ML14351A458
| ML14351A458 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/23/2014 |
| 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: ML14351A458 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 23, 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 13 (TAC NO. MF4222)
Dear Mr. Kaminskas:
By letter dated April 24, 2014, DTE Electric Company (DTE or the applicant) submitted an application pursuant to Title10 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 January 26, 2015. If you have any questions, please contact me at 301-415-3301 or by e-mail at 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:RPB2:DLR* PM:RPB1:DLR PM:RPB1:DLR BC:RPB1:DLR* PM:RPB1:DLR NAME IBetts DMeléndez-Colón ESayoc YDíaz-Sanabria DMeléndez-Colón DATE 12/18/14 12/22/14 12/22/14 12/23/14 12/23/14
SUBJECT:
REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE FERMI 2 LICENSE RENEWAL APPLICATION - SET 13 (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 B. Harris, OGC D. Roth, OGC M. Kunowski, RIII B. Kemker, RIII V. Mitlyng, RIII P. Chandrathil, RIII A. Stone, RIII C. Lipa, RIII S. Sheldon, RIII
ENCLOSURE FERMI 2 LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION - SET 13 (TAC NO. MF4222)
RAI 3.1.2.1-1
Background:
License Renewal Application (LRA) Table 3.1.1 compares the applicants aging management review (AMR) results for the reactor coolant system against the corresponding entries in Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) Table 3.1-1. Item 96 of SRP-LR Table 3.1-1 summarizes the components for which implementation of activities consistent with Generic Aging Lessons Learned (GALL) Report aging management program (AMP) XI.M6, BWR Control Rod Drive Return Line Nozzle, is an acceptable way to manage the effects of aging. LRA Table 3.1.1 states that there are no AMR results that are comparable with this item.
Issue:
LRA Section B.1.5 states that the applicant has an existing BWR Control Rod Drive (CRD)
Return Line Nozzle Program that is consistent with GALL Report AMP XI.M6. The components that are within the scope of the applicants BWR CRD Return Line Nozzle Program are the CRD return line nozzle, the nozzle-to-vessel weld, and the nozzle cap. LRA Table 3.1.2-1 includes an AMR line item for the nozzle cap, but there are no AMR line items in the LRA for the CRD return line nozzle and the associated nozzle-to-vessel weld. Without this information, the LRA does not sufficiently demonstrate that the effects of aging for these 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 required by Title 10 of the Code of Federal Regulations (10 CFR) 54.21(a)(3).
Request:
- 1. Provide the AMR results for the CRD return line nozzle and its nozzle-to-vessel weld if these components are within the scope of the BWR CRD Return Line Nozzle Program. Describe how these results compare with SRP-LR Table 3.1-1, item 96.
- 2. If the CRD return line nozzle and its nozzle-to-vessel weld are not within the scope of the BWR CRD Return Line Nozzle Program, explain how the effects of aging for these components will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation.
- 3. Revise the LRA as appropriate.
RAI 3.5.1.36-1
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.
LRA Table 3.5.1, item 3.5.1-36, states that Fermi 2 plant operating experience has not identified fretting or lock up due to mechanical wear for the drywell head and downcomers; that Fermi 2 inspects the drywell head and downcomers per the requirements of American Society of Mechanical Engineers (ASME) Code Section XI; and that the drywell head is a stationary or fixed component and the downcomers are stationary, well-braced components and the spatial distance between connecting components makes it unlikely for fretting and lock up to occur; therefore these aging mechanisms are not applicable.
The staff noted that Section 3.8.2.1.3.6, Access for Refueling Operations, of the updated final safety analysis report (UFSAR) states that the drywell head is removed during refueling operations and that it is held in place by bolts and is sealed with a double seal.
Issue:
Considering the drywell head description in LRA Table 3.5.1, item 3.5.1-36 and the description in Section 3.8.2.1.3.6 of the UFSAR, it is not clear to the staff whether the drywell head is a fixed or removable component and whether the effects of aging on the component has been adequately managed. GALL Report Chapter IX.F states that wear occurs in parts that experience intermittent relative motion, frequent manipulation, or in clamped joints where relative motion is not intended, but may occur due to a loss of the clamping force. Although fretting or lock up due to mechanical wear has not been identified for the drywell head and downcomers, the relative motion between these surfaces over time may experience fretting or lock up due to wear.
Request:
- 1. Clarify whether the drywell head is fixed or removable.
- 2. If the drywell head is removable, provide an acceptable AMP to demonstrate that the effects of aging on the components will be adequately managed during the period of extended operation. Otherwise provide additional information to justify that fretting or lock up due to mechanical wear does not require aging management.
RAI 3.5.1.93-1
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 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 Table 3.5-1, item 93, recommends that galvanized steel, aluminum, or stainless steel support members, welds, bolted connections, and support anchorage exposed to an air outdoor environment be managed for loss of material due to pitting and crevice corrosion by the Structures Monitoring Program. Per the GALL Report, this item relates to supports for cable trays, conduit, HVAC (heating, ventilating, and air conditioning) ducts, tubetrack, instrument tubing, and non-ASME Code piping and components, or to supports for emergency diesel generator, HVAC system components, and other miscellaneous mechanical equipment. LRA Table 3.5.2-4 identifies an AMR result which states that for stainless steel structural bolting exposed to an air outdoor environment, the Inservice Inspection - IWF Program will be used to manage loss of material. This AMR line item cites generic note E, indicating that the material, environment, and aging effect is consistent with the GALL Report but a different AMP is credited. However, the staff notes the SRP-LR Table 3.5-1, item 91, addresses steel support members, welds, bolted connections, and support anchorage for ASME Code Classes 1, 2, 3 and MC supports and recommends the ASME Code Section XI, Subsection IWF Program.
Issue:
Based on the information provided in the LRA, it is not clear whether the AMR line item in LRA Table 3.5.2-4 addresses stainless steel structural bolting for ASME Code Section XI, Subsection IWF component supports (e.g. Classes 1, 2, 3, and metal containment piping and components and their associated supports) or non-ASME Code supports as indicated by the reference to GALL Report item III.B2.TP-6. The scope of the Inservice Inspection - IWF Program described in LRA Section B.1.22 appears to be limited to ASME Code Classes 1, 2, 3, and MC piping and component supports.
Request:
- 1. For the LRA Table 3.5.2-4 AMR line item associated with SRP-LR Table 3.5-1, item 93, which credits the Inservice Inspection - IWF Program, clarify whether the stainless steel structural bolting is associated with ASME Code Section XI, Subsection IWF components or non-ASME Code component supports.
- 2. If the structural bolting is for non-ASME Code related component supports, clarify if the stainless steel structural bolting are within the scope of the Inservice Inspection - IWF Program, or propose an AMP that will adequately manage the effects of aging for the stainless steel structural bolting.
RAI 3.5.2.2.2.1-2
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(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 3.5.2.2.2.1, item 3, addresses cracking and distortion due to increased stress levels from settlement in below-grade inaccessible concrete areas of all groups of structures and states that the existing program relies on structure monitoring programs to manage these aging effects. The SRP-LR also states that some plants may rely on a de-watering system to lower the site ground water level and, if the plants CLB credits a de-watering system, the GALL Report recommends verification of the continued functionality of the de-watering system during the period of extended operation. LRA Table 3.5.1, item 44, states that Fermi 2 is consistent with the GALL Report recommendation since the concrete in inaccessible areas of all groups of structures exposed to a soil environment will be managed for cracking and distortion due to increased stress levels from settlement by the Structures Monitoring Program. However, the further evaluation, LRA Section 3.5.2.2.2.1, item 3, states that this aging effect is not applicable to Fermi 2 Groups 1-3 and 5-9 concrete structures since they are founded on bedrock with the exception of the process facilities and yard structures for which this aging effect will be manage by the Structures Monitoring Program. LRA Section 2.4 list all structures associated with Fermi 2 process facilities and yard structures and categorize the turbine building as a different group of structures.
