ML15051A420

Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 23

ML15051A420
Person / Time
Site:	Fermi
Issue date:	03/13/2015
From:	Melendez-Colon D License Renewal Projects Branch 1
To:	Kaminskas V DTE Electric Company
Melendez-Colon D, 415-3301
References
TAC MF4222
Download: ML15051A420 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 13, 2015 Mr. Vito Kaminskas Site Vice President - Nuclear Generation DTE Electric Company Fermi 2 - 280 OBA 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE FERMI 2 LICENSE RENEWAL APPLICATION - SET 23 (TAC NO. MF4222)

Dear Mr. Kaminskas:

By letter dated April 24, 2014, DTE Electric Company (DTE or the applicant) submitted an application pursuant to Title10 of the Code of Federal Regulations Part 54, to renew the operating license NPF-43 for Fermi 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

This request for additional information was discussed with Ms. Lynne Goodman, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-3301 or e-mail Daneira.Melendez-Colon@nrc.gov.

Sincerely,

/RA/

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

Enclosure:

Request for Additional Information cc w/encl: ListServ

ML15051A420 *Concurred via e-mail OFFICE LA:RPB1:DLR PM:RPB1:DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME YEdmonds DMeléndez-Colón RPlasse YDíaz-Sanabria DMeléndez-Colón DATE 3/10/15 3/12/15 3/12/15 3/13/15 3/13/15

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE FERMI 2, LICENSE RENEWAL APPLICATION - SET 23 (TAC NO. MF4222)

DISTRIBUTION:

E-MAIL:

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D. Melendez-Colon Y. Diaz-Sanabria E. Keegan B. Wittick D. McIntyre, OPA B. Harris, OGC D. Roth, OGC M. Kunowski, RIII B. Kemker, RIII V. Mitlyng, RIII P. Chandrathil, RIII C. Lipa, RIII S. Sheldon, RIII

FERMI 2 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION SET 23 (TAC NO. MF4222)

RAI B.1.1-1a

Background:

In request for additional information (RAI) B.1.1-1 dated December 17, 2014, the staff requested that DTE Electric state how the aging effects of loss of material and cracking of the aluminum in the proximity of the interface between the condensate storage tank (CST) and its concrete foundation will be managed during the period of extended operation.

In its response dated January 20, 2015, DTE Electric stated that the insulation on the CST prevents access to the interface between the tank and its concrete foundation and is expected to prevent the intrusion of water and moisture. License Renewal Application (LRA)

Sections A.1.1, A4, and B.1.1 were revised to perform a volumetric examination consisting of four 1-foot sections of the tank/concrete interface prior to entering the period of extended operation. The RAI response also stated that although caulking was not included in the design and installation specifications for the CST there appears to be caulking present at some locations along the tank/concrete interface.

Issue:

The RAI response did not provide a basis for why it is expected that the insulation will prevent access to the tank/concrete interface and prevent loss of material from occurring during the period of extended operation. It is unclear to the staff how the configuration of the tank and insulation preclude the possibility of water and moisture intrusion in the outdoor environment/weather. If the interface is not appropriately protected from water and moisture intrusion the partially present caulk may potentially act to trap moisture that has intruded. If a one-time volumetric examination is conducted to demonstrate that aging effects are being effectively managed, then the examination is to be of a representative area. Based on its review, the staff has concluded that four 1-foot sections do not constitute a representative sample size for this type of inspection. License Renewal Interim Staff Guidance (LR-ISG)-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation, Aging Management Program (AMP) XI.M29, Aboveground Metallic Tanks, provides examples of representative sample sizes.

Request:

1. If the tank insulation is being credited as a moisture barrier or preventive measure, provide the basis and justification for why it is expected that the insulation on the CST will prevent the access of water and moisture to the tank/concrete interface and is an appropriate preventive action to manage loss of material during the period of extended operation. The response should include:

• the intended function of the insulation on the CST ENCLOSURE

• a physical description or drawing of the insulation relative to the tank/concrete interface.

The level of detail in the description should provide for an understanding of how the configuration of the tank and insulation preclude the possibility of water and moisture intrusion in the outdoor environment/weather. The description should include relevant dimensions. This description is only needed if the tank insulation is being credited as a preventive measure against loss of material at the tank/concrete interface.

• an estimate (both total length and percentage) of how much of the tank/concrete interface has the preexisting caulking present to potentially entrap water and moisture.

Clarify if the caulking will remain in a partially present condition during the period of extended operation.

• if caulking is credited as a preventive measure, clarify if it will be inspected consistent with Generic Aging Lessons Learned (GALL) Report AMP XI.M29, as modified by LR-ISG-2012-02.

2. If the one-time volumetric inspection is being performed to demonstrate the effectiveness of the insulation in preventing moisture intrusion at the tank/concrete interface, instead of establishing the general condition of the tank prior to entering the period of extended operation, state and justify the basis used to determine that four 1-foot sections of the tank/concrete interface is a representative sample. If an alternate inspection is being used to manage the loss of material in the proximity of the tank/concrete interface, provide the basis and justification for the inspection method, extent of inspection, and frequency of inspection.