NRC-15-0002, DTE Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 9

DTE Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 9

ML15016A022
Person / Time
Site:	Fermi
Issue date:	01/15/2015
From:	Kaminskas V DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-15-0002
Download: ML15016A022 (53)

Text

Vito A. Kaninskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kamninskasy @dteenergy.com DTE~ Enrg 10 CFR 54 January 15, 2015 NRC-15-0002 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 9 (TAC No.

MF4222)," dated December 9, 2014 (ML14329B233)

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 9 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 (RAI).

Two new commitments are being made in this submittal. The new commitments are in Item 14, Fire Water System, of LRA Table A.4 as indicated in the responses to RAIs B.1.19-7 and B.1.19-8.

In addition, revisions have been made to commitments previously identified in the LRA. These revised commitments are as follows:

• Item 6, Buried and Underground Piping, in LRA Table A.4 as indicated in the response to RAI B.1.4-3.

• Item 14, Fire Water System, in LRA Table A.4 as indicated in the responses to RAIs B.1.19-L, B.1.19-2, B.1.19-3, B.1.19-4, B.1.19-5, B.1.19-6.

USNRC NRC-15-0002 Page 2

• Item 28, Periodic Surveillance and Preventive Maintenance, in LRA Table A.4 as indicated in the response to RAI B.1.19-1.

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

I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 15, 2015 a j jjrr~

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 9 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 NRC15-0002 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 9

Enclosure to NRC-15-0002 Page 1 RAI B.L4-1

Background

The "detection of aging effects" program element of the Buried and UndergroundPiping Program states that buriedpiping inspections will be conducted in a manner consistent with those in the "detection of aging effects" element of GenericAging Lessons Learned (GALL)

Report aging managementprogram (AMP) XL M41, as modified by LR-ISG-2011-03.

Issue During the staff's review of buriedpipe inspection reports, it was noted that the coatings on two excavatedpipe inspections were classified as being in 'fair condition." However; the reportsfor the two inspections state that coating holidays ranging in size from 2 in2 to 10 in2for one pipe and 30 in2 to 95 in 2for the otherpipe were detected. Such sizes indicate that significant amounts of bare metal have been exposed. The classificationof the coating condition may not be consistent with LR-ISG-2011-03 Table 4a, "Inspectionsof Buried Pipe," Footnote 2, which states that inspection CategoryE, opposed to Category F (Category E has a lower number of inspections relative to Category F), may be used if there is "no signficant coating degradation."

The staff lacks sufficient information to conclude that, given the size of the holidays reported, the coating condition is appropriatelyclassified as "fair"ratherthan significantly degraded. As a result of classifying the coatingsas being in "faircondition," the number of inspections conducted may not be consistent with the "detection of aging effects" program element of GALL Report AMP XL M41, as modified by LR-ISG-2011-03.

Request State the basisfor why the condition of the coatings on the pipes discussed above were classified as being in "faircondition."

Response

As described in License Renewal Application (LRA) Section B.1.4, the Buried and Underground Piping Program is a new program. The information requested above on the classification of the coatings pertains to existing inspections/results per NEI 09-14, "Guideline for the Management of Underground Piping and Tank Integrity." Similarly, the statement of the issue above discusses how the existing NEI 09-14 inspections/results are consistent with the guidance of LR-ISG-2011-03. DTE agrees that it will be important to correctly determine and document a basis for which inspection category is chosen during implementation of the new Buried and Underground Piping Program. However, the changes to the existing activities to manage buried pipe degradation per NEI 09-14, as implemented at Fermi 2 by MES71, due to the new Buried and Underground Piping Program have not yet been determined.

Enclosure to NRC-15-0002 Page 2 The basis for concluding the coating condition is "Fair" rather than "Degraded" follows.

"Significant coating degradation" is used to categorize the piping where the original cathodic protection (CP) design (i.e. current output) can no longer accommodate the amount of bare metal observed. CP and coatings are linked as noted in the LR-ISG-2011-03 footnotes. All CP system designs assume a percentage of bare metal, even for new pipe, and if this percentage increases beyond the available current needed to polarize the bare metal then "significant coating degradation" has been observed and more excavations and inspections may be required. For the new Buried and Underground Piping Program, the LR-ISG-2011-03 criteria will be used to determine which category for inspections are applicable. However, inspections performed to date indicate protection was observed for the subject piping. Thus the categorization of fair has been selected.

As for the LR-ISG-2011-03 categories C, E, and F and the question regarding correct categorization of the piping in the existing NEI 09-14 inspection reports, the reports were not intended to make judgments regarding categorization for license renewal purposes. The report indicates that 10% of the inspected piping was shown to be affected by the coating holidays which is below the criteria specified in LR-ISG-2011-03 ("no significant degradation or metal loss in more than 10% of inspections conducted"). Category E is for plants that do not have CP or have CP, but fail to meet effective CP criteria as defined in Ci, Cii, and Ciii. At this time, DTE has not determined that effective CP has not been met. A categorization of Group E could eventually be concluded only if the CP criteria for category C are not met. A categorization for Group F is very unlikely because there has been no significant pipe surface corrosion or wall loss noted to date.

LRA Revisions:

None.

Enclosure to NRC-15-0002 Page 3 RAI B.1.4-2

Background:

The "acceptance criteria"program element of the Buried and UndergroundPiping Program states that the program activities associatedwith the acceptance criteriaare consistent with GALL Report AMP XL M41, as modified by LR-ISG-2011-03.

The GALL Report AMP recommends that if a 100 mV polarizationcriterionis used to assess the performance of the cathodicprotection system, then the license renewal application(LRA) should include the basisfor why adequateprotection is providedfor steel components exposed to a mixed potential environment.

Issue:

Based on documents reviewed during the audit, the applicant'sacceptance criteriafor the cathodicprotection system include negative 0.85 V and 100 mV of cathodicpolarization. The applicant'sacceptancecriteriaalso includes an allowancefor polarizationpotentials less negative than 0.85 V if the buried components are in high resistivity soils that are well drained and well aerated. The applicantdid not provide the basisfor the alternative acceptance criteria of the cathodicprotection system.

Reguest:

State the basisfor why: (a) 100 mV polarizationacceptance criterionand (b) polarization potential of less than negative 0.85 V (if the buried components are in high resistivity soils that are well drainedand well aerated)will provide adequateprotectionfor buried steel piping in a mixed metal environment.

Response

(a) The Buried and Underground Piping aging management program (AMP) is a new program at Fermi 2. This new program will be consistent with the program described in NUREG-1801 Generic Aging Lessons Learned (GALL) Report,Section 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."

