ML14356A212

Requests for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 17

ML14356A212
Person / Time
Site:	Fermi
Issue date:	01/14/2015
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: ML14356A212 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 14, 2015 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 17 (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 (10 CFR) 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 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

ML14356A212

• Concurred via e-mail OFFICE LA:RPB2:DLR* PM:RPB1:DLR PM:RPB1:DLR* BC:RPB1:DLR PM:RPB1:DLR NAME IBetts DMeléndez-Colón JDaily YDíaz-Sanabria DMeléndez-Colón DATE 12/30/14 1/13/15 1/14/15 1/14/15 1/14/15

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE FERMI 2, LICENSE RENEWAL APPLICATION - SET 17 (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 17 (TAC NO. MF4222)

RAI 3.3.2.9-1

Background:

License Renewal Application (LRA) Tables 3.3.2-9 and 3.3.2-12 address carbon steel bolting in a lube oil (exterior) environment. The LRA states that the aging effects of loss of material and loss of preload will be managed through the Bolting Integrity Program. The LRA states that for items that cite a generic Note G, the environment is not in the Generic Aging Lessons Learned (GALL) Report for the component and material combination. LRA Section B.1.2 states that the Bolting Integrity Program is an existing program, with enhancements, that will be consistent with GALL Report Aging Management Program (AMP) XI.M18, Bolting Integrity.

GALL Report AMP XI.M18 includes preventive measures to minimize loss of preload, such as proper torqueing of bolts and checking for uniformity of gasket compression. GALL Report AMP XI.M18 also recommends periodic inspections (at least once per refueling cycle) of closure bolting for signs of leakage to ensure the detection of age-related degradation due to loss of material and loss of preload.

Issue:

It is not clear whether the referenced bolts in a lube oil (exterior) environment are submerged in lube oil. If the bolts are in a submerged environment it is not clear how the program will be able to detect leakage of submerged bolted connections; therefore, it is not clear how the program will detect loss of material and loss of preload for submerged bolted connections prior to loss of intended function.

Request:

For the aging management review (AMR) items in LRA Tables 3.3.2-9 and 3.3.2-12 that address carbon steel bolting in a lube oil (exterior) environment through the Bolting Integrity Program state whether the bolts are submerged in lube oil. If the bolts are in a submerged environment, describe how the program will be capable of detecting both loss of material and loss of preload, and also describe how the proposed bolting inspections will be capable of detecting loss of material in crevice locations (e.g., threaded regions or the shank below the bolt heads) that are not readily visible.

RAI 3.3.2.3.17.10-1

Background:

LRA Table 3.3.2-17-10 contains AMR items for plastic piping and valve bodies internally exposed to treated water in the potable water system. No aging effect is cited and no AMP is proposed for these items. No detail was provided on the type of plastic used or the nature of the treated water environment (the treated water in other AMR items in Table 3.3.2-17-10 was specifically identified as equivalent to raw potable water).

Regulatory Issue Summary 2012-02, Insights into Recent License Renewal Application Consistency with the Generic Aging Lessons Learned Report, states that, when an applicant states that there is no aging effect requiring management (AERM) and no proposed AMP, the application should state the specific material type and grade of polymeric materials and greater detail on the specific environment (e.g., high temperatures, chemicals).

Issue:

The staff does not have sufficient information to evaluate the determination that the subject plastic piping has no aging effects. The staff noted that some polymeric materials may be susceptible to degradation in water environments. For example, the GALL Report states that high density polyethylene (HDPE) materials exposed to raw water are susceptible to cracking, blistering, and change in color due to water absorption.

Request:

For the subject plastic piping and valve bodies:

1. State the specific material type or grade.

2. Clarify whether the treated water environment is raw potable water and identify any environmental considerations that may cause the plastic components to age, such as exposure to high temperatures or chemicals.

3. Provide the basis for why there is no AERM, or otherwise, propose an AMP to manage the AERM.

RAI 3.5.1.90-1

Background:

Section 54.21(a)(3) of Title 10 of the Code of Federal Regulations (10 CFR) Part 54 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 NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report when evaluation of that matter in the GALL Report applies to the applicants plant.

