NRC-15-0005, Response to NRC Request for Additional Information for the Review of License Renewal Application - Set 10

Response to NRC Request for Additional Information for the Review of License Renewal Application - Set 10

ML15021A393
Person / Time
Site:	Fermi
Issue date:	01/20/2015
From:	Kaminskas V DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-15-0005
Download: ML15021A393 (24)

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 20, 2015 NRC-15-0005 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 10 (TAC No.

MF4222)," dated December 17, 2014 (ML14342A868)

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 10 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 12, Fatigue Monitoring, of LRA Table A.4 as indicated in the response to RAI B.1.17-2.

In addition, a revision has been made to a commitment previously identified in the LRA. The revised commitment is in Item 3, Aboveground Metallic Tanks, in LRA Table A.4 as indicated in the response to RAI B.1.1-1.

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

USNRC NRC-15-0005 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 20, 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 10 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-15-0005 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 10

Enclosure to NRC-15-0005 Page 1 RAI B.1.1-1

Background

Generic Aging Lessons Learned (GALL) Report aging management program (AMP) XIM29, "Aboveground Metallic Tanks," recommends that sealant or caulking be applied to outdoor tanks at the external interface between the tank and concrete foundation. The function of the sealant or caulk is to minimize the amount of water and moisture penetrating the interface between the tank and concrete foundation. The GALL Report, as revised by LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation, "further states that sealant or caulking is not necessary if the configuration of both the tank bottom and foundation is sloped in such a way that water cannot accumulate. License Renewal Application (LRA) Section B.1.1 states that, "[ijn accordance with installation and design specifications, the tanks do not employ caulking or sealant at the concrete/tank interface."

The LRA further states that the design of the condensate storage tank (CST) foundation is a concrete ring with the aluminum tank bottom in contact with graded sand. During the AMP audit the staff noted that the design also incorporates drains to facilitate the removal of water from the interior of the concrete ring foundation. However, the top surface of the concrete ring is not sloped to prevent water and moisture intrusion at the outside interface of the ring foundation.

Issue It is not clear to the staff if the applicant's Aboveground Metallic Tanks Program contains the appropriate preventive actions to manage this aging effect associated with the CST The accumulation of water or moisture at the outside interface of the ring foundation could result in the loss of material or cracking of the aluminum.

Request In the absence of caulking or sealant, state how the aging effects of loss of material and cracking of the aluminum in the proximity of the interface between the tank and concrete foundation will be managed during the period of extended operation for the CST.

Response

As stated in License Renewal Application (LRA) Section B.1.1, the condensate storage tank (CST) design and installation specifications did not include caulking or sealant at the interface of the CST and its concrete ring foundation. Although not specified, there does appear to be caulking in some places at the concrete/tank interface. However, this caulking is not being credited to prevent the intrusion of water or moisture. The tank insulation prevents access to the concrete/tank interface and is expected to prevent the intrusion of water and moisture.

Enclosure to NRC-15-0005 Page 2 Within the 10 years prior to the period of extended operation, a volumetric examination will be performed on a sampling basis to assess the condition of the outer portion of the tank bottom that is in contact with the concrete ring foundation. Four 1-foot sections of the interface between the tank and concrete ring foundation will be examined for cracking and loss of material. If cracking and loss of material are not present, then further volumetric examination is not necessary to demonstrate that water and moisture intrusion are not causing aging effects on the aluminum tank bottom.

To ensure that the insulation continues to protect the concrete/tank interface, subsequent inspection may be conducted of the exterior surface of the insulation. The inspection of the exterior surface of insulation will be consistent with GALL Report AMP XLM29 Aboveground Metallic Tanks, as modified by LR-ISG-2012-02 "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation" as described in element 4 "Detection of Aging Effects".

If cracking or loss of material are detected, additional inspections or assessments will be conducted in accordance with the Corrective Action Program.

The LRA will be revised to reflect this response.