Note 2 of Table 6a of GALL Report AMP XI.M41 as modified by LR-ISG-2011-03 states that when the -100 mV criterion is used in lieu of the -850 mV copper/copper sulfate reference electrode (CSE) criterion for steel piping, applicants must explain in the application why the effects of mixed potentials are minimal and why the most anodic metal in the system is adequately protected. If the new program, when developed, allows use of the -100 mV criterion for piping within the scope of the Buried and Underground Piping AMP, then the program will

Enclosure to NRC-15-0002 Page 4 address why the effects of mixed potentials are minimal and why the most anodic metal in a system for which this criteria is used is adequately protected as required by Note 2 of Table 6a of GALL Report AMP XI.M41 as modified by LR-ISG-2011-03.

(b) Table 6a of GALL Report AMP XLM41 as modified by LR-ISG-201 1-03 does not allow the use of a polarization potential less negative than -850 mV for buried steel piping. The new Buried and Underground Piping AMP will be consistent with Table 6a of GALL Report AMP XLM41 as modified by LR-ISG-2011-03.

LRA Revisions:

None.

Enclosure to NRC-15-0002 Page 5 RAI B.1.4-3

Background:

License Renewal Application Section A.4 states that the new Buried and UndergroundPiping Programwill be implemented, "[p]riorto September 20, 2024, or the end of the last refueling outage prior to March 20, 2025, whichever is later."

Issue:

The implementation schedulefor the Buried and UndergroundPipingProgramis not consistent with GALL Report AMP XI.M41, as modified by LR-ISG-2011-03, which recommends that inspections should commence in the 10-year periodprior to the periodof extended operation.

LRA Section A.4 is clear for some of the other programs where inspections commence prior to the periodof extended operation. For example, the implementation schedulefor the One-Time Inspection Program, Commitment No. 26, states, "[i]nspectionswill be performed within the 10 years prior to March 20, 2025."

Request:

State the basisfor why the implementation schedulefor the Buried and UndergroundPiping Programdoes not state that inspections will commence in the 10-year periodprior to the period of extended operation.

Response

License Renewal Application (LRA) Section A.4, Item 6, will be revised under "Implementation Schedule" to indicate that the inspections will be performed within the 10 years prior to the period of extended operation. The LRA revisions are indicated below.

LRA Revisions:

LRA Section A.4 is revised as shown on the following page. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0002 Page 6 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source

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___ ____ ___ ___ ____ ___ ____ ___ ___Schedule_ _ _ _

6 Buried and Implement new Buried and Underground Piping Program Prior to September 20, A.1.4 Underground Piping that will manage the effects of aging on the external 2024, or the end of the surfaces of buried and underground piping within the last refueling outage prior scope of license renewal. Soil testing will be conducted to March 20, 2025, once in each ten-year period starting ten years prior to whichever is later. Initial the period of extended operation, if a reduction in the directed inspections and number of inspections recommended in Table 4a of soil testing (if the NUREG 1801, XI.M41, is taken based on a lack of soil reduction in inspections corrosivity. based on soil testing is taken will be performed within the ten years prior to March 20. 2025.

Enclosure to NRC-15-0002 Page 7 RAI B1.19-1

Background:

As amended by letter dated July 30, 2014, Exception No. 7 to the "detection of aging effects" program element of the Fire Water System Programstates that a one-time inspection of the internalsurfaces of the dry piping downstream of the manual isolation valve for the wet pipe system for the cable spreading room will be conducted. LRA Table 3.3.2-7 states that the piping is exposed to indoor air.

GALL Report AMP XL M27, as modified by LR-ISG-2012-02, recommends that periodic inspections should be conducted of fire water system piping that is exposed to indoor air.

Issue:

It is not clear to the staff that the proposed exception is consistentwith GALL Report AMP XLM27, as modified by LR-ISG-2012-02, because the applicantdid not provide a basisfor why there is reasonable assurance that the currentlicensing basis (CLB) intendedfunction(s) of the piping would be met when only a one-time inspection is conducted.

Request:

State the basisfor why there is reasonable assurance that the CLB intendedfunction(s) of the piping downstream of the manual isolation valve for the wet pipe system for the cable spreading room will be met during the periodof extended operation when only a one-time inspection is conducted.

Response

The cable spreading room wet pipe system has been replaced by a Halon system as the primary means of fire suppression. The wet pipe system for the cable spreading room was isolated, however not removed. Rather than a one-time inspection of the wet pipe system, Exception No.

7 will be revised to place the piping system in the Periodic Surveillance and Preventive Maintenance Program (B.1.35). Inspections will begin within the 5 years prior to the period of extended operation and will continue every 5 years during the period of extended operation.

Each inspection will visually examine 20 percent of the piping system. This will provide a representative sample of the condition of the piping system. Should in the future this piping system be charged, the applicable sections of the Fire Water System Program (B.1.19) for wet pipe systems would apply.

LRA Revisions:

LRA Sections A.1.19, A.1.35, A.4, B.1.19, and B.1.35, and LRA Table 3.3.2-7 (and associated plant-specific note) are revised as shown on the following pages. Additions are shown in

Enclosure to NRC-15-0002 Page 8 underline and deletions are shown in strike-through. Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-0051) are not shown in underline or strike-through such that only the new changes due to RAI B.1.19-1 are shown as revisions.

Enclosure to NRC-15-0002 Page 9 Table 3.3.2-7 Fire Protection - Water System Summary of Aging Management Evaluation Table 3.3.2-7: Fire Protection - Water System Aging Effect Aging Component Intended Requiring Management NUREG-1801 Table 1 Type Function Material Environment Management Programs Item Item Notes Piping Pressure Carbon Air - indoor Loss of material Fire Water VII.G.A-404 3.3.1-131 A boundary steel int System Pi ing Pressure Carbon Air - indoor Flow blockage Periodic VlGA-04 3L1-131 E, I1 boundary steel .(int due to fouling Su rvejlance and Preventive Maintenance Piping Pressure Carbon Air - outdoor Loss of material External Vll.l.A-78 3.3.1-78 A boundary steel (ext) Surfaces Monitoring Notes for Table 3.3.2-1 through 3.3.2-17-36 Plant-Specific Notes 311 The Periodic Surveillance and Preventive Maintenance Program will be used to oeriodically assess the condition of this piping by ins ection of 20% of thesvse oina.

Enclosure to NRC-15-0002 Page 10 A.1.19 Fire Water System Program The Fire Water System Program will be enhanced as follows.

