ML15030A229

AMP Audit Summary Report Enclosure

ML15030A229
Person / Time
Site:	Fermi
Issue date:	02/11/2015
From:	Melendez-Colon D License Renewal Projects Branch 1
To:	Kaminskas V DTE Electric Company
Melendez-Colon D, DLR/RPB1, 301-415-3301
Shared Package
ML15030A219	List: ML15030A229
References
TAC MF4222
Download: ML15030A229 (106)

Text

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL Docket No: 50-341 License No: NPF-43 Licensee: DTE Electric Company Facility: Fermi 2 Nuclear Power Plant Location: Newport, MI Dates: September 15 - 19, 2014 September 29, 2014 - October 3, 2014 Reviewers: D. Meléndez-Colón, Project Manager, Division of License Renewal (DLR)

J. Mitchell, Project Manager, DLR D. Morey, Branch Chief, DLR M. Marshall, Branch Chief, DLR C. Hovanec, Materials Engineer, DLR S. Cuadrado de Jesús, General Engineer, DLR W. Holston, Sr. Mechanical Engineer, DLR M. Homiack, Mechanical Engineer, DLR Z. Bart Fu, Mechanical Engineer, DLR S. Min, Materials Engineer, DLR M. Yoo, General Engineer, DLR C. Doutt, Sr. Electrical Engineer, DLR J. Gavula, Mechanical Engineer, DLR V. Kalikian, Materials Engineer, DLR J. López-Ferrer, Structural Engineer, DLR G. Facco, General Engineer, DLR D. Brittner, Mechanical Engineer, DLR A. Buford, Structural Engineer, DLR A. Obodoako, Materials Engineer, Division of Engineering K. Green, Sr. Mechanical Engineer, DLR G. Banerjee, Structural Engineer, DLR A. Prinaris, Structural Engineer, DLR W. Gardner, General Scientist, DLR J. Wise, Materials Engineer, DLR E. Gettys, Project Manager, DLR M. Sadollah, Electrical Engineer, DLR G. Thomas, Sr. Structural Engineer, DLR Approved By: Yoira Díaz-Sanabria, Chief Projects Branch 1 Division of License Renewal ENCLOSURE

Dennis Morey, Chief Aging Management of Reactor Systems Branch Division of License Renewal Michael Marshall, Chief Aging Management of Structures, Electrical, and Systems Branch Division of License Renewal Gloria Kulesa, Chief Steam Generator Tube Integrity and Chemical Engineering Branch Division of Engineering

1 Introduction The U.S. Nuclear Regulatory Commission (NRC or the staff) conducted a 10-day audit at the Fermi 2 Nuclear Power Plant (Fermi 2), in Newport, MI, from September 15 to October 3, 2014.

The purpose of the audit was to examine DTE Electric Companys (DTE or the applicant) aging management programs (AMPs) and related documentation to verify the applicants claims of consistency with the corresponding AMPs in NUREG-1801, Revision 2, Generic Aging Lessons Learned (GALL) Report, dated December 2010. As described in the GALL Report, the staff based its evaluation of the adequacy of each AMP on its review of the following 10 program elements in each AMP: (1) scope of the program; (2) preventive actions; (3) parameters monitored or inspected; (4) detection of aging effects; (5) monitoring and trending; (6) acceptance criteria; (7) corrective actions; (8) confirmation process; (9) administrative controls; and (10) operating experience.

Exceptions to the GALL Report AMP elements will be evaluated separately as part of the staffs review of the Fermi 2 license renewal application (LRA) and documented in the staffs safety evaluation report (SER).

NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), Revision 2, dated December 2010, provides staff guidance for reviewing an LRA. The SRP-LR allows an applicant to reference in its LRA the AMPs described in the GALL Report. By referencing the GALL Report AMPs, the applicant concludes that its AMPs correspond to those AMPs reviewed and approved in the GALL Report and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL Report program. The applicants determination should be documented in an auditable form and maintained onsite.

During the audit, the staff audited AMP elements 1 - 6 and 10 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and operating experience). These elements of the applicants AMPs were claimed to be consistent with the GALL Report and were audited against the related elements of the associated AMP described in the GALL Report, unless otherwise indicated in this audit report. Elements 7 - 9 (corrective actions, confirmation process, and administrative controls) were audited during the scoping and screening methodology audit conducted on August 4 - 7, 2014, and are evaluated separately. The staff audited all AMPs that the applicant stated were consistent with the GALL Report AMPs.

During the audit, if the applicant took credit for a program in the GALL Report, the staff verified that the plant program contained all the elements of the referenced GALL Report program.

In addition, the staff verified the conditions at the plant were bounded by the conditions for which the GALL Report program was evaluated.

In addition to auditing AMP elements 1 through 6 and 10, the staff also reviewed documentation associated with the following aging management review (AMR) items: (1) LRA Table 3.3.2-6, Compressed Air Systems, (2) LRA Table 3.3.2-12, Control Center Heating, Ventilation and Air Conditioning System, and (3) LRA Table 3.4.2-3-7, Circulating Water System, Nonsafety-Related Components Affecting Safety-Related Systems. The activities and observations associated with these AMR items are documented at the end of this report.

2 In performing the audit, the staff examined the applicants LRA, program-bases documents, and related references; interviewed various applicant representatives; and conducted walkdowns of several plant areas. In total, 44 AMPs were reviewed and 41 breakout (discussion) sessions with applicant representatives were conducted. This report documents the staffs activities during the audit.

LRA AMP B.1.1, Aboveground Metallic Tanks Summary of Information in the Application. The LRA states that AMP B.1.1, Aboveground Metallic Tanks, is a new program that will be consistent with the program elements in GALL Report AMP XI.M29, Aboveground Metallic Tanks, as modified by License Renewal Interim Staff Guidance (LR-ISG)-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document and applicable plant-specific operating experience. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the combustion turbine generator (CTG) fuel oil tank and condensate storage tank (CST). The staff also conducted an independent search of the applicants operating experience database using the keywords: tank, inspect and insulation.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Evaluation Report Non-Class 1 1.FERMI-RPT-12-LRD03 Revision 2 Mechanical: Aboveground Metallic Tanks Operating Esperance Review Report - Aging

2. FERMI-RPT-LRD09 Management Program Effectiveness: Aboveground Revision 1 Metallic Tanks

3. WO-33628290 Flashing on Top of CST Coming Apart 03/27/2013

4. Condition Assessment Resolution Document Contaminated Fuel Oil 12/08/1999 (CARD) 99-19232 Integrity Testing for the Combustion Turbine Generator,

5. CARD 03-22558 01/01/2003 required under new SPCC rules and FL/CL rules Coating Improvements for Fuel Tank as per Inspection

6. CARD 05-25080 06/16/2006 Results [CTG tank]

7. CARD 03-01084 Separated Sheet Metal Seams on the Roof [CST tank] 12/19/2003

8. WO-E517100100 Perform External Tank Inspection 08/14/2010

9. CARD 06-27638 Flashing Loose on Condensate Storage Tank 10/17/2008

3 Document Title Revision / Date

10. CARD 12-28843 More Insulation Blown from Top of CST 12/17/2012

11. Drawing 6C721K-1 Fuel Oil Storage Tank Foundation and Dike Revision C

12. Drawing Condensate Storage Tank Foundation Unit #2 Revision D 6C721Y-2002 Functional System Description for Condensate Storage

13. P11-00-SD Revision 2 and Transfer System 600,000 Gal. Condensate Storage Tank P1100A005 Low

14. Drawing 5M721-5938 Revision 0 Cone Roof and Bottom Plate Layout 600,000 Gal. Condensate Storage Tank P1100A005 Low

15. Drawing 5M721-5922 Revision A Cone Roof and Shell Layout During the audit of program elements one through six, the staff verified that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the preventive actions program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing a request for additional information (RAI) for the subject discussed below.

• The preventive actions program element of the LRA AMP states that [i]n accordance with installation and design specifications, the tanks do not employ caulking or sealant at the concrete/tank interface. The GALL Report AMP recommends that sealant or caulking be applied to outdoor tanks at the external interface between the tank and concrete foundation. The function of the sealant or caulk is to minimize the amount of water and moisture penetrating the interface between the tank and concrete foundation.

The GALL Report AMP further states that sealant or caulking are not necessary if the configuration of both the tank bottom and foundation is sloped in such a way that water cannot accumulate.

It is not clear to the staff that these statements are consistent for the CST. The design of the CST foundation is a concrete ring with the tank bottom in contact with graded sand. The design also incorporates drains to facilitate the removal of water from the interior of the concrete ring foundation. However, the top surface of the concrete ring is not sloped to prevent water and moisture intrusion at the outside interface of the ring foundation. The accumulation of water or moisture at the outside interface of the ring foundation could result in the loss of material or cracking of the aluminum.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

• During the review of the past 10-years of applicable operating experience it was noted that there have been multiple instances of degradation of the insulation and jacketing on the roof of the CST, including separations in the sheet metal seams, loss of flashing, and loss of insulation due to weather. In 2013 the CST roof insulation was completely

4 removed and pre-fabricated insulation was installed. The as-found condition of the aluminum roof was not documented in the work order. The aluminum roof has been exposed to weather on multiple occasions and it is unclear if there is any age-related degradation under the pre-fabricated insulation.

The staff also audited the description of the LRA AMP provided in the updated final safety analysis report (UFSAR) supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI for the subject discussed below.

• The UFSAR supplement contains a commitment (Commitment No. 3) to implement the Aboveground Metallic Tanks Program. The implementation schedule for this commitment is [p]rior to September 20, 2024, or the end of the last refueling outage prior to March 20, 2025. LR-ISG-2012-02, Table 3.0-1, recommends that the program be implemented 10 years prior to the period of extended operation. The recommendation to implement the program 10 years prior to the period of extended operation is to support the inspection guidance provided in LR-ISG-2012-02, Table 4a, Tank Inspection Recommendations. The guidance provided in Table 4a includes inspections of all tank interior and exterior surfaces, including tank tops and bottoms, in timeframes ranging from within 5 to 10 years prior to the period of extended operation.

Audit Results. Based on this audit, the staff verified that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M29. The staff also identified certain aspects of the preventive actions program element of the LRA AMP for which additional information or evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. The staff also found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP.

In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR supplement.

LRA AMP B.1.2, Bolting Integrity Summary of Information in the Application. The LRA states that AMP B.1.2, Bolting Integrity, is an existing program with enhancements and an exception that is consistent with the program elements in GALL Report AMP XI.M18, Bolting Integrity. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. The exception to the GALL Report AMP not necessary for consistency with the GALL Report is evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the turbine building, reactor building, and the residual heat removal (RHR) complex. The staff also

5 conducted an independent search of the applicants operating experience database using the keywords: bolt, torque, preload, crack, leak, corrosion, and seal cap.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. Corrective Action RHR Reservoir RF14 Work Order Documentation Issues 02/22/2014 No. 14-21539

2. Corrective Action RBCCW SCS Plate HX inlet/outlet flange & bolting 04/19/2010 No. 10-23235 corrosion wastage

3. WO 32962709 Routine Div. 2 1.5 Year Lubrication Activities 12/05/2012

4. WO 30691577 Routine Div. 2 1.5 Year Lubrication Activities 06/03/2011

5. FERMI-RPT-12-LRD03 Fermi 2 License Renewal Project, Aging Management Revision 2 Program Evaluation Report Non-Class 1 Mechanical, Bolting Integrity

6. FERMI-RPT-12-LRD09 Fermi 2 License Renewal Project Operating Experience Revision 1 Review Report-Aging Management Program Effectiveness

7. 43.000.005 Plant Technical Procedure-Fermi 2 Visual Examination of Revision 35 Piping and Components (VT-2)

8. 35.000.240 Plant Technical Procedure-Fermi 2 Maintenance Revision 41 Procedure-Bolting and Torquing

9. MCE02 Fermi 2 Chemistry and Environmental Monitoring Conduct Revision 16 Manual Chemical Controls

10. Design Specification The Detroit Edition Company Specification for Approved Revision B Number 3071-377 Threaded Fasteners

11. MES25 Engineering Support Conduct Manual, Visual Examination Revision 7

12. 43.000.014 Visual Examination (VT-1) of ASME Class 1 Pressure Retaining Bolting

13. FBP-70001 System Walkdown Checklist Revision 0

14. ISI-NDE Program Inservice Inspection Nondestructive Examination (ISI-NDE) Revision 7 Program (Plan) for Fermi 2 Power Plant

15. MES49 Evaluation and Control of Leakage from Class 1, 2, and 3 Revision 7 piping systems

16. PEP06 Section XI Inservice Inspection Program Revision 1

6 Document Title Revision / Date

17. MES30 Repair and Replacement Programs Revision 9

18. MQA11 Condition Assessment Resolution Document Revision 35

19. CARD 03-14451 Corroded Bolts on RHRSW Pump A Column Flanges 01/01/2003

20. WO 000Z031277 Corroded Bolts on RHRSW Pump A Column Flanges 04/06/2003

21. CARD 03-16370 Adverse Trend: Second Valve Found with Loose Seal 01/01/2003 Bonnet Bolting During RF09 ISI NDE Inspections

22. CARD 03-16366 Valve Bonnet Pressure Seal Plate Bolting Loose 5/7/2003

23. CARD 10-30499 Damaged Bolting on Drywell Dome 04/05/2011

24. WO 34488149 Check torque and lockwire EDG [emergency diesel 10/11/2012 generator] 11 Vertical Drive Bolts The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of the detection of aging effects program element of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

During the audit, the staff verified that the preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff noted that aspects of the detection of aging effects program element not associated with the exception are not consistent with the corresponding program element in the GALL Report AMP.

The staffs evaluation of aspects of the detection of aging effects program element associated with the exception will be addressed in the SER. In addition, the staff found that for the scope of program program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

• LRA Section B.1.2 states that the Bolting Integrity Program manages loss of preload, cracking, and loss of material for accessible closure bolting for safety-related and nonsafety-related pressure components. GALL Report AMP XI.M18 scope of program program element states that the program manages aging of closure bolting for pressure retaining components within the scope of license renewal, including both safety-related and non-safety-related bolting. The GALL Report AMP also recommends periodic inspections of closure bolting be performed at least once per refueling cycle for signs of leakage to ensure the detection of age-related degradation due to loss of material and loss of preload. It is not clear to the staff whether all pressure-retaining closure bolting (both accessible and inaccessible) within the scope of license renewal is managed for age-related degradation. In addition, if inaccessible bolting is managed differently, the

7 staff is not clear as to the applicants criteria for considering bolting inaccessible. The staff needs this information to determine whether the effects of aging will be managed consistent with the recommendations in the GALL Report AMP.

• LRA Section B.1.2 states an enhancement to the Bolting Integrity Program to revise the procedures to inspect the residual heat removal service water (RHRSW), emergency equipment service water (EESW), and emergency diesel generator service water system pump and valve bolting submerged in the RHRSW reservoir at least once per refueling outage. GALL Report AMP XI.M18 detection of aging effects program element 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. The staff reviewed the program basis documents and was not clear how the submerged closure bolting will be inspected such that loss of material and loss of preload can be detected prior to loss of intended function consistent with the GALL Report AMP detection of aging effects program element.

During the audit the staff performed a database search of Fermi 2 operating experience and found no results for the keyword seal cap associated to their installation for closure bolting at Fermi 2.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience. The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

• The LRA states that [p]lant procedures prohibit the use of lubricants containing molybdenum disulfide. The GALL Report AMP states that molybdenum disulfide should not be used as a lubricant due to its potential contribution to stress corrosion cracking (SCC), especially for high-strength bolts. During the audit the staff was able to confirm that plant procedures prohibit the use of molybdenum disulfide lubricants; however, it is not clear whether molybdenum disulfide lubricants have been used at Fermi 2 before plant procedures were revised to prohibit their use. If these lubricants have been used in the past, the staff needs additional information regarding how the program will manage aging of closure bolts lubricated with molybdenum disulfide.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M18. The staffs evaluation of aspects of the detection of aging effects program element associated with exceptions will be addressed in the SER. The staff also identified certain aspects of the scope of program and detection of aging effects program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

8 Based on this audit, the staff also found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.3, Boraflex Monitoring Summary of Information in the Application. The LRA states that AMP B.1.3, Boraflex Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M22, Boraflex Monitoring. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: Boraflex, neutron-absorber, and coupon.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. 57.000.19 Spent Fuel Storage Rack Management Guidelines Revision 5 High Density Spent Fuel Storage Rack Surveillance

2. 82.000.16 Revision 34 Coupon Removal/Installation

3. MQA13 Trending Revision 10

4. MQA11 Condition Assessment Resolution Document Revision 37

5. NRC-96-0129 Detroit Edison Response to NRC Generic Letter 96-04 Inspection and Testing of Boraflex Surveillance Coupons

6. NET-300023-01 from the Fermi 2 Generating Station Notice 87-043: Gaps in Neutron-Absorbing Material in

7. DER 90-0491 High-Density Spent Fuel Storage Racks

8. FERMI-RPT-12-LRD03 Boraflex Monitoring Revision 2 Boraflex Test Coupon From High Density Fuel Storage

9. CARD 99-10401 Racks Exceeds Shrinkage Criteria of Procedure 82.000.16 Emerging Trend Observed in Spent Fuel Pool (SFP) Silica

10. CARD 09-27451 Level Document Applicability of NRC Information Notice

11. CARD 11-22582 2011-03, Nonconservative Criticality Safety Analyses for Fuel Storage

12. CARD 12-27120 NRC Information Notice 2012-13 Boraflex Degradation

9 Document Title Revision / Date Surveillance

13. NET-300010-01 BADGER Test Campaign at Enrico Fermi Power Plant 2 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subject discussed below.

• The applicant stated that three Boraflex panels were taken out of service due to the fact that their boron-10 areal density measurement test results did not meet the acceptance criteria. The measurement test results are provided in the 2013 Fermi 2 BADGER report, which summarizes the Boraflex test campaign conducted in 2013. The report provides information on the condition of the Boraflex material in the spent fuel pool. The staff reviewed the 2013 BADGER test report briefly during the audit; however, more information is needed to complete the review. The staff requests that the applicant provide this report to the NRC so a more detailed review can be performed.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M22.

Based on this audit, the staff also found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.4, Buried and Underground Piping Summary of Information in the Application. The LRA states that AMP B.1.4, Buried and Underground Piping, is a new program that will be consistent with the program elements in GALL Report AMP XI.M41, Buried and Underground Piping and Tanks, as modified by LR-ISG-2011-03, Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program XI.M41, Buried and Underground Piping and Tanks. To verify

10 this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the scope of the program, buried and underground inspection results, cathodic protection acceptance criteria, risk ranking of inspection locations, plant-specific operating experience, and the UFSAR supplement. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted a walkdown of the condensate storage tank dog house pit entranceway in order to view the associated underground piping. The staff also conducted an independent search of the applicants operating experience database using the keywords: buried, coat, degrad, dug, excavat, holiday, leak, through-wall, and vault.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. FERMI-RPT-12-LRD03 Aging Management Program Evaluation Report Revision 2 Non-Class Mechanical Buried and Underground Piping

2. 1000128.405 Life Cycle Management and Buried Piping Evaluation Revision 1 Report for Fermi-2 Nuclear Generating Station

3. 6M721-4232 Yard Piping - Material Specifications, Codes, General Revision H Notes RHR Complex

4. Cathodic Protection Program Health Report Fermi-2 4th Qtr. 2013

5. 05000341/2013004 Fermi Power Plant, Unit 2, NRC Integrated Inspection 10/22/2103 Report

6. Buried Pipe Inspections Program Health Report 4th Qtr. 2013 Fermi-2

7. 1000128.401 Soil Analysis Results for Enrico Fermi 2 Nuclear Revision 2 Generating Station

8. 1000128.403 APEC Survey Fermi 2 Nuclear Generating Station - Revision 0 August 2011

9. 1101381.401 Direct Examinations at Enrico Fermi Power Plant 2 - Revision 0 July through September 2012

10.12-042 As-Found Buried Piping Visual Inspection Report - 6 09/10/2012 General Service Water

11. MES71 Buried Pipe Inspection Program Revision 3

12. 1201079.401 Direct Examinations at Enrico Fermi Power Plant 2 - Revision B June through July 2013

13. TMIS-11-0130 Year 2011 Annual Cathodic Protection System 11/18/2011 Evaluation Report for Fermi 2

11 Document Title Revision / Date

14. Year 2012 Annual Cathodic Protection System 08/23/2012 Evaluation Report for Fermi 2

15. Year 2013 Annual Cathodic Protection System 08/23/2013 Evaluation Report for Fermi 2

16. 1000128.402 Enrico Fermi Nuclear Generating Station Inspection Revision 3

[Below-grade Piping] Plan

17. 1000128.404 Fermi 2 Nuclear Generating Station Buried Piping Risk Revision 0 Analysis Final Report

18. 4P-644 Piping Standard Details for Water Tight Sleeves Revision D Through Walls

19. CARD 09-00627 12 Underground Piping [removed fire water system 06/29/2009 piping] for ISI

20. WO 31084561 & WO Work Order - Inspect all Piping, Valves, and Flanges 09/25/2012, 33383621 Inside CST [Condensate Storage Tank] Valve Pit - 05/09/2014 Results

21. PEP31 Performance Engineering Cathodic Protection Manual Revision 0

22. CARD 12-26291 Protected Coating on 6-inch GSW Pipe Found 07/26/14 Degraded

23. 6M721-3479 Isometric Yard 12 Condensate Return to Storage Revision B Tank Unit 2

24. 6M721-3480 Isometric Yard 14 Condensate Supply from Storage Revision C Tanks

25. 6M721-3481 Isometric Yard 8 Condensate Return to Storage Tank Revision D Unit 2

26. 6M721-2852-1 Piping Isometric 16 HPCI RCIC Pump Suction in Yard Revision G from Condensate Storage Tank

27. 6M721-3228-1 Piping Isometric Condensate Return to Storage Tanks Revision Q from Reactor & Radwaste Bldg Cond Systems

28. 6M721-3499 Isometric Yard 18 CRD [control rod drive] & CSS Revision B Suction from Storage Tank Unit 2

29. 6M721-3230-1 Piping Isometric Condensate from Storage Tank to Revision K System Pumps

30. 6M721-3126-1 Piping Isometric Condensate Normal Emergency Revision M Relief Control Station to Condensate Storage Tanks Turbine Building Unit 2

31. 6M721-3226-1 Piping Isometric Condensate from Storage Tanks to Revision M HPCI RCIC and CSS Pumps Unit 2

32. 6M721Y-2001 Valve Pit and Piping Condensate Return in Yard Revision T During the audit of program elements one through six, the staff verified that the scope of program, parameters monitored or inspected, preventive actions, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of

12 GALL Report AMP XI.M41, as modified by LR-ISG-2011-03. For the detection of aging effects and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of GALL Report AMP XI.M41, as modified by LR-ISG-2011-03. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of GALL Report AMP XI.M41, as modified by LR-ISG-2011-03, the staff will consider issuing RAIs for the subjects discussed below.