LRA Revisions:

LRA Sections A.1.1, A.4, and B.1.1 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0005 Page 3 A.1.1 Aboveground Metallic Tanks Program The Aboveground Metallic Tanks Program is a new program that will manage loss of material and cracking for outdoor tanks within the scope of license renewal that are sited on soil or concrete. Preventive measures to mitigate corrosion and cracking were applied during construction, such as using the appropriate materials, protective coatings, and elevation as specified in design and installation specifications. For the painted carbon steel combustion turbine generator (CTG) fuel oil tank, the program will monitor the external surface condition for indications and precursors of loss of material. For the insulated aluminum condensate storage tank (CST), the program will monitor the condition of a representative sample of the tank external surface for signs of loss of material and cracking, using visual inspections and surface examinations. Exterior portions of the tanks will be inspected in accordance with Table 4a, "Tank Inspection Recommendations," identified in LR-ISG-2012-02. There are no indoor tanks included in this program.

CST internal inspections will be conducted in accordance with Table 4a, identified above.

Internal inspections of the CTG fuel oil tank will be conducted in accordance with NUREG-1801, XI.M30.

This program will also manage the bottom surfaces of both in-scope aboveground metallic tanks, which are on concrete ring foundations and sand. The program will require ultrasonic testing (UT) of the tank bottoms to assess the thickness against the thickness specified in the design specification. UT of the tank bottoms will be performed whenever the tanks are drained or at intervals not less than those recommended in Table 4a during the period of extended operation.4 r?-sene ea'-wdhinsa#atirandre c,

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rkteaee Caulking or sealant at the concrete/tank interfaces is not credited in the installation and design spechica tiors.

Within the ten yeas prior to the period of extended opration, a volumetric examination of four 1-foot sections of the interface between the CST and concrete ring foundation will be performed for cracking and loss of material. If cracking and loss of material are not Present his prog ram will conduct subsequent inspections of the exterior surface of the insulation.

This program will be implemented prior to the period of extended operationwith initial inspections within the ten vears prior to the period of extended operation.

Enclosure to NRC-15-0005 Page 4 A.4 LICENSE RENEWAL COMMITMENT LIST No.

Program or Activity Commitment Implementation Source Schedule 3

Aboveground Metallic Implement new Aboveground Metallic Tanks Program that will Prior to

.1.1 Tanks manage loss of material and cracking for outdoor tanks within September 20, the scope of license renewal that are sited on soil or concrete.

2024, or the end CST internal inspections will be conducted in accordance with of the last Table 4a of LR-ISG-2012-02; internal inspections of the CTG refueling outage fuel oil tank will be conducted in accordance with NUREG-1801, prior to March 20, XI.M30. This program will also manage the bottom surfaces of 2025, whichever both in-scope aboveground metallic tanks. Within the ten years is later. initia prior to the period of extended operation, a volumetric inspections will be examination of four 1-foot sections of the interface between the performed within CST and concrete rind foundation will be performed for cracking the ten years prior and loss of material If cracking and loss of material are not to March 20, present, this prograrn will conduct subsequent ins pecions of the 2025.

exterior surface of the insulation.

Enclosure to NRC-15-0005 Page 5 B.1.1 ABOVEGROUND METALLIC TANKS The Aboveground Metallic Tanks Program is a new program that will manage loss of material and cracking for outdoor tanks within the scope of license renewal that are sited on soil or concrete. Preventive measures to mitigate corrosion and cracking were applied during construction, such as using the appropriate materials, protective coatings, and elevation as specified in design and installation specifications. For the painted carbon steel combustion turbine generator (CTG) fuel oil tank, the program will monitor the external surface condition for indications and precursors of loss of material. For the insulated aluminum condensate storage tank (CST), the program will monitor the condition of a representative sample of the tank external surface for signs of loss of material and cracking using visual inspections and surface examinations. Exterior portions of the tanks will be inspected in accordance with Table 4a, "Tank Inspection Recommendations," identified in LR-ISG-2012-02. There are no indoor tanks included in this program.

CST internal inspections will be conducted in accordance with Table 4a, identified above.

Internal inspections of the CTG fuel oil tank will be conducted in accordance with NUREG-1801, XI.M30.