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inra an al-#tk4sk- wu+-

Enclosure to NRC-15-0002 Page 11 A.1.35 Periodic Surveillance and Preventive Maintenance Program There is no corresponding NUREG-1801 program.

The Periodic Surveillance and Preventive Maintenance Program manages aging effects not managed by other aging management programs, including loss of material, fouling, loss of material due to wear, and loss of sealing. Any indication or relevant condition of degradation detected is evaluated. Inspections occur at least once every five years during the period of extended operation.

The Periodic Surveillance and Preventive Maintenance Program also manages loss of material in carbon steel components exposed to raw water due to the recurring internal corrosion aging mechanism collectively referred to as multiple corrosion mechanisms (MCM). MCM was identified as a recurring internal corrosion aging mechanism (RICAM) in an operating experience review conducted by DTE in accordance with LR-ISG 2012-02 Section A.

The Fermi 2 aging management review credits the following inspection activities.

• Visually inspect and manually flex the rubber gasket/seal for reactor building spent fuel storage pool gates to verify no loss of sealing.

• Determine wall thickness of selected service water system piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

• Visually inspect a representative sample of EDG system air coolant, lube oil, and jacket water heat exchanger tubes to manage loss of material due to wear.

• Determine wall thickness of selected EDG system piping components to manage loss of material due to recurring internal corrosion by multiple corrosion mechanisms.

• Use visual or other NDE techniques to inspect internal surfaces to manage fouling of the fire water system heat exchanger tubes exposed to raw water.

Visually inspect a representative sarnleof the dry pipin downstream of the manual isolation valve for the cable spreading room wet pipe system for filow blockage. The first inspection will be within five years of the period of extended operation.

• Visually inspect a representative sample of CTG system lube oil heat exchanger tubes to manage loss of material due to wear.

Enclosure to NRC-15-0002 Page 12 A.1.35 Periodic Surveillance and Preventive Maintenance Program The Periodic Surveillance and Preventive Maintenance Program will be enhanced as follows.

Revise the Periodic Surveillance and Preventive Maintenance Program procedures to state that the acceptance criterion is no indication of relevant degradation and to incorporate the following:

Examples of acceptance criteria for metallic components a No excessive corrosion (loss of material).

• No leakage from or onto internal surfaces (loss of material).

o No excessive wear (loss of material).

o No flow blockage due to fouling.

• No loss of piping component structural integrity.

Examples of acceptance criteria for elastomeric components Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

Enclosure to NRC-15-0002 Page 13 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source Schedule 14 Fire Water System Enhance Fire Water System Program as follows: Prior to .1.19 September 20,

-ye 2024, or the end F a etn- -dof the last prtiem n p-yt4seat-4 e refueling outage le-sp r - emevi-ap;nkie wa -d prior to March 20, e sen-in pps- g4's=r+g 2025, whichever eiad 4egn- ra-ar rga e is later, with the ma 'eie-44.atA&+c-.

sx e e'tr4%c-4"-kage-ei exception that the Vpr4Rk~4as- activities described in this commitment for piping segments designed to be dry but determined to be collecting water shall be conducted within five years prior to March 20, 2025.

Enclosure to NRC-15-0002 Page 14 No. Program or Activity Commitment Implementation Source

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_ ____

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___ ___ ___ ____ ___ ___ ___ ____ ___ ___ ___ Schedule _ _ _ _

28 Periodic Surveillance Enhance Periodic Surveillance and Preventive Maintenance Prior to .1.35 and Preventive Program as follows: September 20, Maintenance 2024. Initial

b. Revise the Periodic Surveillance and Preventive irns-ec ion of Maintenance Program procedures to state that acceptance cable peading criterion is no indication of relevant degradation and to room r digin incorporate the following: wi be prormed

• Examples of acceptance criteria for metallic components within the five

- No excessive corrosion (loss of material) years prior to

- No leakage from or onto internal surfaces (loss of March 2_0Q2025.

material)

- No excessive wear (loss of material)

- No flow blockage ue to foulina

- No loss of piping component structural integrity

• Examples of acceptance criteria for elastomeric components

- Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

Enclosure to NRC-15-0002 Page 15 B.1.19 FIRE WATER SYSTEM Exceptions Element Affected Exception

4. Detection of Aging Effects NFPA 25, Section 14.2 specifies performing at least every five years an internal inspection of the wet and dry fire water piping. Fermi 2 performs full flow testing of the piping downstream of the deluge valves for transformers, but does not perform an internal inspection on the dry piping downstream of the deluge valves for transformers.

Fermi 2 does not inspect the dry lines downstream of the manual isolation valves for the control center HVAC make-up filter charcoal filter absorber unit, control center HVAC recirculation filter charcoal absorber unit, and the manual wet pipe cable spreading room fire water supply.!

Exception Notes

7. Performing full flow testing downstream of the deluge valves associated with transformers at least once each refueling outage satisfactorily indicates organic or inorganic material within the system.

Performing an internal inspection or performing an air or smoke test of the piping downstream of the manual isolation valves for the control center HVAC make-up filter charcoal filter absorber unit and the control center HVAC recirculation filter charcoal absorber would require system modification. Therefore, this piping and the nozzles associated with the charcoal absorber unit will be internally inspected when the charcoal is replaced. The wet pipe system for the cable spreading room is isolated and is now the backup system for the Halon system that provides fire suppression for the cable spreading room.-Pr'min-°are 4pe eseef4e-y g s-e ue -deteu e-t +n ae kndis °f- -ef4 hee GG f-e '- Visual Vin pecting a representative sample of the wet ip systern downstrear of the manual isolation vave for the cable spreadina room in accordance with the Periodic Surveillance and Preventive Maintenance Pro ram with initial inspection within five years of the period of extended opeation is sufficient to determine the material condition of this section of dry oina.

Enclosure to NRC-15-0002 Page 16 B.1.19 FIRE WATER SYSTEM Enhancements Element Affected Enhancement 4-.e teetie'reAgl:g.';eeta Vete- Fogmi eee pedc+Y-ue 3-,,4 ° #a-en- #re-tem# L4 & f

,nspee +y t eaa systm+>seeiaedrith~e cale-preaing-eem remeing enakorcwar4e-ef-eneaira line-41 pugee-f ep.sg YFVsf-atrd enc44e-resns-e4eTswrai-n-nra

Enclosure to NRC-15-0002 Page 17 B.1.35 PERIODIC SURVEILLANCE AND PREVENTIVE MAINTENANCE The Fermi 2 aging management review credits the following inspection activities.