Issue:
Based on a review of the information provided in LRA Section 2.4, which states that the turbine building is a nonsafety-related structure, and a review of the information described in Fermi 2 UFSAR Section 3.7.1.5 and Figure 2.4-22, which states that safety related structures and shore barrier are founded on bedrock, the staff was unable to verify whether all portions of the turbine building are founded on bedrock. The staff does not have sufficient information to determine whether the concrete below-grade portion of the turbine building is susceptible to cracking and distortion due to increased stress levels from settlement.
Request:
- 1. Describe the foundation type for the Fermi 2 turbine building.
- 2. If the Fermi 2 turbine building is not founded on bedrock and is susceptible to cracking and distortion due to increased stress levels from settlement, state how this aging effect will be adequately managed for the period of extended operation. Otherwise provide additional information to justify that cracking and distortion due to increased stress levels from settlement does not require aging management.
RAI 3.5.2.2.2.1-3
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(s) will be maintained consistent with the current licensing basis for the period of extended operation.
SRP-LR Section 3.5.2.2.2.1, item 4, addresses increase in porosity and permeability, and loss of strength due to leaching of calcium hydroxide and carbonation in below-grade inaccessible concrete areas of Groups 1-5 and 7-9 structures and states that the GALL Report recommends further evaluation if leaching is observed in accessible areas that impacts the intended functions of the concrete structure. The SRP-LR also states that a plant-specific AMP is not required for the reinforced concrete exposed to flowing water if (1) there is evidence in the accessible areas that the flowing water has not caused leaching of calcium hydroxide and carbonation or (2) evaluation determined that the observed leaching of calcium hydroxide and carbonation in accessible areas has no impact on the intended function of the concrete structure.
LRA Table 3.5.1, item 47, states that this item is not applicable since Fermi 2 Category I structures are founded on bedrock, do not have water flowing underneath the foundation, and leaching has not been observed on accessible portions of Fermi 2 accessible concrete areas.
The further evaluation, LRA Section 3.5.2.2.2.1, item 4, also states that this aging effect is not applicable for concrete of Fermi 2 Groups 1-5 and 7-9 concrete structures since structures are not subject to the flowing water environment necessary for this aging effect to occur. However, during the onsite AMP audit, the staff observed indications of concrete leaching in the floor and walls of the turbine building basement, and identified operating experience associated with groundwater in-leakage and leaching issues in the reactor building, residual heat removal (RHR) complex, and manholes.
Issue:
The statement that leaching has not been observed on accessible portions of Fermi 2 accessible concrete areas in LRA Table 3.5.1, item 47, is not consistent with the applicants operating experience reviewed by the staff during the onsite AMP audit.
LRA Section 3.5.2.2.2.1, item 4, does not discuss operating experience related to the leaching observed in accessible areas nor discuss any evaluation of how the observed leaching of calcium hydroxide and carbonation in accessible areas has no impact on the intended function of the concrete structure in order to address the further evaluation criteria.
Request:
- 1. Provide a summary of operating experience regarding leaching of calcium hydroxide and carbonation in accessible areas of Fermi 2 Groups 1-5 and 7-9 concrete structures.
- 2. State if an evaluation to determine the impact of the observed leaching of calcium hydroxide and carbonation on the intended function of the concrete structure has been performed and describe the results.
- 3. If no evaluation has been performed for the observed leaching of calcium hydroxide and carbonation in accessible areas, state and describe how this aging effect will be adequately managed for inaccessible areas.
RAI B.1.3-1
Background:
During the Fermi 2 onsite AMP audit, the applicant stated that three Boraflex panels were taken out of service because their Boron-10 areal density measurement test results did not meet the acceptance criteria. The measurement test results are found in the 2013 Fermi 2 BADGER test report, which summarizes the Boraflex test campaign conducted in 2013.
Issue:
The report provides information on the condition of the Boraflex material in the spent fuel pool and by extension the effectiveness of the Boraflex Monitoring Program. The staff reviewed the 2013 BADGER test report briefly during its onsite audit; however, more information is needed to complete its review and reach a conclusion on the adequacy of the Boraflex Monitoring Program to manage the effects of aging.
Request:
Please provide the 2013 BADGER test report to the staff so a more detailed review can be performed to assess the condition of the Boraflex material and the effectiveness of the Boraflex Monitoring Program.