NRC-15-0004, DTE Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 14

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

ML15016A056
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-15-0004
Download: ML15016A056 (27)

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 10 CFR 54 January 15, 2015 NRC-15-0004 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 14 (TAC No.

MF4222)," dated December 16, 2014 (ML14335A188)

Subject:

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

No new commitments are being made in this submittal. However, revisions have been made to commitments previously identified in the LRA to inspect sand cushion drain lines and determine drywell shell thickness in the sand cushion areas. These revised commitments are in Item 9 in Table A.4 as indicated in the responses to RAIs B.1.12-2 and B.1.12-4.

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

USNRC NRC-15-0004 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 15, 2015 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 14 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-15-0004 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 1

Enclosure to NRC-15-0004 Page 1 RAI B.L12-1

Background

Section 54.21(a)(3) of Title 10 of the Code of FederalRegulations (10 CFR) Part54 requires that the applicantdemonstrate that the effects of agingfor structuresand components will be adequately managed so that the intendedfunction(s) will be maintained consistent with the current licensing basis (CLB)for the period of extended operation. As described in the "StandardReview Planfor Review of License Renewal Applicationsfor NuclearPower Plants" (SRP-LR), an applicantmay demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the Generic Aging Lessons Learned (GALL) Report and when evaluation of the matter in the GALL Report applies to the plant.

The "detection of aging effects" program element of GALL Report aging managementprogram (AMP) XI.S], "ASME Section XI, Subsection IWE," recommends that the program is augmented to require surface examination, in addition to visual examination, to detect cracking in stainless steel penetrationsleeves, dissimilarmetal welds, bellows, and steel components that are subject to cyclic loading but have no CLB fatigue analysis. This program element also states that, where feasible, appropriateAppendix J tests (AMP XL S4) may be performed in lieu of surface examination.

The "ProgramDescription" of GALL Report AMP XL S1 states that "[t]he program is also augmented to require surface examination of dissimilarmetal welds of vent line bellows in accordancewith examination CategoryE-F, as specified in the 1992 Edition of the ASME Code,Section XI, Subsection IWE."

License Renewal Application (LRA) Section B. 1.12 states that Fermi 2 primary containment is a GeneralElectric Mark I pressuresuppressionsteel containment consisting of a drywell, a torus, and a connecting vent system. LRA Section B.1.12, "ContainmentInservice Inspection - IWE,"

states that the existing program,with the enhancements, will be consistent with GALL Report AMP XLS.

During the audit, the staff noted that the "detection of aging effects" program element in the LRA AMP basis document (FERMI-RPT-12-LRD05,Revision 1, Section 3.2) states that stainless steel penetration sleeves, dissimilarmetal welds, bellows, and steel components that are subject to cyclic loading but have no CLB fatigue analysis are monitoredfor cracking. It also states that, X.S4 ContainmentLeak Rate Program(10 CFR Part50, Appendix J) tests may be performed in lieu of surface examination.

Issue It is not clear to the staff that the statements noted abovefor the "detection of aging effects" program element are consistent with the GALL Report because the LRA AMP basis document does not state that supplemental surface examinations will be performed, in addition to visual

Enclosure to NRC-15-0004 Page 2 examinations, to detect cracking in stainless steel penetrationsleeves, dissimilarmetal welds, bellows, and steel components that are subject to cyclic loading but have no CLB fatigue analysis. Further; if the option to perform appropriateAppendix J tests, in lieu of surface examinations, will be usedfor any of the mentioned components, the LRA AMP does not mention the type of Appendix J test that would be performedfor the specific components in orderfor the staff to evaluate the appropriatenessof the test to detect cracking in these components prior to loss of intendedfunction.

Rest

1. State whether the supplemental surface examination recommended in GALL ReportAMP XIS] will be performed, in addition to visual examination, to detect cracking in the following containmentpressure boundary components: (I) stainlesssteel and dissimilarmetal welds of penetrationsleeves, penetrationbellows, and vent line bellows and (2) steel components that are subject to cyclic loading but have no CLB fatigue analysis, if any. If supplemental surface examinationswill be performed, indicate what standardwill be used to perform surface examinationsof stainless steel and dissimilarmetal welds.

2. If an Appendix J test is used to detect cracking, in lieu of supplemental surface examination, for the components noted in Request 1, indicate the type of Appendix J test that will be used for the applicablecomponents, andjustify its appropriatenessto detect crackingprior to loss of intendedfunction.

3. If supplemental examinations will not be performed or supplemental examination methods other than those described in GALL Report AMP XIS] will be used,justify the adequacy of the proposed exception regardingthe method to identify the aging effects of cracking in the components noted in Request 1.

4. Update the LRA and UpdatedFinalSafety Analysis Report (UFSAR) supplement, as applicable, to be consistent with the responses to the above requests.

Response

1. The penetration sleeves at Fermi 2 are carbon steel but some include dissimilar metal welds.

The penetration bellows and the dissimilar metal welds of the penetration sleeves are inaccessible and it is not possible to perform a surface examination. Based on the design of the torus vent line bellows, a liquid penetrant examination of the bellows weld might be possible; however, it would be very difficult to perform an exam because of the difficulty in removing the excess penetrant in the bellows convolute area. This is further complicated because it is a confined space, high contamination area, and the pipe is on a steep angle creating safety issues. Fermi 2 follows ASME Section XI, Subsection IWE, 2001 Edition with the 2003 Addenda, which specifies a general visual examination. The supplemental surface examination discussed in GALL Report AMP XLS 1 will not be performed.