• The detection of aging effects program element of the LRA AMP states that buried piping inspections will be conducted in a manner consistent with those in the detection of aging effects element of GALL Report AMP XI.M41, as modified by LR-ISG-2011-03.

During the staffs review of buried pipe inspection reports, it was noted that the coatings for 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. 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 F (category E has a lower number of inspections relative to 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.

• The acceptance criteria program element of the LRA AMP 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 millivolt (mV) polarization criterion is used to assess the performance of the cathodic protection system, the LRA should include the basis for why adequate protection is provided for steel components exposed to a mixed potential environment.

The applicants acceptance criteria for the cathodic protection system includes negative 0.85 volts and 100 mV of cathodic polarization. The applicants acceptance criteria also includes an allowance for polarization potentials less negative than 0.85 volts 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 acceptance criterion of the cathodic protection system.

During the audit, the staff made the following observations:

• The staff reviewed drawing 4P-644 and confirmed that buried piping penetrates plant building walls through a steel sleeve and is therefore not in contact with concrete.

• The staff reviewed program manual PEP31 and confirmed that the acceptance criteria for cathodic protection includes: (a) at least negative 0.85 volts, (b) a minimum of 100 mV of cathodic polarization, and (c) a polarization potential of less negative than 0.85 volts if the component is buried in high resistivity soil (greater than 10,000 ohm-cm) that is well drained and well aerated.

• The staff reviewed the buried piping drawings listed above, documents 23 through 32, and confirmed that there are no bolted flanged connections in the buried steam and power conversion systems.

13 During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in LR-ISG-2011-03 Table 3.0-1.

Audit Results. Based on this audit, the staff verified that the scope of program, parameters monitored or inspected, preventive actions, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M41, as modified by LR-ISG-2011-03. The staff also identified certain aspects of the detection of aging effects and acceptance criteria program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in LR-ISG-2011-03 Table 3.0-1.

LRA AMP B.1.5, BWR CRD Return Line Nozzle Summary of Information in the Application. The LRA states that AMP B.1.5, BWR CRD Return Line Nozzle, is an existing program that is consistent with the program elements in GALL Report AMP XI.M6, BWR Control Rod Drive Return Line Nozzle. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: return line nozzle, fatigue, and crack.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Class 1

1. FERMI-RPT-12-LRD02 Revision 1 Mechanical Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Revision 1 Management Program Effectiveness Inservice Inspection-Nondestructive Examination Revision 7

3. ISI-NDE Program (ISI-NDE) Program (Plan) for Fermi 2 Power Plant 10/28/2010

14 Document Title Revision / Date Engineering Support Conduct Manual, Inservice Revision 18

4. MES23 Inspection and Testing 12/21/2012 Revision 2

5. PEP06 Section XI Inservice Inspection Program 1/15/2013

6. Surveillance Procedure Revision 28 Performance of ISI-NDE Inspections 43.000.016 10/26/2010

7. Surveillance Procedure Revision 24 Reactor Pressure Vessel - Invessel Internals Inspection 43.000.017 5/8/2013 Inservice Inspection Detail Dwg. Reactor Vessel Shell & Revision A

8. Drawing 6M721-5361-5 Top Head Nozzles 6/21/1990

9. General Electric Stress Stress and Fatigue Analysis for the Cap and the Revision 0 Report 22A5506 CRDHSR Nozzle 3/24/1977 Submittal of NRC Requested Additional Information on

10. Letter NRC-89-0106 5/12/1989 Generic Letter 88-01

11. Letter NRC-03-0061 Inservice Inspection Summary Report 8/8/2003

12. Summary Component Summary for N-9 CRD Ref. Nozzle-to-Vessel 4/13/2012 No. FNP2-B3.90-0013 Weld

13. Summary Component Summary for CRD Return Nozzle-to-Safe 4/22/2012 No. FNP2-R1.16-0071 End Butt Weld (DM)

RVIM Self-Assessment Critical Attribute #6 Identified Program Implementation Deficiency. Inspections

14. CARD 13-20060 1/2/2013 Performed on N9 Nozzle in RF15 Did Not Meet ASME or BWRVIP Guidelines Established in BWRVIP-03

15. UFSAR Control Rod Drive Hydraulic System Revision 18 Section 4.5.2.2.2.3 BWR Feedwater Nozzle and Control Rod Drive Return

16. NUREG-0619 November 1980 Line Nozzle Cracking During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit, the staff made the following observation:

• Per UFSAR Section 4.5.2.2.2.3, the applicant has eliminated the control rod drive return line as a preventive measure to avoid cracking. With this design change and the other system modifications described in UFSAR Section 4.5.2.2.2.3, there are no ongoing maintenance or testing activities from NUREG-0619 that would apply to Fermi 2.

Therefore, under the applicants Boiling-Water Reactor (BWR) Control Rod Drive Return Line Nozzle Program, the only activities for detecting the effects of cracking are the periodic examinations that are implemented in accordance with American Society of Mechanical Engineers (ASME) Code,Section XI, Table IWB-2500-1.

15 During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M6.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.6, BWR Feedwater Nozzle Summary of Information in the Application. The LRA states that AMP B.1.6, BWR Feedwater Nozzle, is an existing program that is consistent with the program elements in GALL Report AMP XI.M5, BWR Feedwater Nozzle. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: feedwater nozzle, crack, and fatigue.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Class 1

1. FERMI-RPT-12-LRD02 Revision 1 Mechanical Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Revision 1 Management Program Effectiveness Inservice Inspection-Nondestructive Examination Revision 7

3. ISI-NDE Program (ISI-NDE) Program (Plan) for Fermi 2 Power Plant 10/28/2010 Engineering Support Conduct Manual, Nondestructive Revision 8

4. MES24 Examination 8/26/2010 Revision 2

5. PEP06 Section XI Inservice Inspection Program 1/15/2013

16 Document Title Revision / Date

6. Surveillance Procedure Revision 28 Performance of ISI-NDE Inspections 43.000.016 10/26/2010

7. Deviation Event Report Unusual Surface Conditions Identified on RPV Cladding 5/19/1994 No. 94-0204 and Nozzles NQA Audit Recommendation - ISI Program Owner to

8. CARD 12-22846 Follow Up on the Inspection Frequency of Feedwater 4/6/2012 Nozzles

9. CARD 12-23820 Feedwater Nozzle and Sparger Condition Monitoring 4/26/2012 Enhancement to MES29 - Documentation and Reporting

10. CARD 12-24128 of Operating Transients and Cycles to Support License 5/3/2012 Renewal Reactor Coolant Pressure Boundary Component

11. CARD 13-24539 5/25/2013 Thermal-Pressure Cycles

12. Design NUREG 0619 RPV Feedwater Nozzle Crack Growth Revision 0 Calculation 5922 Reevaluation, Volume 1 11/26/1997 ASME Section XI Appendix L Operating Plant Fatigue

13. Design Revision 0 Assessment - RCPB Components, Volume 1, Book 2, Calculation 6222 4/2/2006 Miscellaneous Class 1 Components Updated NUREG-0619 Feedwater Nozzle Fatigue Crack Revision 0

14. GE-NE-523-22-0292 Growth Analysis July 1992 Manual Ultrasonic Examination of BWR Reactor Vessel

15. Contractor Procedure Revision 7 Nozzle Inner Radius Regions and Nozzle to Shell Welds 54-ISI-850 10/6/2010 (Inner 15%)

Procedure for the Examination of Reactor Pressure

16. Contractor Procedure Vessel Nozzle Inner Radius and Nozzle to Vessel Welds Revision 1 GE-UT-705 with the GERIS 2000 OD in Accordance with Appendix 9/14/2004 VIII Automated Ultrasonic Procedure for Examination of

17. Contractor Procedure Revision 1 Feedwater Nozzle Inner Radius Areas at Fermi Using the GFRM2-ISI-246 9/20/2001 Intraspect Imaging System Fermi Unit 2 Reactor Pressure Vessel (RPV) Feedwater

18. IR-2010-431 October 2010 Nozzle Examinations

19. Wesdyne International Fermi 2 ISI NDE Examination Summary Sheet RF-08 11/18/2001 Report R8-65

20. Wesdyne International Fermi 2 ISI NDE Examination Summary Sheet RF-08 11/19/2001 Report R8-69

21. Wesdyne International Fermi 2 ISI NDE Examination Summary Sheet RF-08 11/19/2001 Report R8-70

22. Wesdyne International Fermi 2 ISI NDE Examination Summary Sheet RF-08 11/19/2001 Report R8-75

23. Wesdyne International Fermi 2 ISI NDE Examination Summary Sheet RF-08 11/18/2001 Report R8-78

17 Document Title Revision / Date

24. Wesdyne International Fermi 2 ISI NDE Examination Summary Sheet RF-08 11/17/2001 Report R8-86

25. Wesdyne International Fermi 2 ISI NDE Examination Summary Sheet RF-08 11/17/2001 Report R8-87

26. Wesdyne International Fermi 2 ISI NDE Examination Summary Sheet RF-08 11/17/2001 Report R8-88 GE Nuclear Energy UT [ultrasonic testing] Examination

27. Summary No. 09-12 4/14/2003 Summary Sheet

28. AREVA Report RPV Nozzle Ultrasonic Examination Summary Sheet 10/30/2007 No. RFO12-14

29. AREVA Report RPV Nozzle Ultrasonic Examination Summary Sheet 10/30/2007 No. RFO12-15

30. AREVA Report Ultrasonic Examination Summary Sheet 10/28/2007 No. RFO12-21

31. AREVA Report Ultrasonic Examination Summary Sheet 10/29/2007 No. RFO12-22

32. AREVA Report Ultrasonic Examination Summary Sheet 10/27/2007 No. RFO12-28

33. AREVA Report Ultrasonic Examination Summary Sheet 10/27/2007 No. RFO12-29

34. Summary Component Summary for F.W. Nozzle-to-Vessel Weld 11/19/2010 No. FNP2-B3.90-0017

35. Summary Component Summary for N21-2336-Feedwater Loop A 11/17/2010 No. FNP2-R1.11-0001 Circ Weld

36. Summary Component Summary for N21-2336-Feedwater Loop A 11/17/2010 No. FNP2-R1.11-0015 Circ Weld

37. Summary Component Summary for F.W. Nozzle-to-Vessel Weld 11/19/2010 No. FNP2-B3.90-0018

38. Summary Component Summary for Nozzle Inner Bore Region 11/19/2010 No. FNP2-N/A-0002

39. Summary No.

Component Summary for Nozzle Inside Radius Section 11/19/2010 FNP2-B3.100-0017

40. Summary No.

Component Summary for Nozzle Inside Radius Section 11/19/2010 FNP2-B3.100-0018

41. Summary Component Summary for N21-2336-Feedwater Loop B 4/10/2012 No. FNP2-R1.11-0005 Circ Weld (CS)

42. Summary Component Summary for N21-2336-Feedwater Loop B 4/10/2012 No. FNP2-R1.11-0019 Circ Weld (CS)

43. Summary No. Component Summary for N4E Nozzle Inside Radius 4/12/2012 FNP2-B3.100-0021 Section

18 Document Title Revision / Date

44. Summary No. Component Summary for N4F Nozzle Inside Radius 4/17/2012 FNP2-B3.100-0022 Section

45. Summary Component Summary for N4F Nozzle Inner Bore Region 4/17/2012 No. FNP2-N/A-006

46. Summary Component Summary for (N4E) F.W. Nozzle-to-Vessel 4/13/2012 No. FNP2-B3.90-0021 Weld

47. Summary Component Summary for (N4E) F.W. Nozzle-to-Vessel 4/13/2012 No. FNP2-B3.90-0021 Weld

48. Summary Component Summary for (N4F) F.W. Nozzle-to-Vessel 4/13/2012 No. FNP2-B3.90-0022 Weld During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M5.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.7, BWR Penetrations Summary of Information in the Application. The LRA states that AMP B.1.7, BWR Penetrations, is an existing program that is consistent with the program elements in GALL Report AMP XI.M8, BWR Penetrations. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: crack, penetration, nozzle, stub, stress corrosion, CRD, RPV, and SCC.

19 The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Class 1

1. FERMI-RPT-12-LRD02 Revision 1 Mechanical - BWR Penetrations Operating Experience Review Results - Aging

2. FERMI-RPT-12-LRD09 Management Program Effectiveness, Section 3.1.3, Revision 1 BWR Penetrations Program Performance Engineering Program Manual, In Core

3. PEP16 Guide Tube and Dry Tube, Core Plate DP and SLC Revision 7 Lines, and Instrument Penetrations.

4. PEP06 Section XI Inservice Inspection Program Revision 2 Indication Noted in Control Rod Drive Guide Tube 06-35

5. CARD 10-30178 (Weld CRGT-2) Manufacturing Discontinuity Identified on 11/5/2010 CRGT-2 Weld in Cell 06-35 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or the staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M8.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.8, BWR Stress Corrosion Cracking Summary of Information in the Application. The LRA states that AMP B.1.8, BWR Stress Corrosion Cracking, is an existing program that is consistent with the program elements in GALL Report AMP XI.M7, BWR Stress Corrosion Cracking. To verify this claim of

20 consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: IGSCC, weld, stress corrosion, and safe end.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Class 1

1. FERMI-RPT-12-LRD02 Revision 1 Mechanical, Section 4.4 BWR Stress Corrosion Cracking Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Revision 1 Management Program Effectiveness Revision 2

3. PEP06 Section XI Inservice Inspection Program 01/15/2013 Inservice Inspection-Nondestructive Examination Revision 7

4. ISI-NDE Program (ISI-NDE) Program (Plan) for Fermi 2 Power Plant 10/13/2010 Fermi 2 Engineering Support Conduct Manual MES24, Revision 8

5. MES24 Nondestructive Examination 08/26/2010 Fermi 2 Engineering Support Conduct Manual MES23, Revision 18

6. MES23 Inservice Inspection and Testing 12/21/2012 Fermi 2 Engineering Support Conduct Manual MES30, Revision 10

7. MES30 Repair and Replacement Programs 12/20/2012

8. NRC-03-0061 Inservice Inspection Summary Report 08/08/2003 Fermi 2 Response to Generic Letter 88-01, Supplement 1, NRC Position on Intergranular Stress Corrosion

9. NRC-92-0090 07/29/1992 Cracking (IGSCC) in BWR Austenitic Stainless Steel Piping NRC Letter to Detroit Edison Company, Fermi-2 Removal of 24 Condensate and Feedwater System

10. 12/18/1992 Welds from the Inservice Inspection Nondestructive Examination (ISI-NDE) Program (TAC No. M84177)

Institute of Nuclear Power Operations Event Report

11. CARD 13-23127 (IER) 13-17 Level 4 Main Condenser Cooling Water 05/03/2013 Leakage

12. CARD 11-21607 Condenser Leak SW Hotwell Quad 2/10-11/2011 02/11/2011

13. CARD 08-26361 Indications of a Small Condenser Tube Leak 09/26/2008 ISI Ultrasonic Exam Adversely Affected by Component

14. CARD 07-26347 10/18/2007 Surface Profile

21 Document Title Revision / Date Ultrasonic Examination (Refueling Outage RF16; Component ID FW-RD-2-B19; Recirculation system safe

15. VE-S14-003 3/8/2014 end extension to safe end weld; and Work Order 34704484)

Ultrasonic Examination (Refueling Outage RF16;

16. VE-S14-001 Component ID 101-304E; Recirculation system nozzle to 3/7/2014 safe end weld; and Work Order 34704433)

During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

• The LRA states that the BWR Stress Corrosion Cracking Program is consistent with GALL Report AMP XI.M7, with no exceptions. The detection of aging effects program element of the GALL Report AMP states that the extent and schedule of the inspection are described in NRC Generic Letter (GL) 88-01 and may be modified in accordance with Boiling-Water Reactor Vessel and Internals Project (BWRVIP)-75-A. The staff noted that the applicants Category A welds are subsumed in the applicants risk-informed inservice inspection. The staff also noted that the percentage of Category A welds to be inspected by the applicant is not stated in the LRA. It is unclear to the staff if the extent and schedule of the inspection are consistent with GL 88-01 and BWRVIP-75-A.

• The aging management review tables for the condensate and feedwater systems in the LRA do not include AMR items to manage IGSCC for Category D welds, which were identified in the 1992 communications between the Detroit Edison Company and the NRC (letters dated July 29, 1992, and December 18, 1992, referenced in the document table above). The staff cannot determine the adequacy of the applicants program and AMR results without additional information to justify the omission of relevant AMR items.

• The staff also noted that the 1992 communications (letters dated July 29, 1992, and December 18, 1992, referenced in the document table above) indicate that the applicants Category D welds are located outboard of the containment isolation valves and at least 10 percent of these welds should be inspected during each refueling outage. The staff further noted that the extent and frequency of these inspections are different from the inspection guidelines provided in GL 88-01 and BWRVIP-75-A.

BWRVIP-75-A states that in the case of the implementation of hydrogen water chemistry 100 percent of Category D welds should be inspected every 10 years and at least 50 percent of these welds should be inspected in the first 6 years. However, the LRA does not identify this difference as a program exception. The staff finds that additional information is necessary to clarify why this difference is not identified as a program exception and to confirm whether this difference is acceptable for adequate aging management.

22 During the audit of the operating experience program element, the staff found a need to confirm whether the plant-specific operating experience regarding condenser inleakage affects the sufficiency of the LRA program. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subject discussed below.

• The staff noted that CARD 11-21607 states that during the startup on February 10, 2011, the applicants plant was shut down due to main condenser tube inleakage and associated water chemistry excursions. CARD 11-21607 also indicates that inspections of all condenser water boxes identified the ejection of tube plugs from receptive condenser tubes. The ingress of chloride, sulfate, and other contaminants into the reactor coolant system, due to main condenser inleakage, can promote IGSCC in BWR piping and piping welds. However, LRA Section B.1.8 and the onsite program evaluation report for the applicants program do not clearly address the potential impact of condenser cooling water inleakage on the effectiveness of the applicants program.

The staff finds that additional information is necessary to confirm that the applicants assessment of operating experience regarding condenser inleakage ensures the effectiveness of the applicants program.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M7. The staff also identified certain aspects of the detection of aging effects program element of the LRA AMP for which additional information or evaluation is required before consistency can be determined.

Based on this audit, the staff also finds that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.9, BWR Vessel ID Attachment Welds Summary of Information in the Application. The LRA states that AMP B.1.9, BWR Vessel ID Attachment Welds, is an existing program that is consistent with the program elements in GALL Report AMP XI.M4, BWR Vessel ID Attachment Welds. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: cracking, wear, hold down, core spray, attachment welds, steam dryer, and jet pump.

23 The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Class 1

1. FERMI-RPT-12-LRD02 Revision 1 Mechanical - BWR Vessel ID Attachment Welds Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Management Program Effectiveness Section 3.1.7 BWR Revision 1 Vessel ID Attachment Welds Program Performance Engineering Program Manual, Reactor

3. PEP16 Revision 7 Vessel Internals Management Program Vessel ID Attachment Weld Inspection and Flaw

4. BWRVIP-48-A 06/2004 Evaluation Guidelines Inservice Inspection Non-Destructive Examination

5. ISI-NDE Program Revision 7 Program Plan for Fermi 2 Condition Assessment Resolution Document,

6. CARD 05-24653 Misunderstanding of New Inspection Criteria in BWRVIP - 08/09/2005 48 Guideline Condition Assessment Resolution Document, Inspection

7. CARD 06-22432 Scheduled for New Inspection Criteria in BWRVIP - 48 04/07/2006 Guideline INPO [Institute of Nuclear Power Opeations]

8. CARD 05-25333 Recommendations Resulting from the BWR Vessel and 09/07/2005 Internals Review Visit During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff noted inconsistencies in the operating experience provided in the LRA AMP. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

• The operating experience section of the LRA discusses plant-specific inspection results from 2001, 2005, and 2012. It specifically states that, In 2005, shroud support weld examinations as well as other inspections of reactor vessel internal welds and components were performed as scheduled by the Reactor Vessel Internals Management (RVIM) program. However, the staff discovered during the onsite audit that there was no such inspection in 2005.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

24 Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M4.

Based on this audit, the staff also found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.10, BWR Vessel Internals Summary of Information in the Application. The LRA states that AMP B.1.10, BWR Vessel Internals, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M9, BWR Vessel Internals. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: shroud, jet pump, stress corrosion cracking, embrittlement, cast, steel, bolt, nickel alloy, and top guide.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report: BWR

1. Fermi-RPT-12-LRD02 Revision 1 Vessel Internal Fermi 2 Engineering Support Conduct Manual, Chapter Revision 8

2. MES47 47 - Reactor Vessel Internals Management (RVIM) 11/07/2012 Program Performance Engineering Program Manual: Fermi-2 Revision 7

3. PEP16 Reactor Vessel Internals Management (RVIM) Program 09/26/2012 Plan Variance from BWRVIP-25 Guidelines on Performing

4. DD-2011-01 03/30/2011 Recommended Inspections on Core Plate Bolting Aging Management Review of the Reactor Vessel

5. FERMI-RPT-12-AMM02 06/09/2014 Internals INPO BWRVIP Recommendation, BWRVIP Program

6. CARD 05-25333 09/20/2005 Improvements Observation From the Self-Assessment of the Reactor

7. CARD 08-26919 10/20/2008 Vessel Internals Management Program

25 Document Title Revision / Date

8. CARD 10-30726 Indications on 0 degree Access Hole Cover 11/16/2010 Jet Pump 7/8 Weld RS-1 Condition Monitoring

9. CARD 12-23540 04/20/2012 Inspection during RF-15 Wedge Wear identified on Jet Pump #2 during Invessel

10. CARD 06-22334 04/14/2006 Visual Inspections The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements. During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the scope of program program element, insufficient information was available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report, the staff will consider issuing an RAI for the subjects discussed below.