Fire water system Use visual or other NDE techniques to inspect internal surfaces to manage fouling of the heat exchanger tubes exposed to raw water.

Visually inspect a representative saMple of the d iping downstrearn of the manual isoiation valve for the cable spreading room wet ippe systern for flow block ae. The first inspection will be within five years of the period of extended oJration.

Enhancements Element Affected Enhancement

6. Acceptance Criteria Revise the PSPM Program procedures to state that the acceptance criterion is no indication of relevant degradation and to incorporate the following:

• Examples of acceptance criteria for metallic components:

- No excessive corrosion (loss of material).

- No leakage from or onto internal surfaces (loss of material).

- No excessive wear (loss of material).

- No flow blockage due to fouling.

- No loss of piping component structural integrity.

• Examples of acceptance criteria for elastomeric components:

- Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

Enclosure to NRC-15-0002 Page 18 RAI B.L19-2

Background:

As amended by letter dated July 30, 2014, Exception No. 7 to the "detection of aging effects" program element of the Fire Water System Programstates that in lieu of conducting a deluge test with air or smoke for the control center HVAC make-up filter charcoalfilter absorber unit and the control center HVAC recirculationfilter charcoalabsorberunit, inspectionsof the internal surfaces of the piping downstream of the manual isolation valves whenever the charcoal is replacedwill be conducted.

GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that, as stated in National Fire ProtectionAssociation (NFPA) 25 Section 13.4.3.2.2.4, deluge valve testing should be conducted at least every 3 years.

Issue:

It is not clear to the staff that the proposed exception is consistent with GALL Report AMP XL M27, as modified by LR-ISG-2012-02. During the audit, the staff reviewed charcoal filter media replacementwork orders and determined that media is replaced approximately every 7 to 10 years.

Request:

State the basisfor why there is reasonableassurance that the CLB intendedfunction(s) of the deluge systems for the control center HVAC make-up filter charcoalfilter absorberunit and the control center HVAC recirculationfilter charcoalabsorber unit, will be met during the period of extended operationwhen inspectionsdo not occur every 3 years.

Response

NFPA 25 (2011 Edition), Section 13.4.3.2.2.4 addresses full flow trip testing of deluge valves every three years. The deluge valves for the control center HVAC make-up filter charcoal filter adsorber unit and HVAC recirculation filter charcoal adsorber unit are manual valves. Therefore, the provision of NFPA 25 (2011 Edition), Section 13.4.3.2.2.4 regarding full flow trip testing every three years does not apply.

The proposed inspection frequency, i.e., whenever the charcoal is replaced, should be adequate to ensure the intended function of this fire suppression piping for both units will be met during the period of extended operation. The majority of the fire suppression piping downstream of the manual isolation valve is contained within the respective HVAC filtering train and is not exposed to an adverse environment. This portion of piping is normally isolated from the wet portion of the fire protection system by a manual isolation valve. The piping downstream of the isolation valve is stainless steel and is located in a charcoal bed that is heated to maintain dry conditions.

Enclosure to NRC-15-0002 Page 19 This suppression system does not have nozzles. Water would be distributed through a series of holes in the piping. The piping upstream of the isolation valves is charged with water. The upstream piping is carbon steel and this piping is routinely flushed to assure no blockage.

Should obstructive material be found during flow testing, an obstruction investigation would be performed in accordance with NFPA 25 Section 14.3.1 (2). The manual isolation valves are physically located at a high point in this section of piping which would hinder the accumulation of debris that could be introduced into the charcoal bed fire suppression piping in the event the manual valves would be opened.

Due to the stainless steel material of the suppression system downstream of the manual isolation valve, the routine flushing of the carbon steel pipe upstream of the manual isolation valve, the piping configuration, and the dry condition of the charcoal bed, inspecting the fire suppression piping for the control center HVAC charcoal bed when the charcoal is replaced in the adsorber unit provides reasonable assurance that the fire suppression piping will be able to perform its intended function if called upon to suppress a fire in the charcoal adsorber unit.

Therefore, as originally proposed in Exception 7, DTE will perform an inspection of the internal piping of the control center HVAC make-up filter charcoal filter adsorber unit and the control center HVAC recirculation filter charcoal adsorber unit, downstream of the manual isolation valves, whenever the charcoal is replaced.

Two clarifications will be made to License Renewal Application (LRA) Section B.1.19, "Fire Water System." The term "absorber" will be changed to "adsorber." Second, a change will be made to reflect the absence of nozzles on the charcoal bed fire suppression piping. An additional clarification will be made to LRA Sections A.1.19, A.4, and B.1.19 to change the term "sprinkler" associated with the control center HVAC recirculation and make-up charcoal beds to "water distribution piping."

LRA Revisions:

LRA Sections A.1.19, A.4, and B.1.19 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-0051) are not shown in underline or strike-through such that only the new changes due to RAI B.1.19-2 are shown as revisions.

Enclosure to NRC-15-0002 Page 20 A.1.19 Fire Water System Program The Fire Water System Program will be enhanced as follows.

Revise Fire Water System Program procedures to perform an inspection of the e ;gn1awate distriulonpjri.associated with charcoal filters for loss of material and foreign organic or inorganic material when the charcoal beds are replaced.

Enclosure to NRC-15-0002 Page 21 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source

_____ ________________________________________

_______________ Schedule ____

14 Fire Water System Enhance Fire Water System Program as follows: Prior to A.1.19 September 20,

j. Revise Fire Water System Program procedures to perform 2024, or the end an inspection of the api44erswater distri utoni mg of the last associated with charcoal filters for loss of material and foreign refueling outage organic or inorganic material when the charcoal beds are prior to March 20, replaced. 2025, whichever is later, with the exception that the activities described in this commitment for piping segments designed to be dry but determined to be collecting water shall be conducted within five years prior to March 20, 2025.

Enclosure to NRC-15-0002 Page 22 B.1.19 FIRE WATER SYSTEM Exceptions Element Affected Exception

4. Detection of Aging Effects NFPA 25, Section 14.2 specifies performing at least every five years an internal inspection of the wet and dry fire water piping. Fermi 2 performs full flow testing of the piping downstream of the deluge valves for transformers, but does not perform an internal inspection on the dry piping downstream of the deluge valves for transformers.

Fermi 2 does not inspect the dry lines downstream of the manual isolation valves for the control center HVAC make-up filter charcoal filter adsorber as4 -- unit, control center HVAC recirculation filter charcoal adsorber v ba r-unit, and the manual wet pipe cable spreading room fire water suppyI.'