Enclosure to NRC-15-0004 Page 3 As described in the Updated Final Safety Analysis Report (UFSAR) Section 3.8.2.1.3.1, sleeved penetration assemblies with bellows consist of the process pipe, guard pipe, penetration sleeve bellows, and flued head. For Class 1 piping (Fermi 2 Group A), the design of the flued head meets ASME Section III Class 1 requirements, which specify a fatigue analysis that determines the cumulative usage factor for the flued head. UFSAR Figure 3.8-9 provides a cross-sectional drawing of the penetration assemblies and a listing of the penetrations that utilize this design (designated as Type I). The usage factors are shown in License Renewal Application (LRA) Table 4.6-2 for these flued head penetrations based on the number of cycles shown in the analysis input value column in LRA Table 4.3-1.

The specification for the bellows for these penetrations required the bellows to be analyzed for at least 200 cycles of normal operation thermal movement and 10 faulted (accident pressure and temperature) cycles. The analysis for these bellows determined they were capable of handling the movement from many more normal operation or faulted cycles than were specified. The bellows are qualified for more than the projected number of startups and shutdowns, and therefore, the bellows analysis remains valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i). DTE will manage the aging effects due to fatigue of these penetrations using the Fatigue Monitoring Program (LRA Section B.1.17) in accordance with 10 CFR 54.21(c)(1)(iii). The Fatigue Monitoring Program monitors the plant transients that contribute to fatigue usage.

LRA Section 4.6.2 for the Vent Line Bellows states, "The vent line bellows were specified to be qualified for at least 500 cycles of bellows expansion from the drywell and torus temperature increase following an accident, 600 cycles from operating basis earthquakes (OBE), and 300 cycles from safe shutdown earthquakes. The calculation determined the bellows were qualified for over 6000 cycles. Accident or earthquake cycles have not occurred. Therefore, the bellows analysis remains valid for the period of extended operation in accordance with 10 CFR 54.21 (c)(1)(i)."

LRA Section 4.6.3 for the Refueling and Drywell Seal Bellows states, "Fermi 2 has a refueling bellows attached to the vessel near the reactor vessel flange and a drywell seal bellows outside of the drywell shell. A calculation determined that the refueling bellows were qualified for 45,000 thermal cycles and 9,000 refueling cycles, and the drywell bellows were qualified for 2,800 thermal cycles and 180,000 refueling cycles. The analyzed number of cycles is many more than the expected number of startups and shutdowns and refueling outages through the period of extended operation. Therefore, the bellows analysis remains valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i)."

LRA Section 4.6.4 for the Traversing Incore Probe Penetration Bellows states, "There are penetration bellows at the traversing incore probe (TIP) penetrations. The fatigue analysis determined the bellows were qualified for over 6900 cycles of earthquake or thermal cycles, which are many more cycles than they are expected to experience. Therefore, the bellows remain valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i)."

Enclosure to NRC-15-0004 Page 4 The penetration sleeves and penetration bellows are inaccessible and due to the industrial safety hazards (high radiation area, contamination area and confined space), it is not feasible to perform a supplemental surface examination on the torus vent line bellows. As allowed in the GALL Report, DTE will be performing the alternate testing (Appendix J) that is provided in the GALL Report, Section XLS 1, Element 4.

No containment steel components that are subject to cyclic loading but have no current licensing basis fatigue analysis were identified.

2. As provided under detection of aging effects in NUREG-1801,Section X.S1, Appendix J tests (AMP XI.S4) may be performed in lieu of the surface examination. The Fermi 2 Containment Leak Rate Program (LRA Section B. 1.. 13) is consistent with NUREG-1801 AMP X.S4. The Appendix J tests that are performed on the penetration sleeves, penetration bellows, and torus vent line bellows are Type B tests (bellows) and Type A (ILRT) tests (bellows and sleeves). The acceptance criterion for the bellows at Fermi 2 is less than or equal to 1 scfh. With this low acceptance criterion, testing is able to detect extremely small leaks due to cracking prior to loss of intended function.

Additionally, Fermi 2 Deviation Event Report (DER) 92-0130 documents an evaluation of Information Notice (IN) 92-20 in regards to suitability of the Appendix J test for the torus vent line bellows design for Fermi 2. The evaluation determined that the "bellows installed at Fermi 2 are supplied and manufactured by Tube Turns. The Tube Turns bellows has a screen mesh separator that is oriented diagonally to the circumferential lines, that will keep a space between the inner and outer ply of a minimum of between 0.008 and 0.016 inches,"

which allows a Leak Rate Test to be performed.

3. DTE performs the alternate testing (Appendix J) that is allowed in GALL Report Section XI.S1, Element 4, for the dissimilar metal welds of penetration sleeves, penetration bellows and torus vent line bellows. No exception is necessary nor is an exception proposed.

4. LRA Sections A.1.1.2 and B.1.12 will be modified to clarify that the alternative of Appendix J tests is being used for the stainless steel and dissimilar metal welds of the penetration sleeves, penetration bellows and torus vent line bellows, as allowed by Section XI.S 1 of the GALL Report. The LRA revisions are indicated below. Based on review of the wording, the LRA is also being revised to identify that the program specifies augmented inspections as required.