• The scope of program program element of the GALL Report AMP includes BWRVIP-58-A as guidelines for the repair design criteria for the control rod drive housing and BWRVIP-57-A as the guidelines for the repair design criteria for the lower plenum components. The applicant references these documents as the repair design criteria guidelines for these components as well as BWRVIP-55-A; however, the plant procedures only reference BWRVIP-55-A. The staff is unclear if the applicant is using any BWRVIP guidelines beyond those in the GALL Report AMP.

• The scope of program program element of the GALL Report AMP includes BWRVIP guidelines for which the BWR vessel internal components are subject and which may contain applicant action items. The applicant responded to these BWRVIP applicant action items in LRA Appendix C. The staff is unclear if LRA Appendix C includes the accurate list of BWRVIP guidelines actually used at Fermi 2 or if the responses to the applicant action items considered the recently approved measurement uncertainty recapture power uprate.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description to be consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M9. The staff also identified certain aspects of the scope of

26 program program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.11, Compressed Air Monitoring Summary of Information in the Application. The LRA states that AMP B.1.11, Compressed Air Monitoring, is an existing program with enhancements and an exception that is consistent with the program elements in GALL Report AMP XI.M24, Compressed Air Monitoring. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. The exception to the GALL Report AMP will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: dew point, instrument air, air quality, and compressed air.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date INSTRUMENT AIR SUPPLY SYSTEM PROBLEMS

1. Generic Letter 88-13 08/08/1988 AFFECTING SAFETY-RELATED EQUIPMENT

2. NRC-89-0046 DTE Response to NRC Generic Letter 88-18 03/01/1989

3. Health Report P5000 System Health Report P5000, Compressed Air Systems 2012

4. LRA License Renewal Application 2014

5. CHS-AUX-14 Station/Instrument Air Chemistry Specifications Revision 7 FERMI 2 LRD09 Program Owner Interview

6. Interview 03/27/2013 Documentation Industry Trend- EDG leaks/Failures Identified in INPO

7. CARD 07-21958 04/11/2007 OEs Aging Management Review of the Compressed Air

8. FERMI-RPT-12-AMM21 Revision 0 System

9. WO36214845 East IAS Dryer Outlet Dewpoint 05/27/2014

10. WO36207201 West IAS Dryer Outlet Dewpoint 05/27/2014

11. WO35749811 North IAS Dryer Outlet Dewpoint 08/11/2014

27 Document Title Revision / Date

12. WO36305840 South IAS Dryer Outlet Dewpoint 05/27/2014

13. NRC-94-0068 Revision to NRC Commitments 08/29/1994 Water in station air system causes radwaste tank

14. CARD 13-26509 09/15/2013 high-level alarms

15. CARD 09-24276 Condensation buildup in SA header 06/02/2009 Review Recent Communication on Vulnerability to

16. CARD 13-20327 01/13/2013 SOER 88-01, Instrumental Air System Failures Investigate use of reinforced rubber hose for actuator air

17. CARD 04-21812 04/26/2004 supply in Safety Related application

18. CARD 04-22824 Air leak on hose for EDG 11 ACS TCV Loop 06/24/2004 Div 2 Control Air Compressor Room Cooler Fan Wheel

19. CARD 10-22024 03/08/2010 has Minor Cracks Document Applicability for IN Significant Event Report 2-10, Multiple control Rods Fail to Meet Insertion Time

20. CARD 10-25093 06/18/2010 Limits Because of Sluggish Scram Solenoid Pilot Valves, to Fermi Central Station Air Compressor Alarming on Low Cooling

21. CARD 07-24482 08/14/2007 Water flow

22. CARD 04-20873 H21P429 has air leaks on instrumental tubing and fittings 03/03/2004 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of the monitoring and trending program element of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the monitoring and trending program element not associated with the exceptions are consistent with the corresponding program elements in the GALL Report AMP. The staffs evaluation of aspects of this program element associated with the exception will be addressed in the SER.

During the audit of the operating experience program element, the staffs independent database search for Fermi 2 found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program

28 elements in GALL Report AMP XI.M24. The staff also verified that for the monitoring and trending program element, the aspects of the LRA AMP program element not associated with the exception are consistent with the corresponding program element in GALL Report AMP XI.M24. The staffs evaluation of aspects of the program elements associated with exceptions will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.12, Containment Inservice Inspection - IWE Summary of Information in the Application. The LRA states that AMP B.1.12, Containment Inservice Inspection - IWE, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.S1, ASME Section XI, Subsection IWE.

To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. The LRA states that the Fermi 2 primary containment is a General Electric (GE)

Mark I steel pressure suppression containment consisting of a drywell, a torus (or suppression chamber), and a vent system connecting the drywell and the torus.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff reviewed structural drawings of the Fermi 2 primary containment and photographs in recent inspection reports of the torus interior since the plant was at power operation and a walkdown to observe the condition of the steel containment was not possible. The staff also conducted an independent search of the applicants operating experience database using the keywords: blister, containment, corros, shell, drywell, vent, header, downcomer, bellows, torus, suppression chamber, seal, moisture barrier, rust, pit, and loss of material.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Revision 1

1. FERMI-RPT-12-LRD05 Civil/Structural, Section 3.2 Containment Inservice Inspection 03/05/2014 (CII) - IWE Program Operating Experience Review Report - Aging Management Revision 1

2. FERMI-RPT-12-LRD09 Program Effectiveness, Section 3.1.10 Containment Inservice 03/25/2014 Inspection - IWE Program Fermi 2 Engineering Support Conduct Manual - ASME Revision 4

3. MES46 Section XI Containment Inservice Inspection Program 02/19/2010

29 Document Title Revision / Date Inservice Inspection - Nondestructive Examination (ISI-NDE) Revision 7

4. ISI-NDE-Program Program Plan for Fermi 2, Part F - ASME Section XI (Change 2)

Containment ISI Program 5/23/2013 Plant Technical Surveillance Procedure - Primary Containment Revision 5

5. 43.000.019 Inspection 9/10/2010 Fermi Response to GL 87-05, Potential Degradation of Mark I

6. NRC-87-005 06/15/1987 Drywells

7. NRC-88-0081 Revised Response to GL 87-05 04/20/1988

8. CARD 03-12847 Torus Room, Areas of Degraded Coating 30/10/2003 Review Fermi 2 Sand Cushion Investigation History including

9. CARD 09-23951 Evaluation of the Oyster Creek Degraded Drywell Shell as a 04/25/2011 Result of Water in the Drywell Sand Cushion Work Request - Remove Sand from Drywell Shell Drainage

10. 000Z940162 05/12/1994 Area Drywell EL. 583, 0 to 100° AZ Rusty 583 Main I Beam Fl.

11. CARD 00-14421 04/06/2000 Supports Torus Room, Degraded Torus Earthquake Tie Attached to Bay

12. CARD 10-29800 10/30/2010 9

13. CARD 11-30471 Document Applicability of NRC Information Notice 2011-15 11/23/2011 Remove Grating at Four Sand Cushion Drains to Perform

14. CARD 12-24714 05/25/2012 Inspections (WO-34542841)

Drywell, Accumulated Debris on Drywell Vent Jet Deflector

15. CARD 09-23023 04/20/2009 Gusset IWE Primary Containment Inspection Program - 2nd Quarter

16. 07/12/2013 2013 Program Health Report Plant Technical Procedure - Fermi 2 Surveillance Procedure Revision 77

17. 24.000.03 Mode 5 Shiftly, Daily, and Weekly Surveillances, Attachment 1 03/29/14 and 2 Torus Desludge, Inspection and Coating Repair - Immersion Revision 0

18. NUC201202 Area, Final Engineering Report for Fermi 2, Underwater 5/25/2012 Engineering Service Inc. (Proprietary)

Torus Inspection and Coating Repair, Vapor Phase Final Revision 0

19. NUC2014105 Assessment Report for Fermi 2, Underwater Engineering 03/12/2014 Service Inc. (Proprietary)

20. CARD 12-28374 (MMI Blistered Protective Coating on the Torus Wetted Region 10/10/2012 Item No. 110)

Ultrasonic Instrument Calibration Record and Exam Report for

21. WR 34542806 Thickness Measurements at Drywell Basement Az. 300-0-120 03/03/2014 Shell at Sand Cushion Region (CARD 12-24713)

22. 6C721-2971 IWE Containment Inspection Drywell Reference Drawing Rev A, 4/27/07 IWE Containment Inspection Suppression Chamber Reference

23. 6C721-2972 Rev 0, 9/13/01 Drawing

30 Document Title Revision / Date Outside Elevation View at 180 Az of Drywell and Suppression

24. 6C721-2701 Rev A, 5/19/00 Chamber Reactor Bldg and Aux Building Framing Section 40-40 Lower

25. 6C721-2358 Rev T, 10/30/09 (Sand Pocket Detail)

Floor and Equipment Drains Basement and First Floor Reactor

26. 6M721-2219 Rev Z, 10/23/12 Building (Sand pocket drain line detail)

Isometric of HPCI Turbine Exhaust Reactor Building (Sparger

27. 6M721-2219 Rev Z, 3/5/03 Detail E3)

The staff conducted its audit of LRA program elements one through seven based on the contents of the existing program as modified by the proposed enhancements. The staff notes that the scope of the audit covered the additional program element 7 corrective actions because the applicant included an enhancement for this element to establish consistency with the recommended actions in the corresponding element of the GALL Report AMP XI.S1 that is specific to the potential case if moisture is detected or suspected in the inaccessible area on the exterior of Mark I containment drywell shell.

During the audit, the staff verified that the scope of program, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

• The preventive actions program element of GALL Report AMP XI.S1 recommends preventive actions in accordance with Research Council for Structural Connections publication for structural bolting consisting of American Society for Testing and Materials (ASTM) A325, ASTM F1852, and ASTM A490 bolts. The staff noted that the corresponding element, with enhancements, of the LRA AMP basis document (FERMI-RPT-12-LRD05, Revision 1) addresses ASTM A325 and A490 bolting, but made no mention of ASTM F1852 bolting. It is not clear to the staff that the above mentioned program element of the LRA AMP is consistent with the recommendations in the GALL Report AMP because there was no mention of ASTM F1852 bolting. Note that this is a common issue across B.1.12 Containment Inservice Inspection - IWE, B.1.22 Inservice Inspection - IWF, and B.1.42 Structures Monitoring AMPs.

• The detection of aging effects program element of GALL Report AMP XI.S1 recommends that the program be augmented to require surface examination, in addition to visual examination, to detect cracking in stainless steel penetration sleeves, bellows, dissimilar metal welds, and steel components that are subject to cyclic loading but have no current licensing basis fatigue analysis. The GALL Report AMP also states that where feasible, appropriate Appendix J tests may be performed in lieu of surface examination. The LRA AMP program basis document states that the above mentioned components are monitored for cracking. It also states that, additionally, XI.S4 Containment Leak Rate Program tests may be performed in lieu of surface examination.

31 It is not clear to the staff that these statements are consistent because the LRA AMP basis document does not state that to detect cracking supplemental surface examination will be performed on the subject components, in addition to visual examination. Further, it does not identify the specific components for which the option to perform Appendix J tests, in lieu of surface examination, will be used and the type of Appendix J test that would be performed in order for staff to evaluate the appropriateness of the test to detect cracking in these components prior to loss of intended function.

• The preventive action program element of GALL Report AMP XI.S1 recommends that the program be augmented to include preventive actions that ensure that moisture levels associated with an accelerated corrosion rate do not exist in the exterior portion of the BWR Mark I steel containment drywell shell. The actions consist of ensuring that the sand pocket area drains and/or the refueling seal drains are clear. The parameters monitored or inspected program element of the GALL Report AMP recommends that applicants with BWR Mark I steel containments should monitor sand pocket area drains and/or the refueling seal drains for water leakage. The licensees should ensure the drain lines are clear to prevent moisture levels associated with accelerated corrosion rates in the exterior portion of the drywell shell. The preventive action program element of the LRA AMP includes an enhancement to revise plant procedures to require inspection of the sand pocket drain lines prior to the period of extended operation. Also, the parameters monitored or inspected program element of the LRA AMP includes an enhancement to revise plant procedures to specify that inspections of sand pocket drain lines will monitor the internal condition of drain lines. Further, the detection of aging effects program element of the LRA AMP includes an enhancement to revise plant procedures to require visual inspection of sand pocket drain lines to ensure there is no evidence of blockage. Based on item 9 of LRA Section A.4, License Renewal Commitment List, these enhancements (i.e., Commitments No. 9a, 9d and 9e) are scheduled to be completed prior to the period of extended operation. The staff needs additional information to determine that these enhancements are consistent with the recommendations for BWR Mark I steel containments in the preventive actions and parameters monitored or inspected program elements of the GALL Report AMP because: (i) it is not clear if the intent of the license renewal commitments is to revise plant procedures prior to the period of extended operation or to revise plant procedures and perform inspections of drain lines prior to the period of extended operation; (ii) the proposed enhancements (i.e., Commitments No. 9a and 9d) do not provide a stated objective for the inspection (i.e., to ensure that drain lines are clear or to monitor for water leakage or moisture in the drains or both; based on description in the above mentioned program elements, they appear to be exclusively intended to ensure that sand pocket drain lines are clear); and (iii) the enhancements (i.e., Commitments No. 9a, 9d, and 9e) do not provide the associated frequency of inspections and the basis for its adequacy to meet the intended objective; and (iv) it is not clear to the staff as to how the LRA AMP ensures that the refueling seal drains are clear.

• The preventive actions program element of the LRA AMP basis document states on page 26 that:

During refueling the refueling bellows drain empties into a manifold which is equipped with a sight glass. This sight glass is monitored when the refueling pool is flooded to detect potential leakage of water into the space around the drywell shell. The sand pocket drains are also [to] be monitored for signs of moisture. Fermi 2 plans to re-inspect the drain lines to verify their condition prior to the period of extended operation to confirm that these preventative actions

32 are not warranted. The program will be enhanced to require inspection of the sand pocket drain lines prior to the period of extended operation. (emphasis added)

Further, the parameters monitored or inspected program element on page 28 of the program basis document states that: Fermi 2 performs routine surveillances of the drains to record the observed condition of the drain lines for any leakage. Fermi 2 will inspect the sand pocket drain lines to verify their condition prior to the period of extended operation to confirm that the sand pocket drains are clear in ...

The parameters monitored or inspected program element of GALL Report AMP XI.S1 recommends that license renewal applicants with BWR Mark I steel containments should [periodically] monitor the sand pocket area drains and/or the refueling seal drains for water leakage.

During the audit, the staff reviewed Fermi 2 Surveillance Procedure 24.000.03, Revision 77 (including Attachments 1 and 2), and noted that the procedure includes the following regulatory commitments made by letter NRC-88-0081, Revised Response to GL 87-05, dated 4/20/88, and tracked in the applicants Regulatory Action Commitment Tracking System (RACTS) under RACTS 88027. These items require inspection of the reactor-drywell seal bellows and the four sand cushion drain lines for leakage during every refueling outage.

(a) Items (35.0 in Attachment 1 and 1.10 in Attachment 2 identified as commitments

[CM]) requiring verification that reactor-drywell seal bellows leakage is within limits.

The procedure requires this verification to be performed during Mode 5 Refueling on a daily basis for the first 3 days following reactor cavity flooding and at a frequency of 7 days following that with an acceptance criteria of no observed leakage; (b) Item (1.09 in Attachment 2 identified as commitment [CM]) requiring verification that drywell sand cushion leakage is within limits. The procedure requires this verification to be performed during Mode 5 Refueling at a frequency of 7 days (with a note that the commitment is monthly but performance will be 7 days) following reactor cavity flooding with an acceptance criteria of no observed leakage. Checks for leakage are required at Azimuth 90/180/270/360 6 below reactor pedestal catwalk between torus and drywell.

Despite the above existing commitments controlled by Procedure 24.000.03 to periodically monitor the sand pocket cushion drain lines and reactor-drywell seal bellows for signs of water leakage into inaccessible areas of the drywell, it is not clear to the staff if these periodic monitoring of the sand cushion drain lines and refueling seal bellows for water leakage every refueling outage will continue into the period of extended operation because of the inconsistent and contradicting statement (cited with emphasis added in the indented paragraph at the beginning of the bullet for this issue) on page 26 of the program basis document. Therefore, the staff needs additional information to determine if the parameters monitored or inspected program element is consistent with the GALL Report AMP with regard to the recommendation for periodically monitoring the sand pocket area drains and the refueling seal drains for water leakage.

• The monitoring and trending program element of the LRA AMP included the enhancement, 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. The

33 corresponding program element in GALL Report AMP XI.S1 recommends that the applicant 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. During the audit, the staff noted that, for reasons indicated in the letters NRC-87-005 and NRC-88-0081, dated September 10, 1987, and April 20, 1988, respectively, ultrasonic thickness measurements of the drywell shell sand pocket areas were not performed at Fermi 2 in response to Generic Letter 87-05. It is not clear to the staff if these statements are consistent because the proposed enhancement in the LRA AMP program basis does not indicate the minimum number of sets and interval at which UT measurements will be performed, and does not provide the technical basis of how an appropriate corrosion rate will be developed if only one set of UT measurements is intended.

• The corrective actions program element of the LRA AMP included an enhancement to revise plant procedures to require three specific corrective actions should moisture be detected or suspected in the inaccessible area on the exterior of the Mark I steel containment drywell shell. The staff noted that the specific actions included in the above enhancement to the LRA AMP correspond to recommended actions (b), (c), and (d) in the corrective actions program element of GALL Report AMP XI.S1 if moisture has been detected in the inaccessible area on the exterior of the Mark I containment drywell shell or the source of moisture cannot be determined subsequent to root cause analysis.

However, the LRA AMP program basis document and corresponding enhancement did not address action (a) of the GALL Report AMP which recommends including in the scope of license renewal any components that are identified as a source of moisture, if applicable, and performing aging management review. It is not clear to the staff that the corrective actions program element of the LRA AMP is consistent with recommended actions in the GALL Report AMP specifically applicable to inaccessible areas of the drywell shell exterior of Mark I containments because the LRA AMP basis document did not identify the components that are potential sources of moisture to inaccessible areas of the drywell exterior and whether they were subjected to AMR.

During the audit, the staff made the following observations:

• The staff reviewed the ISI-NDE Program Plan for Fermi 2, Part F, ASME Section XI Containment Inservice Inspection Program, Appendix F4.5, and noted that Fermi 2 has a proactive inspection program of the interior wetted surfaces of submerged areas of the torus and the vent header. The interior of the torus is inspected and repaired on an every other refueling outage basis. During these examinations, the submerged areas of the torus shell are cleaned from water line to water line to remove sludge and other foreign material, and then coating inspectors inspect the entire area by VT-3 visual inspection. All areas of broken blisters and mechanical damage exhibiting corrosion on the pressure boundary immersion area are repaired. Additionally, Fermi 2 monitors the blister condition on specific immersed areas of the torus chosen based on their relatively high number of indications. During each inspection, the size, population density and condition of the blisters are monitored and trended to identify and evaluate adverse trends.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by

34 known industry operating experience (e.g., no previously unknown aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR, noting that conforming changes may be required as a result of responses to potential RAI issues identified above.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S1. The staff also identified certain aspects of the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and corrective actions program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR, subject to conforming changes that may be required as a result of responses to the potential RAI issues.

LRA AMP B.1.13, Containment Leak Rate Summary of Information in the Application. The LRA states that AMP B.1.13, Containment Leak Rate, is an existing program that is consistent with the program elements in GALL Report AMP XI.S4, 10 CFR Part 50 Appendix J. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: 10 CFR Part 50 Appendix J, ILRT, LLRT, and leakage.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Fermi 2 License Renewal Project, Aging Management Revision 1

1. FERMI-RPT12-LRD05 Program Evaluation Report Civil/Structural, Containment 03/05/2014 Leak Rate on Pages 11-20.

Engineering Support Conduct Manual, Leakage Revision 17

2. FERMI 2-MES 28 Reduction and Primary Containment Leakage Rate 06/23/2010 Programs.

Revision 0

3. FERMI 2-PEP 22 10 CFR Part 50, Appendix J, Option B Program.

01/26/2011

35 Document Title Revision / Date Plant Technical Procedure-Surveillance Procedure. Revision 31

4. FERMI 2-43.401.100 Leak Rate Test-Type A-General. 08/25/2011 Plant Technical procedure-Surveillance Procedure. Revision 35

5. FERMI 2-43.401.200 Leak Rate Test-Type B-General. 01/30/2009 Plant Technical procedure-Surveillance Procedure. Revision 54

6. FERMI 2-43.401.300 Leak Rate Test-Type C-General. 02/10/2012 Integrated Leak Rate Test [ILRT]-Type A-General,

7. Job ID 1138030328 11/09/2007 Perform 43.101.100 Type A - PCILRT Surveillance.

8. Agencywide Documents U.S. Nuclear Regulatory Commission (NRC) Letter to Access and Management Fermi 2 - Issuance of Amendment 153, A One-Time System (ADAMS) 03/27/2003 Deferral of the Primary Containment Integrated Leak Accession No.

Rate Test.

ML030780865 Detroit Edison Letter to NRC, Proposed License

9. ADAMS Accession Amendment for a One-Time Deferral of the Primary 05/23/2002 No. ML021510342 Containment Integrated Leak Rate Test.

Detroit Edison Letter to NRC, Response to NRC

10. ADAMS Accession Request for Additional Information Regarding the 12/20/2002 No. ML023610417 Proposed License Amendment for a One-Time Deferral of the Primary Containment Integrated Leak Rate Test.

