assurance organization performed a surveillance of LRA development activities Industry peers reviewed the draft LRA The Onsite Safety Review organization and Nuclear Safety Review Group reviewed the LRA The audit team performed a review of implementing procedures and guides, examined the applicants documentation of activities in reports, reviewed the applicants activities performed to assess the quality of the LRA, and held discussions with the applicants license renewal management and staff. The audit team determined that the applicants activities provide assurance that the LRA was developed consistent with the applicants license renewal program requirements.

IX.

Training for License Renewal Project Personnel The staff reviewed the applicants training processes to ensure the guidelines and methodology for the scoping and screening activities were applied in a consistent and appropriate manner.

As outlined in procedures, the applicant required training for personnel participating in the development of the LRA and used trained and qualified personnel to prepare the scoping and screening implementing procedures. The training included the following areas of review:

Fermi 2 License Renewal Project Plan License renewal overview Operating experience review Industry Guidelines for implementation of 10 CFR Part 54 NRC Standard Review Plan - License Renewal NRC Generic Aging Lessons Learned Report System and structure scoping Mechanical system screening and aging management review Structural screening and aging management review Electrical system screening and aging management review Operating experience review Evaluation of aging management programs TLAA and exemptions evaluation License renewal application development The staff discussed training activities with the applicants management and staff and reviewed applicable documentation. The audit team determined that the applicant had developed and implemented adequate controls for the training of personnel performing LRA activities.

X.

Final Briefing A final briefing was held with the applicant on August 7, 2014, to discuss the results of the scoping and screening methodology audit. The audit team identified preliminary areas where additional information would be required to support completion of the staffs LRA review.

XI. Documents Reviewed

1. NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Revision 2

2. NEI 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 -The License Renewal Rule, Revision 6

3. License Renewal Application - Fermi 2

4. EN-FAP-LR-003, System and Structure Scoping for License Renewal

5. EN-FAP-LR-004, Mechanical System Screening and Aging Management Review

6. EN-FAP-LR-005, Electrical System Scoping, Screening and Aging Management Review

7. EN-FAP-LR-006, Structural Screening and Aging Management Review

8. FERMI-RPT-12-LRD01, System and Structure Scoping Results

9. FERMI-RPT-12-AMM25, Aging Management Review of Nonsafety-Related Systems and Components Affecting Safety-Related Systems XII. NRC Audit Team Members Bill Rogers NRR/Division of License Renewal (DLR)

Angela Buford NRR/DLR Donald Brittner NRR/DLR Edward Smith NRR/Division of Safety Systems Jim Nickolaus NRC Contractor XIII. Applicant Personnel Contacted During Audit Vito Kaminskas Site Vice President Lynne Goodman License Renewal Project Manager Angela Rudolph Coordinator James Thorson Manager, Performance Engineering John Tibal Engineering Lead - Mechanical Tom Dong Engineering Lead - Structural and Electrical Brett Gallatin Engineering Programs Liaison Kevin Lynn Licensing Alan Cox Entergy Steve Clair Entergy Jacques Lingenfelter Entergy