This program will also manage the bottom surfaces of both in-scope aboveground metallic tanks, which are on concrete ring foundations and sand. The program will require ultrasonic testing (UT) of the tank bottoms to assess the thickness against the thickness specified in the design specification. The UT testing of the tank bottoms will be performed whenever the tanks are drained or at intervals not less than those recommended in Table 4a during the period of extended operation.-4,-aese daned 4

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eat4exete akerfa-Caulking or sealant at the concrete/tank interfaces is not credited in the installation and desicn specifications.

Within the ten years prior to the period of extended operation a volumetric examination of four 1-foot sections of the interface between the CST and concrete ring foundation will be performed for cracking and loss of raterial. If cracking and loss of material are not present, this prograr will conductsubs e uent inspections of the exterior surface of the insulation.

This program will be implemented prior to the period of extended operationvith jnitial insrections within the ten vears prior to the period of extended operation.

Enclosure to NRC-15-0005 Page 6 RAI B.1.1-2

Background

The staff's review of plant-specific operating experience revealed that there have been multiple instances of degradation of the insulation and jacketing on the roof of the CST. The degradation included separations in the sheet metal seams, loss of flashing, and loss of insulation due to weather. In 2013 the CST roof insulation was completely removed and pre-fabricated insulation was installed. The as-found condition of the CST aluminum roof was not documented in the work order. LRA Section B.1.1 states that the external surfaces of the CST will be inspected in accordance with LR-ISG-2012-02, Table 4a. Note 9 of Table 4a recommends that a minimum of 25 1-square-foot sections or 20 percent of the surface area of insulation, a portion of which will be on the tank roof; be removed to permit inspection of the exterior surface of the tanks during each 10-year period of extended operation.

Issue The aluminum roof of the CST has been exposed to weather on multiple occasions and it is unclear if there is any degradation under the pre-fabricated insulation. As a result, it is unclear to the staff whether the proposed extent of inspections for corrosion under insulation for the CST will be adequate to provide reasonable assurance that the CST will meet its current licensing basis (CLB) intended function during the period of extended operation.

Request Provide an assessment of the condition of the aluminum roof under the pre -fabricated insulation of the CST tank. If the condition of the roof under the pre-fabricated insulation is unknown or it is degraded, state the basis for why the proposed bare metal inspections of the CST roof will be sufficient to provide reasonable assurance that the CST will meet its CLB intended functions during the period of extended operation.

Response

In 2013, a work order was initiated to repair the insulation on the roof of the condensate storage tank (CST). This was performed by complete removal of the old roof insulation and installation of pre-fabricated insulation. The CST roof was exposed for a period of time during this work.

Although not explicitly noted in the work order documentation, the supervisor of the work indicated that a visual examination of the CST roof identified no abnormalities.

License Renewal Application (LRA) Section B.1.1 states that the CST external surfaces will be inspected in accordance with Table 4a of LR-ISG-2012-02. Based on the as-found good condition of the aluminum tank roof in 2013, these inspections will provide reasonable assurance that the CST will meet its current licensing basis during the period of extended operation.

Enclosure to NRC-15-0005 Page 7 LRA Revisions:

None.

Enclosure to NRC-15-0005 Page 8 RAI B.L1-3

Background

The updated final safety analysis report (UFSAR) supplement (LRA Section A.4) contains a commitment (Commitment No. 3) to implement the Aboveground Metallic Tanks Program,

"[pjrior to September 20, 2024, or the end of the last refueling outage prior to March 20, 2025." LR-ISG-2012-02, Table 3.0-1, recommends that the program be implemented 10 years prior to the period of extended operation. The recommendation to implement the program 10 years prior to the period of extended operation is to support the inspections recommended in LR-ISG-2012-02, Table 4a. The guidance provided in Table 4a includes inspections of all tank interior and exterior surfaces, including tank tops and bottoms, in timeframes ranging from within 5 to 10 years prior to the period of extended operation. LRA Section B. 1.1 states that the CST will be inspected in accordance with LR-ISG-2012-02, Table 4a.