NRC Requests for B.1.13: Containment Leak Rate (List

11. 09/29/2014 of Excluded Components)

12. Chicago Bridge & Iron, Revision 8 Shell Stretch-out, Enrico Fermi Power Plant Unit 2.

Contract 69-5562, DWG 2 07/02/1970

13. Fermi 2- Drawing Primary Containment Penetrations Drywell, Detroit 07/31/2009 Number 6C721-2304 Edison Fermi 2.

Quick Hit Self-Assessment Results on Appendix J

14. TMIS-12-0021 02/27/2012 Program.

B2100-F1010B failed its LLRT [local leak rate test],

15. CARD 09-22205 04/03/2009 Investigation, Root Cause, and Closure.

Evaluate Appendix J, Type C Acceptance Criteria Bases,

16. CARD 08-23745 06/06/2008 Industry Benchmarking Investigation.

B2103F019 Exceeded the Maximum Allowable Leakage

17. CARD 12-22315 03/27/2012 in its LLRT.

LLRT of T2301A0011C Exceeded Acceptance Criteria, Overall Leakage Rate of the Containment is Below the

18. CARD 09-23364 04/27/2009 Limit, and this Component is Acceptable within the Measured Leak Rate.

During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit, the staff made the following observation:

• The staff reviewed Reference 11, NRC Requests for B.1.13: Containment Leak Rate (List of Excluded Components), in the table above titled Relevant Documents Reviewed, and noted that for each of the excluded components from the Containment

36 Leak Rate Program, scope of program program element, the applicant has identified the components in the LRA Table 2s requiring aging management and proposed various other AMPs or TLAAs [time-limited aging analyses] to demonstrate that the effects of aging will be adequately managed during the period of extended operation.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S4.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.14, Diesel Fuel Monitoring Summary of Information in the Application. The LRA states that AMP B.1.14, Diesel Fuel Monitoring, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M30, Fuel Oil Chemistry. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the emergency diesel generator tanks, diesel fire pump tanks, and the combustion turbine generator tank. The staff also conducted an independent search of the applicants operating experience database using the keywords: diesel fuel, sampling, and bio-diesel.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date 1.FERMI-RPT-12-AMM14 Aging Management Review of the Fuel Oil System Revision 0 Obtain FERMI 1- CTG Fuel Oil Sample for Analysis

2. WO35253617 01/14/2014 (procedure)

3. CARD 09-26511 High Water and Sediment in EOF Diesel Fuel 08/24/2009

37 Document Title Revision / Date

4. CARD 10-28818 EOF EDG fuel oil sample out of specification 10/04/2014 Evaluate Changing Frequency to Annual (From Quarterly)

5. CARD 10-22346 03/18/2010 for Fuel Oil Stratification Testing

6. CARD 10-24128 DFP FO Tank Contaminated 05/18/2010 Aging Management Program evaluation Report Non-Class

7. FERMI-RPT-12-LRD03 Revision 2 1 Mechanical Operating Experience Review Report-Aging Management

8. FERMI-RPT-12-LRD09 Revision 1 Program Effectiveness

9. 74.000.19 Chemistry Routine Surveillances Revision 24

10. 77.000.81 Sampling EDG Fuel Oil Tanks Revision 1 Layout and Installation For Fire Protection Equipment

11. 6M721S-2008 06/27/2002 General Service Water Pump House

12. 6M721K-0002 Fuel Oil Sys&FI Prot TK-Aux BLR 06/14/2005

13. 11907105 Fuel Oil Day Tank 550 (drawing) Revision 5

14. 6M721K-0001 Fuel Oil Sys&FI Prot TK-Aux BLR 06/14/2005

15. NL10276 Horizontal Diesel Fuel Storage Tanks 06/26/1977

16. Certificate of Analysis EDG13 FO Storage Tank 08/01/2008

17. WO37833595 Obtain Diesel Fire Pump Sample (procedure) 12/17/2013 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M30. The staffs evaluation of aspects of the program elements associated with enhancements that are not necessary for consistency will be addressed in the SER.

38 Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.15, Environmental Qualification (EQ) of Electric Components Summary of Information in the Application. The LRA states that AMP B.1.15, Environmental Qualification (EQ) of Electric Components, is an existing program that will be consistent with the program elements in GALL Report AMP X.E1, Environmental Qualification (EQ) of Electric Components. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: EQ, Environmental Qualification, cable, connection, jacket, and insulation.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Results -

1. FERMI-RPT-12-LRD04 Revision 1 Electrical Page 53 TLAA and Exemption Evaluation Results (includes EQ) -

2. FERMI-RPT-12-LRD06 Revision 1 Page 23 Electrical Environmental Qualification Central File - Revision F

3. EQ1-EF2-044 Limitorque 11/8/2011 Revision E

4. EQI-EF2-038 Electrical Environmental Qualification File - Okinite 2/17/2012 General Information Lead Sheet Environmental Revision L

5. EQ0-EF2-018 Qualification Central File 12/14/2012 EEQ-Lead Sheet - Electrical Environmental Qualification Revision C

6. EQ1-EF2-004 Central File 7/14/2010

7. Program Health Report Fermi 2 - 3rd Quarter 2013 11/25/2013

8. Program Health Report Fermi 2 - 4th Quarter 2012 1/31/2013 Environmental Qualification Program Focused

9. 7/20/2012 Self-Assessment Report Operating Experience Review Report - Aging

10. Fermi-RPT-12-LRD09 Revision 1 Management Program Effectiveness

11. Program Health Report Fermi 2 - 1st Quarter 2011 5/18/2011

39 Document Title Revision / Date

12. Program Health Report Fermi 2 - 2nd Quarter 2011 8/29/2011

13. Program Health Report Fermi 2 - 3rd Quarter 2011 12/7/2011

14. Program Health Report Fermi 2 - 4th Quarter 2011 Program Health Report Fermi 2 - 1st and 2nd Quarter

15. 1/24/2012 2012

16. Program Health Report Fermi 2 - 3rd Quarter 2012

17. Program Health Report Fermi 2 - 1st Quarter 2013 4/17/2013

18. Program Health Report Fermi 2 - 2nd Quarter 2013 7/19/2013

19. Program Health Report Fermi 2 - 4th Quarter 2013 2/3/2014

20. Program Health Report Fermi 2 - 1st Quarter 2014

21. Program Health Report Fermi 2 - 2nd Quarter 2014 7/31/2014 Environmental Qualification Program Focused

22. 7/20/20125 Self-Assessment Report RF15 Indenter Testing of Environmentally Qualified

23. WO 33325460 6/13/2012 Okoprene Cable in Drywell

24. 09-29658 Cable Examination and Contingency Repair Work Orders 12/17/2009

25. EFA-R16-07-003 Engineering Functional Analysis Appendix C and B Revision A During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP B.1.15.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

40 LRA AMP B.1.16, External Surfaces Monitoring Summary of Information in the Application. The LRA states that AMP B.1.16, External Surfaces Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components, as modified by LR-ISG-2011-03, Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2, Aging Management Program XI.M41, Buried and Underground Piping and Tanks, and LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation.

To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. Prior to the staffs audit, the applicant supplemented its program by letter dated July 30, 2014, to include inspections under insulation as recommended in LR-ISG-2012-02, and the staffs audit included this additional aspect of the program. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: rust, pit, corros, leak, and wastage.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report,

1. FERMI-RPT-12-LRD03 Revision 2 Non-Class 1 Mechanical Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Revision 1 Management Program Effectiveness

3. FBP-70 System Engineering Fundamentals Revision 4

4. FBP-70001 System Walkdown Checklist Revision 0

5. MQA13 Quality Assurance Conduct Manual - Trending Revision 9 Quality Assurance Conduct Manual - Condition

6. MQA11 Revision 35 Assessment Resolution Document Licensing/Engineering Conduct Manual - Operating

7. MLS04 Revision 26 Experience Program Rust Found On Div. 1 and Div. 2 CCHVAC Chiller

8. CARD 12-28246 10/04/2012 Isolators

9. CARD 14-20872 Rusty flanges and hardware 2/08/2014 Air seal at Grid G-12 is bulging approx. 12 long x 2 in

10. CARD 11-29134 11/06/2011 CCHVAC Div-2 Mech Room south wall

41 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP, as modified by LR-ISG-2011-03 and LR-ISG-2012-02. However, the staff found that, for the parameters monitored or inspected and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

• The parameters monitored or inspected and detection of aging effects program elements of the LRA AMP include an enhancement to revise program procedures to ensure that walkdowns will include inspections for leakage to detect cracking in stainless steel components exposed to air containing halides. However, some of the subject components have a gaseous internal environment. It is not clear to the staff how external leakage of the gas will be detected.

• LR-ISG-2012-02 revised GALL Report AMP XI.M36 to recommend inspections of thermal insulation when the insulation has a function to reduce heat transfer. The LRA AMP does not contain this activity. The applicants program basis document, FERMI-RPT-12-LRD03, states that thermal insulation is not credited for reduction of heat transfer. However, LRA Table 3.5.2-4 includes an AMR item for insulation with an intended function of heat transfer reduction, and the Structures Monitoring Program is proposed to manage loss of material and change in material properties. It is not clear to the staff whether the activities to inspect thermal insulation under the Structures Monitoring Program are consistent with those recommended in LR-ISG-2012-02.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR, as modified by LR-ISG-2012-02.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M36, as modified by LR-ISG-2011-03 and LR-ISG-2012-02. The staff also identified certain aspects of the parameters monitored or inspected and detection of aging effects program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

42 LRA AMP B.1.17, Fatigue Monitoring Summary of Information in the Application. The LRA states that AMP B.1.17, Fatigue Monitoring, is an existing program that, with enhancements and an exception, is consistent with the program elements in GALL Report AMP X.M1, Fatigue Monitoring. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. The exception to the GALL Report AMP, which is not necessary for consistency with the GALL Report, will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: transient, fatigue, and flaw.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Documentation and Reporting of Operating Transients

1. MES29 Revision 7 and Cycles

2. MQA13 Trending Revision 9 Technical Specification Transient Count on the Reactor

3. CARD 98-14294 06/05/1998 Pressure Vessel Evaluate Cool Down Rate of RPV During Core Spray

4. CARD 06-21871 02/07/2008 Flood UP for Refueling

5. CARD 11-28422 Fatigue Usage Factor at Containment Flued Heads 06/20/2012 Evaluate NRC Regulatory Issues Summary 2008-30,

6. CARD 09-20254 Fatigue Analysis of Nuclear Power Plant Components, for 03/24/2009 impact to Fermi Document Applicability of NRC Regulatory Issues

7. CARD 12-20064 Summary 2011-14, Metal Fatigue Analysis Performed by 02/03/2012 Computer Software

8. FERMI-RPT-12-LRD07 TLAA - Mechanical Fatigue Revision 2

9. 1101554.302 Fermi LR Transient Counting (Proprietary Information) 02/10/2014 License Renewal Transient Events for Thermal Cycle

10. 1101554.301 02/10/2014 Counts (Proprietary Information)

The staff conducted its audit of LRA program elements one through six based on the contents of the existing program, as modified by the proposed enhancements. Aspects of the corrective actions program element of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

43 During the audit, the staff verified that the scope of program, preventive actions, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the corrective actions program element not associated with the exception are consistent with the corresponding program elements in the GALL Report AMP.

The staffs evaluation of aspects of the program element associated with the exception will be addressed in the SER. In addition, the staff found that for the parameters monitored or inspected program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subject discussed below.

• The parameters monitored or inspected program element of the LRA AMP states that the cycle counting method of fatigue monitoring will be used to track the number of occurrences for plant transients. The GALL Report AMP recommends tracking the number of each plant transient, although it does not provide guidance on the use of a specific fatigue monitoring method. The applicants Fatigue Monitoring Program is currently limited to cycle counting and does not allow for more detailed fatigue monitoring methods, such as Cycle-Based Fatigue and Stress-Based Fatigue, to prevent the fatigue design limit from being exceeded. It is not clear to the staff if fatigue monitoring methods other than Cycle Counting are being used to prevent the fatigue design limit of components from being exceeded.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience. The staff also noted that the applicant tracks cumulative operating time on components in support of flaw evaluations. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subject discussed below.

• The applicants Fatigue Monitoring Program is limited to monitoring plant transients in order to remain below component design limits based on crack initiation. The applicant is currently tracking cumulative operating time on components in support of flaw evaluations. The applicants Fatigue Monitoring Program does not track usage time or support crack growth calculations. It is unclear if the TLAAs associated with these components can be tracked using the Fatigue Monitoring Program.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR, although information regarding the methodologies to implement the commitments was not available for review. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement commitments, the staff will consider issuing RAIs for the subject discussed below.

• The applicants Fatigue Monitoring Program contains enhancements to prevent the fatigue design limit of components from being exceeded when accounting for environmental effects. The UFSAR supplement contains a commitment (Commitment No. 12, part b) to calculate environmental correction factors in order to assess the impact of the reactor coolant environment on component fatigue life. As part of this

44 commitment, plant-specific component locations in the reactor coolant pressure boundary that lead the components identified in NUREG/CR-6260 will be identified for tracking purposes. It is unclear what methodology is being used to identify the plant-specific limiting locations.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, detection of aging effects, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP X.M1.

The staff also verified that for the acceptance criteria program element, the aspects of the LRA AMP program element not associated with the exception are consistent with the corresponding program element in GALL Report AMP X.M1. The staffs evaluation of aspects of the program element associated with exceptions will be addressed in the SER. The staff also identified certain aspects of the parameters monitored or inspected program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. However, the sufficiency of the AMP to track parameters other than transients, such as cumulative operating time, may require additional information. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR, although additional information regarding the methodologies being used to satisfy the aspects of the associated commitments may be requested.

LRA AMP B.1.18, Fire Protection Summary of Information in the Application. The LRA states that AMP B.1.18, Fire Protection, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M26, Fire Protection. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP; however, it does not consider the sufficiency of enhancements which are not necessary for consistency, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: carbon dioxide, CO2, damper, fire barrier, halon, and wrap.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report,

1. FERMI-RPT-12-LRD03 Revision 2 Non-Class 1 Mechanical, Section 4.6, Fire Protection Fermi 2 Engineering Support Conduct Manual, Fire

2. MES35 Revision 9 Protection

45 Document Title Revision / Date

3. MOP11 Fermi 2 Operations Conduct Manual, Fire Protection Revision 16

4. 28.507.01 Fire Barrier Inspection Revision 10

5. 28.507.07 Fire Barrier Inspection - BOP Revision 3

6. 28.507.02 Fire Door Surveillance Test Revision 18

7. 28.507.03 Fire Door Inspection - BOP Revision 29

8. 28.507.05 Inspection of Penetration Fire Stops Revision 19

9. 28.502.04 Low Pressure CO2 System Evaluation Test Revision 7 CO2 Fire Suppression Systems Functional Test Zone

10. 28.502.06 9A - Auxiliary Building 2nd Floor Mezzanine Cable Tray Revision 15 Area CO2 Fire Suppression Functional Test Zone 14,

11. 28.502.07 Revision 13 Auxiliary Building, 3rd Floor CO2 Fire Suppression Functional Test RHR Complex

12. 28.502.08 Revision 16 Div I - EDG 11 CO2 Fire Suppression Functional Test RHR Complex

13. 28.502.09 Revision 16 Div I- EDG 12 CO2 Fire Suppression Functional Test RHR Complex

14. 28.502.10 Revision 16 Div II-EDG 13 CO2 Fire Suppression Functional Test RHR Complex

15. 28.502.11 Revision 18 Div II - EDG 14 Standby Gas Treatment System CO2 System Actuation

16. 28.502.18 Revision 10 Test CO2 Fire Suppression Systems Functional Test Zone 9,

17. 28.502.19 Revision 7 Auxiliary Building, 2nd Floor Cable Tray Tunnel

18. 28.503.03 Halon Storage Tank Weight and Pressure Test Revision 12 Halon Fire Suppression System Functional Test Zone 8

19. 28.503.04 Revision 15

- Relay Room Halon Fire Suppression System Functional Test Zone 11

20. 28.503.05 Revision 14

- Cable Spreading Room Halon Fire Suppression System Functional Test Zone 13

21. 28.503.06 Revision 16

- Computer Room Halon Fire Suppression System Functional Test SAS

22. 28.503.11 Revision 1 File Room GH1 Shiftly, Daily, Weekly, and Situation Required

23. 27.000.02 Revision 44 Performance Evaluations

24. 28.507.04 Test and Inspection of Fire Dampers Revision 8

25. 28.507.06 Test and Inspection of Fire Dampers - BOP Revision 3

26. MQA11 Condition Assessment Resolution Document Revision 35

46 Document Title Revision / Date

27. MQA13 Quality Assurance Conduct Manual Revision 9

28. CARD 06-27099 Fire doors need repairing 11/02/2006

29. CARD 09-22369 Cracked fire penetrations due to heat stress 04/06/2009 Foil fire barrier wrap is damaged on conduit run from

30. CARD 09-00005 01/08/2009 H21-P022 panel Deteriorated penetration seals, and excessive debris in

31. CARD 09-22520 04/09/2009 penetration area

32. CARD 10-21247 Hole in floor of UFSAR Fire Barrier 02/11/2010

33. CARD 10-30772 Fire door seal damaged 11/17/2010

34. CARD 10-30102 Penetration fire stops damaged due to heat stress 11/10/2010 Fire Rated Foam Seals damaged on Aux. Building Wall

35. CARD 11-28605 09/19/2011 at EDG Cable Vault Modification area

36. CARD 12-21188 Fire boot seal with hole in it 02/13/2012

37. CARD 12-23205 Penetration fire stops damaged due to heat stress 04/13/2012

38. CARD 12-26531 Damaged Fire Seals and inconsistencies with drawings 08/03/2012

39. CARD 14-20928 Fire barrier cinder block cracked 02/10/2014

40. FERMI-RPT-12-AMC04 Aging Management Review of Bulk Commodities Revision 1 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

However, the staff found that for the detection of aging effects program element, additional information is necessary in order for the staff to complete its review; the staff will consider issuing RAIs for the subject discussed below.

• The staff noticed that the Aging Management Program Evaluation Report for Fire Protection, under the comparison statement for the Detection of Aging Effects program element, states that visual inspection of other fire barrier materials, including fire barrier dampers, is performed at a frequency in accordance with the technical requirements manual, which is every 18 months.

Consistent with the SRP-LR and the GALL Report, DTE selected the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program and the External Surfaces Monitoring Program to manage for loss of material. The periodicity for the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is based on a sampling of at least 20 percent or maximum of 25 components every 10 years. Selection of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program may conflict with DTEs current requirement to inspect the fire damper housings every 18 months.

47 During the audit, the staff made the following observations:

• In Section 4.6 of FERMI-RPT-12-LRD03, under the Detection of Aging Effects element, it states that If any sign of degradation is detected within that sample, the scope of the inspection is expanded to include additional seals. This statement is consistent with the statement in GALL Report AMP XI.M26 for expansion of the sample. The staff noticed that Technical Requirements Manual (TRM) Section 3.12.8 (Technical Requirements Surveillance Requirement (TRSR) 3.12.8.7) states that if apparent changes in appearance or abnormal degradations are found, a visual inspection of an additional 10 percent of each type of sealed penetration shall be made, and that this inspection process shall continue until a 10 percent sample with no apparent changes in appearance or abnormal degradation is found. To show consistency with the GALL Report for this particular activity, DTE references Plant Technical Procedure - Fermi 2 28.507.05, Revision 19, Inspection of Penetration Fire Stops. General Requirement 5.1.1 states, in part, If changes in appearance from normal are found, a visual inspection of an additional 10 percent of that type of sealed penetration shall be made.

This inspection process shall continue until a 10 percent sample is found with no apparent changes in appearance or abnormal degradation.

• Enhancement No. 2 states that Fire Protection Program procedures will be revised to require visual inspections of in-scope fire wrap and fire stop materials constructed of fibersil cloth, cerafoam, kaowool, thermolag, flamemastic, and pyrocrete. The staff noticed that LRA Table 3.5.2-4 does not include cerafoam, kaowool, flamemastic or pyrocrete as materials. However, FERMI-RPT-12-AMC04 states that [m]aterial used for fire stops and fire wraps include carborundum durablankets, carborundum fibersil cloth, silicone fabric boot, silicone elastomers and steel. It is not clear if the applicant uses cerafoam, kaowool, flamemastic or pyrocrete in the plant as fire stop materials.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M26. The staff also identified certain aspects of the detection of aging effects program element of the LRA AMP for which additional information or additional evaluation is required before the staff can complete its review.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

48 LRA AMP B.1.19, Fire Water System Summary of Information in the Application. As amended by letter dated July 30, 2014, the LRA states that AMP B.1.19, Fire Water System, is an existing program with enhancements and exceptions that will be consistent with the program elements in GALL Report AMP XI.M27, Fire Water System, as modified by LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with LR-ISG-2012-02 AMP XI.M27 and exceptions to LR-ISG-2012-02 AMP XI.M27.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the general service water pump house and the fuel oil tank for the diesel-driven firewater pump.