LRA Table 3.5.1, item 90, discusses aging management of support members; welds; bolted connections; support anchorage to building structure which will be managed for loss of material due to general (steel only), pitting, and crevice corrosion by the Water Chemistry Control-BWR and Inservice Inspection-IWF programs. The discussion column on LRA Table 3.5.1, item 90, states that this item is consistent with the GALL Report. The SRP-LR states that item 3.5.1-90 corresponds to GALL Report item III.B1.1.TP-10. LRA Tables 3.5.2-1 and 3.5.2-4, which reference GALL Report item III.B1.1.TP-10, state that carbon steel vent header supports and anchorage/embedments (respectively) exposed to fluid environment will be managed for the aging effect of loss of material by the Water Chemistry Control-BWR and Inservice Inspection-IWF programs. For the carbon steel vent header supports the LRA cites a Note A indicating that the AMR item is consistent with component, material, environment, aging effect and AMP recommended in the GALL Report. For the anchorage/embedments the LRA cites a Note C indicating that the AMR item component is different, but consistent with material, environment, aging effect, and AMP recommended in the GALL Report.

Issue:

1. LRA Table 3.0-2, Service Environments for Structural Aging Management Reviews, states, in part, that the exposed to fluid environment used in the application corresponds to the GALL Report environment treated water >140 °F. However, GALL Report AMR item III.B1.1.TP-10 addresses steel and stainless steel components exposed to an environment of treated water less than 140 °F. It is not clear how the LRA description of an exposed to fluid environment is consistent with an environment of treated water less than 140 °F in GALL Report AMR item III.B1.1.TP-10.

2. For stainless steel components exposed to treated water greater than 140 °F, the GALL Report lists cracking as an aging effect/mechanism for which age management is recommended. It is not clear whether stainless steel anchorage/embedment components exposed to treated water greater than 140 °F will be managed for cracking.

Request:

1. Clarify how the exposed to fluid environment defined in the LRA is consistent with an environment of treated water less than 140 °F in GALL Report AMR item III.B1.1.TP-10.

2. State how the aging effects of cracking for anchorage/embedments stainless steel components exposed to treated water greater than 140 °F will be adequately managed during the period of extended operation. If cracking is not an aging effect to be managed at Fermi 2 for this component, material, and environment provide the technical justification.

RAI B.1.28-1

Background:

The applicant states that LRA AMPs B.1.26, Metal Enclosed Bus Inspection, and B.1.28, Non-EQ Cable Connections, are new programs that are consistent with GALL Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, and GALL Report AMP XI.E4, Metal Enclosed Bus.

During its onsite audit, the staff reviewed plant maintenance procedures that included procedures for verifying the torque of bolted electrical connections. The staff found that the applicants procedures were inconsistent with the guidelines set forth by Electric Power Research Institute (EPRI) TR-104213, Bolted Joint Maintenance & Applications Guide, concerning verifying proper torque of bolted electrical connections.

EPRI TR-104213, Bolted Joint Maintenance & Applications Guide, states:

Inspect bolted joints for evidence of overheating, signs of burning or discoloration, and indications of loose bolts. The bolts should not be re-torqued unless the joint requires service or the bolts are clearly loose. Verifying the torque is not recommended. The torque required to turn the fastener in the tightening direction (restart torque) is not a good indicator of the preload once the fastener is in service. Due to relaxation of the parts of the joint, the final loads are likely to be lower than the installed loads. However, this load reduction has little effect on electrical conductivity or joint performance. Check the joint resistance of bolted joints using a low range ohm meter.

GALL Report AMP XI.E4 recommends checking bus connections for increased resistance by using thermography or by measuring connection resistance using a micro-ohmmeter.

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 when evaluation of that matter in the GALL Report applies to the applicants plant.

Issue:

The re-torqueing of bolted electrical connections is not recommended per industry guidance (i.e., EPRI TR-104213) and is inconsistent with GALL Report AMPs XI.E4 and XI.E6.

Therefore, Fermi 2 maintenance practices of re-torqueing within scope bolted electrical connections may not support the applicants conclusion that LRA AMPs B.1.26 and B.1.28 are consistent with the GALL Report or that LRA AMPs B.1.26.and B.1.28 will be effective in managing aging mechanisms and effects for the period of extended operation.

Request:

Explain why plant procedures specify re-torqueing of bolted electrical connections versus the recommended practice referenced in EPRI TR-104213, Bolted Joint Maintenance &

Applications Guide, not to re-torque bolted electrical connections once the fastener is in service.

RAI B.1.28-2

Background:

The applicant states that LRA AMP B.1.28, Non-EQ Cable Connections, is a new program that is consistent with GALL Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

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 when evaluation of that matter in the GALL Report applies to the applicants plant.

