NRC-14-0072, Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 2

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 2

ML14322A930
Person / Time
Site:	Fermi
Issue date:	11/18/2014
From:	Kaminskas V DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-14-0072, TAC MF4222
Download: ML14322A930 (8)

Text

Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasv@dteenergy.com DTE Energy-10 CFR 54 November 18, 2014 NRC-14-0072 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) DTE Electric Company Letter to NRC, "Fermi 2 License Renewal Application," NRC-14-0028, dated April 24, 2014 (ML14121A554)

3) NRC Letter, "Requests for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 2 (TAC No.

MF4222)," dated October 20, 2014 (ML14266A344)

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 2 In Reference 2, DTE Electric Company (DTE) submitted the License Renewal Application (LRA) for Fermi 2. In Reference 3, NRC staff requested additional information regarding the Fermi 2 LRA. The Enclosure to this letter provides the DTE response to the request for additional information.

No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Lynne Goodman at 734-586-1205.

USNRC NRC-14-0072 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on N vemb 18, 2014 Vito A. Kaminskas Site Vice President Nuclear Generation

Enclosure:

DTE Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 2 cc: NRC Project Manager NRC License Renewal 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-14-0072 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 2

Enclosure to NRC-14-0072 Page 1 RAI 2.1-1

Background

10 CFR 54.4, "Scope," states, in part:

(a) Plantsystems, structures and components [SSCs] within the scope of this part are -

(1) Safety-related systems, structures,and components which are those relied upon to remainfunctional during andfollowing design-basisevents (as defined in 10 CFR 50.49 (b)(1)) to ensure the following functions - (i) the integrity of the reactor coolant pressure boundary; (ii) the capability to shut down the reactorand maintain it in a safe shutdown condition; or (iii) the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11, as applicable.

(2) All nonsafety-related systems, structuresand components whose failure could prevent satisfactoryaccomplishment of any of the functions identified in (a)(1)(i), (ii), or (iii) of this section.

LRA Section 2.1.1.2.2(1), "Nonsafety-Related SSCs Directly Connected to Safety-Related SSCs,"

states that nonsafety-relatedSSCs attached to safety-related SCs [structuresand components]

are in the scope of license renewal in accordancewith 10 CFR 54.4(a)(2) up to the first seismic (or equivalent)anchoror alternativebounding criteria,past the safety-related/

nonsafety-relatedinterface.

LRA Section 2.1.1.2.2(2)(c), "Spray or Leakage," states that a nonsafety-relatedSSC with the potentialfor spray or leakage that could prevent safety-related SSCs from performing their requiredsafety function is within the scope of license renewal in accordancewith the requirements of 10 CFR 54.4(a)(2) and is that portion of the nonsafety-relatedSSC contained in the same space as the safety-related SSC.

Issue During the on-site scoping and screeningmethodology audit the staff reviewed the implementing document used by the applicant to identify nonsafety-relatedSSCs with the potential to affect safety-relatedSSCs, for inclusion within the scope of license renewal. The applicant's implementing document states that only nonsafety-relatedSSCs that had not been included within the scope of license renewal based on the potentialfor spray or leakage needed to be reviewedfor nonsafety-relatedSSCs directly attached to safety-related SSCs to identify the portion of the nonsafety-relatedSSC up to the first anchor, equivalent anchor or bounding condition,past the safety-related/nonsafety-relatedinterface.

Enclosure to NRC-14-0072 Page 2 During the audit the applicantstated that the implementing document had been followed and thatfluid-filled, nonsafety-relatedSSCs located within the same space as safety-related SSCs, were included within the scope of license renewal. However,for fluid-filled nonsafety-related SSCs that were also attached to safety-related SSCs, the staff did not have sufficient information to determine how the applicanthad identified the portion of the nonsafety-relatedSSC past the safety-related/nonsafety-relatedinterface to be included within the scope of license renewal, up to and including an anchor, equivalent anchor or bounding condition.

Request The staff requests that the applicantprovide a basisfor identifying the portions of nonsafety-relatedSSCs attachedto safety-related SSCs up to and including an anchor,equivalent anchor or bounding condition, and including these portions within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).

Response

License Renewal Application (LRA) Section 2.1.1.2.2(1) states that for nonsafety-related systems, structures or components (SSCs) directly connected to safety-related SSCs, components within the scope of license renewal include the connected piping and supports up to and including the first seismic or equivalent anchor beyond the safety-nonsafety interface, or up to a point determined by alternative bounding criteria. The methodology for implementing this statement is further discussed in LRA Section 2.1.2.1.2 which states that for directly connected components, appropriate piping and instrument diagrams for the systems were reviewed to identify safety-to-nonsafety interfaces. Piping isometrics were also used to identify seismic anchors and equivalent anchors when required to establish scope boundary. For each interface, the boundary was determined by one of the four criteria in LRA Section 2.1.2.1.2.

As indicated by this RAI (Set 2 RAI 2.1-1), there was discussion during the audit regarding the implementation of the method used to perform the scoping and screening of the nonsafety-related fluid-filled SSCs attached to safety-related SSCs. During the audit, it was discussed that previous license renewal applications have shown that the identification of nonsafety-related fluid-filled SSCs within scope due to spatial interaction per LRA Section 2.1.1.2.2(2) has typically enveloped the nonsafety-related SSCs meeting the criteria of LRA Section 2.1.1.2.2(1).

This is because the seismic boundary is typically within the same space as the nonsafety-to-safety interface and all of the fluid-filled, nonsafety-related SSCs in that space are already included due to potential for spray or leakage. In order to provide verification that the nonsafety-related fluid-filled SSCs necessary for seismic support of safety-related SSCs are included within scope and subject to aging management review, a review of the scoping and screening of the safety-to-nonsafety interfaces was performed. The review utilized the method described in detail below, consistent with the statements in LRA Sections 2.1.1.2.2(1) and 2.1.2.1.2.

Enclosure to NRC-14-0072 Page 3 The LRA drawings were reviewed to identify instances where nonsafety-related fluid-filled SSCs are directly connected to safety-related SSCs. For each instance, the seismic boundaries were identified as (1) a seismic anchor, (2) an equivalent anchor, (3) a flexible connection, end of piping run, or base-mounted component, or (4) the seismic boundaries used for the design calculation. The seismic or equivalent anchors or other components credited for providing the boundaries were then located on piping isometrics. The locations of these boundary points on the piping isometrics were used to identify the corresponding locations on the LRA drawings.

Then the LRA drawings were reviewed to determine if all the piping and components up to the boundary points were marked (highlighted) as subject to aging management review per 10 CFR 54.4(a)(2).

The results of the review confirmed that, for each safety-to-nonsafety interface, the connected fluid-filled piping and supports up to and including the first seismic or equivalent anchor (or up to a point determined by the alternative bounding criteria) were included as in scope and subject to aging management review in accordance with 10 CFR 54.4(a)(2). No new SSCs were identified as subject to aging management review as a result of this review. The review was performed consistent with the methodology described in LRA Sections 2.1.1.2.2(1) and 2.1.2.1.2. Therefore, no changes to the LRA are necessary.

LRA Revisions:

None.

Enclosure to NRC-14-0072 Page 4 RAI 2.1-2

Background:

10 CFR 54.4, "Scope," states, in part:

(a) Plantsystems, structuresand components [SSCs] within the scope of this partare -

(1) Safety-related systems, structures, and components which are those relied upon to remainfunctional during andfollowing design-basisevents (as defined in 10 CFR 50.49 (b)(1)) to ensure the following functions - (i) the integrity of the reactor coolantpressure boundary; (ii) the capability to shut down the reactorand maintain it in a safe shutdown condition; or (iii) the capability to prevent or mitigate the consequences of accidents which could result in potentialoffsite exposures comparableto those referred to in 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11, as applicable.

(2) All nonsafety-relatedsystems, structuresand components whose failure could prevent satisfactory accomplishment of any of the functions identified in (a)(1)(i), (ii), or (iii) of this section.

Issue:

Duringthe on-site scoping and screening methodology audit the staff reviewed the license renewal application,license renewal implementing documents, currentlicensing basis documentation and performed a walkdown of site structures. The staff determined that the outage building, immediately adjacent to, and in contact with, the reactorbuilding (included within the scope of license renewal in accordancewith 10 CFR 54.4(1)), in which personnel perform activities requiredprior to entry into the reactorbuilding andfollowing exit from the reactorbuilding, was not included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).

Request:

The staff requests that the applicantprovide a basisfor not including the outage building, which is located adjacent to, and in contact with, the reactorbuilding, within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). If an analysis is cited as the basis for not including the outage building within the scope of license renewal, indicate how the analysis considers the effects of aging.

Enclosure to NRC-14-0072 Page 5

Response

The Outage Building (OB) is a nonsafety-related structure and is not included within the scope of license renewal because it has no intended function for 10 CFR 54.4(a)(1), (a)(2), or (a)(3).

The purpose of the OB is to provide personnel access to the radiologically restricted area, as well as restroom facilities. The OB is located south of the Reactor/Auxiliary Building (RAB) and east of the Railroad Bay Airlock. The Railroad Bay Airlock is discussed in License Renewal Application (LRA) Section 2.4.1 as part of the description of the Reactor Building. The Railroad Bay Airlock is considered part of the RAB.

The OB is a two-story, steel framed structure with non-load bearing, 8" masonry exterior walls.

The OB was designed for applicable wind and seismic loading in accordance with the provisions of the 1991 Uniform Building Code. The OB is structurally separated from the RAB by a 2" gap where the foundations meet and a 4" isolation gap on the upper portions. Non-structural flashing is attached to the RAB to cover the gap between the RAB and OB. The high-point roof elevation of the OB is lower than the roof elevation of the adjacent structures. However, the RAB Personnel Airlock on the south side of the RAB is completely enclosed by the OB such that the OB structure (second floor and roof) is framed over the top of the airlock.

The Fermi 2 Seismic Category I structures are designed and constructed in a manner that their intended function would not be affected by failure of adjacent non-seismic structures. The RAB, including the Personnel Airlock, is QA Level I, Seismic Category I, reinforced concrete structure designed in accordance with NRC "General Design Criteria For Nuclear Power Plants" as specified in Appendix A to 10 CFR Part 50. As such, it has been designed for impact loading attributable to tornado generated missiles. The RAB walls and the Personnel Airlock walls and roof are 18" thick, reinforced concrete. The relatively low-energy, impact loading imposed on any of these elements due to a postulated collapse of the OB is bounded by the loading from tornado generated missiles, as described in Updated Final Safety Analysis Report (UFSAR)

Section 3.5.2.1. Furthermore, as stated in UFSAR Section 9A.4.1.1 and 9A.4.11, the OB is of completely noncombustible construction and there is no safe shutdown equipment located in the OB. Should a failure of the OB occur (including failure due to the effects of aging), there would be no loss of a license renewal intended function per 10 CFR 54.4(a)(1) of the adjacent RAB.

Therefore, the OB does not fall within the scope of 10 CFR 54.4(a)(2).

LRA Revisions:

None.