The staff also conducted an independent search of the applicants operating experience database using the keywords: biofoul, biological, clog, silt, through-wall, and foul.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report

1. FERMI-RPT-12-LRD03 Revision 2 Non-Class 1 Mechanical Fire Water System Fire Hose Station Flow Test and Fire Hose Hydrostatic

2. 28.501.10 Revision 9 Test

3. TR 3.12.1 Technical Requirements Manual - Fire Protection Revision 75 08/03/2012

4. 28.501.14 Sprinkler System Integrity Inspection - Results 01/30/2014 04/10/2012

5. 28.501.16 Sprinkler System Integrity Inspection - BOP Results 01/13/2014

6. 28.504.04 Fire Suppression Water System Flow Test Revision 24

7. 28.501.13 Sprinkler System Simulated Automatic Actuation Test Revision 22

8. 23.501.01 Fire Water Suppression System Revision 53 Sprinkler System Simulated Automatic Actuation Test -

9. 28.501.15 Revision 17 BOP 05/14/2008 05/13/2009 07/21/2010 Fire Suppression Water System Flow Test - Test

10. 28.504.04 03/17/2011 Results 09/06/2012 09/07/2012 12/13/2012

49 Document Title Revision / Date Fire Protection Engineering Evaluation of Impact of

11. FPEE-11 Degraded C Factor on TRM Required Sprinkler Water 03/04/2011 Supply Deluge System and Pre-Action Sprinkler System Trip

12. 28.501.17 Revision 28 Test - BOP INPO RFI [Recommendation for Improvement] Lack of

13. CARD 12-28274 Detailed Plan for Resolution of the Underground Fire 10/05/2012 Header Issue

14. CARD 12-20083 External Corrosion on 12 Ring Header 01/09/2012 Trending Identified Underground Fire Suppression Ring

15. CARD 08-23973 06/16/2008 Header Degradation 12 Underground Piping [removed fire water system

16. CARD 09-00627 06/29/2009 piping] for ISI

17. CARD 10-24296 Condition of Underground Fire Header 05/24/2010 PM [Preventive Maintenance] - Performance Scheduling

18. 1284705 Tracking (PST) Database - Perform Functional Test on the Deluge System for the Hydrogen Seal Oil Unit

19. 28.504.06 Fire Suppression Water System - Flush Revision 25

20. P80/82-00 Fire Protection System Design Basis Document Revision C

21. WO 000Z031830 & WO 05/02/2003 CCHVAC Makeup Charcoal Replacement 000Z966845 11/02/1996

22. WO 000Z050437 & WO 04/05/2006 CCHVAC Recirc Charcoal Replacement 000Z966956 10/26/1996 Fire Sprinkler Piping Contains Large Amounts of Silt and

23. CARD 04-23042 07/06/2004 Corrosion Products Perform 28.501.19 (Sect 5.4) Deluge System Functional

24. WO 34393618 03/24/2013 Test for Main Transformer 2A Perform 28.501.17 (Sect 5.1) Deluge System Functional

25. WO 34422151 02/19/2014 Test for SYS SER Transformer 64 Perform 28.501.17 (Sect 5.5) Functional Test for

26. WO 36286444 08/26/2014 Loading Dock Pre-Action Sprinkler Perform 28.501.17 (Sect 5.3) Deluge System Functional

27. WO 34617819 07/31/2014 Test for Hydrogen Seal Oil Deluge Perform 28.501.19 (Sect 5.3) Deluge System Functional

28. WO 38192166 04/22/2014 Test for Main Transformer 2B The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of the detection of aging effects program element of the LRA AMP associated with the exceptions were evaluated during this audit. Aspects of the program elements that are not associated with the exceptions were evaluated and are described below.

50 During the audit, the staff verified that the scope of program, preventive actions, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the detection of aging effects program element not associated with the exceptions are consistent with the corresponding program elements in the GALL Report AMP. The staffs evaluation of aspects of this program element associated with the exceptions will be addressed in the SER.

In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

• Enhancement Nos. 2 and 7 to the parameters monitored or inspected and detection of aging effects program elements of the LRA AMP state that an inspection of the wet fire water system piping condition will be conducted at least once every 5 years. The applicant will conduct the test by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line. LR-ISG-2012-02 AMP XI.M27 recommends that, as stated in National Fire Protection Association (NFPA) 25 Section 14.2.2, the licensee inspect every other system in buildings with multiple wet pipe systems every 5 years. 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.

• Enhancement No. 4 to the detection of aging effects program element of the LRA AMP, as amended by letter dated July 30, 2014, states that a basis for the acceptance criteria of less than or equal to 25 pounds per square inch gauge (psig) and less than or equal to 10 psig that currently exists in the main drain test procedures will be developed.

LR-ISG-2012-02 AMP XI.M27 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.

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 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.

• Enhancement No. 6 to the detection of aging effects program element of the LRA AMP, as amended by letter dated July 30, 2014, states that sprinklers will be cleaned if obstructions are identified during internal inspections. LR-ISG-2012-02 AMP XI.M27 recommends that, as stated in NFPA 25 Section 5.2.1.1.2, licensee should replace corroded or loaded sprinklers. The applicant did not provide a basis for why corroded or loaded sprinklers can be cleaned versus replaced.

• Enhancement No. 11 to the detection of aging effects program element of the LRA AMP, as amended by letter dated July 30, 2014, states that an obstruction investigation will be conducted after an extended shutdown of more than one year. LR-ISG-2012-02 AMP XI.M27 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). During the audit, the staff did not find any procedures that included the additional criteria, nor did the applicant provide a basis for why its enhancement is sufficient to ensure that obstruction investigations would be conducted when

51 appropriate. It is not clear to the staff that these statements are consistent because only one criterion to conduct an obstruction investigation is identified.

• Exception No. 7 to the detection of aging effects program element of the LRA AMP, as amended by letter dated July 30, 2014, 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 in the cable spreading room will be conducted. LR-ISG-2012-02 AMP XI.M27 recommends that a licensee should conduct periodic inspections of fire water system piping exposed to indoor air (see LRA Table 3.3.2-7). It is not clear to the staff that these statements are consistent because the applicant did not provide a basis for why there is reasonable assurance that the current licensing basis intended function(s) of the piping would be met when only a one-time inspection is conducted.

• Exception No. 7 to the detection of aging effects program element of the LRA AMP, as amended by letter dated July 30, 2014, states that in lieu of conducting a deluge test with air or smoke for the control center heating, ventilation, and air conditioning (HVAC) make-up filter charcoal filter absorber unit and the control center HVAC recirculation filter charcoal absorber unit, it will inspect the internal surfaces of the piping downstream of the manual isolation valves whenever the charcoal is replaced. LR-ISG-2012-02 AMP XI.M27 recommends that, as stated in NFPA 25 Section 13.4.3.2.2.4, a licensee should conduct deluge valve testing at least every 3 years. It is not clear to the staff that these statements are consistent because during the audit, the staff reviewed charcoal filter media replacement work orders and determined that media is replaced approximately every 7 to 10 years.

• The acceptance criteria program element of the LRA AMP, as amended by letter dated July 30, 2014, does not include an acceptance criteria associated with corrosion of sprinklers during periodic visual sprinkler inspections. LR-ISG-2012-02 AMP XI.M27 recommends that, as stated in NFPA 25 Section 5.2.1.1.2, licensees should replace sprinklers that exhibit corrosion. It is not clear to the staff that these statements are consistent because the Fire Water System Program does not include a criterion to replace corroded sprinklers and the applicant did not provide a basis for why corroded sprinklers can remain in service.

During the audit, the staff made the following observations:

• The staff reviewed procedure 23.501.01 and confirmed that there are seven main drain locations in the reactor building, two in the auxiliary building, three in the radwaste building, eight in the turbine building, three in the on-site storage facility, four in the residual heat removal building, and one in the general service water pump house. The staff also reviewed procedure 28.501.13 in conjunction with 23.501.01 and confirmed that the applicant conducts main drain tests in accordance with NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, at locations in the reactor building, auxiliary building, and general service water pump house building every 18 months.

• The staff reviewed CARD 08-23973. The CARD states that recent testing, May 2008, demonstrated that the C factor for the east and north portion of the header is approximately 59 and for the south and west portion of the header, the C factor is approximately 61. The previous test yielded C factors of 63 and 62 respectively. The design calculation uses a value of 60. CARD 01-24296 states that the May 2009 testing resulted in a C factor of 64. CARD 01-24296 also states that the applicant detected an error in the calculation of hydrant flows resulting in an average C factor increase of 3.6.

52 CARD 01-24296 further states that average C factor results are as follows: 66 in 2001, 61 in 2002, 63 in 2005, 57 in 2008, and 60 in 2009.

• The staff reviewed procedure 28.504.04 and confirmed that the applicant conducts a fire water system main header flow testing every 3 years.

• The staff reviewed procedure 28.501.10 and confirmed that the applicant conducts a flow confirmation at each hose station every 3 years.

• The staff reviewed procedure PST 1284705 and confirmed that the applicant tests the hydrogen seal oil unit deluge system every 364 days.

• The staff reviewed the Fire Protection System Design Basis Document and confirmed that the fire water system pressure at all automatic and manual water-based system points should be 150 psig plus or minus 10 psig.

• The staff reviewed procedure 28.504.06 and confirmed that the applicant conducts a flush of the yard piping every 12 months.

• The staff reviewed the corrective actions associated with CARD 04-23042, which documented silting in fire protection sprinkler piping, and confirmed that the degraded piping was associated with a warehouse supplied from Fermi Unit 1. The applicant flushed the piping to remove all debris and implemented a modification to supply the sprinklers from Fermi Unit 2. The staff noted that NFPA 25, Sections D.5, Flushing Procedures, cites flushing as an effective method to conduct obstruction investigations of yard mains, risers, feed mains, cross mains, and branch lines.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

• 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 current licensing basis, to annual testing. 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 staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing RAIs for the subject discussed below.

• 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 UFSAR supplement summary description for the Fire Water System Program should also state that it manages fouling and flow blockage. Although LRA Section A.1.19 references fouling

53 and flow blockage, it is only in reference to conducting visual inspections and not all of the inspections and testing in the program. It is not clear to the staff that the applicants current licensing basis 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.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding program elements in LR-ISG-2012-02 AMP XI.M27. The staff also verified that for the detection of aging effects program element, the aspects of the LRA AMP program element not associated with the exception are consistent with the corresponding program element in LR-ISG-2012-02 AMP XI.M27. The staffs evaluation of aspects of the program element associated with exceptions will be addressed in the SER. The staff also identified certain aspects of the parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of the LRA AMP for which additional information or evaluation is required before consistency can be determined.

Based on this audit, the staff also found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR supplement.

LRA AMP B.1.20, Flow-Accelerated Corrosion Summary of Information in the Application. The LRA states that AMP B.1.20, Flow-Accelerated Corrosion, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M17, Flow-Accelerated Corrosion, as modified by LR-ISG-2012-01, Wall Thinning Due to Erosion Mechanisms. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: cavitat, erosi, fac, flow accel, flow assist, impinge, through-wall, and wall-thinning.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report,

1. FERMI-RPT-12-LRD03 Non-Class 1 Mechanical, Section 4.8 Flow-Accelerated Revision 2 Corrosion Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Management Program Effectiveness, Section 3.1.18, Revision 1 Flow-Accelerated Corrosion

54 Document Title Revision / Date

3. NRC-89-0164 Fermi 2 Response to NRC Generic Letter 89-08 7/21/1989 Engineering Support Conduct Manual, Flow Accelerated

4. MES26 Revision 12 Corrosion Prediction, Detection, and Correction

5. PEP 19 Program Notebook, Flow Accelerated Corrosion Revision 2 FAC [Flow Accelerated Corrosion] Program Susceptibility

6. PEP 19, Appendix A Revision 1 Review

7. PEP 19, Appendix I FAC Program Long Range Plan Revision 3 Flow Accelerated Corrosion Program Evaluation Data,

8. WR E965060100 3/31/2006 No. 3160-2A, RHR A-AC, 1-29

9. CARD 13-25054 Peer Review Performance Deficiency - FAC Model 7/17/2013 MES26 to be Revised to Include Process for Technical

10. CARD 11-24244 4/26/2011 Justification for Deferrals

11. CARD 11-24236 NDE.014 Regarding Upstream Gridding 4/26/2011 MES26 Does Not Require Collecting Baseline UT for

12. CARD 11-24233 4/26/2011 Replacement Components High Mild Steel Corrosion Rates Indicated in RHRSW and

13. CARD 98-11053 2/2/1998 Associated Systems

14. TE-N22-11-027 RF14 FAC Program Outage Summary Report Revision 0

15. TE-N22-12-047 RF15 FAC Program Outage Summary Report Revision 0 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements. During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. However, the staff found that for the scope of program program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

• The Flow Accelerated Corrosion Program includes safety-related components. Electric Power Research Institute (EPRI) guidelines in Nuclear Safety Analysis Center (NSAC)-202L, Recommendations for an Effective Flow Accelerated Corrosion Program, recommend that appropriate quality assurance be applied to all phases of the Flow Accelerated Corrosion Program. The current Flow Accelerated Corrosion Program allows projected wall thicknesses to be determined using a wear value that is calculated by the CHECWORKSTM computer software. The wall thickness projection ensures that a component will continue to meet the minimum wall thickness allowed by design codes until its next scheduled inspection. Fermi 2 currently classifies CHECWORKSTM as a Category B software, which should not be used for safety-related design activities. For safety-related components, it is not clear that only results from software classified as Category A will be used to demonstrate that the design wall thickness will be met at the

55 next refueling outage. Otherwise, the other options included in the Flow Accelerated Corrosion Program, which use wall thickness measurements based on an engineering evaluation of ultrasonic testing data, should be used for safety-related applications.

• Program Notebook PEP19, Flow-Accelerated Corrosion, contains a discussion for the inspection scope selection, which includes a Feedwater Heater Shell Susceptibility Review. However, in its review of LRA Tables 3.4.2-2, Feedwater and Standby Feedwater System, and 3.4.2-3-2, Condensate System, Nonsafety-Related Components Affecting Safety-Related Systems, that contain the feedwater heaters, the staff could not identify any heat exchanger items for the feedwater heater shell that are managed by the Flow Accelerated Corrosion Program. Therefore, it is not clear as to how the effects of aging will be adequately managed for these components.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR, as modified by LR-ISG-2012-01.

Audit Results. Based on this audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M17, as modified by LR-ISG-2012-01. The staff also identified certain aspects of the scope of program program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR, as modified by LR-ISG-2012-01.

LRA AMP B.1.21, Inservice Inspection Summary of Information in the Application. The LRA states that AMP B.1.21, Inservice Inspection, is an existing program that is consistent with the program elements in GALL Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: cracking, leak, flaw, failure, degradation, repair, and weld.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

56 Relevant Documents Reviewed Document Title Revision / Date Inservice Inspection Nondestructive Examination Revision 7

1. ISI-NDE Program Program Plan for Fermi 2 10/28/2010 Revision 2

2. PEP06 Section XI Inservice Inspection Program 01/15/2013 Engineering Support Conduct Manual - Inservice Revision 18

3. MES23 Inspection and Testing 12/21/2012 Engineering Support Conduct Manual - Revision 8

4. MES24 Nondestructive Examinations 08/26/2010 Engineering Support Conduct Manual - Visual Revision 7

5. MES25 Examination 08/26/2010 Revision 9

6. MQA13 Fermi 2 Quality Assurance Manual - Trending 02/10/2011 Fermi 2 Engineering Support Conduct Manual - Revision 10

7. MES30 Repair Replacement Programs 12/20/2012

8. TMIS 12-0002 Self-Assessment of ISI 01/05/2012 Program Health Report Fermi 2 - ISI-NDE

9. 02/07/2013 Program Some Areas of the ASME Class 1 Pressure Retaining Boundary Were Not Pressurized as

10. CARD 04-20518 Required by ASME Section XI and Code 02/11/2004 Case N-498-1 during the 10-year System Leakage Test Performed during RF-06 Determine Next Reasonable Opportunity for

11. CARD 04-20518-03 03/05/2004 Testing

12. CARD 04-20518-05 Create SST Event for 1-Year Pressure Test 03/05/2004 Investigate Hope Creek Recirc Decon Line Crack

13. CARD 05-22440 04/18/2005 Cause Determination for Applicability to Fermi Visual Inspection Type is Incorrect for Three

14. CARD 05-23381 ASME Class 3 Integral Attachment Welds in the 06/02/2005 ISI NDE Program Plan GE 10 CFR 21 Communication - Safety

15. CARD 07-20239 01/16/2007 Information Communication ISI Ultrasonic Exam Adversely Affected by

16. CARD 07-26347 07/18/2007 Component Surface Profile New Weld Selection Required Due to Component

17. CARD 07-26900 11/01/2007 Configuration ISI Weld Selection Change Due to ALARA

18. CARD 07-25329 09/21/2007 Considerations Minimum Wall Condition Detected during UT

19. CARD 10-20422 01/19/2010 Thickness Inspection

57 Document Title Revision / Date Wall Thinning Detected on DGSW Piping during

20. CARD 10-20777 01/29/2010 UT Inspection for WO 29999174 Assess Impact of RPV Ligament Calibration

21. CARD 11-20456 01/14/2011 Standard Design On Exam Coverage Collet Failure on CRDM 4141 (insert/ withdraw

22. CARD 12-22124 03/20/2012 ports)

During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M1.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in SRP-LR.

LRA AMP B.1.22, Inservice Inspection-IWF Summary of Information in the Application. The LRA states that AMP B.1.22, Inservice Inspection IWF, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.S3, ASME Section XI, Subsection IWF. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the turbine building, reactor building, and the RHR complex. The staff also conducted an independent search of the applicants operating experience database using the keywords: loss of material, torque, preload, corrosion, support, Lubrite, and vibration isolator.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

58 Relevant Documents Reviewed Document Title Revision / Date

1. 43.000.004 Visual Examination of Component Supports Revision 32 Perform 43.000.004 Visual Examination of Component

2. WO 34378913 4/24/2012 Supports (VT-3)

Inservice Inspection-Nondestructive Examination (ISI-NDE)

3. ISI-NDE Program Revision 7 Program (Plan) for Fermi 2 Power Plant

4. 35.000.240 Bolting and Torquing Revision 41

5. 43.000.004.090404 Visual Examination of Component Supports 04/04/2009

6. ISI/IWF Program Owner Interview 03/27/2013

7. 43.000.004.120424 Visual Examination of Component Supports 04/28/2012

8. 43.000.004.120428 Visual Examination of Component Supports 04/28/2012 Evaluation of Piping System Component Anchor Points Need

9. CARD 08-21085 02/12/2009 to Support ISI Scope Determination (Closed)

Guide Clearance Less Than Shown on Hanger Sketch

10. CARD 10-29737 04/25/2011 (Closed)

Spring Can E41-3172-G01 Found More Than 5% Out of

11. CARD 10-30130 04/07/2011 Tolerance (Closed)

Spring Can E41-3172-G01 Found More Than 5% Out of

12. WO 32031674 11/12/2010 Tolerance Spring Can Pair for P44-3048-G10 More than 5% Out of

13. WO 32031768 11/14/2010 Range

14. Corrective Action Broken Bolt on West CW Reservoir Make-up pump pipe 04/26/2010 No. 10-23486 support in GSWPH

15. MES02 Evaluation Modify Support X21-2005-G69 7/14/2011 Spring Support P42-3340-G06 is out of tolerance based on the

16. CARD 14-21174 02/15/2014 current hanger sketch Support paddles misaligned on RHR Div. 1 Strut

17. CARD 14-21422 02/20/2014 E11-3158-G33

18. CARD 14-21596 Unacceptable Conditions on Spring Support E41-3162-G01 02/24/2014

19. CARD 14-21869 Rigid Support E11-3151-G29 is Bound Up 03/03/2014

59 Document Title Revision / Date

20. CARD 14-21926 Rigid Support E11-3158-G46 is Bound Up 03/03/2014

21. CARD 14-21868 Spring Support Out of Tolerance 03/01/2014 Evaluate Loss of Flange Material in Div. I EESW, DGSW & Revision 0,

22. TE-P45-14-018 RHRSW Pump Column Flange Connections 02/18/2014 EDG-11 Service Water Pump has slight Mass Loss on Bolts

23. CARD 14-21177 02/15/2014 and Flanges

24. WO 38055356 Div 2 EESW pump column and flange bolting contingency 02/18/2014

25. WO 38055401 Div 2 DGSW pump column and flange bolting contingency 03/03/2014 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the monitoring and trending and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the scope of program, preventive actions, parameters monitored or inspected and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

• The GALL Report AMP states that the scope of the program includes high-strength structural bolting. The GALL Report AMP preventive actions program element recommends using bolting material that has an actual measured yield strength of less than 150 kilopounds per square inch (ksi). The GALL Report AMP parameters monitored or inspected program element also recommends that high-strength structural bolting (actual measured yield strength greater than or equal to 150 ksi) in sizes greater than 1 inch nominal diameter, susceptible to stress corrosion cracking be monitored for cracking. In addition, the GALL Report AMP detection of aging effects program element recommends that, for high-strength structural bolting (actual measured yield strength greater than or equal to 150 ksi) in sizes greater than 1 inch nominal diameter, volumetric examination be performed to detect cracking. It is not clear that the Inservice Inspection-IWF Program is consistent with the GALL Report AMP because, based on its review of the LRA and associated AMP basis documents, the staff found no mention of the GALL Report AMP XI.S3 recommendations in the preventive actions, parameters monitored or inspected, and detection of aging effects program elements recommendations described above. In addition, for the scope of program program element it is not clear if there are high-strength structural bolts (actual measured yield strength greater than or equal to 150 ksi) in sizes greater than 1 inch nominal diameter within the scope of the Inservice Inspection-IWF Program.

During the audit, the staff made the following observations:

60

• The Inservice Inspection-IWF Program basis document states that Fermi 2 does not have ASME Code Section XI, Subsection IWF vibration isolation supports. The staff performed a database search using the keyword vibration isolator and found no vibration isolation supports within the scope of the Inservice Inspection-IWF Program.

• LRA Table 3.5.1, item 3.5.1-75, addresses sliding surfaces of column base plates that rest on Lubrite pads exposed to air - indoor uncontrolled. The LRA states that [l]ubrite plates are not subject to aging management because the listed aging mechanisms are event driven and typically can be avoided though proper design. The staff reviewed the applicants claim and noted that the applicant has not screened in any sliding surfaces with Lubrite within the scope of license renewal. During the audit, the staff performed a search of the applicants operating experience database and found no results for the keyword Lubrite.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience. The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed below.

• ASME Code Section XI, Subsection IWF, states, that to the extent practical, the same supports selected for examination during the first inspection interval shall be examined during each successive inspection interval. Recent industry operating experience has revealed situations in which supports within the IWF sample were degraded, but did not meet the IWF threshold for repair. The supports were reworked to as-new condition and remained in the IWF sample. The staffs concern with respect to aging management is that if ASME Code,Section XI, Subsection IWF supports that are part of the inspection sample are reworked to as-new condition, they are no longer typical of the other supports in the population. Subsequent ASME Code,Section XI, Subsection IWF inspections of the same sample would not represent the age-related degradation of the rest of the population. The LRA and the associated basis documents provided no discussion of how this issue would be addressed.