The AC (alternating current) power recovery path at Fermi 2 includes a 3000 amp and a 1200 amp tap box located in the Division 2 4160 V switchgear room as well as three similar tap boxes in the Division 1 switchgear room. There are electrical bolted connections inside these boxes that are subject to ohmic heating and electrical transients aging mechanisms which can contribute to increased resistance of these connections as stated in the parameters monitored/inspected program element of GALL Report AMP XI.E6. These connections are within the scope of license renewal according to 10 CFR 54.4(3).

The detection of aging effects program element of the LRA AMP basis document states that the technical basis for the sample selected will be documented. Sample selection methodology and the technical basis have not been developed by the applicant and were not available for the staff to review at the time of its onsite audit. Factors listed for consideration for sampling per GALL Report AMP XI.E6, Electrical Cable Connections not Subject to 10 CFR 50.49 Environmental Qualification Requirements, include voltage level (medium and low voltage); circuit loading (high load); and connection type and location (high temperature, high humidity, vibration). The technical basis for sample selection should be documented according to this AMP.

During its onsite audit, the staff requested the operating experience associated with these devices and records of any maintenance activities performed. The applicant stated that no such documents were found and that there has been no reported operating experience regarding these cable connections since these tap boxes are not in the applicants preventive maintenance program.

Issue:

GALL Report AMP XI.E6 detection of aging effects program element allows the applicant to take credit for the existing maintenance practices. It states, The one-time test provides additional confirmation to support industry operating experience that shows that electrical connections have not experienced a high degree of failures, and that existing installation and maintenance practices are effective. Given that these particular devices have not been inspected or maintained, it is not clear that a one-time test under LRA AMP B.1.28 performed on a sampling basis, is adequate to ensure that aging of these cable connections will be addressed. Depending on the sampling methodology adopted by the applicant, these devices may never be tested or inspected for aging effects. Sample selection methodology and the technical basis have not been developed by the applicant and were not available for the staff to review at the time of the audit.

Request:

Justify that a one-time test, on a sampling basis, per LRA AMP B.1.28, is adequate to ensure that aging of these in-scope cable connections is properly managed, given that they have never been inspected nor maintained. Explain if a representative number of these cable connections will be included in the overall population of the tested devices according to the applicants sampling methodology.

RAI 4.3.1-1

Background:

Pursuant to 10 CFR 54.21(c)(1)(iii), an applicant must demonstrate that the effects of aging on the intended function(s) of a component will be adequately managed for the period of extended operation. LRA Sections 4.3.1.1, 4.3.1.4, 4.3.1.5, and 4.3.1.6 state that the effects of fatigue will be managed by the Fatigue Monitoring Program (LRA Section B.1.17) in accordance with 10 CFR 54.21(c)(1)(iii). LRA Table 4.3-1, Analyzed Transients with Projections, contains the transient cycles that require tracking for the time-limited aging analyses (TLAAs) in LRA Section 4.3.1. LRA Table 4.3-1 also contains events which are not design transient cycles. LRA Section 4.3.1.2 discusses the applicants TLAA to manage the effects of fatigue on the reactor pressure vessel feedwater nozzle in accordance with 10 CFR 54.21(c)(1)(iii).

Issue:

1. It is unclear to the staff which events in LRA Table 4.3-1 are being used to calculate the cumulative usage factors (CUFs) for the TLAAs in LRA Sections 4.3.1.1, 4.3.1.2, 4.3.1.4, 4.3.1.5, and 4.3.1.6. The staff cannot determine if events other than design transients are being used to determine CUF values for these sections.

2. LRA Section 4.3.1.2 does not identify the program being used to manage the effects of fatigue on the feedwater nozzle for the period of extended operation.

Request:

1. State which events are being used to calculate the CUFs for the TLAAs in LRA Sections 4.3.1.1, 4.3.1.2, 4.3.1.4, 4.3.1.5, and 4.3.1.6. Provide a clear distinction between events which are design transients and those that are not design transients. Justify the use of the Fatigue Monitoring Program to track any events which are not design transients.

2. State what program is being used to manage the effects of fatigue on the feedwater nozzle for the period of extended operation, in accordance with 10 CFR 54.21(c)(1)(iii),

in LRA Section 4.3.1.2.

