ML14322A526

Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 8

ML14322A526
Person / Time
Site:	Fermi
Issue date:	11/25/2014
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: ML14322A526 (13)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 25, 2014 Mr. Vito Kaminskas Site Vice President - Nuclear Generation DTE Electric Company Fermi 2 - 280 OBA 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE FERMI 2 LICENSE RENEWAL APPLICATION - SET 8 (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, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Ms. Lynne Goodman, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-3301 or e-mail Daneira.Melendez-Colon@nrc.gov.

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

Enclosure:

Requests for Additional Information cc w/encl: ListServ

ML14322A526

• Concurred via e-mail OFFICE LA:RPB1:DLR* PM:RPB1:DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME YEdmonds DMeléndez-Colón ESayoc YDíaz-Sanabria DMeléndez-Colón DATE 11/24/14 11/25/14 11/24/14 11/25/14 11/25/14

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE FERMI 2, LICENSE RENEWAL APPLICATION - SET 8 (TAC NO. MF4222)

DISTRIBUTION:

E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRsrg Resource RidsNrrPMFermi2 Resource D. Melendez-Colon Y. Diaz-Sanabria M. Wentzel B. Wittick 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 FERMI 2 LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION SET 8 (TAC NO. MF4222)

RAI B.1.25-1

Background:

Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21(a)(3) requires applicants to demonstrate that the effects of aging will be adequately managed so that intended functions will be maintained consistent with the current licensing basis (CLB) during the period of extended operation.

License Renewal Application (LRA) Section B.1.25 states that the Masonry Wall Program is consistent, with enhancements, with GALL Report AMP XI.S5, Masonry Walls. The acceptance criteria program element of GALL Report AMP XI.S5 states that for each masonry wall, the extent of observed shrinkage and/or separation and cracking of masonry may not invalidate the evaluation basis or impact the walls intended function. However, during the audit, the staff noted that the acceptance criteria program element of the LRA aging management program (AMP) basis document for the Masonry Wall Program states that potential non-conforming conditions identified during the course of an inspection are noted, evaluated, and corrective action taken as necessary. The staff also noted that in Section 4 of the referenced MMR14 procedure, the qualitative criteria for evaluation of inspection results are described in terms of structural function only.

Issue:

It is not clear that the acceptance criteria program element of LRA Section B.1.25, Masonry Wall, is consistent with the recommendations in GALL Report AMP XI.S5 because this program element does not appear to address the invalidate evaluation basis aspect of the acceptance criteria.

Request:

1. Clarify how the acceptance criteria for the inspection of masonry walls are consistent with that described in GALL Report AMP XI.S5. If it is determined that a program enhancement is needed for consistency with GALL Report AMP XI.S5, provide the supporting program enhancement.

2. If criteria other than that described in the GALL Report are being used, provide a description of the exception that includes the acceptance criteria and technical basis for its determination.

RAI B.1.39-1

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

LRA Section B.1.39, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, which is implemented as part of LRA Section B.1.42, Structures Monitoring, states that the program is an existing program that, following enhancement, will be consistent with GALL Report AMP XI.S7. The detection of aging effects program element of GALL Report AMP XI.S7 states that the program should include provisions for increased inspection frequency if the extent of the degradation is such that the structure or component may not meet its design basis if allowed to continue uncorrected until the next normally scheduled inspection.

However, during the AMP audit, the staff noted that the applicants AMP does not address the provisions for more frequent inspections.

Issue:

It is not clear that the detection of aging effects program element of the Regulatory Guide (RG) 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program is consistent with the recommendations in GALL Report AMP XI.S7 regarding provisions for more frequent inspections.

Request:

1. State how the LRA RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program is consistent with the GALL Report provision for identifying and addressing the need to increase inspection frequency to adequately manage the effects of aging, during the period of extended operation.

2. Otherwise, provide the technical justification for the exception to the GALL Report recommendation.

RAI B.1.39-2

Background:

LRA Section B.1.39 states that the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program performs periodic visual examinations to monitor the water-control structures and structural components, includingsteel piles required for the stability of the shore barrier. LRA Table 3.5.2-2, Water-Control Structures Summary of Aging Management Evaluation, indicates that the Structures Monitoring Program will manage the carbon steel sheet piles for the shore barrier, exposed to air - outdoor or a fluid environment, for loss of material. However, during its onsite audit, thru discussion with the applicant, the staff became aware that the applicant does not plan to perform visual inspections of the submerged steel piles at the shore barrier as described in LRA Section B.1.39.

Issue:

For these components identified in the LRA as within the scope of license renewal and subject to an AMR, it is not clear how either the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program or the Structures Monitoring Program will manage loss of material of the steel piles required for stability of the shore barrier if visual inspection will not be performed.

Request:

Clarify whether the steel piles at the shore barrier will be managed for age-related degradation thru visual inspections as described in the LRA, and if not, describe how the proposed AMP(s) will adequately manage the effects of aging during the period of extended operation.

RAI B.1.42-1

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

LRA Sections B.1.42, "Structures Monitoring," B.1.22, Inservice Inspection-IWF, and B.1.12, Containment Inservice Inspection-IWE, state that the programs are existing programs that, following enhancement, will be consistent with GALL Report AMPs XI.S6, XI.S3, and XI.S1.

The preventive actions, parameters monitored or inspected, and detection of aging effects program elements of GALL Report AMP XI.S6, XI.S3, and XI.S1, as applicable, explicitly address the aging management of ASTM A325, ASTM F1852, and ASTM A490 structural bolting. However, during the AMP audit, the staff reviewed the LRA AMPs basis documents for the Structures Monitoring Program, Inservice Inspection-IWF, and Containment Inservice Inspection-IWE, and noted that the program elements, with enhancements, address ASTM A325 and A490 bolting, but made no mention of ASTM F1852 bolting.

Issue:

It is not clear that the preventive actions, parameters monitored or inspected, and detection of aging effects program elements of LRA Section B.1.42; preventive actions, and detection of aging effects program elements of LRA Section B.1.22; and the preventive actions program element of LRA Section B.1.12 are consistent with the recommendations in GALL Report AMPs XI.S6, XI.S3, and XI.S1, because there was no mention of ASTM F1852 bolting.

Request:

1. State whether ASTM F1852 structural bolting is used in Fermi 2 structures and is within the scope of license renewal.

2. If ASTM F1852 structural bolting is within the scope of license renewal, state how the effects of aging will be adequately managed for the period of extended operation.

RAI B.1.42-2

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function will be maintained consistent with the CLB for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

GALL Report AMPs XI.S6 and XI.S7 address the detection of aging effects for inaccessible, below-grade concrete structural elements, which depends on the plants specific ground water/soil condition. For plants with non-aggressive ground water/soil, the programs recommend: (a) evaluating the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas and (b) examining representative samples of the exposed portions of the below grade concrete, when excavated for any reason. For plants with aggressive ground water/soil (pH < 5.5, chlorides > 500 ppm, or sulfates > 1500 ppm) and/or where the concrete structural elements have experienced degradation, the GALL Report recommends a plant specific AMP to manage the concrete aging effects during the period of extended operation.

During the audit, the staff noted that the LRA AMP basis document indicates that the Fermi 2 concrete structures are subjected to an aggressive ground water/soil environment. The staff also noted that in updated final safety analysis report (UFSAR) Table 2.5-16, Chemical Analysis of Ground Water, the ground water tested in Fermi 2 had sulfate content above the 1500 ppm limit stated in the GALL Report for aggressive groundwater.

Issue:

LRA Section B.1.42, "Structures Monitoring", states that the program is an existing program that, following enhancement, will be consistent with GALL Report AMPs XI.S6 and XI.S7.

However, the proposed enhancement to the Structures Monitoring does not appear to be consistent with the GALL Report recommendations for an aggressive water/soil environment.

Additional information is requested to verify consistency with the GALL Report for the detection of aging effects in inaccessible, below-grade concrete structural elements exposed to an aggressive ground water/soil environment.

Request:

1. Clarify how the enhancement for the detection of aging effects program element is consistent with that described in the GALL Report AMPs XI.S6 and XI.S7 for inaccessible areas exposed to aggressive ground water/soil.

2. If criteria other than that described in the GALL Report are being used, provide the basis to justify the adequacy of the proposed exception to manage the aging effects in inaccessible areas.

RAI B.1.42-3

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function will be maintained consistent with the CLB for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

LRA Section B.1.42, "Structures Monitoring," states that the program is an existing program that, following enhancement, will be consistent with GALL Report AMP XI.S6. LRA Section B.1.42 includes enhancements to the parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements to revise procedures to meet the guidelines provided in American Concrete Institute Standard (ACI) 349.3R, to demonstrate consistency with the GALL Report. During the audit, the staff noted that the program basis document references the 1996 edition of ACI 349.3R. However, the staff notes that GALL Report AMP XI.S6 is based on, and references, the 2002 edition of ACI 349.3R.

Issue:

Based on the deviation in edition of the referenced ACI 349.3R industry standard, it is not clear that LRA AMP B.1.41 is consistent with GALL Report AMP XI.S6. Substantive differences exist between the versions, particularly the requirements for qualifications of personnel. The staff notes that the program enhancements do not reference a specific version; however, the reference to the 1996 version of ACI 349.3R introduces potential inconsistencies with the GALL Report AMP XI.S6 recommendations.

Request:

1. Describe how inconsistencies between the ACI 349.3R version referenced in the program basis document and the GALL Report are being addressed to demonstrate consistency with the GALL Report recommendations.

2. Otherwise, provide technical justification for the exception to the GALL Report recommendations.

RAI B.1.42-4

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

LRA Section B.1.39, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, which is implemented by the applicant as part of LRA Section B.1.42, Structures Monitoring, states that the programs are existing programs that, following enhancement, will be consistent with GALL Report AMPs XI.S6 and XI.S7. The parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of GALL Report AMPs XI.S6 and XI.S7, explicitly address the aging management of high-strength (measured yield strength 150 ksi) structural bolts greater than 1 inch in diameter. The GALL Report recommends that visual inspections of high-strength structural bolts be supplemented with volumetric or surface examinations to detect cracking.

Based on a review of information in the LRA and provided during the AMP audit, the staff noted that sufficient information was not provided to determine whether high-strength structural bolts (other than ASTM A325, F1852, and A490 used in civil structures) are used in the structures and how stress corrosion cracking (SCC) will be managed by the AMP(s).

Issue:

It is not clear if there are high-strength structural bolts used in Fermi 2 structures (other than ASTM A325, F1852, and A490 used in civil structures) and, if used, whether the preventive actions, parameters monitored or inspected, and detection of aging effect program elements of LRA Sections B.1.42 and B.1.39 are consistent with the recommendations in GALL Report AMPs XI.S6 and XI.S7 regarding the provision to monitor for stress corrosion cracking in high-strength structural bolts greater than 1 inch in diameter through supplemental volumetric or surface examinations to detect cracking.

Request:

1. State whether high-strength (measured yield strength 150 ksi) structural bolts greater than 1 inch in diameter are used in Fermi 2 structures (including those within the scope of the Structures Monitoring Program and RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program).

2. If high-strength structural bolts greater than 1 inch in diameter are used (other than ASTM A325, F1852, and A490 used in civil structures), state how the preventive actions, parameters monitored or inspected, and detection of aging effects program elements are consistent with the GALL Report recommendations to monitor for SCC through supplemental volumetric or surface examinations.

RAI 3.5.2.2.2.2-1

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

SRP-LR Section 3.5.2.2.2.2 addresses reduction of strength and modulus of concrete structures due to elevated temperatures and states that the GALL Report recommends further evaluation of a plant-specific program if any portion of the safety-related and other concrete structures exceeds temperature limits of more than 150 degrees Fahrenheit (°F) for general areas and more than 200°F for local areas. The SRP-LR also states that higher temperatures may be allowed if tests and/or calculations are provided to evaluate the reduction in strength and modulus of elasticity and these reductions are applied to the design calculations.

LRA Table 3.5.1, item 48, states that reduction of strength and modulus due to elevated temperatures do not require aging management for Fermi 2 Group 1-5 concrete structures.

However, the further evaluation, LRA Section 3.5.2.2.2.2, states that the Structures Monitoring Program manages this aging effect for the main steam tunnel in the turbine building since the general temperature in this area exceeds 150°F during normal operation.

Issue:

Based on the information provided in the LRA, it is not clear how the Structures Monitoring Program is adequate to manage the changes in material properties due to elevated temperatures for Fermi 2 Group 1-5 concrete structures, and/or whether a reduction in strength and modulus of elasticity where applied to the design calculations based on tests and/or calculations that evaluates these reductions due to the elevated temperatures.

Request:

1. State whether a reduction in strength and modulus of elasticity was applied in the design calculations of Fermi 2 Group 1-5 concrete structures exposed to general area temperatures above 150°F or local area temperatures above 200°F.

2. If a reduction in strength and modulus of elasticity was not applied in the design calculations, explain how the Structures Monitoring Program will adequately manage this aging effect.

RAI 3.5.1.83-1

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

LRA Table 3.5.2-4 identifies stainless steel anchor bolts exposed to a fluid environment for water-control structures as Note A to indicate that this item is consistent with the GALL Report item III.A6.TP-221. However, GALL Report item III.A6.TP-221 addresses steel structural bolting when exposed to several environments.

Per the material definition in GALL Report Chapter IX.C, stainless steel is considered a different category from the steel category. These two material categories exposed to certain environments may experience different aging effects/mechanism. The GALL Report states that cracking due to SCC can occur in austenitic stainless steel at ambient temperature if there is a harsh environment, at temperatures above 140°F (60 degrees Celsius), or where an environment with stagnant, oxygenated borated water systems is present. LRA Table 3.5.2-4 indicates that the stainless steel anchor bolts are exposed to a fluid environment and states that the aging effect requiring management is loss of material. However, the LRA environment description for Exposed to Fluid Environment corresponds to a broad list of environment types that includes environments with treated water and/or treated water with temperature above 140°F which makes a stainless steel material susceptible to SCC.

Issue:

Based on the information in the LRA, it is not clear if the stainless steel anchor bolts listed in LRA Table 3.5.2-4 are exposed to an environment conducive to SCC.

Request:

1. Describe the fluid environment to which these anchor bolts are exposed including temperature and water chemistry.

2. If the anchor bolts are in an environment conducive to SCC, state how the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP will adequately manage this aging effect.

RAI 3.5.2.3.2-1

Background:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

LRA Table 3.5.2-2, states that asbestos cement board exposed to a fluid environment in water-control structures will be managed for loss of material by the RG 1.127, Inspection of Water Control Structures Associated with Nuclear Power Plants Program. LRA Table 3.0-2 describes the fluid environment for structures at Fermi 2 as either raw water or treated water with various temperatures.

GALL Report Table IX.C describes asbestos cement as a cementitious material and defines it as any material having cementing properties, which contributes to the formation of hydrated calcium silicate compounds. GALL Report Table IX.F also describes different aging mechanisms like abrasion, aggressive chemical attack, leaching of calcium hydroxide and carbonation which, depending on the type of environment and its aggressiveness, can lead to aging effects such as increase in porosity and permeability, cracking, loss of material (spalling, scaling), loss of strength, among others, for similar cementitious materials.

Issue:

Based on the information provided in the LRA, it is not clear to which type of fluid environment the asbestos cement board is exposed (e.g., raw water, treated water) and whether all applicable aging effects/mechanism for this cementitious material exposed to that fluid environment are being adequately managed.

Request:

1. Describe the fluid environment to which the asbestos cement board is exposed (i.e., raw water, treated water), including the water chemistry.

2. Considering the environment to which the asbestos cement board is exposed, explain why other aging effects related to cementitious materials (e.g., increase in porosity and permeability, cracking, and loss of strength) are not considered credible aging effects.