Exception Notes

7. Performing full flow testing downstream of the deluge valves associated with transformers at least once each refueling outage satisfactorily indicates organic or inorganic material within the system.

Performing an internal inspection or performing an air or smoke test of the piping downstream of the manual isolation valves for the control center HVAC make-up filter charcoal filter adsorber dbee sunit and the control center HVAC recirculation filter charcoal adsorber a sac -would require system modification. Therefore, thicte piping (an rkee associated with the charcoal adsorber absetae-+unit will be internally inspected when the charcoal is replaced. The wet pipe system for the cable spreading room is isolated and is now the backup system for the Halon system that provides fire suppression for the cable spreading room. Performing a one-time inspection of the dry piping downstream of the manual isolation valve for the wet pipe system for the cable spreading room is sufficient to determine the material condition of this section of dry piping.

Enhancements Element Affected Enhancement

4. Detection of Aging Effects Revise Fire Water System Program procedures to perform an inspection of the sr 4 es-ater dstri ion Jiji nassociated with charcoal filters for loss of material and foreign organic or inorganic material when the charcoal beds are replaced.

Enclosure to NRC-15-0002 Page 23 RAI B.L19-3

Background:

As amended by letter dated July 30, 2014, EnhancementNos. 2 and 7 to the "parameters monitored or inspected" and "detection of aging effects" programelements of the Fire Water System Programstate that an inspection of the wet fire water system piping condition will be conducted at least once every 5 years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line.

GALL Report AMP X.M27, as modified by LR-ISG-2012-02, recommends that, as stated in NFPA 25 Section 14.2.2, in buildings with multiple wet pipe systems every other system should be inspected every 5 years.

Issue:

During the audit, the applicant confirmed that it has multiple wet pipe systems in buildings with in-scope components protectedby the fire water system. The applicantdid not provide a basis for why testing only one system every 5 years is sufficient.

Request:

State the basisfor why inspecting only one of the wet pipe systems in each building every 5 years will provide reasonable assurance that the wet fire water system piping will be capable of performing its CLB intendedfunction(s) during the periodof extended operation.

Response

DTE will inspect every other system every five years where multiple wet-pipe systems are in a building. For example, if there are multiple wet-pipe systems with six sprinkler systems in a building, DTE will initially inspect three of the six systems. Then, in the next five year period, DTE will inspect the remaining three systems in that building. This meets the requirements of NFPA 25 Section 14.2.2. The License Renewal Application (LRA) will be revised as indicated below to clarify this enhancement.

LRA Revisions:

LRA Sections A.1.19, A.4, and B.1.19 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-0051) are not shown in underline or strike-through such that only the new changes due to RAI B.1.19-3 are shown as revisions.

Enclosure to NRC-15-0002 Page 24 A.1.19 Fire Water System Program The Fire Water System Program will be enhanced as follows.

Revise Fire Water System Program procedures to perform an inspection of wet fire water system piping condition at least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic or inorganic material that could result in flow obstructions or blockage of a sprinkler head. Where multiple wetjipe system s are in a building, every other system shall be inspected in a five year period. Then, in the next five year period the ernaininsysterrm s in that buildinq shall be insgecLed. (Refer to NFPA 25 (2011 Edition) Sections 14.2.1 and 14.2.2) The inspection method used shall be capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling. Ensure procedures require a follow-up volumetric wall thickness evaluation where irregularities are detected.

Revise Fire Water System Program procedures to perform an internal inspection of wet fire water system piping conditions at least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of the branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinkler heads. Where multiple we-pipe systems are in a bjjnceryrohesten shajlbe inscted in a fyveyea erio_<;_Threnin the ned five year period. the remaiina stems in that builcina shall be insected.

Enclosure to NRC-15-0002 Page 25 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source

____ ________________________________________________________ Schedule ____

14 Fire Water System Enhance Fire Water System Program as follows: Prior to .1.19 September 20,

b. Revise Fire Water System Program procedures to perform an 2024, or the end inspection of wet fire water system piping condition at least once of the last every five years by opening a flushing connection at the end of one refueling outage main and by removing a sprinkler toward the end of one branch prior to March 20, line for the purpose of inspecting the interior for evidence of loss of 2025, whichever material and the presence of foreign organic or inorganic material is later, with the that could result in flow obstructions or blockage of a sprinkler exception that the head. Where mut lewe-pipe systems are in a building every activities other system shalj be ipspeced in a period Then in the described in this year pive next five year period, the re maininq sy'stems Vi hat building shal commitment for be nsete cL_(Refer to NFPA 25 (2011 Edition) Sections 14.2.1 piping segments and 14.2.2) The inspection method used shall be capable of designed to be detecting surface irregularities that could indicate wall loss due to dry but corrosion, corrosion product deposition, and flow blockage due to determined to be fouling. Ensure procedures require a follow-up volumetric wall collecting water thickness evaluation where irregularities are detected. shall be conducted within

g. Revise Fire Water System Program procedures to perform an five years prior to internal inspection of wet fire water system piping conditions at March 20, 2025.

least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of the branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinkler heads. Where multie wetpie st2ms are in a bulPid vcLother syst em shall iejnseein ajfie year roTi ein ex efe ye rejiieremningsAslerms j in that buildin shall be inspected.

Enclosure to NRC-15-0002 Page 26 B.1.19 FIRE WATER SYSTEM Enhancements Element Affected Enhancement

3. Parameters Monitored or Revise Fire Water System Program procedures to Inspected perform an inspection of wet fire water system piping condition at least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic or inorganic material that could result in flow obstructions or blockage of a sprinkler head. Vhere nuljle vet-pije svstemns are in a buileinq, every other systern shall be inspected in a five yar period. Then, in the next five year perio, the remaining systems in that building shall be inspected.(Refer to NFPA 25 (2011 Edition) Sections 14.2.1 andFi4.2.2) The inspection method used shall be capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling.

Ensure procedures require a follow-up volumetric wall thickness evaluation where irregularities are detected.

4. Detection of Aging Effects Revise Fire Water System Program procedures to perform an internal inspection of wet fire water system piping conditions at least once every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of the branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinkler heads._ Wheremutjpe wet-pige sy~ters are ir a buiLdn every other ysemsjhalI be inspected in a five year period. Then in the next five year period, the remaining systems in that buildin shall be inspected.

