ML15078A337

Request for Additional Information for the Review of the Fermi, Unit 2 License Renewal Application - Set 28

ML15078A337
Person / Time
Site:	Fermi
Issue date:	03/26/2015
From:	Melendez-Colon D Division of License Renewal
To:	Kaminskas V DTE Electric Company
Melendez-Colon D
References
TAC MF42222
Download: ML15078A337 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 26, 2015 Mr. Vito Kaminskas Site Vice President - Nuclear Generation DTE Electric Company Fermi 2 - 280 OBA 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE FERMI 2 LICENSE RENEWAL APPLICATION - SET 28 (TAC NO. MF4222)

Dear Mr. Kaminskas:

By letter dated April 24, 2014, DTE Electric Company (DTE or the applicant) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating license NPF-43 for Fermi 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Ms. Lynne Goodman, and a mutually agreeable date for the response is within 40 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:

Requests for Additional Information cc w/encl: ListServ

ML15078A337

• 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 3/24/15 3/25/15 3/25/15 3/26/15*

3/26/15

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE FERMI 2 LICENSE RENEWAL APPLICATION - SET 28 (TAC NO. MF4222)

DISTRIBUTION:

E-MAIL:

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FERMI 2 LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION SET 28 (TAC NO. MF4222)

RAI B.1.10-2

Background:

License Renewal Application (LRA) Commitment No. 7, Part c, in LRA Table A.4 provides activities that the applicant will need to complete in order to manage loss of preload due to stress relaxation in the plants core plate rim hold-down bolts. By letter dated December 23, 2014, the staff issued request for additional information (RAI) 4.1-2, which relates to identification of the future aging analysis that will be performed in evaluation of the plants core plate rim hold-down bolts and why that analysis would not need to be submitted to the staff for approval prior to the period of extended operation. By letter dated February 5, 2015, the applicant responded to RAI 4.1-2, which amended LRA Commitment No. 7, Part c, Option (b).

Under this part of Commitment No. 7, the applicant will only be submitting an inspection plan to the staff for approval if the future Electric Power Research Institute (EPRI) Boiling Water Reactor Vessel and Internals Project (BWRVIP) inspection and evaluation (I&E) guideline bases for boiling water reactor (BWR) core plate rim hold-down bolts will continue to call for inspections of these components.

Issue:

LRA Commitment No. 7, Part c, Option (b), as amended by letter dated February 5, 2015, does not constitute an adequate basis for managing loss of preload/stress relaxation in the core plate rim hold-down bolts because: (a) the proposed action in the option is based on the applicants speculation that the BWRVIP will be updating its inspection guidance for core plate rim hold-down bolts, which has yet to be done (including proper regulatory review by the staff), and (b) the proposed action in the option does not indicate that the inspection plan for the core plate rim hold-down bolts, along with the supporting loss of preload/stress relaxation analysis and justification, will be submitted to the staff for approval at least two years prior to entering into the period of extended operation, regardless of whether inspections of the bolts will be implemented or eliminated in the updated I&E guidelines for the components.

Request:

Justify why amended versions of LRA Commitment No. 7, Part c, Option (b), in LRA Table A.4 and LRA Section A.1.10 do not commit to submittal of an inspection plan for the core plate rim hold-down bolts, along with a supporting loss of preload/stress relaxation analysis and justification, for staff review and approval at least two years prior to entering into the period of extended operation, regardless of whether the submitted basis proposes inspections or justifies elimination of inspections for the core plate rim hold-down bolts.

ENCLOSURE

RAI 4.2.7-1

Background:

LRA Section 4.2.7 describes the applicants time-limited aging analysis (TLAA) evaluation for the reactor pressure vessel (RPV) core reflood thermal shock analysis. The LRA states that the analysis currently in effect is documented in General Electric (GE) Technical Report (TR) No.

NEDO-10029, An Analytical Study on Brittle Fracture of GE-BWR Vessels Subject to the Design Basis Accident, dated June 1969. The LRA also states that a later thermal shock analysis, Fracture Mechanics Evaluation of a Boiling Water Reactor Vessel Following a Postulated Loss of Coolant Accident, was developed by S. Ranganath in August 1979. The LRA explains that the Ranganath analysis bounds the Fermi 2 RPV considering the maximum adjusted reference temperature for the Fermi 2 RPV beltline materials at the end of the period of extended operation. Therefore, the LRA concludes that the RPV core reflood thermal shock analysis has been projected to the end of the period of extended operation.

Issue:

1. The analysis in TR No. NEDO-10029 represents the RPV core reflood thermal shock analysis that is currently in effect for the current licensing basis (CLB), not the 1979 Ranganath analysis. In addition, the 1979 Ranganath analysis was performed in analysis of a GE BWR-6 reactor design; however, the reactor at Fermi 2 is a GE BWR-4 reactor design.

Therefore, the applicant has yet to demonstrate that the TLAA in LRA Section 4.2.7 is acceptable in accordance with either 10 CFR 54.21(c)(1)(ii) because the LRA does not identify: (a) which of the two RPV core reflood analysis reports, NEDO-10029 or the 1979 Ranganath analysis, will be relied upon for the period of extended operation, and (b) the limit on the end-of-life RTNDT value that is established in the core reflood analysis that will be relied upon for the period of extended operation.

2. In addition, if the 1979 Ranganath analysis will be relied upon as the RPV core reflood analysis report for the period of extended operation, the staff would need further justification on the basis for using a report on a GE BWR-6 reactor design as the basis for the RPV at Fermi 2, which is a GE BWR-4 reactor design.

Request:

1. Clarify which of the two RPV core reflood analysis (i.e., the NEDO-10029 report or the 1979 Ranganath analysis) will be used for the period of extended operation. Identify the limit that is placed on the end-of-life RTNDT value for the RPV core reflood analysis report that will be relied upon for the period of extended operation. Identify whether the specific limit is based on the inside surface location, RPV base metal-to-clad interface location, or 1/4T location of the RPV.

2. If the 1979 Ranganath analysis will be the report that is relied upon for the period of extended operation, justify the basis for applying the 1979 Ranganath report to the licensing basis for Fermi 2 during the period of extended operation, when the RPV at Fermi 2 is that for a GE BWR-4 reactor design. As part of this response demonstrate that the stress and

neutron fluence levels assumed in the Ranganath analysis for the RPV in a BWR-6 reactor design are bounding for those that will apply to the RPV at Fermi 2 at the end of the period of extended operation (i.e., through 52 effective full power years [52 EFPY]).