• The LRA states that [p]lant procedures prohibit the use of lubricants containing molybdenum disulfide. GALL Report AMP XI.S3 preventive action program element states that molybdenum disulfide should not be used as a lubricant due to its potential contribution to SCC, especially for high-strength bolts. During the audit, the staff was able to confirm that plant procedures inhibit the use of molybdenum disulfide lubricants; however, it is not clear whether molybdenum disulfide lubricants have been used at Fermi 2 before plant procedures were revised to prohibit their use. If these lubricants have been used, the staff needs additional information regarding what will be done to age manage structural bolts lubricated with molybdenum disulfide.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA AMP.

61 Audit Results. Based on this audit, the staff verified that the monitoring and trending and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S3. The staff also identified certain aspects of the scope of program, preventive actions, parameters monitored or inspected, and detection of aging effects program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application. The LRA states that AMP B.1.23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the following equipment areas: reactor building crane, turbine building cranes, hoist for residual heat removal pumps Division 1 A and C, hoists for core spray pumps A and C, reactor core isolation cooling (RCIC) pump and turbine hoist Division 1, and channel handling boom jib crane (nonsafety related). The staff also conducted an independent search of the applicants operating experience database using the keywords: crane, steel, rail, wear, corrosion, bolt, and preload.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Fermi 2 License Renewal Project, Aging Management Evaluation Report Civil/Structural. Inspection of

1. FERMI-RPT-12-LRD05 Revision 1 Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems (pages 125-143).

Fermi 2 License Renewal Project, System and Structure Scoping Results, Attachment 2, Structures. Revision 2

2. FERMI-RPT-12-LRD01 Determination of Applicability to License Renewal, Cranes, Trolleys, Monorails, and Hoists (page 200/246).

3.1.21 Inspection of Overhead Heavy Load and light

3. FERMI-RPT-12-LRD09 Load (Related to Refueling) Handling Systems Revision 1 (pages 48-93).

62 Document Title Revision / Date Plant Technical Procedure-Fermi 2, Maintenance

4. 35.717.003 Procedure. Reactor Building Crane-Frequent and Revision 7 Periodic Inspection.

Plant Technical Procedure-Fermi 2, Maintenance

5. 35.716.003 Procedure. Turbine Building Cranes-Frequent and Revision 10 Periodic Inspection.

Plant Technical Procedure-Fermi 2, Maintenance

6. 35.RIG.012 Revision 29 Procedure. Trolley and Trolley Beam Inspection.

Plant Technical Procedure-Fermi 2, Maintenance

7. 35.RIG.014 Procedure. Miscellaneous Top Running and Gantry Revision 5 Crane Inspections.

Turbine House Overhead Travelling Crane, Enrico Fermi Atomic Power Plant, Unit 2, Chapter 11, Design

8. Specification 3071-1 04/18/1970 and Construction, A. Bridge - Girders Design, EOCI Specification 61.

Fermi 2, Maintenance Conduct Manual. Hoisting, Revision 20

9. MMA07 Rigging and Load Handling. 12/18/2013 Material Handling Lifting and Rigging, Quick Hit

10. 06/17/2013 Self-Assessment Report.

11. CARD 09-28093 Sheared Bolt, Turbine Building Overhead Crane. 10/15/2009 Plan of Crane Girders and Walkway - Turbine Building

12. Drawing Detroit Edison Fermi 2 (includes location of sheared 08/12/2002 Number 6C721-2100 bolt).

Crane and Heavy Lift Inspection-NRC Operating

13. CARD 09-27996 10/13/2009 Experience Smart Sample Program.

Maintenance Crane/Hoist Inspection Procedure

14. CARD 05-26142 11/02/2005 Changes Required.

Monroe Power Plant Fuel Systems Monorail Hoist

15. CARD 04-23330 07/26/2004 Failure.

Review of Crane, Hoisting, Lifting, and Rigging

16. CARD 05-22527 04/20/2005 Related Events April 2005.

The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

63 Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M23.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.24, Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The LRA states that AMP B.1.24, Internal Surfaces in Miscellaneous Piping and Ducting Components, is a new program that will be consistent with the program elements in GALL Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, as modified by LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation. To verify this claim of consistency, the staff audited the LRA AMP.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants program basis document.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: rust, pit, corros, leak, microbiologi, min wall, MIC, and wastage.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report,

1. FERMI-RPT-12-LRD03 Revision 2 Non-Class 1 Mechanical Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Revision 1 Management Program Effectiveness Buried Pipe Inspections Indicate the Rad Waste Decant

3. CARD 12-29798 12/6/2012 Line Has Limited Remaining Service Life

4. CARD 05-25531 Untimely replacement of EDG 12 Muffler 9/30/2005 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP, as modified by LR-ISG-2012-02.

64 Although the staff verified the program elements to be consistent with those in GALL Report AMP XI.M38, the staff noted an issue that may require an RAI for clarification.

• The applicants program manages reduction of heat transfer due to fouling for heat exchanger tubes and fins exposed to various air environments, as listed in LRA Table 3.3.2-11. Based on discussions during the audit, some of the associated components are related to room coolers that are within the scope of GL 89-13, Service Water System Problems Affecting Safety-Related Equipment. The staff noted that GL 89-13 expects heat exchangers to be tested or inspected at least every 5 years, whereas the Internal Surfaces in Miscellaneous Piping and Ducting Components Program includes only a 20 percent sample that is inspected every 10 years. Therefore, it is not clear whether implementation of the Internal Surfaces in Miscellaneous Piping and Ducting Components Program would relax existing current licensing basis inspections for these room coolers.

The LRA states that the program is new and therefore provides no operating experience associated with the program. The operating experience basis document, FERMI-RPT-12-LRD09, states that a search of operating experience associated with ducts and housings did not identify any aging effects beyond those identified in the GALL Report. During the audit of the operating experience program element, the staffs independent database search did not identify any plant-specific operating experience that would indicate that the program is not capable of managing the effects of aging for components within the programs scope.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR, as modified by LR-ISG-2012-02.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M38, as modified by LR-ISG-2012-02.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.25, Masonry Wall Summary of Information in the Application. The LRA states that AMP B.1.25, Masonry Wall, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.S5, Masonry Walls. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. The LRA also states that this program is implemented as part of AMP B.1.42, Structures Monitoring, and enhancements to the program are included in the enhancements to the Structures Monitoring AMP.

65 Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the turbine building and the reactor building. The staff also conducted an independent search of the applicants operating experience database using the keywords: masonry, crack, grout, mortar, block, CMU, and wall.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Revision 1

1. FERMI-RPT-12-LRD05 Civil/Structural, Section 2.0 Background and Section 3.5 03/05/2014 Masonry Wall Program Fermi 2 Maintenance Rule Conduct Manual - Structures Revision 2

2. MMR14 Monitoring (Section 2 - General Requirements, Section 3.3 01/05/2009 Inspection Guidelines, Section 4 Evaluation of Results Operating Experience Review Report - Aging Revision 1

3. FERMI-RPT-12-LRD09 Management Program Effectiveness, Section 3.1.22 03/25/2014 Masonry Wall Program Deviation Event Report NRC Notice 87-67: Lessons

4. DER 89-0453 Learned from Regional Inspections of Licensee Actions to 06/13/1990 IE Bulletin 80-11 Nuclear Generation Memorandum - Results of

5. TMPE-08-0005 Maintenance Rule Periodic Inspection of Existing 01/09/2008 Structures in Accordance with MMR14

6. CARD 07-25811 Maintenance Rule Structural Walkdown Findings (Closed) 11/14/2008

7. WO-25823898 Work Order Details: 03-Repair grout and paint 12/09/2008 Crack in Wall Masonry on Right Side of Freight Elevator

8. CARD 08-00848 03/13/2009 Going to the Ceiling (TB-3 North Isle)

The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the acceptance criteria program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subject discussed below.

• The acceptance criteria program element of the LRA AMP basis document (FERMI-12-LRD05, Section 3.5) states that potential non-conforming conditions identified during the course of an inspection are noted and evaluated and corrective action will be taken as necessary. Section 4.0 of procedure MMR14 is referenced as the

66 basis. This section provides qualitative criteria, described in terms of structural function only, for evaluation of inspection results. The GALL Report AMP states that the extent of observed shrinkage and/or separation and cracking of masonry may not invalidate the evaluation basis or impact the walls intended function. It recommends that further evaluation is conducted if the extent of cracking and loss of material is sufficient to impact the intended function of the wall or invalidate its evaluation basis. It is not clear to the staff that this element of the LRA AMP is consistent with the recommendations in GALL Report AMP XI.S5 because the LRA acceptance criteria do not appear to address the invalidate evaluation basis aspect of the GALL Report acceptance criteria.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S5. The staff also identified certain aspects of the acceptance criteria program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.26, Metal Enclosed Bus Inspection Summary of Information in the Application. The LRA states that AMP B.1.26, Metal Enclosed Bus Inspection, is a new program that is consistent with the program elements in the GALL Report AMP XI.E4, Metal Enclosed Bus. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed what was in the applicants basis document, FERMI-RPT-12-LRD04, Metal Enclosed Bus Inspection. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the 120 kV switchyard, including the in-scope metal enclosed bus installed between CTG transformer CTG 11-1 and peaker bus 1-2b. The staff also conducted an independent search of the applicants operating experience database using the keywords: metal enclosed bus, loose connections, and water intrusion.

67 The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. FERMI-RPT-12-LRD04 Metal Enclosed Bus Inspection Revision 1

2. FERMI-RPT-12-AME01 Aging Management Review of Electrical Systems Revision 1

3. 47.000.88 Infrared Inspection Revision 6

4. CP-EM-346 Vendor Training - Infrared Thermography Revision 2

5. LRA-E-001-0 Offsite Power Recovery Paths Revision 0 Aging Management Program Evaluation Report

6. FERMI-RPT-12-LRD05 Revision 1 Civil/Structural The staff conducted its audit of the LRA program elements one through six based on the contents of the new program.

During the audit, the staff verified that the scope of program, preventive actions, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the bases documents are consistent with the corresponding elements of GALL Report AMP XI.E4, Metal Enclosed Bus.

For the parameters monitored or inspected program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

• GALL Report AMP XI.E4, Metal Enclosed Bus, program element parameters monitored or inspected states that the external portions of the metal enclosed bus, including accessible gaskets, boots, and sealants, are inspected for hardening and loss of strength due to elastomer degradation. The detection of aging effects program element states that accessible elastomers (e.g., gaskets, boots, and sealants) are inspected for degradation including surface cracking, crazing, scuffing, dimensional change, (e.g., ballooning and necking), shrinkage, discoloration, hardening, and loss of strength.

• Basis Document Fermi RPT-12-LRD04 Metal Enclosed Bus Inspection, states that it is a new condition monitoring program that is consistent with GALL Report AMP XI.E4, Metal-Enclosed Bus.

• The staff reviewed the AMP basis document program element parameters monitored or inspected and it is not clear to the staff that the program element of the LRA AMP is consistent with the recommendation in the GALL Report AMP since there was no mention of the aging effects of elastomers in the proposed program element. The GALL Report AMP program element states that the external portions of the metal enclosed bus be inspected for hardening and loss of strength due to elastomer degradation.

68 In the LRA, the applicant stated that there is no operating experience at Fermi 2 involving the aging effects managed by this program. The applicant did not identify any operating experience for this program. During the audit of the operating experience program element, the staffs independent database search did not find any operating experience that would not be bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements of GALL Report AMP XI.E4. The staff also identified certain aspects of the parameters monitored or inspected program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.27, Neutron-Absorbing Material Monitoring Summary of Information in the Application. The LRA states that AMP B.1.27, Neutron-Absorbing Material Monitoring, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M40, Neutron-Absorbing Materials Other than Boraflex. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: Boral, neutron-absorber, and coupon.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. 57.000.19 Spent Fuel Storage Rack Management Guidelines Revision 5 High Density Spent Fuel Storage Rack Surveillance Coupon

2. 82.000.16 Revision 34 Removal/Installation

3. MQA13 Trending Revision 9

4. MQA11 Condition Assessment Resolution Document Revision 35

5. NET-300058-01 Inspection and Testing of Boral Surveillance

69 Document Title Revision / Date Coupon YD610122-1-7 from the Fermi 2 Generating Station

6. CARD 10-27652 Boral Coupon Test Results

7. CARD 10-27755 Enhancements to Boral Coupon Surveillance

8. FERMI-RPT-12-LRD03 Neutron Absorbing Material Monitoring Revision 2 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M40, Neutron-Absorbing Materials Other than Boraflex. The staffs evaluation of aspects of the program elements associated with enhancements that are not necessary for consistency will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.28, Non-EQ Cable Connections Summary of Information in the Application. The LRA states that AMP B.1.28, Non-EQ Cable Connections, is a new program that is consistent with the program elements in GALL Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the LRA AMP.

Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the 120 kV switchyard, 345 kV switchyard, transformer SS #64, transformer SS #65, and the Division 2 ESS switchgear room in the 3rd floor of the auxiliary building as well as levels 3 and 2 of the reactor building. The staff also conducted an independent search of the applicants

70 operating experience database using the keywords: loose connections, connections, and corrosion, as well as documents provided to support the subject LRA AMP.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date One Line Diagram - Plant 4160 V. & 480 V. System Revision AZ

1. Drawing 2500-01 Service 6/22/14 Revision 0

2. Drawing LRA-E-001-0 Offsite Power Recovery Paths 10/3/2012 3000 Amp & 1200 Amp Bus Tap Box System Service Revision A

3. Drawing 4E721-2988-10 Box 65X 2/9/74 3000 Amp & 1200 Amp Bus Tap Box System Service Revision A

4. Drawing 4E721-2988-7 Box 64 2/9/74 DYH Bus, 3000 Amp to 1200 Amp Bus Tap Box System Revision AB

5. Drawing 4E721-2988-8 Service Box 64 11/17/76 Revision A

6. Drawing 4E721-2988-11 1200 Amp Bus Tap Box System Service Box 65X 2/9/74 Cable Bus Reactor Aux Bldg 4160 V, 480 V Switchgear Revision I

7. Drawing 6E721-2988-02 Rooms 2nd and 3rd Floors 7/8/10 Plant Technical Procedures - Fermi 2 Infrared Revision 6

8. 47.000.88 Inspection 8/20/13 Perform Infrared Inspection of 2PB2-5 Div 2 130 VDC

9. Work Order 35253609 5/9/14 Dist Panel Perform Infrared Inspection of 64A 4160 V BOP SWGR

10. Work Order 35219249 5/4/14 Bus Perform Infrared Inspection of Recirc MG Regulator

11. Work Order 35097157 1/30/14 Cabinet

12. Work Order 34617947 Perform Infrared Inspection of MPU-4 BOP-2 2/15/14

13. CARD 14-20090 Thermal Anomalies in PRMG set B Voltage regulator 1/23/14

14. CARD 13-28052 Thermal Anomalies in MPU4 11/14/13

15. Work Order Inspect & Test 4160 V Switchgear Bus 69K 3/31/12 R332100100 Plant Technical - Fermi 2 Maintenance Procedure 4160 Revision 35

16. 35.301.001 V Switchgear 4/23/10 Plant Technical - Fermi 2 Maintenance Procedure 480 Revision 35

17. 35.304.005 V Switchgear General Maintenance 4/23/2010

71 Document Title Revision / Date Design Engineering Standard for Cable Connectors and Revision AT

18. Spec. No 3071-128-EQ Terminations 8/7/14 Electrical Engineering Standard for Cable Splices and

19. Spec. No 3071-128-ER Revision AJ 7/14 Joints During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the parameters monitored or inspected and detection of aging effects program elements sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subject(s) discussed below.

• The applicant stated that one method of testing cable connections relied upon for maintenance is the use of thermography (infrared inspection). The staff reviewed the applicants thermography procedure 47.000.88. It is not clear to the staff that the thermography inspections are directed to take place under normal full load conditions of the affected electrical connections.

• It is not clear to the staff as to whether the representative sample designated by the applicant adequately addresses the various connection types noted by the staff (per Spec. No. 3071-128-EQ).

• Maintenance Procedures 35.301.001 and 35.301.001 provide values for checking the connection tightness by providing electrical connection torque values. It is not clear to the staff that these procedures are consistent with EPRI Guidance (EPRI TR-104213, Bolted Joint Maintenance & Applications Guide) concerning re-torqueing of electrical connections.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). A total of 57 work orders were identified. The review of the identified items did not reveal any significant or unusual operating experience issues.

During the staff walkdown, the staff identified concerns with cable connection maintenance. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subject(s) discussed below.

• During the electrical connection walkdown, the staff noted two 3000 amp/1200 amp bus tap boxes located in the Division 2 ESS 4160 V and 480 V switchgear room. It is not clear to the staff whether the connections inside these tap boxes are inspected under the current preventive maintenance procedures. These connections are within the scope of license renewal. The staff is concerned that if the in-scope tap box connections are not inspected or tested under current plant maintenance programs, then a one-time test under LRA AMP B.1.28 performed on a sampling basis may not be adequate to ensure

72 that either aging of metallic cable connections is not occurring and/or that the existing preventive maintenance program is effective such that a periodic inspection program is not required.

• It is not clear to the staff what routine maintenance is currently performed on the in-scope safety related 4160 V bus (including low side connections of transformer SS #65) electrical connections. The staff concern is that a one-time test under LRA AMP B.1.28 performed on a sampling basis may not be adequate to ensure that either aging of metallic cable connections is not occurring and/or that the existing preventive maintenance program is effective such that a periodic inspection program is not required.

• During the electrical connection walkdown of the 345 kV recovery path, a large number of birds were observed on the cable bus (Calvert bus) installed from SS #65 transformer to 4160 V bus 65 in the auxiliary building. This cable bus is depicted on one-line diagram 6SD721-2500-01 and drawing 6E721-2988-02. The staff is concerned that this cable bus can experience accelerated degradation due to bird debris.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR for a one-time inspection.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.E6. The staff also identified certain aspects of the parameters monitored or inspected and detection of aging effects program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.29, Non-EQ Inaccessible Power Cables (400 V to 13.8 kV)

Summary of Information in the Application. The LRA states that AMP B.1.29, Non-EQ Inaccessible Power Cables (400 V to 13.8 kV), is a new program that will be consistent with the program elements in GALL Report AMP XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the AMP program elements described in the applicants basis document, the referenced supporting documentation, and relevant plant specific operating experience. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of in-scope manholes. The staff also reviewed additional documentation including corrective actions, engineering design packages, and completed manhole and duct bank modifications.

The staff also reviewed manhole construction photographs including as-found and as-left

73 manhole refurbishment. The staff also conducted an independent search of the applicants operating experience database using the keywords: cable, vault, manhole, submerged, insulation, jacket, and duct.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Electrical Screening and Aging Reviews - Sections 3.3.5, Revision 1

1. FERMI-RPT-12-AME01 4.1.4.5, 4.7.2 and Attachment 4 Aging Management Program Evaluation Results -

2. FERMI-RPT-12-LRD04 Electrical - Non-EQ Inaccessible Power Cable (400 V to Revision 1 13.8 kV) Program NQA Observations of the Dewatering Efforts for the 120

3. 07-28031 12/14/2007 kV Switchyard Manholes

4. 07-23319 Degraded Conditions in Electrical Manholes 6/13/2007

5. 07-23463 Degraded Electrical Conditions in Manholes 6/21/2007

6. 08-23283 Degraded Conditions Noted in Underground Duct Banks 5/1/2008

7. 08-27043 Underground Cable Ducts and Manholes 10/23/2008 Include LV Power, I&C Cables Between MH16946 &

8. 12-23595 12/23/95 16947 into the Cable Condition Monitoring Program

9. 0500034/2011005 Fermi Power Plant, Unit 2: Integrated Inspection Report 1/30/2012

10. 0500034/2012005 Fermi Power Plant, Unit 2: Integrated Inspection Report 1/26/2013

11. 0500034/2013005 Fermi Power Plant, Unit 2: Integrated Inspection Report 1/27/2014 NQA Surveillance 06-0125 Fermi Vulnerability to

12. 07-10001 1/5/2007 Underground Cable failures

13. 13-26016 Manhole Cover Not Water Tight 6/27/2013 Sump Pump Installation for EF-1, South EF-2 Area Revision 0

14. EDP-35533 Manholes Sump Pump Discharge Piping Installation for 120 V Area Revision A

15. EDP-35532 Manholes

16. EDP-35534 Sump Pump Installation For N-W EF2 Manholes Revision 0

17. EDP-35536 Sump Pump Installation for SBO Manholes Revision A Material Condition of cable Manhole 16955 is

18. 07-22745 5/18/2007 Unsatisfactory Appendix A - Compensatory Pumping Frequency for Revision 0

19. PEP-21 Manholes with Sump Pumps 9/16/2011

74 Document Title Revision / Date

20. WO#24243797 Manhole Inspections Division 2 5/10/2007 Inaccessible or Underground Power Cable Failures That

21. GL 2007-01 Disable Accident Mitigation Systems or Cause Plant 2/7/2007 Transients Detroit Edisons 90 Day Response to Generic Letter 2007-01, Inaccessible or Underground Power Cable

22. NRC-07-0017 5/4/2007 Failures That Disable Accident Mitigation Systems or Cause Plant Transients Fermi 2 - Closeout of Generic Letter 2007-01 Inaccessible or Underground Power Cable Failures That

23. 10/31/2008 Disable Accident Mitigation Systems or Cause Plant Transients Aging Management Program Evaluation Results -

24. FERMI-RPT-12-RD04 Revision 1 Electrical NRC CDBI - Discrepancy Between UFSAR and Edison

25. 07-23612 7/24/2007 Specifications for Cables Manhole 16944 Has High Water Alarm With Sump Pump

26. 11-00013 11/25/2011 Running Manhole 16522 Sump Pump Running Continuously in

27. 11-00014 11/25/2011 Auto with level low in Sump

28. 11-00012 Manhole 16551 High Level Alarm With Pump Running 11/25/2011 NQA Surveillance 06-0125 Fermi Vulnerability to

29. 07-10001 Underground Cable Failures

30. 34472172 Work Order - Perform Annual Water Level Monitoring 10/14/2013 Revision 5