LRA Revisions:

LRA Sections A.1.12 and B.1.12 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0004 Page 5 A.1.12 Containment Inservice Inspection - IWE Prograrn The Containment Inservice Inspection (CII) - IWE Program implements the requirements of 10 CFR 50.55a. The regulations in 10 CFR 50.55a impose the inservice inspection (ISI) requirements of the ASME Boiler and Pressure Vessel (B&PV) Code,Section XI, Subsection IWE, for steel containments (Class MC). The Fermi 2 containment design does not include a concrete containment subject to ASME Section XI, Subsection IWL requirements, and therefore the requirements of Class CC are not applicable. There are no tendons associated with Fermi 2's steel containment vessel. The Fermi 2 primary containment is a General Electric Mark I pressure suppression containment and consists of a drywell, a torus (or suppression chamber), and a vent system connecting the drywell and the torus. The scope of the CiI-IWE Program includes the steel containment vessel and its integral attachments, containment equipment hatches and airlock and moisture barriers, and pressure-retaining bolting. Visual inspections monitor loss of material of the steel containment vessel surface areas, including welds and base metal and containment vessel integral attachments, metal shell, personnel and equipment access hatches, and pressure-retaining bolting. The CII-IWE Program specifies acceptance criteria, corrective actions, augmented inspections as eciuired,and provisions for expansion of the inspection scope when identified degradation exceeds the acceptance criteria.

AppendixJ and Tvpe B testing is erormed ir eu of surface examinations of dissirnilar rnetal welds of penetration sleeves, penetration bellows, and torus vent line bellows as allowed as an alternative in NUGREG:101,Section XI.81, The code of record for the examination of the Fermi 2 containment, Class MC components, and related requirements is in accordance with ASME Code Section XI, Subsections IWE, 2001 Edition with the 2003 Addenda, as mandated and modified by 10 CFR 50.55a.

Enclosure to NRC-15-0004 Page 6 B.1.12 CONTAINMENT INSERVICE INSPECTION - IWE Program Description The Containment Inservice Inspection - IWE (CII-IWE) Program implements the requirements of 10 CFR 50.55a. The regulations in 10 CFR 50.55a impose the inservice inspection (ISI) requirements of the ASME Boiler and Pressure Vessel (B&PV) Code,Section XI, Subsection IWE, for steel containments (Class MC). The Fermi 2 containment design does not include a concrete containment subject to ASME Section XI, Subsection IWL requirements, and therefore the requirements of Class CC are not applicable. There are no tendons associated with Fermi 2's steel containment vessel. The Fermi 2 primary containment is a General Electric Mark I pressure suppression containment and consists of a drywell, a torus (or suppression chamber),

and a vent system connecting the drywell and the torus. The code of record for the examination of the Fermi 2 containment, Class MC components and related requirements is in accordance with ASME Code Section XI, Subsections IWE, 2001 Edition with the 2003 Addenda, as mandated and modified by 10 CFR 50.55a.

The scope of the Fermi 2 CII-IWE Program includes the free-standing steel containment vessel and its integral attachments, containment hatches, airlocks, moisture barriers, and pressure-retaining bolting. The program performs visual examinations (general visual, VT-1 and VT-3) to assess the general condition of the containment and to detect evidence of degradation that may affect structural integrity or leak tightness. The visual inspections monitor loss of material of the steel containment vessel surface areas including welds and base metal and containment vessel integral attachments, metal shell, personnel and equipment access hatches, and pressure-retaining bolting. The CII-IWE Program specifies acceptance criteria, corrective actions, a-uenteg jnsp ectins asrecuiured and provisions for expansion of the inspection scope when identified degradation exceeds the acceptance criteria. Apen , vp and Type B tsting is peforned in lieu of surface exaninations of dissimilar metal welds of pienetration aleeves enetration bellows -a nd torus vent line bellows as allowed as an alternative in NUREG- 1801,Section XI.S1.

Enclosure to NRC-15-0004 Page 7 RAI B.1.12-2

Background

Section 54.21(a)(3) of 10 CFR requires that the applicantdemonstrate that the effects of aging for structuresand components will be adequately managed so that the intendedfunction will be maintainedconsistent with the CLB for the period of extended operation. As described in the SRP-LR, an applicantmay demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluationof the matter in the GALL Report applies to the plant.

The "preventive action" program element of GALL Report AMP XL SI recommends that the program be augmented to include preventive actions that ensure that moisture levels associated with an acceleratedcorrosion rate do not exist in the exteriorportion of the BWR Mark 1 steel containmentdrywell shell. The actions consist of ensuring that the sand pocket area drains and/or the refueling seal drains are clear.