Enclosure to NRC-15-0002 Page 27 RAI B.L19-4

Background:

As amended by letter dated July 30, 2014, Enhancement No. 4 to the "detection of aging effects" program element of the Fire Water System Programstates that a basis for the acceptance criteriaof less than or equal to 25 psig and less than or equal to 10 psig that currently exists in the main drain test procedures will be developed.

GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that, as stated in NFPA 25 Section 13.2.5.2, a 10 percent reduction on full flow pressureduring main drain tests should be corrected.

Issue:

During the audit, the staff confirmed that the fire water system headerpressure is 150 psig plus or minus 10 psig. While the less than or equal to 10 psig acceptance criterionis less than the 10 percent reduction recommended in NFPA 25 and, therefore, could be conservative based on the 150 psig headerpressure, it is not clear to the staff how a less than or equal to 25 psig criterion can be justified. Although the enhancement states that the basisfor the less than or equal to 25 psig and less than or equal to 10 psig criteriawill be developed priorto the period of extended operation,the staff cannot complete its review of the Fire Water System Programuntil the basis for the acceptance criteriais provided.

Request:

Provide the basisfor the acceptance criteriaof less than or equal to 25 psig and less than or equal to 10 psig that currently exists in the main drain test procedures.

Response

DTE is unable to determine the basis for the acceptance criteria of 5 25 psig and 10 psig in the main drain test procedures. Therefore, DTE will revise the main drain test procedure in accordance with NFPA 25 Section 13.2.5.2 that states, "When there is a 10 percent reduction in full flow pressure when compared to the original acceptance test or previously performed tests, the cause of the reduction shall be identified and corrected as necessary."

LRA Revisions:

LRA Sections A.1.19, A.4, and B.1.19 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-0051) are not shown in underline or strike-through such that only the new changes due to RAI B.1.19-4 are shown as revisions.

Enclosure to NRC-15-0002 Page 28 A.1.19 Fire Water System Program The Fire Water System Program will be enhanced as follows.

Revise Fire Water System Program procedures to a) specify that in accordance with NFPA Section 13.2.5.2 when there is a 10 percent reduction in full flow- ressure when corn ared to the original acceptance test or previously perforrmed testsh te cause of the reduction shall be identified and corrected as necessary and a ere-a. 9%<eea

~n-presse i* em+e-ma+4*44e-prev44as-main-' re res4eek b) note the time to return to static pressure after performing a main drain testr 44d4ejaaa aslede -e - . s4 _25-.!4- s a- evFr

Enclosure to NRC-15-0002 Page 29 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source

____ ___

___ ___

___ ___

___ ___ ___ ___ ___ ___ ___ Schedule S uc 14 Fire Water System Enhance Fire Water System Program as follows: Prior to A.1.19 September 20,

d. Revise Fire Water System Program procedures to a) specify 2024, or the end that in accordance with NFPA Section 13,2.5.2 when there is a of the last 10 percent reduction in full flow pressure when cpared to refueling outage the ariail acceptance test or previous prformed test the prior to March 20, cause of the reduction shall be identified and corrected as 2025, whichever necessara n des-a %4dre e re rm is later, with the ee+ rn e~-e-a-ismrr+-tesk es  ; b) exception that the note the time to return to static pressure after performing a activities main drain test a1-4v p- 5aier4; ta described in this elteesp4 a ee -thec commitment for mi=ass-est-p ee . piping segments designed to be dry but determined to be collecting water shall be conducted within five years prior to March 20, 2025.

Enclosure to NRC-15-0002 Page 30 B.1.19 FIRE WATER SYSTEM Enhancements Element Affected Enhancement

4. Detection of Aging Effects Revise Fire Water System Program procedures to a) specify that in accordance with NFPA Section 132.5.2 when there is a 10 percent reduction in full flow pressure when compared to the original acceptance test or previously performed tests, the cause of the reduction shall be identified and corrected as necessary and )-adde-a40%

p b) note the time to return to static pressure after performing a main drain test;-ed a-cas f4et

Enclosure to NRC-15-0002 Page 31 RAI B.1.19-5

Background:

As amended by letter dated July 30, 2014, EnhancementNo. 6 to the "detection of aging effects" program element of the Fire Water System Programstates that, "sprinklersare cleaned if obstructions are identified during internal inspections."

GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that, as stated in NFPA 25 Section 5.2.1.1.2, sprinklers that are corrodedor that exhibit loading should be replaced.

Issue:

The applicantdid not provide a basisfor why corroded or loaded sprinklers can be cleaned versus replaced.

Request:

State the basisfor why cleaning debrisfrom a sprinklerwill not impact its ability to perform its CLB intendedfunction(s) during the period of extended operation.

Response

The License Renewal Application (LRA), as amended by letter NRC-14-0051 dated July 30, 2014, contains an enhancement for the Fire Water System Program that states, "Revise Fire Water System Program procedures to ensure piping and sprinklers are cleaned if obstructions are identified during internal inspections." The intent of this enhancement was to perform internal inspections of piping for obstructions, consistent with the 2011 Edition of National Fire Protection Association (NFPA) 25 Sections 14.2 and 14.3 as identified in Table 4a of LR-ISG-2012-02. The cleaning applies only to the piping; sprinklers would be replaced in this case. Therefore, the LRA will be revised as indicated below.

The inspection of sprinklers is performed consistent with NFPA 25 Section 5.2.1.1 as identified in Table 4a of LR-ISG-2012-02. The corrosion of sprinklers is addressed in the response to RAI B.1.19-7. Regarding loaded sprinklers, the LRA, as amended by the July 30, 2014 letter, takes exception to NFPA 25 Section 5.2.1.1 since loading due to dust or debris is not an effect of aging and is therefore not included in the aging management program. Although not a part of the aging management program, plant procedures do address loaded sprinklers. Sprinklers that are loaded with dust are cleaned by using air to remove the dust and sprinklers that are loaded with debris other than dust are replaced.

Enclosure to NRC-15-0002 Page 32 LRA Revisions:

LRA Sections A.1.19, A.4, and B.1.19 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-0051) are not shown in underline or strike-through such that only the new changes due to RAI B.1.19-5 are shown as revisions.

Enclosure to NRC-15-0002 Page 33 A.1.19 Fire Water System Program The Fire Water System Program will be enhanced as follows.

• Revise Fire Water System Program procedures to ensure piping iscteaned and sprinklers are repac~d e4ead 2 if obstructions are identified during internal inspections.

Srinklers loaded with dust rnav be cleaned usinc air rather thanr epced.

