ML14335A474

Summary of Telephone Conference Call Held on November 26, 2014, Between the U.S. Nuclear Regulatory Commission and DTE Electric Company, Concerning Draft Requests for Additional Information B.1.12-1 and B.1.12-4 Pertaining to the Fermi 2 Nu

ML14335A474
Person / Time
Site:	Fermi
Issue date:	12/12/2014
From:	Melendez-Colon D License Renewal Projects Branch 1
To:	Office of Nuclear Reactor Regulation
Melendez-Colon D, 301-415-3301
References
TAC MF4222
Download: ML14335A474 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 12, 2014 LICENSEE:

DTE Electric Company FACILITY:

Fermi 2 Nuclear Power Plant

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON NOVEMBER 26, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING DRAFT REQUESTS FOR ADDITIONAL INFORMATION B.1.12-1 AND B.1.12-4 PERTAINING TO THE FERMI 2 NUCLEAR POWER PLANT, LICENSE RENEWAL APPLICATION (TAC. NO.

MF4222)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company held a telephone conference call on November 26, 2014, to discuss and clarify the staffs draft requests for additional information (DRAIs) B.1.12-1 and B.1.12-4 concerning the Fermi 2 Nuclear Power Plant, license renewal application. The telephone conference call was useful in clarifying the intent of the staffs DRAIs.

provides a listing of the participants, and Enclosure 2 contains the DRAIs discussed with the applicant, including a brief description on the status of the item.

The applicant had an opportunity to comment on this summary.

/RA/

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

Enclosures:

1. List of Participants

2. Summary of Telephone Conference Call cc w/encls: Listserv

ML14335A474

• 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 YDiaz-Sanabria DMeléndez-Colón DATE 12/9/14 12/10/14 12/11/14 12/12/14 12/12/14

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON NOVEMBER 26, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING DRAFT REQUESTS FOR ADDITIONAL INFORMATION B.1.12-1 AND B.1.12-4 PERTAINING TO THE FERMI 2 NUCLEAR POWER PLANT, LICENSE RENEWAL APPLICATION (TAC. NO.

MF4222)

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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 C. Kanatas, OGC M. Kunowski, RIII B. Kemker, RIII V. Mitlyng, RIII P. Chandrathil, RIII

ENCLOSURE 1 TELEPHONE CONFERENCE CALL FERMI 2 NUCLEAR POWER PLANT LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS November 26, 2014 PARTICIPANTS AFFILIATIONS Daneira Meléndez-Colón U.S. Nuclear Regulatory Commission (NRC)

George Thomas NRC Lynne Goodman DTE Electric Company (DTE)

Kevin Lynn DTE Glenda Patzsch-Velasquez DTE

ENCLOSURE 2

SUMMARY

OF TELEPHONE CONFERENCE CALL FERMI 2 NUCLEAR POWER PLANT LICENSE RENEWAL APPLICATION November 26, 2014 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company held a telephone conference call on November 26, 2014, to discuss and clarify the following draft requests for additional information (DRAIs) concerning the Fermi 2 license renewal application (LRA).

DRAI B.1.12-1

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 current licensing basis (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.

The detection of aging effects program element of GALL Report AMP XI.S1, ASME Section XI, Subsection IWE, recommends that the program is augmented to require surface examination, in addition to visual examination, to detect cracking in stainless steel penetration sleeves, dissimilar metal welds, bellows, and steel components that are subject to cyclic loading but have no CLB fatigue analysis. This program element also states that where feasible, appropriate Appendix J tests (AMP XI.S4) may be performed in lieu of surface examination.

The Program Description of GALL Report AMP XI.S1 states that [t]he program is also augmented to require surface examination of dissimilar metal welds of vent line bellows in accordance with Examination Category E-F, as specified in the 1992 Edition of the ASME Code,Section XI, Subsection IWE.

License Renewal Application (LRA) Section B.1.12 states that Fermi 2 primary containment is a General Electric Mark I pressure suppression steel containment consisting of a drywell, a torus and a connecting vent system. LRA Section B.1.12, "Containment Inservice Inspection - IWE,"

states that the existing program, with the enhancements, will be consistent with GALL Report AMP XI.S1.

During the audit, the staff noted that the detection of aging effects program element in the LRA AMP program basis document (FERMI-RPT-12-LRD05, Revision 1, Section 3.2) states that stainless steel penetration sleeves, dissimilar metal welds, bellows, and steel components that are subject to cyclic loading but have no CLB fatigue analysis are monitored for cracking. It also states that, additionally, XI.S4 Containment Leak Rate Program (10 CFR Part 50, Appendix J) tests may be performed in lieu of surface examination.