31. MES60 Electrical Cable Monitoring Program 9/2/2011

32. TMIS-07-0084 Benchmark Results - Underground Cable Management 9/14/2007 Manholes Installed by SBO Modification Do Not Have

33. 04-24082 9/7/2004 Water Removal Capability

34. 05000341/2011002 Fermi Power Plant, Unit 2, Integrated Inspection Report 5/2/2011

35. 05000341/20110003; Fermi Power Plant, Unit 2, Integrated Inspection Reports 8/1/2012 07200071/2010001

36. 05000341/2013002 Fermi Power Plant, Unit 2, Integrated Inspection Report 5/6/2013

37. 05000341/2013005 Fermi Power Plant, Unit 2, Integrated Inspection Report 1/27/2014

38. 05000341/2014003 Fermi Power Plant, Unit 2, Integrated Inspection Report 7/25/2014 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

75 During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the program elements, scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.E3.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.30, Non-EQ Instrumentation Circuits Test Review Summary of Information in the Application. The LRA states that AMP B.1.20, Non-EQ Instrumentation Circuits Test Review Program, is a new program that will be consistent with the program elements in GALL Report AMP XI.E2, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits. To verify this claim of consistency, the staff audited the LRA AMP.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the AMP program elements described in the applicants basis document, referenced supporting documentation, and relevant plant specific operating experience. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: cable, connector, termination, radiation monitoring, flux monitoring, insulation, and jacket.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Area Radiation Monitor (ARM) Detector, Channel 48,

1. 10-24025 5/13/2010 Cable Connection Degradation Operating Experience Review Report - Aging

2. FERMI RPT-12-LRD09 Management Program Effectiveness: 3.2.7 Non-EQ Revision 1 Instrumentation Circuits Test Review Program

76 Document Title Revision / Date Aging Management Review of Electrical Systems - Revision 1

3. FERMI-RPT-12-AME01 Sections 3.3.4, 4.1.4.4, 4.7.4, and Attachment 3 3/5/2014 Aging Management Program Evaluation Results -

4. FERMI-RPT-12-LRD04 Revision 1 Electrical PASS General Area Radiation Monitor and PASS Liquid

5. 11-23833 4/14/2011 sampling Radiation detector Cables Deteriorating Detector cable Insulation Cracked and Cable No Longer

6. 10-00570 5/13/2010 Restrained By Connector System D1100, Process Radiation Monitor Classified as

7. 07-20839 (a)(1) by MRule Expert Panel

8. 06-23087 Loose Wiring Connection Causing Spurious Alarms 5/3/2006 Fuel Pool Ventilation Exhaust Radiation Monitor, Division Revision 15

9. 64.020.105 1 Channel A Radiological Calibration 10/14/2007 Revision 2

10. PEP21 Cable Monitoring Notebook 10/21/2011 Engineering Support Conduct Manual - Electrical Cable Revision 6

11. MES60 Monitoring Program 6/20/2013

12. 07-22348 Main Steam Line Radiation Monitor D Self-Test Fault 6/1/2007

13. 05-21965 SS-1 Rad Monitor Control Terminal Failed 3/24/2005 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.E2.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

77 LRA AMP B.1.31, Non-EQ Insulated Cables and Connections Summary of Information in the Application. The LRA states that AMP B.1.31, Non-EQ Insulated Cables and Connections, is a new program that is consistent with the program elements in GALL Report AMP XI.E2, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: cable, connection, jacket, and termination.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. EDP-35501 Degraded Cables on Unitized Actuators Revision 2

2. PEP21 Cable Monitoring Program Notebook 10/21/11 Aging Management Program Evaluation Results -

3. FERMI-RPT-12-LRD04 Revision 1 Electrical Engineering Support Conduct Manual MES60 - Electrical Revision 5

4. MES60 Cable Monitoring Program 9/2/11

5. 10-29898 Cables for N2100F609 are in intermediate stage of aging 11/1/2010 Age Related Degradation of Cables to LP Valve Unitized

6. 06-25291 6/16/2006 Actuators

7. 09-22863 Heat Damaged Cables on N2100F609 4/16/2009 Indications That Some BOP cables are Operating Above

8. 12-24807 5/30/2012 Calculated Ampacity Limits Aging Management Review of Electrical Systems - Revision 1

9. FERMI-RPT-12-AME01 Sections 3.3.1, 4.1.4.1, and 4.7.3. 3/5/2014 Document Applicability of INPO Topical Report 10-69,

10. 10-2394 5/11/2014 Cable Aging and Monitoring to Fermi

11. 06-22521 Heat Damage to Control Cable to Motor Operator 4/19/2006 Document Applicability of INPO Topical Report 10-69,

12. 10-23934 5/11/2010 Cable Aging and Monitoring to FERMI

78 Document Title Revision / Date Management Request for Independent Gap Analysis

13. 10-23652 Between INPO EFG-16 and MES60 - Electric Cable 4/30/2010 Monitoring Program Document GAP Study Between INPO EPEG 16 and the

14. 10-21248 2/18/2010 Cable Monitoring Program During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the parameters monitored or inspected program element sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subject discussed below.

• LRA AMP B.1.31, Non-EQ Insulated Cables and Connections, states in the program description that adverse localized environments will be determined based on a plant spaces approach. Basis document, FERMI-RPT-12-LRD04, Aging Management Program Evaluation Results - Electrical, also states in the program description that an adverse localized is a plant-specific condition that will be determined based on a plant spaces approach. In addition, the AMP basis document, under program element parameters monitored or inspected, also states that, The adverse localized environment is a plant-specific condition that will be determined based on a plant spaces approach.

GALL Report AMP XI.E1, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, states, Adverse localized environments can be identified through the use of an integrated approach.

This approach may include, but is not limited to, (a) the review of Environmental Qualification (EQ) zone maps that show radiation levels and temperatures for various plant areas, (b) consultations with plant staff who are cognizant of plant conditions, (c) utilization of infrared thermography to identify hot spots on a real-time basis, and (d) the review of relevant plant-specific and industry operating experience. Clarification is needed on the applicants use of a plant spaces approach in identifying adverse localized environments, operating experience, and its consistency with GALL Report AMP XI.E1.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in

79 GALL Report AMP XI.E1. The staff also identified certain aspects of the parameters monitored or inspected program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in SRP-LR Table 3.0-1, FSAR Supplement for Aging Management of Applicable Systems.

LRA AMP B.1.32, Oil Analysis Summary of Information in the Application. The LRA states that AMP B.1.32, Oil Analysis, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M39, Lubricating Oil Analysis. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted a walkdown of the chemistry laboratory. The staff also conducted an independent search of the applicants operating experience database using the keywords: fouling, samples, and lubricate.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date CTG 11-1 demulsibility characteristic of lube oil sample is

1. CARD 11-29661 10/26/2011 out of specification

2. CARD 10-25611 Contaminant Found in EDG 12 Crankcase Oil Sample 07/02/2010 Copper in East CRD Gearbox Lubricating Oil on

3. CARD 09-20718 02/04/2009 Increasing Trend

4. CARD 12-21327 Slight Decrease in EDG 11 lube oil pressure 02/17/2012

5. CARD 08-25580 High Wear on RCIC Pump Oil Samples 08/28/2008 Revise Specifications 3071-128-EQ. ER ET and

6. CARD 12-26097 07/19/2012 Maintenance Procedure 35.CON.027

7. CARD 10-21441 PM E902, Flush RCIC EG-R not needed 02/16/2010 Aging Management Program Evaluation Report

8. FERMI-RPT-12-LRD03 Revision 2 Non-Class 1 Mechanical Operating Experience Review Report- Aging

9. FERMI-RPT-12-LRD09 Revision 1 Management Program Effectiveness

10. DCR 10-0414 Predictive Maintenance Program Revision 1

80 Document Title Revision / Date Water and Sediment in Lubricating and Fuel Oils by

11. DCR 88-4979 Revision 1 Centrifuge Method

12. DCR 051598 Color and Appearance Test for Oils Revision 5

13. DCR 09-1073 Water Separability of Oils Revision 3

14. DCR 06-2276 HIAC/ROYCO Automatic Particle Size Analyzer Revision 10

15. DCR 10-1587 Trending Revision 9 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M39. The staffs evaluation of aspects of the program elements associated with enhancements that are not necessary for consistency will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.33, One-Time Inspection Summary of Information in the Application. The LRA states that AMP B.1.33, One-Time Inspection, is a new program that will be consistent with the program elements in GALL Report AMP XI.M32, One-Time Inspection. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: corros, crack, foul, and loss of material.

81 The table below lists the document that was reviewed by the staff and was found relevant to the audit. This document was provided by the applicant or was identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report,

1. FERMI-RPT-12-LRD03 Non-Class 1 Mechanical, Section 3.4, One-Time Revision 2 Inspection During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

In the LRA, the applicant stated that [t]his inspection program applies to potential aging effects for which there is no operating experience at Fermi 2 indicating the need for an aging management program. Therefore, the applicant did not identify any operating experience.

During the audit of the operating experience program element, the staffs independent database search did not find any operating experience that would not be bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M32.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.34, One-Time Inspection - Small-Bore Piping Summary of Information in the Application. The LRA states that AMP B.1.34, One-Time Inspection - Small-Bore Piping, is a new program that is consistent with the program elements in GALL Report AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping.

To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: weld, cracking, crack, failure, socket, butt, thermal, fatigue, and leakage.

82 The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Class 1

1. FERMI-RPT-12-LRD02 Revision 1 Mechanical Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Revision 1 Management Program Effectiveness

3. FERMI-RPT-12-LRD08 Operating Experience Review Report Revision 1 Steam Leak on 2 inch Weldolet on East End of Heat

4. CARD 04-25140 11/05/2004 Exchanger

5. CARD 08-21104 Bent Vent Line off of RCIC Pump Discharge 02/14/2008 NDE of Socket Fillet Weld (3/4 sockolet to pipe fillet

6. CARD 08-21170 02/18/2008 weld)

Leakage Identified during RPV Pressure Test

7. CARD 14-22693 03/22/2014 E1100f116A (Threaded Cap)

During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

• During the audit, the staff noted that the LRA does not provide the weld population for the applicants in-scope small-bore piping. The GALL Report AMP, detection of aging effects program element recommends that, for a one-time inspection to detect cracking due to thermal or mechanical cycling or due to stress corrosion cracking, volumetric examinations should be performed at sufficient number of locations to ensure an adequate sample size. It is not clear to the staff how the inspection sample size would be calculated, since the population of Class 1 small-bore butt welds and socket welds within scope of the program are not provided in the LRA.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance

83 criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M35. The staff also identified certain aspects of the detection of aging effects program element of the LRA AMP, for which additional information and evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.36, Protective Coating Monitoring and Maintenance Summary of Information in the Application. The LRA states that AMP B.1.36, Protective Coating Monitoring and Maintenance, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.S8, Protective Coating Monitoring and Maintenance Program. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: coating, torus, and Service Level 1.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. Fermi-RPT-12-LRD05 Protective Coating Monitoring and Maintenance Program Revise PM to Inspect AUX BLR Stack for Wall Thinning

2. CARD 03-12878 (Closed)

3. CARD 03-12847 Revise PM to Inspect Aux BLR Stack for wall thinning

4. CARD 04-26143 Degraded Protective Coatings in Torus Vent Header

5. CARD 04-26144 Evaluate Degraded Coatings in Drywell Basement

6. CARD 04-26062 Degraded Protective Coating in Drywell Basement Area Protective Coating Deficiencies Noted During IWE

7. CARD 05-25459 Inspections of Torus Exterior

8. CARD 07-26887 Degraded Protective Coating in Drywell

9. CARD 08-21804 Repair of Degrade Protective Coatings in Torus

10. CARD 09-22447 Torus Interior Degraded Coating Repairs

11. CARD 09-22973 Torus Coating Degraded on RHR Test Return Line

84 Document Title Revision / Date

12. CARD 07-26785 NRC Identified Issues in Torus

13. WO 27262434 Repair Degraded Coatings inside Torus

14. WO 27001052 Areas of loose coating found Repeated Wetting and Drying Has Degraded the Torus

15. CARD 09-27158 Protective Coating

16. CARD 10-30087 Loose Flaking/Coatings Inside Torus

17. WO 30368456 Torus Vapor Space Coating Inspections and Repairs Design Specification for Field Painting Level I Steel and

18. 3071-359 Revision B Concrete Coating Inside Drywell Enrico Fermi Atomic Power Plant Unit No 2. Evaluation Revision 4

19. DECO-12-2191 of Containment Coatings 06/1985

20. 35.CON.002 QA Level I Protective Coating Systems Revision 31

21. 43.000.019 Primary Containment Inspection Revision 5

22. MQA10 Quality Assurance Program Applicability Revision 8

23. MQA11 Condition Assessment Resolution Document Revision 36

24. Containment ISI Section XI IWE Program Owner Input 03/27/2013 IWE Primary Containment Inspection Program 2nd

25. Quarter 2013 Program Health Report The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S8.

85 Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.37, Reactor Head Closure Studs Summary of Information in the Application. The LRA states that AMP B.1.37, Reactor Head Closure Studs Program, is an existing program with an exception and enhancements that is consistent with the program elements in GALL Report AMP XI.M3, Reactor Head Closure Stud Bolting. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. This audit report does not consider the sufficiency of the exception, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: bolt, bolting, closure stud, stress corrosion cracking, wear, and cracking.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Class 1

1. FERMI-RPT-12-LRD02 Revision 1 Mechanical - Reactor Head Closure Studs Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Management Program Effectiveness Section 3.1.9 Revision 1 Reactor Head Closure Studs

3. DSN 35.710.026 Reactor Vessel Reassembly Revision 16

4. DNS F2S82-5866 Preservice Inspection of RPV Studs and Nuts 10/8/1982

5. FNP2-B6.20-0001 UT Examination, Closure Head Stud in Place 11/6/2010

6. GE RF-11-04 Bolting Visual Examination Report 03/27/2006 Condition Assessment Resolution Document, Stud

7. CARD 12-23778 4/25/2012 Elongation Readings Out of Spec Condition Assessment Resolution Document, RPV

8. CARD 06-22792 04/26/2006 Head Was Cocked While Lowering on RPV Guidepins Condition Assessment Resolution Document, Lost

9. CARD 12-22362 03/28/2012 Screw during RPV Head De-tensioning The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of the preventive actions and corrective actions program elements of the LRA AMP associated with the

86 exception were not evaluated during this audit. Aspects of these program elements that are not associated with the exception were evaluated and are described below.

During the audit, the staff verified that the scope of program, parameters monitored or inspected, monitoring and trending, and acceptance criteria of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the preventive actions and corrective actions program elements not associated with the exception are consistent with the corresponding program elements of the GALL Report AMP.

The staffs evaluation of aspects of these program elements associated with the exception will be addressed in the SER.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that for the corrective actions, and preventive actions program elements, the aspects of the LRA AMP program elements not associated with the exceptions are consistent with the corresponding program elements in GALL Report AMP XI.M3. The staffs evaluation of aspects of the program elements associated with exceptions will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.38, Reactor Vessel Surveillance Summary of Information in the Application. The LRA states that AMP B.1.38, Reactor Vessel Surveillance, is an existing program with enhancement and exception that is consistent with the program elements in GALL Report AMP XI.M31, Reactor Vessel Surveillance. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes the enhancement necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. The exception to the GALL Report AMP will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: weld, plate, vessel, neutron, irradiation, embrittlement, and surveillance program.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

87 Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Class 1

1. FERMI-RPT-12-LRD02 Revision 1 Mechanical, Section 4.10, Reactor Vessel Surveillance Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Management Program Effectiveness, Section 3.1.28, Revision 1 Reactor Vessel Surveillance Program Revision 1

3. FERMI-RPT-12-LRD06 TLAA and Exemption Evaluation Results 03/14/2014 NRC Letter to Detroit Edison Company, Fermi 2 -

Issuance of Amendment Re: Implementation of the

4. 01/30/2003 BWRVIP RPV ISP to Address the Requirements of Appendix H to 10 CFR Part 50 (TAC No. MB5840)

Fermi 2 Engineering Support Conduct Manual, Inservice Revision 18

5. MES23 Inspection and Testing, Section 3.9, Reactor Vessel 12/21/2012 Material Surveillance DTE Energy Letter to the NRC, Proposed Licensed Amendment Request to Revise the Reactor Coolant

6. NRC-05-0001 03/17/2005 System Pressure and Temperature Limit Curves in Technical Specifications 3.4.10 Technical Specification Curves for Pressure/Temperature

7. CARD 11-30644 for Core Critical and Core Not Critical Determined to be 12/01/2011 Non-Conservative DTE Energy Letter to the NRC, Response to Request for Additional Information Regarding the Proposed License

8. NRC-13-0026 07/09/2013 Amendment to Relocate the Pressure and Temperature Curves to a Pressure Temperature Limits Report GE Hitachi Report, DTE Energy/Enrico Fermi Power Plant Revision 1

9. NEDC-33785P 2 Pressure and Temperature Limits Report Up To 24 and 32 Effective Full-Power Years June 2013 NRC Letter to DTE Energy, Fermi 2 - Issuance of Amendment Re: Relocation of Pressure and Temperature

10. 02/04/2014 Curves to a Pressure Temperature Limits Report (TAC No.

MF0446)

11. GE Hitachi Nuclear Revision 0 Energy Fermi-2 Fluence Report to Support P-T Curve Evaluation 0000-0145-9377-R0 April 2012

12. GE Hitachi Nuclear Pressure-Temperature Curves and RPV Fracture Revision 2 Energy Toughness Evaluation for DTE Energy Fermi Unit 2 December 2013 0000-0144-4325-R2 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancement. Aspects of the detection of aging effects program element of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

88 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the detection of aging effects program element not associated with the exception are consistent with the corresponding program elements in the GALL Report AMP.

The staffs evaluation of aspects of this program element associated with the exception will be addressed in the SER.

In addition, the staff found that for the monitoring and trending program element associated with the program enhancement, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subject discussed below.

• The program enhancement states that the applicant will revise its procedures to ensure that new fluence projections through the period of extended operation and the latest vessel beltline adjusted reference temperature tables are provided to the Boiling Water Reactor Vessel Internals Project prior to the period of extended operation (i.e., prior to September 20, 2024). The staff noted that the applicants program is an existing program and upon receipt of renewed license the program should continue to provide adequate fracture toughness and dosimetry data throughout the license renewal term.

However, the LRA states that the applicants enhancement will be implemented prior to the period of extended operation, but not within a specific time period upon receipt of renewed license. The staff finds that the enhancement regarding data sharing is important to maintain the effectiveness of the Integrated Surveillance Program (ISP) and, therefore, it is necessary to implement the program enhancement within a specific time period upon receipt of renewed license unless adequate justification is provided.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing RAIs for the subject discussed below.

• As previously discussed, the monitoring and trending program element is associated with the program enhancement. The staff finds that it is necessary to revise the description of the program enhancement in the UFSAR supplement in such a manner to implement the enhancement within a specific time period upon receipt of renewed license unless adequate justification is provided.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M31. The staff also verified that for the detection of aging effects program element, the aspects of the LRA AMP program element not associated with the exception are consistent

89 with the corresponding program element in GALL Report AMP XI.M31. The staffs evaluation of aspects of the program element associated with the exception will be addressed in the SER.

The staff also identified certain aspects of the monitoring and trending program element of the LRA AMP associated with the program enhancement, for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR supplement.

LRA AMP B.1.39, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Summary of Information in the Application. The LRA states that AMP B.1.39, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the RHR complex, general service water pumphouse, and shore barrier. The staff also conducted an independent search of the applicants operating experience database using the keywords:

RHR, RHR complex, RHR service water, general service water pumphouse, pumphouse, and shore barrier.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Revision 1

1. FERMI-RPT-12-LRD05 Civil/Structural 03/05/2014 Fermi 2 Maintenance Rule Conduct Manual - Structures Revision 2

2. MMR-14 Monitoring 01/05/2009 Revision B

3. 3071-099 Project Specification - Structural Steel 06/21/1983 Revision 41

4. 35.000.240 Fermi 2 Maintenance Procedure - Bolting and Torquing 12/14/2009 Operating Experience Review Report - Aging Revision 1

5. FERMI-RPT-12-LRD09 Management Program Effectiveness RG. 1.127 03/25/2014

90 Document Title Revision / Date Memorandum - Results of Maintenance Rule Periodic Inspection of Existing Structures in Accordance with

6. TMPE-08-0005 01/09/2008 MMR14 with Completed MMR14001 Structural Walkdown Checklist

7. TMPE-02-0122 Baseline Structures Inspection for Maintenance Rule 04/05/2002 2012 Maintenance Rule Focused Self-Assessment

8. TMPE-12-0066 07/06/2012 Report EDG 12 Service Water Pump Has Some Mass Loss on

9. CARD 14-21178 02/15/2014 Bolts and Flanges NRC Question - Investigate RHR Complex North Wall

10. CARD 09-26756 09/01/2009 Condition Div. 1 EESW Pump Column Flange and Bolting Missing

11. CARD 14-21175 02/15/2014 Some Mass Perform Div. 1 RHR Reservoir Zebra Mussel and Ball

12. 02/08/2014 Valve Inspection

13. 43.000.001 Shore Barrier Surveillance 07/10/2014 MMR14 Structures Monitoring Walkdown - CTG

14. CARD 14-27002 09/09/2014 Findings

15. Drawings 6C721-0044, 045, 046, 047, 048 03/19/2014

16. Baseline Structures Inspection Report 04/16/1997 Revision 24

17. 43.000.001 Shore Barrier Surveillance 03/13/2002 RG 1.127 Water Control System Program Owner

18. 03/22/2013 Interview

19. CARD 07-27267 Support W-R30-N5177-G14 has one anchor nut missing 11/12/2007

20. CARD 07-26112 Maintenance Rule structural walkdown finding 10/23/2007

21. WO-26166643 11/21/2007

22. WO-25883684 10/15/2007 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

91

• 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 greater than or equal to 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. 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 parameters monitored or inspected, detection of aging effects, and acceptance criteria 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.