Enclosure to NRC-15-0002 Page 34 AA4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source

____

___ ___ _ ___

_ ___

___ ___ ___ ___ ___ ____ ___ ___ ___ ___ ___ ___ Schedule _ _ _ _

14 Fire Water System Enhance Fire Water System Program as follows: Prior to A.1.19 September 20,

f. Revise Fire Water System Program procedures to ensure 2024, or the end piping is cleaned and sprinklers are re aced_csre4-if of the last obstructions are identified during internal inspections. refueling outage Sprinklers loaded with dust may be cleaned using air rather prior to March 20, than relpaced. 2025, whichever is later, with the exception that the activities described in this commitment for piping segments designed to be dry but determined to be collecting water shall be conducted within five years prior to March 20, 2025.

Enclosure to NRC-15-0002 Page 35 B.1.19 FIRE WATER SYSTEM Enhancements Element Affected Enhancement

4. Detection of Aging Effects Revise Fire Water System Program procedures to ensure piping is cleaned and sprinklers are replace eaa mdif obstructions are identified during internal inspections. _oriniersjoaded vith dust may e cleaned usin air rather than reolaced.

Enclosure to NRC-15-0002 Page 36 RAI B..19-6

Background:

As amended by letter dated July 30, 2014, EnhancementNo. 11 to the "detection of aging effects" program element of the Fire Water System Programstates that an obstruction investigation will be conducted after an extended shutdown of more than one year.

GALL Report AMP XLM27, as modified by LR-ISG-2012-02, recommends that, as stated in NFPA 25 Sections 14.2.1.3 and 14.3.1, there are additionalcriteriafor conducting obstruction investigations(e.g., discharge of obstructive materialduring routine water tests, plugging of inspector'stest connection,pinhole leaks).

Issue:

During the audit, the staff did not find any procedures that included the additionalcriteriafor conducting an obstruction investigation. In addition, the applicantdid not provide a basisfor why its enhancement is sufficient to ensure that obstruction investigationswould be conducted when appropriate.

Request:

State the criteria that will be used to determine when an obstruction investigation should be conducted.

Response

Fire Water System Program procedures will be revised to require obstruction investigation whenever any of the criteria listed in the 2011 Edition of National Fire Protection Association (NFPA) 25 Sections 14.2.1.3 or 14.3.1 are met. The License Renewal Application (LRA) will be revised as indicated below.

LRA Revisions:

LRA Sections A.1.19, A.4, and B.1.19 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-0051) are not shown in underline or strike-through such that only the new changes due to RAI B.1.19-6 are shown as revisions.

Enclosure to NRC-15-0002 Page 37 A.1.19 Fire Water System Program The Fire Water System Program will be enhanced as follows.

Revise Fire Water System Program procedures to perform an obstruction investigation whenever anv of the criteria listed in NFPA Section 4.2.1.3 or 4.3.1 are met e~era

Enclosure to NRC-15-0002 Page 38 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source

_____ _______________________________________

_______________ Schedule 14 Fire Water System Enhance Fire Water System Program as follows: Prior to A.1 19 September 20,

k. Revise Fire Water System Program procedures to perform 2024, or the end an obstruction investigation whenever any of the criteria listed of the last in NFPA Section 14. or 143. are ret ar eeded refueling outage prior to March 20, 2025, whichever is later, with the exception that the activities described in this commitment for piping segments designed to be dry but determined to be collecting water shall be conducted within five years prior to March 20, 2025.

Enclosure to NRC-15-0002 Page 39 B.1.19 FIRE WATER SYSTEM Enhancements Element Affected Enhancement

4. Detection of Aging Effects Revise Fire Water System Program procedures to perform an obstruction investigation whenever an, of the criteria listed in NFPA Section 14.2.1.3 or 14,3.1 are met e rsdro dran

______

______ ______ _ thef - en~e-vea t

Enclosure to NRC-15-0002 Page 40 RAI B..19-7

Background:

The "acceptance criteria"program element of the Fire Water System Program,as amended by letter dated July 30, 2014, does not include an acceptance criteriaassociatedwith corrosion of sprinklers during periodic visual sprinkler inspections. In addition, during the audit, the staff reviewed the applicant'splant-specificproceduresfor inspecting sprinklers. The acceptance criteriain the proceduresdid not address corrosion of the sprinklers.

GALL Report AMP XI.M27, as modified by LR-ISG-2012-02, recommends that, as stated in NFPA 25 Section 5.2.1.1.2, sprinklers that exhibit corrosionshould be replaced.

Issue:

The applicantdid not provide a basisfor why corrodedsprinklers can remain in service.

Request:

State the basisfor why a corroded sprinkler will be capable of performing its CLB intended function during the period of extended operation.

Response

All sprinklers are inspected annually from the floor level using, where appropriate, magnification tools and lighting to ensure that sprinklers are free of corrosion. As discussed in the response to RAI B.1.19-5, if any sprinkler is found with a build-up of dust that can be cleaned with compressed air, it will be acceptable to do so. Any sprinkler that shows signs of corrosion shall be replaced. The License Renewal Application (LRA) will be revised as indicated below to address this replacement of sprinklers.

LRA Revisions:

LRA Sections A.1.19, A.4, and B.1.19 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-005 1) are not shown in underline or strike-through such that only the new changes due to RAI B.1.19-7 are shown as revisions.

Enclosure to NRC-15-0002 Page 41 A.1.19 Fire Water System Program The Fire Water System Program will be enhanced as follows.

Revise Fire Water System Program procedures to replace sprinklers associated with representative tested sprinkler, if the representative test sprinkler fails to meet the test requirements.

Pe vie Fire Water Systern Program procedures to replace any sprinkler that shows signs of corrosion.

Enhancements will be implemented prior to the period of extended operation.

Enclosure to NRC-15-0002 Page 42 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source

____

___ _ __ _ ___

___ ___ ______ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ Schedule _ _ _ _

14 Fire Water System Enhance Fire Water System Program as follows: Prior to A.1.19 September 20,

o. Revise Fire Water System Program procedures to replace 2024, or the end sprinklers associated with representative tested sprinkler, if the of the last representative test sprinkler fails to meet the test refueling outage requirements. prior to March 20, 2025, whichever pevise Fire Water Saern_P rced ustprejace r prom is later, with the any sprinkler that shows signs of corrosion. exception that the activities described in this commitment for piping segments designed to be dry but determined to be collecting water shall be conducted within five years prior to March 20, 2025.