Issue The implementation schedule for the Aboveground Metallic Tanks Program is not consistent with LR-ISG-2012-02, Table 4a, which recommends that inspections commence in the 10-year period prior to the period of extended operation.

Request State the basis for why the implementation schedule for the Aboveground Metallic Tanks Program does not state that inspections will commence in the 10-year period prior to the period of extended operation.

Response

License Renewal Application (LRA) Section A.4, Item 3, will be revised under "Implementation Schedule" to indicate that the initial inspections will be performed within the 10 years prior to the period of extended operation. This revision was included in the response to RAI B.1.1-1.

LRA Revisions:

LRA Section A.4 is revised as shown in the response to RAI B.1.1-1.

Enclosure to NRC-15-0005 Page 9 RAI B.L9-1

Background

The operating experience discussion in LRA Section B. 1.9 summarizes plant-specific inspection results from 2001, 2005, and 2012. It specifically states that, "In 2005, shroud support weld examinations as well as other inspections of reactor vessel internal welds and components were performed as scheduled by the Reactor Vessel Internals Management (RVIM) program."

Issue The LRA provides the results of the inspections in 2001 and 2012; however; it does not provide the results for the 2005 inspection. In addition, during its onsite audit of the program, the staff discovered that no such inspection was performed in 2005.

Request Provide clarification as to whether there have been any inspections of the BWR vessel inside diameter attachment welds in addition to the ones performed in 2001 and 2012. If there have been any inspections, provide the results and state whether any flaws were detected. Update the LRA as appropriate.

Response

The second operating experience item for License Renewal Application (LRA) Section B.1.9 refers to vessel internal inspection in 2005. Shroud support visual and ultrasonic examinations were performed in RF11 (2006), rather than 2005. There have been no relevant indications noted during any of the examinations for the shroud support welds. LRA Section B.1.9 is being revised to change "2005" to "2006".

LRA Revisions:

LRA Section B.1.9 is revised as shown on the following page. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0005 Page 10 B.1.9 BWR VESSEL ID ATTACHMENT WELDS Operating Experience The following examples of operating experience provide objective evidence that the BWR Vessel ID Attachment Welds Program will be effective in ensuring that component intended functions are maintained consistent with the current licensing basis during the period of extended operation.

Inspections of the shroud support welds as recommended by BWRVIP-38 were completed in 2001 during RF08. Based on no indications on the core shroud support welds, re-inspection dates were established based on the requirements of BWRVIP-38.

In 2t006, shroud support weld examinations as well as other inspections of reactor vessel internal welds and components were performed as scheduled by the Reactor Vessel Internals Management (RVIM) program. The BWRVIP has developed guidelines for inspection of internal components.

Enclosure to NRC-15-0005 Page 11 RAI B.1.10-1

Background

The recommendations in GALL Report AMP XL M9, "BWR Vessel Internals," states that the control rod drive (CRD) housing and lower plenum components are subject to the guidelines in BWRVIP-47-A for inspection and evaluation. GALL AMP XL M9 also states that BWRVIP-58-A provides guidelines for the repair design criteria of the CRD housing and that BWRVIP-57-A provides guidelines for the repair design criteria of the lower plenum components.

LRA AMP B..10, "BWR Vessel Internals," states that the BWR Vessel Internals AMP, with enhancements, is consistent with the recommendations in GALL AMP XL M9.

Issue During its onsite audit of the program, the staff noted that the program documents reference BWRVIP-58-A and BWRVIP-57-A as guidelines for the repair design criteria of the CRD housing and the lower plenum components. The program documents also reference BWRVIP-55-A as repair design criteria guidelines for these components. However; the plant procedures only reference BWRVIP-55-A. The staff is unclear about the inconsistency in the plant documents regarding these guidelines.

Request

1. Identify the specific BWR Vessel Internals Programs (VIP) guidelines that are being used for repairs of the CRD housings and the lower plenum components in the plant design. Clarify whether these guidelines are within the scope of the BWR Vessel Internals Program for the LRA and whether the guidelines have been incorporated into the specific plant procedure that will be used to implement the BWRVIP during the period of extended operation.

2. Identify any additional BWRVIP guidelines being relied upon for the BWRVIP beyond those in GALL Report AMP XI M9. For these additional BWRVIP guidelines, provide the responses to any applicable license renewal applicant action items.

Response

1. Program document PEP16 will be revised to reference the same BWRVIP reports as Aging Management Program Report FERMI-RPT-12-LRD02 pertaining to repairs for lower plenum components and control rod housings.

1) BWRVIP-55-A addresses Control Rod Drive (CRD) Housing, Control Rod Drive Stub Tube, Tncore Housing, Incore Guide Tube, and Incore Stabilizer.

Enclosure to NRC-15-0005 Page 12

2) BWRVIP-57-A addresses reactor vessel water level instrument penetrations (including the nozzle, safe end, and nozzle to vessel shell weld).

3) BWRVIP-58-A addresses one example of weld repair specific to CRD housing penetrations.

PEP 16 will be revised to reflect the following:

Appendix VIII (Control Rod Internal Housing) is associated with BWRVIP-55-A and BWRVIP-58-A.

Appendix IX (In Core Housing / Guide Tube & Dry Tube) is associated with BWRVIP-55-A.

Appendix X (Instrument Penetrations) is associated with BWRVIP-57-A.

The revisions to PEP 16 are being performed as part of the Corrective Action Program.

2. DTE participates in the BWRVIP. Implementation guidance is currently defined in BWRVIP-94NP Revision 2 (Program Implementation Guide). Section 1.4 (Utility Requirements) of this document states that any BWRVIP guidelines containing "mandatory" or "needed" guidance shall be implemented by member utilities to the fullest extent possible.

A list of current BWRVIP reports containing mandatory or needed guidance is provided in the table below. This information is included in PEP16. All BWRVIP guidelines that have license renewal applicant action items have been identified in LRA Appendix C, Response to BWRVIP Applicant Action Items.

Doc Number Rev WRVIP Doc Title WRVIP-02-A 2

WR Core Shroud Repair Design Criteria WRVIP-03 16 BWR Vessel and Internals Project, Reactor Pressure Vessel and Internals Examination Guidelines WR Vessel and Internals Project, Guide for Format and Content of Core Shroud Repair Design Submittals WRVIP-14-A WR Vessel and Internals Project, Evaluation of Crack Growth in BWR Stainless Steel RPV Internals WRVIP-16-A WR Vessel and Internals Project, Internal Core Spray Piping and Sparger Design Criteria WRVIP-18 1-A WR Core Spray Internals Inspection and Flaw Evaluation Guidelines WRVIP-19-A WR Vessel and Internals Project, Internal Core Spray Piping and Sparger Design Criteria WRVIP-25 0

WR Core Plate Inspection and Flaw Evaluation Guidelines WRVIP-26-A WR Top Guide Inspection and Flaw Evaluation Guidelines

Enclosure to NRC-15-0005 Page 13 Doc Number Rev WRVIP Doc Title WRVIP-27-A A

WR Standby Liquid Control System /Core Plate AP Inspection and Flaw Evaluation Guidelines WR Vessel and Internals Project, Technical Basis for WRVIP-34-A A

Part Circumference Weld Overlay Repair of Vessel Internal Core Spray Piping WRVIP-38 0

WR Shroud Support Inspection and Flaw Evaluation Guidelines WRVIP-41 3

WR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines BWR Vessel and Internals Project, LPCI Coupling WRVIP-42 1

Inspection and Flaw Evaluation Guidelines - Not applicable BWRVIP-47-A WR Lower Plenum Inspection and Flaw Evaluation Guidelines WRVIP-48-A WR Vessel and Internals Project, Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines WRVIP-49-A A

BWR Vessel and Internals Project, Instrument Penetration Inspection and Flaw Evaluation Guidelines WRVIP-50-A WR Vessel and Internals Project, Top Guide/Core Plate Repair Design Criteria WRVIP-51 -A A

WR Vessel and Internals Project, Jet Pump Repair Design Criteria WRVIP-52-A A

WR Vessel and Internals Project, Shroud Support and Vessel Bracket Repair Design Criteria WRVIP-53-A A

