NRC-19-0045, Response to Request for Additional Information Regarding Snubber Program Relief Request RR-S1 for the Fourth 10-Year Interval
| ML19164A025 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/12/2019 |
| From: | Fessler P DTE Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC-19-0045 | |
| Download: ML19164A025 (4) | |
Text
Paul Fessler Senior Vice President and Chief Nuclear Officer DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4153 Fax: 734.586.1431 Email: paul.fessler@dteenergy.com DTE June 12, 2019 NRC-19-0045 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43
Subject:
Response to Request for Additional Information Regarding Snubber Program Relief Request RR-S 1 for the Fourth 10-Year Interval
Reference:
- 1) DTE Electric Letter to NRC, "Submittal of the Snubber Program Relief Request RR-S1 for the Fourth 10-Year Interval," NRC-19-0017, dated February 28, 2019 (ML19059A254)
In Reference 1, DTE Electric Company (DTE) submitted a relief request under 10 CFR 50.55a(z) for the Snubber Inservice Testing (IST) program at Fermi 2.
In an email from Ms. Sujata Goetz to Mr. Jason Haas dated May 21, 2019, the NRC sent DTE a request for additional information (RAI) regarding relief request RR-S1 of Reference 1. The response to the RAI for relief request RR-S 1 is provided in the Enclosure.
No new commitments are being made in this submittal.
Should you have any questions or require additional information, please contact Mr. Jason R.
Haas, Manager -Nuclear Licensing, at (734) 586-1769.
Sincerely Paul Fessler Senior Vice President and CNO
Enclosure:
Response to Request for Additional Information for Relief Request RR-S 1
USNRC NRC-19-0045 Page 2 cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)
Enclosure to NRC-19-0045 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to Request for Additional Information for Relief Request RR-S1
Enclosure to NRC-19-0045 Page 1 Response to Request for Additional Information for Relief Request RR-S1 By letter dated February 28, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19059A254), DTE Energy Company (the licensee) requested relief from the requirements for the fourth Snubber Inservice Testing (IST) 10-year interval, which begins on May 2, 2019.
RAI-1
Proposed Alternative Relief Request No. RR-S1, Section 4, Reason for Request, states that Fermi 2 has used Code Case OMN-13, Revision 0, during the previous Inservice Inspection (ISI) 10-year interval and proposes to continue with Revision 2 of this Code Case for the subsequent Snubber Inservice Testing (IST) 10-year interval. Please clarify whether you will be using ISI or the IST for the proposed interval.
RESPONSE
Snubber inspections for the recently concluded third 10-year interval were included in Part C of the Fermi 2 Inservice Inspection (ISI) Program Plan. Snubber inspections were performed in accordance with the rules of the ASME OM Code 2004 Edition. The interval dates for snubber activities have been aligned with the ISI Program since the start of Commercial Operation when snubbers were covered under the rules of ASME Section XI, Subsection IWF. The 2012 Edition of the ASME OM Code fully separated the requirements of the pin to pin portion of a snubber from the balance of the support members, and therefore the Snubber Program was separated from the ISI Program for the fourth 10-year interval and relocated to its own Program Plan at Fermi 2. Although the snubber tests and examinations were relocated from the scope of the ISI Program, the interval dates for snubber activities will remain aligned with the ISI Program as they have always been.
In conclusion, the interval for snubber activities is from May 2, 2019 to December 31, 2029 as described in relief request RR-S1 (Reference 1). These dates use the fourth 10-year ISI interval, consistent with ISI Program relief requests recently submitted to the NRC (Reference 2).
References:
- 1) DTE Electric Letter to NRC, Submittal of the Snubber Program Relief Request RR-S1 for the Fourth 10-Year Interval, NRC-19-0017, dated February 28, 2019 (ML19059A254)
- 2) DTE Electric Letter to NRC, Submittal of the Inservice Inspection / Nondestructive Examination Program Relief Requests for the Fourth Ten-year Interval, NRC-19-0016, dated February 28, 2019 (ML19059A327)