The "parametersmonitored or inspected" program element of GALL Report AMP XI.S1 recommends that "applicantswith BWR Mark I steel containments should monitor the sand pocket area drains and/or the refueling seal drainsfor water leakage. The licensees should ensure the drains are clear to prevent moisture levels associatedwith acceleratedcorrosion rates in the exterior portion of the drywell shell." LR A Section B. 1.12 states that Fermi 2 primary containment is a General ElectricMark I pressure suppression steel containment consisting of a drywell, a torus, and a connecting vent system. LRA Section B. 1.12, "ContainmentInservice Inspection - IWE," states that the existing program,with enhancements, will be consistent with GALL Report AMP XL SL To demonstrate consistency with the recommendationsfor a BWR Mark I containment drywell shell in the GALL Report AMP, LRA Sections A. 1.12 and B. 1.12 include enhancements to program elements that will be implemented prior to the period of extended operation. The "preventive action" program element of the LRA AMP includes an enhancement (Commitment 9a in LRA Section A.4) to revise plantprocedures to require inspection of the sand pocket drain lines priorto the periodof extended operation. The "parametersmonitored or inspected" program element of the LRA AMP includes an enhancement (Commitment 9d in LRA Section A.4) to revise plantprocedures to specify that inspections of sandpocket drain lines will monitor the internalcondition of drain lines. The "detection of aging effects" programelement of the LRA AMP includes an enhancement (Commitment 9e in LRA Section A.4) to revise plant procedures to require visual inspection of sand pocket drain lines to ensure there is no evidence of blockage.

Issue The staff needs additionalinformation to determine that these enhancements are consistent with the recommendationsfor BWR Mark I steel containments in the "preventive actions" and

Enclosure to NRC-15-0004 Page 8 "parametersmonitored or inspected" program elements of the GALL Report AMP because: (1) it is not clear if the intent of the license renewal commitments is to revise plantproceduresprior to the period of extended operationor to revise plantproceduresand perform inspection of drain lines prior to the period of extended operation; (2) the proposedenhancementsfor license renewal, Commitments 9a and 9d, do not provide a stated objective for the inspection (i.e., to ensure that drain lines are clearor to monitorfor water leakage or moisture in the drains or both); (3) the enhancements, license renewal Commitments 9a, 9d, and 9e, do not provide the associatedfrequency of inspections and the bases for its adequacy to meet the intended objective; and (4) it is not clear to the staff as to how the LRA AMP ensures that the refueling seal drainsare clear.

Request

1. Clarify if the intent of the enhancementfor Commitments 9a, 9d, and 9e in LRA Section A.4 is to revise plant proceduresprior to the period of extended operation or both, to revise plant procedures and perform inspection of drain lines prior to the period of extended operation.

2. Describe the objective(s) (i.e., to ensure that drain lines are clear or to monitorfor water leakage or moisture in the drainsor both); for the program enhancements listed as license renewal Commitments 9a and 9d in LRA Section A.4.

3. Provide the frequency of inspections associatedwith license renewal Commitments 9a, 9d, and 9e in LRA Section A.4 with the basesfor the adequaciesto accomplish the objective (i.e.,

to ensure that drain lines are clear or to monitorfor water leakage or moisture in the drains or both); of the enhancements.

4. Clarify if the LRA AMP B. 1.2 includes actions to ensure that the refueling seal drains are clear in order to prevent moisture levels associatedwith acceleratedcorrosion rates in the exterior portion of the drywell shell as recommended in the "preventive actions" and "parametersmonitoredand inspected" program elements of GALL Report AMP XL SL Otherwise,provide technicaljustificationfor the exception to the GALL Report recommendations.

5. Update the LRA and UFSAR supplement, as appropriate,to be consistent with the responses to the above requests.

Response

1. License Renewal Application (LRA) commitments 9a, 9d, and 9e are being revised and consolidated to clarify the timing and frequency of the sand cushion drain line internal inspections.

Enclosure to NRC-15-0004 Page 9

2. The objective for the sand cushion drain lines inspections in LRA commitments 9a and 9d (revised as indicated above) is to determine the internal condition (e.g. moisture, sand, blockage) and to confirm that the drains are not blocked.

3. The inspections will be performed one time prior to the PEO and once every 10 years during the PEO. The drain lines have been inspected twice, with the most recent inspection being in 2014, after approximately twenty-nine (29) years of plant operation. The inspections revealed that the drain lines were not blocked or obstructed. Based on the Fermi 2 operating experience, an additional inspection prior to PEO and once every 10 years during PEO are considered appropriate to meet the objective.

4. LRA aging management program (AMP) B.1.12 does include actions to visually check the reactor well liner leak detection drain #20 (refueling seal drain line) for water leakage every refueling outage to prevent moisture accumulation on the exterior portion of the drywell shell. No activity is taken to monitor the drain line to ensure it remains clear. The opening to the drain line itself is inaccessible, being sealed off by the drywell seals bellows assembly and associated seal plates. The seal boundary is welded. The drywell seal bellows cannot be visually observed because it is behind a plate. The drywell seal bellows is stainless steel and the condition of the water in contact with it is controlled per the Water Chemistry Control -

BWR Program. As discussed in LRA Section 4.6.3, the drywell seal bellows was analyzed for many more cycles than it is expected to experience through the period of extended operation. Based on the material, design, and water chemistry management, leakage through the bellows is unlikely.

Only if the drywell seals bellows assembly were to leak would water enter the liner area, from which the liner leak detection line drains. There is approximately one hundred feet of small bore pipe between the liner area drain opening and the sight glass used for checking for leakage during refueling outages, with multiple bends and much of the drain line embedded in concrete, so inspection with a boroscope from the sight glass is not practical. In addition to the reactor well liner leak detection drain #20, there are other drain lines in the bellows area (e.g. drywell seal rupture drain lines), which could be used if the drywell bellows seal ruptured to minimize water leaking onto the outside of the drywell shell. If small leakage was occurring, and the reactor well liner leak detection drain #20 was plugged, water could leak along the drywell shell into the sand cushion area. The sand cushion area is also visually checked for water leakage each refueling outage. As addressed above, the sand cushion drains have been inspected and will be inspected periodically during the PEO to ensure they are not blocked.

Per GALL Report AMP XI.S 1, element 2, preventive actions consist of ensuring that the sand pocket area drains and/or the refueling seal drains are clear. Under element 3, GALL Report AMP XI.S 1 states: "As recommended in LR-ISG-2006-01, license renewal applicants with BWR Mark I steel containments should monitor the sand pocket area drains and/or the refueling seal drains for water leakage." Since GALL Report AMP XI.S 1 addresses ensuring the sand pocket area drains and/or (emphasis added) the refueling seal drains are clear and

Enclosure to NRC-15-0004 Page 10 are monitored, DTE's commitment to monitor the sand cushion drain lines for blockage is consistent and no exception is needed.

5. LRA Sections A.1.12, A.4, and B.1.12 will be revised as indicated below.

LRA Revisions:

LRA Sections A.1.12, A.4, and B.1.12 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0004 Page 11 A.1.12 Containment Inservice Inspection - IWE Program The CII-IWE Program will be enhanced as follows:

Revise plant procedures to require inspection of the sand cushion ekedrain lines to monitor the internal conditions of the drain lines (e.g for moisture, sand, blockage) and ensure therei no evidence of blocka.e at least once prior to the period of extended operation and once ever 10 earsdurina the period of extended operatioi.

• Revise plant procedures to specify the preventive actions delineated in NUREG-1339 and in EPRI NP-5769, NP-5067, and TR-104213 that emphasize proper selection of boltl ing material, installation torque or tension, and the use of lubricants and sealants for high strength bolting.

• Revise plant procedures to include the preventive actions for storage of ASTM A325 and A490 bolting from Section 2 of Research Council for Structural Connections publication, "Specification for Structural Joints Using ASTM A325 or A490 Bolts."

" a"#:.

>La.!z..°-._ a"& z'.S-P-. " '"~a w.'-

"' ' ' ' -'Uc i.c s "s -.ra'°:.r- 't

Enclosure to NRC-15-0004 Page 12 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source Schedule 9 Containment Inservice Enhance CII-IWE Program as follows: Prior to A.1.12 Inspection (CII) - IWE September 20,

a. Revise plant procedures to require inspection of the sand 2024, or the end cushiompeke- drain lines to monitor the internal conditions of of the last the drain lines _(ea, or misturesndblockage andensure refueling outage there is no evidence of blockage aieast once prior to the prior to March 20, period of extended operation and once every 10 years during 2025, whichever the period of extended operation. is later.

b. Revise plant procedures to specify the preventive actions delineated in NUREG-1339 and in EPRI NP-5769, NP-5067, and TR-104213 that emphasize proper selection of bolting material, installation torque or tension, and the use of lubricants and sealants for high strength bolting.

c. Revise plant procedures to include the preventive actions for storage of ASTM A325 and A490 bolting from Section 2 of Research Council for Structural Connections publication, "Specification for Structural Joints Using ASTM A325 or A490 Bolts."

'^ e-dra:-; e-eis~an-~eewe4-+ei~-isadneea~-sn =

Enclosure to NRC-15-0004 Page 13 B.1.12 CONTAINMENT INSERVICE INSPECTION - IWE Element Affected Enhancement

2. Preventive Actions Re -p ed e - a s -fe Revise plant procedures to specify the preventive actions delineated in NUREG-1339 and in EPRI NP-5769, NP-5067, and TR-104213 that emphasize proper selection of bolting material, installation torque or tension, and the use of lubricants and sealants for high strength bolting.

Revise plant procedures to include the preventive actions for storage of ASTM A325 and A490 bolting from Section 2 of Research Council for Structural Connections publication, "Specification for Structural Joints Using ASTM A325 or A490 Bolts."

2 Preventive Actions Revise plant procedures to reouire inspecion of the

3. Pararneters Monitored or sand cushion drain lines to monitor the internal inspected conditions of the drain lines (e.g, for moisture, sand,

4. Detection of Agig Eff cs blockaoe) and ensure there is no evidence of blockag at least once prior to the period of extended operation and once every 10 years during th perid of extended operation.

"-.-iamees-'r- - Revi se-pa r-4-p s=e -"}--' s};'ify' hat--nepe io s interned-4endvies f44xedrain,4 es cle . ,.r r eser;c

Enclosure to NRC-15-0004 Page 14 RAI BL12-3

Background

Section 54.21(a)(3) of 10 CFR requires that the applicantdemonstrate that the effects of aging for structures and components will be adequately managed so that the intendedfunction will be maintainedconsistent with the CLB for the period of extended operation. As described in the SRP-LR, an applicantmay demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

The "preventive action" program element of GALL Report AMP XL SI recommends that the program be augmented to include preventive actions that ensure that moisture levels associated with an acceleratedcorrosion rate do not exist in the exteriorportion of the BWR Mark I steel containment drywell shell. The actions consist of ensuring that the sandpocket areas drains and/or the refueling seal drainsare clear.

The "parametersmonitored or inspected" program element of GALL Report AMP XL SI recommends that license renewal applicants with BWR Mark I steel containments should monitor the sandpocket area drains and/or the refueling seal drainsfor water leakage and also ensure the drains are clear.

LRA Section B.12 states that Fermi 2 primary containment is a GeneralElectric Mark I pressure suppressionsteel containment consisting of a drywell, a torus, and a connecting vent system. LRA Section B. . 12, "ContainmentInservice Inspection - IWE," states that the existing program,with enhancements, will be consistent with GALL Report AMP XL SI.

To demonstrate consistency of the program elements in the LRA with that in the GALL Reportfor BWR Mark I containments, LRA Sections A.1.12 and B. 1.2 include enhancements to program elements that will be implemented prior to the periodof extended operation. The "preventive action" program element of the LRA AMP includes an enhancement (Commitment 9a in LRA Section A.4) to revise plantprocedures to require inspection of the sand pocket drain lines prior to the period of extended operation. The "parametersmonitored or inspected" program element of the LRA AMP includes an enhancement (Commitment 9d in LRA Section A.4) to revise plant procedures to specify that inspections of sand pocket drain lines will monitor the internal condition of drain lines.

During the audit,from a review of Fermi 2 Surveillance Procedure24.000.03, Revision 77 (includingAttachments ] and 2), the staff noted that this procedure included implementation of regulatory commitments made by letter NRC-88-0081, "Revised Response to GL 87-05," dated April 20, 1988, and tracked in the applicant'sRegulatory Action Commitment Tracking System (RACTS) under RACTS 88027. These items require inspection of the reactor-drywellseal bellows and the four sand cushion drain linesfor leakage during Mode 5 "Refueling" of every refueling outage. Accordingly, the procedure requires verification of the reactor-drywellseal bellows leakage on a daily basisfor the first 3 days following reactorcavity flooding and at a

Enclosure to NRC-15-0004 Page 15 frequency of 7 days following that with an acceptancecriteriaof no observed leakage. The procedure also requires verification of the drywell sand cushion leakage at a frequency of 7 days (with a note that the commitment is monthly but performance will be 7 days) following reactor cavity flooding with an acceptance criteriaof no observed leakage. Checks for leakage are requiredat Azimuth 90/180/270/360 degrees, 6 inches below reactorpedestal catwalk between torus and drywell.

Issue The "preventive actions" programelement of the LRA AMP basis document states on page 26 that:

During refueling the refueling bellows drain empties into a manifold which is equipped with a sight glass. This sight glass is monitored when the refueling pool isflooded to detect potential leakage of water into the space aroundthe drywell shell. The sand pocket drains are also being monitoredfor signs of moisture. Fermi 2 plans to re-inspect the drain lines to verify their conditionprior to the period of extended operationto confirm that these preventative actions are not warranted[emphasis added by the staff].

The program will be enhanced to require inspection of the sandpocket drain lines prior to the period of extended operation.

Further,the "parametersmonitored or inspected" program element on page 28 of the program basis document states that: "Fermi 2 performs routine surveillancesof the drains to record the observed condition of the drain linesfor any leakage. Fermi 2 will inspect the sandpocket drain lines to verify their conditionprior to the period of extended operationto confirm that the sand pocket drains are clear...."

Despite the above existing commitments controlledby Procedure24.000.03 to periodically monitor the sandpocket cushion drain lines and reactor-drywellseal bellows for signs of water leakage into inaccessible areas of the drywell, it is not clear to the staff if the periodic monitoring of the sand cushion drain lines and refueling seal bellows for water leakage every refueling outage will continue into the periodof extended operation because of the inconsistent and contradictingstatement on page 26 of the LRA program basis document that is cited with added emphasis in the indentedparagraphabove. This statement appearsto provide an indicationthat the periodicmonitoring of sand cushion drain lines and refueling seal bellows may be discontinued. Therefore, the staff needs additionalinformation to determine if the "parametersmonitored or inspected" program element is consistent with GALL Report AMP XLSI with regard to the recommendationfor periodicallymonitoring the sandpocket area drains and the refueling seal drainsfor water leakage.

Request

1. Confirm if the refueling seal bellows and the sand cushion drain lines of the Fermi 2 Mark I steel containment will continue to be monitoredperiodicallyevery refueling outagefor water

Enclosure to NRC-15-0004 Page 16 leakage or signs of moisture, in accordancewith Procedure 24.000.03, through the period of extended operation. If these will be monitoredperiodically through the period of extended operation,provide an explanation of the contradictingstatement on page 26 of the LRA AMP basis document that "Fermi 2 plans to re-inspect the drain lines to verify their condition prior to the period of extended operation to confirm that these preventative actions are not warranted" in the context of demonstrating consistency with the "parametersmonitored or inspected" program element of GALL Report AMP XL SL

2. If monitoring of the refueling seal bellows and the sand cushion drain lines for water leakage will not continue into the period of extended operation, as recommended in the "parameters monitored or inspected" program element of GALL Report AMP XI. S, justify the adequacy of the proposed exception to manage the aging effects of corrosion in inaccessible areas of the drywell shell exterior.

3. Update the LRA and UFSAR supplement, as applicable, to be consistent with the responses to the above requests.

Response

1. DTE plans to continue monitoring of the drywell seal bellows and sand cushion drain lines every refueling outage for water leakage or signs of moisture through the period of extended operation. The statement "to confirm that these preventative actions are not warranted" was intended to indicate that periodic confirmation that the sand cushion drain lines were clear is not necessary during the period of extended operation. As discussed in the response to RAI B.1.12-2, DTE has revised commitment 9a to specify inspecting the drain lines to verify their condition prior to the period of extended operation and once every 10 years during the period of extended operation.

2. Monitoring the drywell seal bellows and sand cushion drain lines for water leakage will continue each refueling outage during the period of extended operation.

3. No changes are needed to the LRA. The responses above identify that the monitoring of the drain lines for leakage is consistent with GALL Report AMP XLS 1.

LRA Revisions:

None.

Enclosure to NRC-15-0004 Page 17 RAI B. 1.12-4

Background

Section 54.21(a)(3) of 10 CFR requires that the applicantdemonstrate that the effects of aging for structures and components will be adequately managed so that the intendedfunction will be maintainedconsistent with the CLB for the period of extended operation. As described in the SRP-LR, an applicantmay demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluationof the matter in the GALL Report applies to the plant.

The "monitoringand trending" program element in GALL Report AMP XI.Sl recommends that license renewal applicantsfor plants with a BWR Mark I containment develop a corrosion rate that can be inferredfrom past ultrasonictesting (UT) examinations or establish a corrosion rate using representativealternate means and provide a technical basis based on the developed or establishedcorrosion rate that the drywell will have sufficient thickness to perform its intended function through the period of extended operation.

LRA Section B. 12 states that Fermi 2 primary containmentis a GeneralElectric Mark I pressure suppressionsteel containment consisting of a drywell, a torus, and a connecting vent system. LRA Section B.1.12, "ContainmentInservice Inspection - IWE," states that the existing program, with enhancements, will be consistent with GALL Report AMP XI.SI.

To establish consistency of the program element in the LRA with that in the GALL Report, LRA Sections A.1.12 and B.1.12 include an enhancement to the "monitoringand trending" program element that will be implementedprior to the periodof extended operation. This enhancement (Commitment 9f in LRA Section A.4) states: "Revise plantprocedures to determine drywell shell thickness in the sandpocket areasbefore the period of extended operation. From the results, develop a corrosionrate to demonstrate that the drywell shell will have sufficient thickness to perform its intendedfunction through the period of extended operation." During the audit, the staff noted that,for technical reasons indicatedin the letters NRC-87-005 and NRC-88-0081, dated September 10, 1987, and April 20, 1988, respectively, and summarized in LRA Section B. 1.12, ultrasonicthickness measurements of the drywell shell sandpocket areas were not performed at Fermi 2 in response to GenericLetter (GL) 87-05.

Issue It is not clear to the staff if the statements above in the "monitoringand trending" program elements of the GALL Report AMP and LRA AMP are consistent because the proposed enhancement to the "monitoringand trending" program element in the LRA AMP does not indicate the minimum number of sets and interval at which UT measurements will be performed, and it does not provide the technicalbasis of how an appropriatecorrosion rate will be developed if only one set of UT measurements is intended.

Enclosure to NRC-15-0004 Page 18 Request

1. State the minimum number of sets of UT measurements and the interval at which they will be performed to determine the corrosionrate of the drywell shell sand pocket area. Also, explain the basisfor the selected number of sets and intervalfor UT measurements of the drywell shell. Provide the technical basis that the drywell shell will have sufficient thickness to perform its intendedfunction through the period of extended operation.

2. If only one set of UT measurements is intended in the response to Request 1, provide the technical basis of how an appropriateor conservatively-biasedcorrosion rate will be developed based on one set of UT measurements.

3. Update the LRA and UFSAR supplement, as applicable, to be consistent with the responses to the above requests.

Response

1. One set of UT measurements was taken in spring of 2014 (RF16) on the drywell shell sand cushion area. The measurements were taken from 300 degrees progressing clockwise every 12 inches and ending at 120 degrees. One reading was taken at the moisture barrier and another reading was taken approximately 6 inches above the moisture barrier. Out of the 150 readings taken, the lowest reading was 1.557 inches and the highest reading was 1.690 inches. All measurements were above the nominal design value of 1.5 inches, with no apparent material loss after almost 30 years of operation, so there is reasonable assurance that the drywell shell will have sufficient thickness to perform its intended function throughout the period of extended operation (PEO). A second set of UT measurements will be taken prior to the PEO to determine a corrosion rate from the two sets. UT measurements will be re-performed once each interval (i.e. ten years) during PEO.

2. Not applicable since more than one set of UT measurements will be used as discussed above.

3. The License Renewal Application (LRA) will be revised as indicated below to reflect the response above.

LRA Revisions:

LRA Sections A.1.12, A.4, and B.1.12 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0004 Page 19 A.1.12 Containment Inservice Inspection - IWE Program The CII-IWE Program will be enhanced as follows:

Revise plant procedures to determine drywell shell thickness in the sand cushions w-ke areas before the period of extended operation and once in each ten year interval during thejerod of extended oeration. From the results (including prior resuLts), develop a corrosion rate to demonstrate that the drywell shell will have sufficient wall thickness to perform its intended function through the period of extended operation.

Enclosure to NRC-15-0004 Page 20 AA LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source Schedule 9 Containment Inservice Enhance CII-IWE Program as follows: Prior to A.1.12 Inspection (CI1) - IWE September 20,

f. Revise plant procedures to determine drywell shell thickness 2024, or the end in the sand cushion zeek t-areas before the period of of the last extended operation and once in each ten year interval during refueling outage the period of extended operation. From the results_inguding prior to March 20, prjirresauts), develop a corrosion rate to demonstrate that the 2025, whichever drywell shell will have sufficient wall thickness to perform its is later.

intended function through the period of extended operation.

Enclosure to NRC-15-0004 Page 21 B.1.12 CONTAINMENT INSERVICE INSPECTION - IWE Element Affected Enhancement

5. Monitoring and Trending Revise plant procedures to determine drywell shell thickness in the sand cushion et-areas before the period of extended operation and once in eaci ten year interval durin the oeriod of extended operation. From the resultsincudinjLprior resujs, develop a corrosion rate to demonstrate that the drywell shell will have sufficient wall thickness to perform its intended function through the period of extended operation.

Enclosure to NRC-15-0004 Page 22 RAI B..12-5

Background

Section 54.21(a)(3) of 10 CFR requires that the applicantdemonstrate that the effects of aging for structuresand components will be adequately managed so that the intendedfunction will be maintainedconsistent with the CLB for the period of extended operation. As described in the SRP-LR, an applicantmay demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

The "corrective actions" program element in GALL Report AMP XI.S1 recommends that:

If moisture has been detected or suspected in the inaccessible areas on the exterior of the Mark I containment drywell shell or the source of moisture cannot be determined subsequent to root cause analysis, then:

(a) Include in the scope of license renewal any components that are identifiedas a source moisture, if applicable, such as the refueling seal or cracks in the stainless liners of the refueling cavity pools walls, and perform aging management review.

(b) Identify surfaces requiring examination by implementing augmented inspectionsfor the period of extended operation in accordance with Subsection IWE-1240, as identified in Table IWE-2500-1, Examination Category E-C.

(c) Use examination methods that are in accordancewith Subsection IWE-2500.

(d) Demonstrate, through use of augmented inspectionsperformed in accordancewith Subsection IWE, that corrosion is not occurring or that corrosion is progressingso slowly that the age-relateddegradationwill not jeopardize the intendedfunction of the drywell shell through the period of extended operation.

LRA Section B.1.12 states that the Fermi 2 primary containment is a GeneralElectric Mark I pressure suppressionsteel containment consisting of a drywell, a torus, and a connecting vent system. LRA Section B.1.12, "ContainmentInservice Inspection - IWE, " states that the existing program,with enhancements, will be consistent with GALL Report AMP XI SL LRA Sections A.1.12 and B. 1.2 include an enhancement to the "corrective action" program element of the LRA AMP that will be implemented prior to the period of extended operation.

This enhancement (Commitment 9g in LRA Section A.4) commits to revise plantprocedures to require three specific corrective actions should moisture be detected or suspected in the inaccessible areas on the exterior of the Mark I steel containment drywell shell. These specific actions included in the above enhancement to the LRA AMP correspondto recommended actions (b), (c), and (d) (as listed above) in the "corrective actions" program element of GALL Report AMP XI.S1 if moisture has been detected in the inaccessible areas on the exterior of the Mark I

Enclosure to NRC-15-0004 Page 23 containmentdrywell shell or the source of moisture cannot be determinedsubsequent to root cause analysis. However, the LRA AMP program basis document and corresponding enhancement did not address action (a) of GALL Report AMP XI.S1 which recommends including any components that are identified as a source of moisture, if applicable,within the scope of license renewal and performing an aging management review.

Issue It is not clear to the staff that the "corrective actions" program element of the LRA AMP is consistent with recommended actions in the GALL ReportAMP. Specifically, if moisture is detected or suspected in inaccessible areas of the drywell shell exterior of Mark I containments, the LRA AMP basis document did not identify the components that are potential sources of moisture to inaccessibleareas of the drywell exterior and whether they were subjected to AMR.

Request

1. With regard to the enhancement in the "corrective action" program element of the LRA AMP B.112, clarify if components that are sources of moisture to inaccessibleareas of the Mark I containmentdrywell shell exterior have been identified and subjected to an AMR, as recommended in item (a) of the correspondingelement in GALL Report AMP XL Si. List the components that have been identifiedas potential sources of moisture to inaccessible areas of the drywell exterior and have been subjected to an AMR.

2. Otherwise,justify the adequacy of the proposed exception to manage the aging effects of corrosiondue to moisture intrusion in inaccessible areas of the drywell shell exterior.

3. Update the LRA and UFSAR supplement, as applicable, to be consistent with the responses to the above requests.

Response

1. The components that are potential sources of moisture to the inaccessible area of the drywell exterior are the reactor cavity liner and refueling bellows assembly. These components are subject to aging management review as indicated in License Renewal Application (LRA)

Table 2.4-1. Aging management review results are provided in LRA Table 3.5.2-1. As noted in LRA Table 3.5.2-1, loss of material for the stainless steel reactor cavity liner is managed by the Water Chemistry Control - BWR aging management program (AMP). Loss of material for the refueling bellows assembly is managed by the Water Chemistry Control -

BWR and Structures Monitoring AMPs.

2. Not applicable since the potential sources of moisture are subject to aging management review as indicated in the LRA.

Enclosure to NRC-15-0004 Page 24

3. No updates to the LRA are needed since the information is included in the LRA as described above.

LRA Revisions:

None.