Enclosure to NRC-15-0002 Page 43 B.1.19 FIRE WATER SYSTEM Enhancements Element Affected Enhancement

6. Acceptance Criteria Revise Fire Water System Program procedures to specify that ifthe presence of sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected during pipe inspections, the material is removed and the source and extent of condition determined, corrected, and the condition entered into the Corrective Action Program.

6. cceotance_Criteria Revise Fire Water S stern Program procedures to repiace any sprinkler that shows signs of corrosion

7. Corrective Actions Revise Fire Water System Program procedures to replace sprinklers associated with representative test sprinkler, if the representative test sprinkler fails to meet the test requirements.

Enclosure to NRC-15-0002 Page 44 R AI B..19-8

Background:

One of the plant-specific operatingexperience examples cited in the LRA describesfire suppressionflow testing that demonstrateddegradingconditions in the undergroundpiping system. The applicant stated that it increasedthe frequency of testing and evaluation of this pipingfrom 3 years, as required in the CLB, to annual testing. However, the applicantdid not state that increasedfrequency will continue into the period of extended operation.

Issue:

Based on its review of corrective action reports that describe the trend of degradation,it is not clear to the staff why the increasedfrequency of testing should not be continued during the period of extended operation.

inoteprido xede prto, unuehwteisu isit akround. [Per discussion with NRC on 1/12/15, the sentence in strike-through is not part of the RA.]

Request:

State the basisfor why performing the fire suppressionflow test of the undergroundpiping system every 3 years during the PEO will be adequate to detect a decreasingtrendprior to the system not being able to perform its CLB intendedfunction.

Response

DTE performs annual water flow tests per the Corrective Action Program due to anomalies in water flow test data. DTE will continue to conduct annual water flow tests until an appreciable number of test results indicate no degradation. At that time (which is forecasted to be prior to the period of extended operation), DTE will resume Technical Requirements Surveillance Requirement (TRSR) 3.12.2.19 water flow test frequency of 3 years; exceeding the NFPA 25 Section 7.3.1 requirement of 5 years.

Additionally, an enhancement will be added to program element 7, "Corrective Actions," to revise Fire Water System Program procedures to consider, in accordance with the Corrective Action Program, increasing test frequency if there is a decreasing trend in flow in the fire water system flow test. The License Renewal Application (LRA) will be revised as indicated below.

LRA Revisions:

LRA Sections A.1.19, A.4, and B.1.19 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-0051) are not shown in

Enclosure to NRC-15-0002 Page 45 underline or strike-through such that only the new changes due to RAI B.1.19-8 are shown as revisions.

Enclosure to NRC-15-0002 Page 46 A.1.19 Fire Water System Procrar The Fire Water System Program will be enhanced as follows.

Revise Fire Water System Program procedures to replace sprinklers associated with representative tested sprinkler, if the representative test sprinkler fails to meet the test requirements.

Fevise Fire Water_SsPerogram procedures to consider in accordance with the Corrective Action Prograrn increasing test freauencv if there is a decreasing trend in flow in the fire water system flow test.

Enhancements will be implemented prior to the period of extended operation.

Enclosure to NRC-15-0002 Page 47 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source Schedule 14 Fire Water System Enhance Fire Water System Program as follows: Prior to A.1.19 September 20,

o. Revise Fire Water System Program procedures to replace 2024, or the end sprinklers associated with representative tested sprinkler, if the of the last representative test sprinkler fails to meet the test refueling outage requirements. prior to March 20, 2025, whichever ie

g. Re FireWatel r°ce dcures to consid roorar pjstem is later, with the in accordance with the Corrective Action Proqram, jncreasing exception that the test frequenov if there is a decreasingtrend in flow in the fire activities watersystem flow test. described in this commitment for piping segments designed to be dry but determined to be collecting water shall be conducted within five years prior to March 20, 2025.

Enclosure to NRC-15-0002 Page 48 B.1.19 FIRE WATER SYSTEM Enhancements Element Affected Enhancement

7. Corrective Actions Revise Fire Water System Program procedures to replace sprinklers associated with representative test sprinkler, if the representative test sprinkler fails to meet the test requirements.

7. Corrective Actions Revise FRe Water S stern Program procedures to consjder in accor dance with the Corrective Action Prograrnjincreasing test frequen jf there is a decreasing trend in flow in the fire water system flow test_

Enclosure to NRC-15-0002 Page 49 RAI B1.19-9

Background:

As amended by letter dated July 30, 2014, LRA Section A.L19 states that "[t]he Fire Water System Programmanages loss of materialfor in-scope long-lived passive water-basedfire suppression system components using periodicflow testing and visual inspections."

LR-ISG-2012-02 Table 3.0-1 recommends that the updatedfinal safety analysis report(UFSAR) supplement summary descriptionfor the Fire Water System Programshould also state that it managesfouling andflow blockage.

Issue:

Although LRA Section A. 1.9 referencesfouling andflow blockage, it is only in reference to conducting visual inspections,not all of the inspections and testing in the program. It is not clear to the staff that the applicant'sCLB will be adequate during the periodof extended operation if the Fire Water System Program UFSAR supplement does not state that the program managesfouling andflow blockage.

Request:

State the basisfor not includingfouling andflow blockage in the UFSAR descriptionfor the Fire Water System.

Response

The License Renewal Application (LRA), as amended by letter NRC-14-0051 dated July 30, 2014, contains a description of the Fire Water System Program that states that the program,

"... manages loss of material for in-scope long-lived passive water-based fire suppression system components..." As indicated by later statements in the program description, the program also manages flow blockage and aging effects caused by fouling. In order to make this intention clear, the program description in the LRA will be revised as indicated below.

LRA Revisions:

LRA Sections A.1.19 and B.1.19 are revised as shown on the following page. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-0051) are not shown in underline or strike-through such that only the new changes due to RAI B.1.19-9 are shown as revisions.

Enclosure to NRC-15-0002 Page 50 A.1.19 Fire Water System Program The Fire Water System Program manages loss of material due o generlajitig, and crevi-ce corrsion microbiologically influenced corrosion, or fouling, and flow blockage due to fouling for in-scope long-lived passive water-based fire suppression system components using periodic flow testing and visual inspections. When visual inspections are used to detect loss of material, the inspection technique is capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling.

B.1.19 FIRE WATER SYSTEM Program Description The Fire Water System Program manages loss of material dg eqge ralpjttin, and crevice corrosion, rnicro iologically influenced corrosion, or fouling, and flow blockage due to fouling for in-scope long-lived passive water-based fire suppression system components using periodic flow testing and visual inspections. When visual inspections are used to detect loss of material, the inspection technique is capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling.