ML14329B233
| ML14329B233 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/09/2014 |
| From: | Melendez-Colon D License Renewal Projects Branch 1 |
| To: | Kaminskas V DTE Electric Company |
| Melendez-Colon D, DLR/RPB1, 301-415-3301 | |
| References | |
| TAC MF4222 | |
| Download: ML14329B233 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 9, 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 9 (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 38 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,
/RA/
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
- Concurred via e-mail OFFICE LA:RPB1:DLR* PM:RPB1:DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME YEdmonds DMeléndez-Colón LRobinson YDíaz-Sanabria DMeléndez-Colón DATE 12/2/14 12/3/14 12/4/14 12/9/14 12/9/14
SUBJECT:
REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE FERMI 2, LICENSE RENEWAL APPLICATION - SET 9 (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 9 (TAC NO. MF4222)
RAI B.1.4-1
Background:
The detection of aging effects program element of the Buried and Underground Piping Program states that buried piping inspections will be conducted in a manner consistent with those in the detection of aging effects element of Generic Aging Lessons Learned (GALL)
Report aging management program (AMP) XI.M41, as modified by LR-ISG-2011-03.
Issue:
During the staffs review of buried pipe inspection reports, it was noted that the coatings on two excavated pipe inspections were classified as being in fair condition. However, the reports for the two inspections state that coating holidays ranging in size from 2 in2 to 10 in2 for one pipe and 30 in2 to 95 in2 for the other pipe were detected. Such sizes indicate that significant amounts of bare metal have been exposed. The classification of the coating condition may not be consistent with LR-ISG-2011-03 Table 4a, Inspections of Buried Pipe, Footnote 2, which states that inspection Category E, opposed to Category F (Category E has a lower number of inspections relative to Category F), may be used if there is no significant coating degradation.
The staff lacks sufficient information to conclude that, given the size of the holidays reported, the coating condition is appropriately classified as fair rather than significantly degraded. As a result of classifying the coatings as being in fair condition, the number of inspections conducted may not be consistent with the detection of aging effects program element of GALL Report AMP XI.M41, as modified by LR-ISG-2011-03.
Request:
State the basis for why the condition of the coatings on the pipes discussed above were classified as being in fair condition.
RAI B.1.4-2
Background:
The acceptance criteria program element of the Buried and Underground Piping Program states that the program activities associated with the acceptance criteria are consistent with GALL Report AMP XI.M41, as modified by LR-ISG-2011-03.
The GALL Report AMP recommends that if a 100 mV polarization criterion is used to assess the performance of the cathodic protection system, then the license renewal application (LRA) should include the basis for why adequate protection is provided for steel components exposed to a mixed potential environment.
Issue:
Based on documents reviewed during the audit, the applicants acceptance criteria for the cathodic protection system include negative 0.85 V and 100 mV of cathodic polarization. The applicants acceptance criteria also includes an allowance for polarization potentials less negative than 0.85 V if the buried components are in high resistivity soils that are well drained and well aerated. The applicant did not provide the basis for the alternative acceptance criteria of the cathodic protection system.
Request:
State the basis for why: (a) 100 mV polarization acceptance criterion and (b) polarization potential of less than negative 0.85 V (if the buried components are in high resistivity soils that are well drained and well aerated) will provide adequate protection for buried steel piping in a mixed metal environment.
RAI B.1.4-3
Background:
License Renewal Application Section A.4 states that the new Buried and Underground Piping Program will be implemented, [p]rior to September 20, 2024, or the end of the last refueling outage prior to March 20, 2025, whichever is later.
Issue:
The implementation schedule for the Buried and Underground Piping Program is not consistent with GALL Report AMP XI.M41, as modified by LR-ISG-2011-03, which recommends that inspections should commence in the 10-year period prior to the period of extended operation.
LRA Section A.4 is clear for some of the other programs where inspections commence prior to the period of extended operation. For example, the implementation schedule for the One-Time Inspection Program, Commitment No. 26, states, [i]nspections will be performed within the 10 years prior to March 20, 2025.
Request:
State the basis for why the implementation schedule for the Buried and Underground Piping Program does not state that inspections will commence in the 10-year period prior to the period of extended operation.
RAI B.1.19-1
Background:
As amended by letter dated July 30, 2014, Exception No. 7 to the detection of aging effects program element of the Fire Water System Program states that a one-time inspection of the internal surfaces of the dry piping downstream of the manual isolation valve for the wet pipe system for the cable spreading room will be conducted. LRA Table 3.3.2-7 states that the piping is exposed to indoor air.
GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that periodic inspections should be conducted of fire water system piping that is exposed to indoor air.
Issue:
It is not clear to the staff that the proposed exception is consistent with GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, because the applicant did not provide a basis for why there is reasonable assurance that the current licensing basis (CLB) intended function(s) of the piping would be met when only a one-time inspection is conducted.
Request:
State the basis for why there is reasonable assurance that the CLB intended function(s) of the piping downstream of the manual isolation valve for the wet pipe system for the cable spreading room will be met during the period of extended operation when only a one-time inspection is conducted.
RAI B.1.19-2
Background:
As amended by letter dated July 30, 2014, Exception No. 7 to the detection of aging effects program element of the Fire Water System Program states that in lieu of conducting a deluge test with air or smoke for the control center HVAC make-up filter charcoal filter absorber unit and the control center HVAC recirculation filter charcoal absorber unit, inspections of the internal surfaces of the piping downstream of the manual isolation valves whenever the charcoal is replaced will be conducted.
GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that, as stated in National Fire Protection Association (NFPA) 25 Section 13.4.3.2.2.4, deluge valve testing should be conducted at least every 3 years.
Issue:
It is not clear to the staff that the proposed exception is consistent with GALL Report AMP XI.M27, as modified by LR-ISG-2012-02. During the audit, the staff reviewed charcoal filter media replacement work orders and determined that media is replaced approximately every 7 to 10 years.
Request:
State the basis for why there is reasonable assurance that the CLB intended function(s) of the deluge systems for the control center HVAC make-up filter charcoal filter absorber unit and the control center HVAC recirculation filter charcoal absorber unit, will be met during the period of extended operation when inspections do not occur every 3 years.
RAI B.1.19-3
Background:
As amended by letter dated July 30, 2014, Enhancement Nos. 2 and 7 to the parameters monitored or inspected and detection of aging effects program elements of the Fire Water System Program state that an inspection of the wet fire water system piping condition will be conducted at least once every 5 years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line.
GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that, as stated in NFPA 25 Section 14.2.2, in buildings with multiple wet pipe systems every other system should be inspected every 5 years.
Issue:
During the audit, the applicant confirmed that it has multiple wet pipe systems in buildings with in-scope components protected by the fire water system. The applicant did not provide a basis for why testing only one system every 5 years is sufficient.
Request:
State the basis for why inspecting only one of the wet pipe systems in each building every 5 years will provide reasonable assurance that the wet fire water system piping will be capable of performing its CLB intended function(s) during the period of extended operation.
RAI B.1.19-4
Background:
As amended by letter dated July 30, 2014, Enhancement No. 4 to the detection of aging effects program element of the Fire Water System Program states that a basis for the acceptance criteria of less than or equal to 25 psig and less than or equal to 10 psig that currently exists in the main drain test procedures will be developed.
GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that, as stated in NFPA 25 Section 13.2.5.2, a 10 percent reduction on full flow pressure during main drain tests should be corrected.
Issue:
During the audit, the staff confirmed that the fire water system header pressure is 150 psig plus or minus 10 psig. While the less than or equal to 10 psig acceptance criterion is less than the 10 percent reduction recommended in NFPA 25 and, therefore, could be conservative based on the 150 psig header pressure, it is not clear to the staff how a less than or equal to 25 psig criterion can be justified. Although the enhancement states that the basis for the less than or equal to 25 psig and less than or equal to 10 psig criteria will be developed prior to the period of extended operation, the staff cannot complete its review of the Fire Water System Program until the basis for the acceptance criteria is provided.
Request:
Provide the basis for the acceptance criteria of less than or equal to 25 psig and less than or equal to 10 psig that currently exists in the main drain test procedures.
RAI B.1.19-5
Background:
As amended by letter dated July 30, 2014, Enhancement No. 6 to the detection of aging effects program element of the Fire Water System Program states that, sprinklers are cleaned if obstructions are identified during internal inspections.
GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that, as stated in NFPA 25 Section 5.2.1.1.2, sprinklers that are corroded or that exhibit loading should be replaced.
Issue:
The applicant did not provide a basis for why corroded or loaded sprinklers can be cleaned versus replaced.
Request:
State the basis for why cleaning debris from a sprinkler will not impact its ability to perform its CLB intended function(s) during the period of extended operation.
RAI B.1.19-6
Background:
As amended by letter dated July 30, 2014, Enhancement No. 11 to the detection of aging effects program element of the Fire Water System Program states that an obstruction investigation will be conducted after an extended shutdown of more than one year.
GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that, as stated in NFPA 25 Sections 14.2.1.3 and 14.3.1, there are additional criteria for conducting obstruction investigations (e.g., discharge of obstructive material during routine water tests, plugging of inspectors test connection, pinhole leaks).
Issue:
During the audit, the staff did not find any procedures that included the additional criteria for conducting an obstruction investigation. In addition, the applicant did not provide a basis for why its enhancement is sufficient to ensure that obstruction investigations would be conducted when appropriate.
Request:
State the criteria that will be used to determine when an obstruction investigation should be conducted.
RAI B.1.19-7
Background:
The acceptance criteria program element of the Fire Water System Program, as amended by letter dated July 30, 2014, does not include an acceptance criteria associated with corrosion of sprinklers during periodic visual sprinkler inspections. In addition, during the audit, the staff reviewed the applicants plant-specific procedures for inspecting sprinklers. The acceptance criteria in the procedures did not address corrosion of the sprinklers.
GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that, as stated in NFPA 25 Section 5.2.1.1.2, sprinklers that exhibit corrosion should be replaced.
Issue:
The applicant did not provide a basis for why corroded sprinklers can remain in service.
Request:
State the basis for why a corroded sprinkler will be capable of performing its CLB intended function during the period of extended operation.
RAI B.1.19-8
Background:
One of the plant-specific operating experience examples cited in the LRA describes fire suppression flow testing that demonstrated degrading conditions in the underground piping system. The applicant stated that it increased the frequency of testing and evaluation of this piping from 3 years, as required in the CLB, to annual testing. However, the applicant did not state that increased frequency will continue into the period of extended operation.
Issue:
Based on its review of corrective action reports that describe the trend of degradation, it is not clear to the staff why the increased frequency of testing should not be continued during the period of extended operation. The background doesnt allude that this testing will not continue into the period of extended operation, unsure how the issue ties into background.
Request:
State the basis for why performing the fire suppression flow test of the underground piping system every 3 years during the PEO will be adequate to detect a decreasing trend prior to the system not being able to perform its CLB intended function.
RAI B.1.19-9
Background:
As amended by letter dated July 30, 2014, LRA Section A.1.19 states that [t]he 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.
LR-ISG-2012-02 Table 3.0-1 recommends that the updated final safety analysis report (UFSAR) supplement summary description for the Fire Water System Program should also state that it manages fouling and flow blockage.
Issue:
Although LRA Section A.1.19 references fouling and flow blockage, it is only in reference to conducting visual inspections, not all of the inspections and testing in the program. It is not clear to the staff that the applicants CLB will be adequate during the period of extended operation if the Fire Water System Program UFSAR supplement does not state that the program manages fouling and flow blockage.
Request:
State the basis for not including fouling and flow blockage in the UFSAR description for the Fire Water System.