RAI 4.3.2-1

Background:

Pursuant to 10 CFR 54.21(c)(1)(i), an applicant must demonstrate that the analyses for a component remain valid for the period of extended operation. LRA Section 4.3.2.1, Piping and In-Line Components, states that non-Class 1 piping calculations are valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i). The LRA also states that none of the TLAAs associated with non-Class 1 piping within the scope of license renewal will exceed the thermal cycle limit of 7000 cycles during the period of extended operation. The LRA further states that for some plant systems the number of thermal cycles coincides with the number of plant heatups and cooldowns, although the number of thermal cycles is independent of plant heatups and cooldowns for other systems. LRA Section 4.3.2.1 provides examples of plant systems for which the number of thermal cycles is independent of plant heatups and cooldowns.

Issue:

1. The LRA does not provide the transients (or cycles) being used to determine that the thermal cycle limit of 7000 will not be exceeded during the period of extended operation.

2. The LRA does not provide the current or projected number of full thermal cycles for the TLAAs being evaluated.

Request:

1. State the transients (or cycles) being counted for the non-Class 1 piping that are used to determine that the stress calculations are valid for the period of extended operation.

2. State the current and, if applicable, projected number of full thermal cycles for the non-Class 1 piping TLAAs being evaluated.

RAI 4.3.2-2

Background:

Pursuant to 10 CFR 54.21(c)(1)(i), an applicant must demonstrate that the analyses for a component remain valid for the period of extended operation. LRA Section 4.3.2.2, Components Other than Piping, states that non-Class 1 expansion joint fatigue analysis calculations are valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i). The LRA also states that the expansion joint fatigue analysis is a TLAA that assumed a bounding number of cycles. The LRA further states that it has been determined that the number of analyzed cycles is adequate for the period of extended operation.

Issue:

The staff lacks sufficient information to evaluate the expansion joint fatigue analysis TLAA (LRA Section 4.3.2.2) for the period of extended operation. The LRA does not include the following information that the staff needs for its evaluation: (a) methodology used to analyze the expansion joints, (b) transients (or cycles) being counted for the fatigue analysis, (c) current number of cycles experienced by the expansion joints, and (d) number of additional cycles projected to the end of the period of extended operation.

Request:

Provide a summary of the fatigue analysis used to evaluate the non-Class 1 expansion joints for the period of extended operation. The summary should include:

methodology or Code used in the analysis transients (or cycles) being counted for the fatigue analysis current number of cycles experienced by the expansion joints number of cycles projected to the end of the period of extended operation assumed number of bounding cycles basis used to establish the assumed number of bounding cycles basis used to disposition this TLAA as remaining valid for the period of extended operation,10 CFR 54.21(c)(1)(i)

RAI 4.3.3-1

Background:

LRA Section 4.3.3, Effects of Reactor Water Environment on Fatigue Life, states that a screening evaluation has been conducted on the six locations identified in NUREG/CR-6260, Application of NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear Power Plant Components, to assess the impact of environmentally assisted fatigue (EAF) for the period of extended operation. The results of the screening evaluation are provided in LRA Table 4.3-8, EAF Screening of Fermi 2 Locations, with multiple locations having projected CUF values exceeding the limit of 1.0 when accounting for environmental effects. The LRA also states that the fatigue usage calculations will be updated using refined fatigue analysis to determine valid CUFs of less than 1.0 for the locations in Table 4.3-8. The LRA further states that DTE will review design basis ASME Class 1 component fatigue evaluations to ensure the Fermi 2 locations evaluated for the effects of the reactor coolant environment on fatigue include the most limiting components within the reactor coolant pressure boundary.

Issue:

The staff lacks sufficient information to evaluate the effects of the reactor coolant environment on component fatigue life during the period of extended operation. It is unclear what methodologies are being used to identify the plant-specific limiting locations. It is also unclear what corrective actions and/or refined fatigue analysis will be used to ensure that the CUF values projected to exceed 1.0, when accounting for environmental effects, will remain within the ASME Code limit.

Request:

1. Provide the methodology being used to identify plant-specific component locations in the reactor coolant pressure boundary that are more limiting than the components identified in NUREG/CR-6260.

2. Explain the technical basis for how this methodology identifies the plant-specific, bounding component locations.

3. Provide the corrective actions being used and/or the methodology to refine the fatigue analysis to ensure that the CUF values projected to exceed 1.0, when accounting for environmental effects, will remain within the ASME Code limit. Justify the use of the Fatigue Monitoring Program to ensure that the CUF ASME Code limit of 1.0 is not exceeded.