• The detection of aging effects program element of the LRA AMP states that inspection of water-control structures will be performed on an interval not to exceed 5 years. The GALL Report AMP recommends periodic inspections to be performed at least once every 5 years. The GALL Report also recommends 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. It is not clear to the staff that the detection of aging effects program element is consistent with the recommendations in GALL Report AMP XI.S7 because no discussion regarding the provision for increased inspection frequency was provided by the applicants AMP.

• As described in the LRA AMP program description in relation to the detection of aging effects program element, the program performs periodic visual examinations to monitor the condition of water-control structures and structural components, including steel piles required for the stability of the shore barrier. The GALL Report AMP recommends visual inspections to detect degradation of water-control structures. However, during its onsite audit, the staff noted that the applicant does not plan to perform visual inspections of the submerged steel piles at the shore barrier. It is not clear how the effects of aging of the steel piles will be adequately managed during the period of extended operation.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S7. The staff also identified certain aspects of the parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

92 LRA AMP B.1.40, Selective Leaching Summary of Information in the Application. The LRA states that AMP B.1.40, Selective Leaching, is a new program that will be consistent with the program elements in GALL Report AMP XI.M33, Selective Leaching. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants Aging Management Program Evaluation Report.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: dealloy, dealum, dezinc, degraph, leach, and graphit.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Fermi 2 License Renewal Project

1. FERMI-RPT-12-LRD03 Aging Management Program Evaluation Report Revision 2 Non-Class 1 Mechanical Fermi 2 License Renewal Project

2. FERMI-RPT-12-LRD09 Operating Experience Review Report - Aging Revision 1 Management Program Effectiveness Condition Assessment Resolution Document

3. CARD 06-27257 11/10/2006 Evaluate OE 23553 on BNL Inline check valves During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience. The staff determined that the lack of relevant operating experience identified by the applicant and confirmed by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging.

During the audit of operating experience program element, the staff made the following observation:

• The staff reviewed CARD 06-27257 documenting the licensees response to an industry operating experience report regarding wall thinning and porosity due to de-aluminification (i.e., selective leaching) of inline check valves operating in the service

93 water system and constructed of aluminum bronze. In response to this report, the licensee conducted a component search and identified 8 similar components and found that they are not susceptible to the same kind of failure due to being constructed of stainless steel and installed in a clean air application.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.33.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.41, Service Water Integrity Summary of Information in the Application. The LRA states that AMP B.1.41, Service Water Integrity, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M20, Open-Cycle Cooling Water System. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff inspected portions of the emergency equipment service water, residual heat removal service water, and the emergency diesel generator service water systems within the RHR complex. The staff also conducted an independent search of the applicants operating experience database using the keywords:

biofoul, biological, blockage, cavitat, cooler, erosi, foul, heat sink, heat exch, heat trans, mic, sediment, service water, and through wall.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report,

1. FERMI-RPT-12-LRD03 Non-Class 1 Mechanical, Section 4.12, Service Water Revision 2 Integrity Operating Experience Review Report - Aging

2. FERMI-RPT-12-LRD09 Management Program Effectiveness, Section 3.1.30, Revision 1 Service Water Integrity

3. NRC-90-0012 Fermi 2 Response to Generic Letter 89-13 1/26/1990

94 Document Title Revision / Date Engineering Support Conduct Manual, GL 89-13

4. MES52 Revision 5 Safety-Related Service Water Monitoring Program Engineering Support Conduct Manual Heat Exchanger

5. MES54 Revision 3 Component Monitoring Program GL 89-13 Internal Corrosion Inspections on RHRSW

6. SIA Rpt 1301233.401 3/14/2014 System Life Cycle Management and Buried Piping Evaluation

7. SIA Rpt 1000128.405 10/30/2012 Report for Fermi-2 Nuclear Generating Station

8. CARD 14-20240 Water Leak Observed from D2 RHRSW 1/13/2014 GL 89-13 SRSW Assessment Enhancement for RHR

9. CARD 11-20137 1/6/2011 Heat Exchanger

10. CARD 09-24571 Ultimate Heat Sink Self-Assessment Deficiency 6/12/2009 Engineering Calculations Not in Place for Heat

11. CARD 09-20096 1/7/2009 Exchangers with Tubes Plugged

12. CARD 04-24254 Higher than Expected Pressure Drops in Div 1 & 2 EESW 9/16/2004

13. B134060100 Heat Exchanger Inspection Report, RHR Div 1 3/29/2009

14. B861060100 Heat Exchanger Inspection Report, RHR Div 2 9/11/2007

15. E1156 B001A, B, & Maintenance Strategy for RHR Mechanical Draft Cooling 5/22/2014 B002A, B Towers, SE, SW, NE, NW The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements. During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. However, the staff found that for the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

• For the detection of aging effects program element, FERMI-RPT-12-LRD03, Aging Management Program Evaluation Report, Non-Class 1 Mechanical, Section 4.12, Service Water Integrity, states that the program manages loss of material for components and fouling of heat exchangers. It is not clear whether the LRA identifies all of these aging effects because, in addition to fouling of heat exchangers, the applicant has detected fouling of spray nozzles in the RHR cooling towers. LRA Table 3.3.2-3, Service Water Systems, lists loss of material as the only aging effect for these nozzles.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

95 The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M20. The staff also identified certain aspects of the detection of aging effects program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.42, Structures Monitoring Summary of Information in the Application. The LRA states that AMP B.1.42, Structures Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.S6, Structures Monitoring. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the turbine building, the reactor building (includes the spent fuel pool), the RHR complex and the CTG tank foundation. The staff also conducted an independent search of the applicants operating experience database using the keywords: leach, leak, crack, spall, freeze, thaw, concrete, degrade, corrosion, and groundwater.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Aging Management Program Evaluation Report Revision 1

1. FERMI-RPT-12-LRD05 Civil/Structural, Section 3.4 Structures Monitoring 03/05/2014 Program Fermi 2 Maintenance Rule Conduct Manual - Structures Revision 2

2. MMR-14 Monitoring 01/05/2009 Revision B

3. 3071-099 Project Specification - Structural Steel 06/21/1983 Revision 41

4. 35.000.240 Fermi 2 Maintenance Procedure - Bolting and Torquing 12/14/2009

96 Document Title Revision / Date Operating Experience Review Report - Aging Revision 1

5. FERMI-RPT-12-LRD09 Management Program Effectiveness - 3.1.31 Structures 3/25/14 Monitoring Program Memorandum - Results of Maintenance Rule Periodic Inspection of Existing Structures in Accordance with

6. TMPE-08-0005 01/09/2008 MMR14 with Completed MMR14001 Structural Walkdown Checklist

7. TMPE-02-0122 Baseline Structures Inspection for Maintenance Rule 04/05/2002

8. TMPE-12-0066 2012 Maintenance Rule Focused Self-Assessment Report 07/06/2012 MMR14 Structures Monitoring Walkdown - Turbine

9. CARD 14-26270 08/06/2014 Building Basement Findings NRC Question - Investigate RHR Complex North Wall

10. CARD 09-26756 09/01/2009 Condition

11. CARD 13-25947 Low Concrete Air Content 08/23/2013

12. CARD 10-22385 White Mineral Deposit found in Walls 03/19/2010 Calcium, Deposits found in RB Sub-Basement and HPCI

13. CARD 12-27792 09/20/2012 Room during Fukushima Walkdown

14. CARD 14-27002 MMR14 Structures Monitoring Walkdown - CTG Findings 9/9/2014

15. CARD 08-20999 Concrete Spalling on RB 1 Ceiling with Rebar Exposed 6/23/2008

16. Baseline Structures Inspection Report 04/16/1997 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

• The preventive actions, parameters monitored or inspected, and detection of aging effects program elements of GALL Report AMP XI.S6 explicitly address the aging management of ASTM A325, ASTM F1852, and ASTM A490 structural bolting. The staff noted that the corresponding elements, with enhancements, of the LRA AMP basis document address ASTM A325 and A490 bolting, but made no mention of ASTM F1852 bolting. It is not clear to the staff that the above mentioned program elements of the LRA AMP are consistent with the recommendations in the GALL Report AMP because there was no mention of ASTM F1852 bolting.

• The preventive actions, parameters monitored or inspected and detection of aging effects program elements of the GALL Report AMP recommends monitoring

97 high-strength bolting greater than 1 inch in diameter for stress corrosion cracking and supplementing visual inspection with volumetric or surface examinations to detect SCC.

The corresponding program elements of the LRA AMP basis document for the Structures Monitoring Program state that plant procedures prevent the use of molybdenum disulfide as a lubricant for bolting, and therefore [high-strength] structural bolting is not susceptible to SCC. This explanation seems to be used as the basis for not supplementing visual examinations of high-strength bolting greater than 1 inch in diameter with volumetric or surface examination as recommended in the GALL Report AMP. The staff notes that the use of molybdenum disulfide is not the only contributor to SCC of high-strength bolts. Also, it is not clear from the LRA program basis document whether high-strength structural bolts are used in Fermi 2 structures and whether molybdenum disulfide lubricants have been used at Fermi 2 before plant procedures were revised to prohibit its use. The staff needs additional information to verify consistency with the GALL Report AMP because is not clear if there are high-strength structural bolts used in Fermi 2 structures and, if used, whether the program elements are consistent with the recommendations in GALL Report AMP XI.S6 and XI.S7 regarding the provision to monitor for SCC through supplemental volumetric or surface examinations to detect cracking.

• The detection of aging effects program element in the LRA AMP basis document states that underground (inaccessible areas) of concrete structures are subject to an aggressive groundwater/soil environment. The GALL Report AMP recommends a plant-specific program to manage concrete aging effects for inaccessible areas subject to an aggressive groundwater/soil environment. The detection of aging effects program element of the LRA AMP includes an enhancement to revise plant procedures to perform opportunistic inspections of inaccessible areas if it becomes accessible for some reason, and additionally, perform inspections of inaccessible areas in environments where observed conditions in accessible areas exposed to the same environment indicate significant degradation. The staff needs additional information to verify consistency with the GALL Report for the detection of aging effects in inaccessible, below-grade concrete structural elements exposed to an aggressive groundwater/soil environment because the proposed enhancement to the Structures Monitoring Program does not appear to be consistent with the GALL Report recommendations for either an aggressive or non-aggressive water/soil environment.

Further, the enhancement for inspections of inaccessible areas based on observations of accessible areas with the same environment appears to limit the scope of inaccessible areas that will be inspected because certain environment conditions may not exist for both accessible and inaccessible areas (i.e., a soil type environment may exist for an inaccessible area and not for an accessible area).

• The LRA AMP 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 (ACI) 349.3R to demonstrate consistency with the GALL Report with regard to selection of parameters monitored, personnel qualifications requirements, and prescribing quantitative acceptance criteria. The program basis document for the LRA AMP references the 1996 edition of ACI 349.3R. However, the GALL Report AMP XI.S6 is based on, and references, the 2002 edition of ACI 349.3R. It is not clear to the staff that the use of the 1996 edition of ACI 349.3R is consistent with the GALL Report because there are substantive differences between the 2002 edition and 1996 edition of ACI 349.3R that introduce potential inconsistencies.

98 During the audit, the staff made the following observations:

• The staff performed a walkdown of the turbine building basement and observed leaching of concrete. The staff reviewed CARD Nos. 10-22385, 12-27792, and 09-26756, which document the presence of leaching in the RHR complex, auxiliary building basement, and reactor building sub-basement. The applicant determined that leaching is due to groundwater in-leakage and that the identified condition does not affect the structural integrity of the structures. However, there is no discussion in LRA AMP operating experience about leaching issues identified at the plant and no discussion about the evaluation performed that documents the impact of observed leaching on the intended function of the concrete and rebar. Additionally, the staff is not clear how LRA Table 3.5.1, item 47, which states that leaching has not been observed on accessible portions of concrete at Fermi 2, is consistent with the GALL Report recommendation when the operating experience provided by the applicant during the audit documents the presence of leaching in structures.

• During the staffs independent database search of operating experience, the staff reviewed CARD No. 13-25947 and noted that the applicant practice to reject concrete with air entrainment outside the 4.5 percent to 7.5 percent range due to inadequate air entrainment content is consistent with the GALL Report recommendation of adequate air content for concrete exposed to cycles of freezing and thawing. The SRP-LR states that the Structures Monitoring Program may not be sufficient to manage loss of material and cracking due to freeze-thaw for plants located in moderate to severe weathering conditions. However, a plant-specific program is not required if documented evidence confirms that the existing concrete has air content between 3 and 8 percent and inspections have not identified degradation related to freeze-thaw.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S6. The staff also identified certain aspects of the preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

99 LRA AMP B.1.43, Water Chemistry Control - BWR Summary of Information in the Application. The LRA states that AMP B.1.43, Water Chemistry Control - BWR, is an existing program that is consistent with the program elements in GALL Report AMP XI.M2, Water Chemistry. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: chloride, conductivity, dissolved oxygen, HWC, hydrogen water chem, iron, moly, noble, and zinc.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Fermi 2 Nuclear Plant Quarterly Chemistry Health Report 1.

Second Quarter 2014 Fermi 2 Nuclear Plant Quarterly Chemistry Health Report 2.

(End of Year Synopsis) (1/01/2012 to 12/31/2012)

Aging Management Program Evaluation Report,

3. Fermi-RPT-12-LRD03 Non-Class 1 Mechanical, Section 4.13, Water Chemistry Revision 2 Control - BWR Operating Experience Review Report - Aging

4. Fermi-RPT-12-LRD09 Management Program Effectiveness, Section 3.1.32, Revision 1 Water Chemistry Control - BWR Program

5. COS 007 Fermi 2 Strategic Water Chemistry Plan Revision 4

6. CHS-PRI-01 Fermi 2 - Chemistry Specification: Condensate Revision 21

7. CHS-PRI-02 Fermi 2 - Chemistry Specification: Control Rod Drive Revision 6

8. CHS-PRI-03 Fermi 2 - Chemistry Specification: Feedwater Revision 13

9. CHS-PRI-04 Fermi 2 - Chemistry Specification: Main Steam Revision 6

10. CHS-PRI-06 Fermi 2 - Chemistry Specification: Reactor Water Revision 21

11. CHS-PRI-07 Fermi 2 - Chemistry Specification: Torus/RHR Revision 5 Forward Pump Drain (FPD) Total Iron Adverse Trend,

12. CARD 07-22666 05/15/2007 Impacting Final Feedwater (FFW) Total Iron Perform Gap Analysis against New BWRVIP 190, BWR

13. CARD 08-26150 09/19/2008 Water Chemistry Guidelines

14. CARD 09-25161 Increased Trend in Forward Pumped Drain Iron 07/02/2009 Potential Flow Accelerated Corrosion Found in Shell of

15. CARD 10-20712 01/27/2010 MSRs

100 Document Title Revision / Date

16. CARD 10-31980 Chemistry Excursion following CFD H placed in service 12/18/2010 Review Fermi 2 Chemistry Specifications against

17. CARD 11-20394 01/13/2011 BWRVIP-190 Interim Guidance

18. CARD 11-21607 Condenser Leak SW Hotwell Quad 2/10-11/2011 02/11/2011 Revise Chemistry Specifications to Align with On-Line

19. CARD 11-21911 02/18/2011 Noble Metal Chem Requirements Reactor Coolant Sulfate Excursion when East Heater

20. CARD 14-23161 04/06/2014 Feed Pump Started Reactor coolant Sulfate excursion exceeding Action Level

21. CARD 14-23200 04/08/2014 1 after placing CFD G in service RF16 startup chemistry excursions forms for Action Level

22. CARD 14-23162 04/06/2014 1 out of specs During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit, the staff made the following observation:

• In Section 4.13 of Fermi-RPT-LRD03, Revision 2, the applicant refers to its commitment to implement the BWROG [boiling water reactor owners group] Chemistry Guidelines.

In the UFSAR, it states that the Water Chemistry Program is based on General Electric Water Quality Document 22A2747. In addition, the UFSAR states that the licensee conforms to Regulatory Guide 1.56, which, although it has been withdrawn by the NRC, endorsed BWRVIP-130. However, in the LRA, the applicant states that it is consistent with GALL Report AMP XI.M2, which recommends the use of BWRVIP-190. Based on this information, the staff was unclear about whether the applicant is currently using BWRVIP-190.

• The applicant explained that General Electric Water Quality Document 22A2747 was the early basis for the Fermi 2 Water Chemistry Program. Later, the BWR Owners Group developed guidelines for BWR plant water chemistry. Such guidelines are now issued through the BWRVIP program. BWRVIP-130, which was issued in 2004, was subsequently modified and issued as EPRI 1016579, otherwise known as BWRVIP-190: BWR Vessel and Internals Project, BWR Water Chemistry Guidelines 2008 Revision.

• The staff reviewed the Fermi 2 Water Chemistry Specifications and the Strategic Water Chemistry Plan. The staff noticed that these documents contain the guidance, needed statements, good practices, and Action Levels recommended in BWRVIP-190. The staff confirmed that the applicants Water Chemistry Control - BWR Program is consistent with the guidance in BWRVIP-190, and therefore, is consistent with GALL Report AMP XI.M2.

101 During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M2.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.44, Water Chemistry Control - Closed Treated Water Systems Summary of Information in the Application. The LRA states that AMP B.1.44, Water Chemistry Control - Closed Treated Water Systems, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M21A, Closed Treated Water Systems. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: chemistry, corrosion, loss of material, oxygen, pitting, and cracking.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.

Documents Reviewed Document Title Revision / Date Revision 4

1. COS 007 Fermi 2 Strategic Water Chemistry Plan 08/20/2009 Revision 1

2. FERMI-RPT-AMC02 Aging Management Review of the Water Control Structures 03/20/14 Revision 1

3. EPRI 1007820 Closed Cooling Water Chemistry Guidelines April 2004 Chemical Addition to the EDG Jacket Cooling Water Revision 14

4. 77.000.53 Systems 10/05/2011 Turbine Building Closed Cooling Water System Chemical Revision 9

5. 78.000.77 Treatment 07/31/2009

102 Document Title Revision / Date Supplemental Cooling Chilled Water System Chemical Revision 7

6. 78.000.78 Treatment 07/17/2009 Reactor Building Closed Cooling Water and Emergency

7. 78.000.79 Not Available Equipment Cooling Water System Aging Management Program Evaluation Report Non-Class

8. FERMI-RPT-12-LRD03 Revision 2 1 Mechanical Revision 3

9. MES54 Heat Exchanger Component Monitoring Program 09/07/2010 Corrosion Coupon Evaluation and Operation of the Corrater Revision 13

10. 77.000.71 in-Line Corrosion Rate Monitors 11/06/2009 Fermi 2 Chemistry and Environmental Monitoring Conduct Revision 11

11. MCE03 Manual - Chemistry Sampling and Analysis 12/28/2009

12. CARD 05-20359 Replace EDG 13 Jacket Coolant 01/21/2005 High Dissolved Oxygen in TBCCW due to High Makeup

13. CARD 05-26353 11/11/2005 Rate TBCCW Shows Intermittent High Out of Specification

14. CARD 08-24046 06/19/2008 Dissolved Oxygen Increase in TBCCW Dissolved Oxygen Following Change of

15. CARD 09-23909 05/15/2009 Inservice Starting Air Compressors

16. CARD 09-23333 Microbiologically-Induced Corrosion (MIC) 04//27/2009

17. NPRP-13-0077 Corrosion Rate Trending 07/08/2012 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the applicants proposed enhancements. During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. During its review, the staff noted that the water testing frequency for the control center heating, ventilation, and air conditioning chill water system is currently done annually, whereas the GALL Report AMP states that the testing frequency should not be greater than quarterly unless justified with an additional analysis. Although the program basis documentation did not address this difference, the staff concluded that the difference between the current testing frequency and the frequency recommended in the GALL Report AMP would be resolved during implementation of the enhancement.

During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience. The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and

103 trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M21A.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

Staff Review of Select AMR Items Associated with Elastomeric and Polymeric Components Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following AMR items:

• LRA Table 3.3.2-6, Compressed Air Systems, cites elastomeric flex-connections exposed to indoor air (external).

• LRA Table 3.3.2-12, Control Center Heating, Ventilation and Air Conditioning System, cites a graphite rupture disc exposed to indoor air (external) and gas (internal).

• LRA Table 3.4.2-3-7, Circulating Water System, Nonsafety-Related Components Affecting Safety-Related Systems, cites plastic piping exposed to raw water with no aging effect requiring management and no AMP.

Audit Acitivies. During its audit, the staff interviewed the applicants staff and reviewed onsite documents provided by the applicant.

The table below lists the documents that were reviewed by the staff and were found relevant to the review of these AMR items. These documents were provided by the applicant.

Relevant Documents Reviewed Document Title Revision / Date Condensate Water Box Drain Down System Turbine

1. 6M721-5841-1 Revision B Building Basement Aging Management Review of the Compressed Air

2. FERMI-RPT-12-AMM21 Revision 0 Systems Aging Management Review of the Control Room HVAC

3. FERMI-RPT-12-AMM29 Revision 2 Systems

4. Stock Code 550-1258 Spare Parts Reference System for rupture disk Audit Results. During the audit, the staff made the following observations:

• The staff reviewed drawing 6M721-5841-1 and identified that the plastic piping exposed to raw water in LRA Table 3.4.2-3-7 is constructed of polyvinyl chloride.

• The staff reviewed report FERMI-RPT-12-AMM21 and identified that the elastomeric flex-connections exposed to indoor air in LRA Table 3.3.2-6 consist of flexible elastomeric hoses.

104

• The staff reviewed report FERMI-RPT-12-AMM29 and identified that the graphite rupture disc exposed to indoor air (external) and gas (internal) is a Mersen Bursting Disc, with a plant-specific stock code of 550-1258.

• The staff reviewed Stock Code 550-1258 and identified that the graphite rupture disc exposed to indoor air (external) and gas (internal) is a 2-inch disc with a temperature rating of 70 degrees Fahrenheit, a maximum burst pressure of 15.75 psig, and a minimum burst pressure of 14.25 psig with a capacity of 1110 cubic feet per minute (cfm). The material for the disc is graphilor with a Trane part number DSK0091.