Issue:

It is not clear to the staff that the statements noted above for the detection of aging effects program element are consistent with the GALL Report because the LRA AMP basis document does not state that supplemental surface examination will be performed, in addition to visual examination, to detect cracking in stainless steel penetration sleeves, dissimilar metal welds, bellows, and steel components that are subject to cyclic loading but have no CLB fatigue analysis. Further, if the option to perform appropriate Appendix J tests in lieu of surface examination will be used for any of the mentioned components, the LRA AMP does not mention the type of Appendix J test that would be performed for the specific components in order for staff to evaluate the appropriateness of the test to detect cracking in these components prior to loss of intended function.

Request:

1. State whether the supplemental surface examination recommended in GALL Report AMP XI.S1 will be performed, in addition to visual examination, to detect cracking in the following containment pressure boundary components: (1) stainless steel and dissimilar metal welds of penetration sleeves, penetration bellows, and vent line bellows; (2) steel components that are subject to cyclic loading but have no CLB fatigue analysis, if any. If supplemental surface examination will be performed, indicate what standard will be used to perform surface examination of stainless steel and dissimilar metal welds.

2. If an Appendix J test is used to detect cracking, in lieu of supplemental surface examination, for the components noted in Request 1, indicate the type of Appendix J test that will be used for the applicable components and justify its appropriateness to detect cracking prior to loss of intended function.

3. If supplemental examination will not be performed or supplemental examination methods other than that described in GALL Report AMP XI.S1 will be used, justify the adequacy of the proposed exception regarding the method to identify the aging effects of cracking in the components noted in Request 1.

4. Update the LRA and Updated Final Safety Analysis Report (UFSAR) supplement, as applicable, to be consistent with the responses to the above requests.

Discussion:

The applicant requested the staff clarify items 1 and 2 of its request. No edits were requested.

This question will be sent as a formal RAI titled: RAI B.1.12-1.

DRAI B.1.12-4

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 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.

The monitoring and trending program element in GALL Report AMP XI.S1 recommends that license renewal applicants for plants with a BWR Mark I containment develop a corrosion rate that can be inferred from past ultrasonic testing (UT) examinations or establish a corrosion rate using representative alternate means and provide a technical basis based on the developed or established corrosion rate that the drywell will have sufficient thickness to perform its intended function through the period of extended operation.

LRA Section B.1.12 states that Fermi 2 primary containment is a General Electric Mark I pressure suppression steel containment consisting of a drywell, a torus and a connecting vent system. LRA Section B.1.12, "Containment Inservice Inspection - IWE," states that the existing program, with the enhancements, will be consistent with GALL Report AMP XI.S1.

To establish consistency of the program element with that in the GALL Report, LRA Sections A.1.12 and B.1.12 include an enhancement to the monitoring and trending program element that will be implemented prior to the period of extended operation. This enhancement (Commitment 9f in LRA Section A.4) states: Revise plant procedures to determine drywell shell thickness in the sand pocket areas before the period of extended operation. From the results, develop a corrosion rate to demonstrate that the drywell shell will have sufficient thickness to perform its intended function through the period of extended operation. During the audit, the staff noted that, for technical reasons indicated in the letters NRC-87-005 and NRC-88-0081, dated 9/10/1987 and 4/20/1988, respectively, and summarized in LRA Section B.1.12, ultrasonic thickness measurements of the drywell shell sand pocket areas were not performed at Fermi 2 in response to Generic Letter (GL) 87-05.

Issue:

It is not clear to the staff if the statements above in the monitoring and trending program elements of the GALL Report AMP and LRA AMPs are consistent because the proposed enhancement to the monitoring and trending program element in the LRA AMP does not indicate the minimum number of sets and interval at which UT measurements will be performed, and it does not provide the technical basis of how an appropriate corrosion rate will be developed if only one set of UT measurements is intended.

Request:

1. State the minimum number of sets of UT measurements and the interval at which they will be performed to determine the corrosion rate of the drywell shell sand pocket area and provide the technical basis that the drywell shell will have sufficient thickness to perform its intended function through the period of extended operation. In addition, explain the basis for the selected number of sets and interval for UT measurements of the drywell shell.

2. If only one set of UT measurements is intended in the response to Request 1, provide the technical basis of how an appropriate or conservatively-biased corrosion rate will be developed based on one set of UT measurements.

3. Update the LRA and UFSAR supplement, as applicable, to be consistent with the responses to the above requests.

Discussion:

The applicant requested the staff clarify its request. No edits were requested. This question will be sent as a formal RAI titled: RAI B.1.12-4.