RAI 4.6.1-1

Background:

LRA Table 3.5.2-1 includes, on LRA page 3.5-64, an item for component type Steel elements (accessible areas): drywell shell; drywell head; drywell shell in sand pocket region, which credits TLAA - metal fatigue as the AMP. LRA Table 3.5.2-1 also includes, on LRA page 3.5-65, an item for component type Steel elements: torus; vent line; vent header; vent line bellows; downcomers. These LRA Table 3.5.2-1 items correspond to Item 3.5.1-9 in LRA Table 3.5.1, which refers to the further evaluation in LRA Section 3.5.2.2.1.5. LRA Section 3.5.2.2.1.5, Cumulative Fatigue Damage, states that the evaluation of fatigue as a TLAA for the Fermi 2 primary containment, including its drywell shell, torus, vent line bellows, downcomers, etc., is addressed in [LRA] Section 4.6. Further, the discussion for Item 3.5.1-27 in LRA Table 3.5.1 states: Fermi 2 does have a CLB fatigue analysis associated with penetration sleeves and downcomers, and therefore this aging effect and mechanism is addressed under Item 3.5.1-9. Also, the discussion for Item 3.5.1-40 in LRA Table 3.5.1 states: Fermi 2 does have a CLB fatigue analysis associated with vent header and downcomers, and therefore this aging effect and mechanism is addressed under Item 3.5.1-9.

Fermi 2 Updated Final Safety Analyses Report (UFSAR) Sections 3.8.2.1.2.1 and 3.8.2.1.2.2 state that the design, fabrication, inspection, and testing of the drywell and the suppression chamber comply with the requirements of Section III, Subsection B, of the ASME Boiler and Pressure Vessel (B&PV) Code, 1968 edition (ASME Code). Further, UFSAR Section 3.8.2.5.b states that the primary containment design details conform to the rules specified in Subarticle N-414 - Basic Stress Intensity Limits of the ASME Code. With regard to analysis for cyclic operation, N-1314(e) of Subsection B, Requirements for Class B Vessels, of Fermi 2 code of record (i.e., the ASME Code) requires that any portion of the containment structure which does not satisfy the provisions of N-415.1 - Vessels Not Requiring Analysis for Cyclic Operation (i.e.,

fatigue waiver analysis) shall be evaluated by and satisfy the provisions of N-415.2 - Design for Cyclic Loading and N-416. If the plants code of record requires a fatigue analysis or a fatigue waiver analysis, then this analysis may be a TLAA to be evaluated in accordance with 10 CFR 54.21(c)(1).

Issue:

LRA Section 4.6 and LRA Subsection 4.6.1, Primary Containment, do not include the fatigue analyses or fatigue waiver analyses of the Fermi 2 primary containment drywell and the downcomers required by Section N-415 of the ASME Code (code of record) as a TLAA that is credited to manage fatigue cracking for the corresponding line items in LRA Table 3.5.2-1 and LRA Table 3.5.1 mentioned under the Background section above.

Request:

1. State whether or not the fatigue analysis or fatigue waiver analysis of (a) the drywell, and (b) the downcomers required by the ASME Code (code of record) is a TLAA under the CLB.

2. If it is a TLAA, provide an evaluation of the analysis for (a) the drywell components, and (b) the downcomers in the LRA in accordance with 10 CFR 54.21(c)(1).

3. If it is not a TLAA, provide information on how aging effects of cumulative fatigue damage of (a) the drywell components, and (b) the downcomers will be managed for the corresponding items in LRA Table 3.5.2-1, included on LRA pages 3.5-64 and 3.5-65, which credit TLAA - metal fatigue in the AMP column.

4. Update the applicable tables and UFSAR supplement, as appropriate, to be consistent with the responses to the above requests.

RAI 4.6.1-2

Background:

The TLAA evaluations for primary containment components in LRA Section 4.6.1 and containment penetrations in LRA Section 4.6.5 appear to include load cycles from seismic operating basis earthquake (OBE) and/or safe shutdown earthquake (SSE) events. The disposition of these TLAA evaluations is that Fermi 2 will manage the aging effects due to fatigue using the Fatigue Monitoring Program, described in LRA Sections B.1.17 and A.1.17, in accordance with 10 CFR 54.21(c)(1)(iii). LRA Section B.1.17 states that the Fatigue Monitoring Program, with enhancements, is consistent with program X.M1, Fatigue Monitoring, in the GALL Report.

Issue:

The program descriptions in LRA Section B.1.17, Fatigue Monitoring, LRA Section A.1.17, Fatigue Monitoring, and GALL Report Section X.M1, Fatigue Monitoring, appear focused on monitoring and tracking critical thermal and pressure transients for selected components. It is not clear to the staff whether the LRA Section B.1.17, Fatigue Monitoring, credited in the disposition of the TLAAs in LRA Sections 4.6.1 and 4.6.5, in accordance with 10 CFR 54.21(c)(1)(iii), include under its scope load cycles from OBE and SSE events as parameters monitored and tracked.

Further, it is not clear as to the number of specific load cycles considered in the fatigue evaluation for each OBE event and/or SSE event that defines the total bounding limit of seismic load cycles monitored against by the credited Fatigue Monitoring Program in LRA Sections B.1.17 and A.1.17.

Request:

1. Clarify whether LRA Section B.1.17, Fatigue Monitoring, credited in the disposition of the TLAA in LRA Sections 4.6.1 and 4.6.5, in accordance with 10 CFR 54.21(c)(1)(iii),

includes under its scope load cycles from OBE and SSE events as parameters monitored and tracked.

2. State the number of specific load cycles considered in the fatigue evaluations in LRA Sections 4.6.1 and 4.6.5 for each OBE event and/or SSE event, as applicable. Also, clarify why seismic SSE is not listed as an analyzed transient in LRA Table 4.3-1.

RAI 4.6.1-3

Background:

With regard to the fatigue evaluations of the primary containment suppression chamber and containment vent, LRA Section 4.6.1 states, in part, The usage factors are identified in Table 4.6-1. The safety relief valve actuations and seismic cycles are tracked and will be maintained below the cycle value used in the fatigue evaluation, or reanalysis will be completed. Fermi 2 will manage the aging effects due to fatigue using the Fatigue Monitoring Program (Section B.1.17) in accordance with 10 CFR 54.21(c)(1)(iii).

Issue:

It is not clear to the staff which specific transient events and the corresponding analysis (cycle) input values were used in calculating the cumulative usage factors documented in LRA Table 4.6-1 for containment suppression chamber and containment vent that will be monitored against by LRA Section B.1.17, Fatigue Monitoring.

Request:

1. State, with the basis, the specific applicable transients and corresponding analysis (cycle) input limits that were used in the design fatigue analysis for calculating the CUF values documented in LRA Table 4.6-1 for containment suppression chamber and containment vent, and that will be monitored by the Fatigue Monitoring Program.

2. Clarify whether the applicable transients identified in the response to Item 1 of the request are included in LRA Table 4.3-1.

RAI 4.6.5-1

Background:

LRA Section 4.6.5 states, in part, that The usage factors are shown in Table 4.6-2 for these flued head penetrations based on the number of cycles shown in the analysis input value column in Table 4.3-1. Further, LRA Section 4.6.5 also states that Fermi 2 will manage the aging effects due to fatigue of these penetrations using the Fatigue Monitoring Program (Section B.1.17) in accordance with 10 CFR 54.21(c)(1)(iii). The Fatigue Monitoring Program monitors the plant transients that contribute to fatigue usage.

LRA Table 4.3-1, Analyzed Transients with Projections, included two OBE events.

Issue:

It is not clear to the staff which specific transient events in LRA Table 4.3-1 and corresponding analysis (cycle) input values were used in calculating the CUFs documented in LRA Table 4.6-2 for flued head penetrations and that will be monitored against by the Fatigue Monitoring Program in LRA Section B.1.17.

Request:

State, with the basis, the specific applicable transients in LRA Table 4.3-1, or other, and corresponding analysis (cycle) input values that were used in the design fatigue analysis for calculating the CUF values documented in LRA Table 4.6-2 for flued head penetrations and that will be monitored using the Fatigue Monitoring Program.

RAI 4.6.5-2

Background:

With regard to the fatigue evaluations of containment penetration bellows, LRA Section 4.6.5 states, in part, that:

The analysis for these bellows determined they were capable of handling the movement from many more normal operation or faulted cycles than were specified. The bellows are qualified for more than the projected number of startups and shutdowns, and therefore, the bellows analysis remains valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i).

Issue:

The number of normal operation or faulted transient cycles that the containment penetration bellows were determined to be capable of handling is not included in LRA Section 4.6.5. The staff needs this information to verify if the bellows analysis remains valid for the period of extended operation.

Request:

State, with the basis, the number of normal operation and/or faulted transient cycles that the containment penetration bellows were determined to be capable of handling by the bellows design fatigue analysis.

RAI 4.7.3-1

Background:

LRA Section 4.7.3 describes a TLAA for auxiliary spring wedge assemblies installed on certain jet pumps. The LRA states that the auxiliary spring wedge assemblies are subject to loss of preload and were designed for a 40-year life based on a fluence of 1.2x1020 n/cm2. The LRA also states that a fluence analysis was performed through the end of the period of extended operation and it was determined for the most limiting case that the projected fluence exceeds the design fluence by 4 percent. The LRA states that this increase in fluence results in a slight increase in the loss of spring preload. The LRA further states that this increased loss of preload has no impact on the most limiting stresses and has no adverse impact on the structural integrity and functional performance of the components. As a result, the LRA concludes that the analysis has been projected to the end of the period of extended operation in accordance with 10 CFR 54.21(c)(1)(ii).

Issue:

For demonstrations made pursuant to 10 CFR 54.21(c)(1)(ii), SRP-LR Section 4.7.3.1.2 states that, The applicant shall provide a sufficient description of the analysis and documents the results of the reanalysis to show that it is satisfactory for the 60-year period. However, LRA Section 4.7.3 does not sufficiently describe the analysis or the results of the re-analysis.

Therefore, it is not clear as to how the increased loss of preload will have no adverse impact on the intended function of the auxiliary spring wedge assemblies.

Request:

Address the following items to support the conclusion that an increased loss of preload due to a 4 percent increase in projected fluence will have no adverse impact on the intended function of the auxiliary spring wedge assemblies.

1. Describe how preload ensures the functional performance of the auxiliary spring wedge assemblies and indicate how much preload is needed to ensure this functional performance.

2. Describe the methodology that was used to calculate neutron fluence through the end of the period of extended operation and provide justification for using this methodology to determine the neutron fluence received by the auxiliary spring wedge assemblies.

3. Describe the methodology that was used to calculate loss of preload in the re-analysis.

Indicate whether this methodology is different from the methodology used in the original analysis. Provide justification if the methodology is different.

4. Quantify the amount of preload loss that was calculated through the end of the period of extended operation and compare that value to the amount of preload loss that is needed to ensure the functional performance of the auxiliary spring wedge assemblies.

RAI 4.7.3-2

Background:

LRA Section A.2.5.3 provides the UFSAR supplement summary description of the TLAA for auxiliary spring wedge assemblies installed on certain jet pumps. It states that an evaluation of the increased fluence on the jet pump auxiliary spring wedge assemblies was evaluated and has no impact on the most limiting stresses.

Issue:

LRA Section A.2.5.3 does not provide a sufficient summary description of this TLAA. This section does not properly identify the auxiliary spring wedge assemblies addressed in the analysis, or which of these assemblies represents the most limiting case. Also, the UFSAR supplement does not provide the acceptance criteria used to determine how functionality of the spring wedge is ensured, or quantify the results of the analysis in terms of the amount of preload loss and compare those results against the acceptance criteria.

Request:

Justify why the information above is not included in the UFSAR supplement. Otherwise, revise LRA Section A.2.5.3, as appropriate, to address each of the issues identified.

RAI 3.6.2.2.2-1

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.

LRA Table 3.6.1, items 3.6.1-2 and 3.6.1-3, identify the component as high-voltage insulators composed of porcelain, malleable iron, aluminum, galvanized steel, and cement. LRA Table 3.6.2 identifies the material as porcelain, galvanized metal, and cement for these two items.

Issue:

The staff found an apparent discrepancy between LRA Table 3.6.1, items 3.6.1-2 and 3.6.1-3, and the corresponding items on LRA Table 3.6.2 in describing the material used for high-voltage insulators. Table 3.6.2 is inconsistent with Table 3.6.1 in that it has omitted malleable iron and aluminum in the list of material that make up this component. LRA Table 3.6.1 is consistent with SRP-LR Table 3.6.1.

Request:

Clarify the discrepancy between LRA Tables 3.6.1 and 3.6.2 regarding high-voltage insulator material as noted above.