WR Vessel and Internals Project, Standby Liquid Control Line Repair Design Criteria WRVIP-55-A WR Vessel and Internals Project, Lower Plenum Repair Design Criteria WRVIP-56-A A

WR Vessel and Internals Project, LPCI Coupling Repair Design Criteria - Not applicable WRVIP-57-A BWR Vessel and Internals Project, Instrument Penetrations Repair Design Criteria WRVIP-58-A WR Vessel and Internals Project, CRD Internal Access Weld Repair WR Vessel and Internals Project, Evaluation of Crack WRVIP-59-A A

Growth in BWR Nickel Base Austenitic Alloys in RPV Internals WR Vessel and Internals Project, Evaluation of Stress WRVIP-60-A Corrosion Crack Growth in Low Alloy Steel Vessel Materials in the BWR Environment

Enclosure to NRC-15-0005 Page 14 Doc Number Rev WRVIP Doc Title BWR Vessel and Internals Project, Technical Basis for WRVIP-62 1

Inspection Relief for BWR Internal Components with Hydrogen Injection WRVIP-74-A A

WR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal WRVIP-76 1

WR Core Shroud Inspection and Flaw Evaluation Guidelines WRVIP-80 A

BWR Vessel and Internals Project, Evaluation of Crack Growth in BWR Shroud Vertical Welds BWR Vessel and Internals Project, Guidelines for WRVIP-84 0

Selection and Use of Materials for Repairs to BWR Internal Components WRVIP-94NP 2

WR Vessel and Internals Project, Program Implementation Guide WRVIP-95-A A

BWR Vessel and Internals Project, Guide for Format and Content of BWRVIP Repair Design Submittals WRVIP-97-A A

WR Vessel and Internals Project, Guidelines for Performing Weld Repairs to Irradiated BWR Internals

'WR Vessel and Internals Project, Crack Growth Rates WRVIP-99-A A

in Irradiated Stainless Steels in BWR Internal Components BWR Vessel and Internals Project, Updated Assessment WRVIP-100-A of the Fracture Toughness of Irradiated Stainless Steel for BWR Core Shrouds WRVIP-121-A A

AMA Fluence Methodology Procedures Manual WRVIP-138 1-A WR Vessel and Internals Project, Updated Jet Pump Beam Inspection and Flaw Evaluation Guidelines WRVIP-139 A

BWR Vessel and Internals Project, Steam Dryer Inspection and Flaw Evaluation Guidelines WRVIP-158-A A

Flaw Proximity Rules for Assessment of BWR Internals WRVIP-159 0

BWR Vessel and Internals Project, HWC/NMCA Experience Report and Application Guidelines WRVIP-180 0

Access Hole Cover Inspection and Flaw Evaluation Guidelines WRVIP-181-A Steam Dryer Repair Design Criteria WR Vessel and Internals Project, Guidance for WRVIP-182-A A

Demonstration of Steam Dryer Integrity for Power Uprate - Not applicable WRVIP-183 0

op Guide Grid Beam Inspection and Flaw Evaluation Guidelines

Enclosure to NRC-15-0005 Page 15 Doc Number Rev WRVIP Doc Title WR Vessel and Internals Project, Volume 1: BWR WRVIP-190 1

Water Chemistry Guidelines - Mandatory, Needed, and Good Practice Guidance and Volume 2: BWR Water Chemistry Guidelines - Technical Basis BWR Vessel and Internals Project, Methodologies for WRVIP-194 0

Demonstrating Steam Dryer Integrity for Power Uprate Not applicable WRVIP-200 0

WR Vessel and Internals Project, Implementation Plan or Two-sided Inspection of BWR Shroud Welds WRVIP-205 0

Bottom Head Drain Line Inspection and Evaluation Guidelines WRVIP-217 0

Access Hole Cover Repair Design Criteria WRVIP-222 0

Accelerated Inspection Program for BWRVIP-75-A Category C Dissimilar Metal Welds LRA Revisions:

None.

Enclosure to NRC-15-0005 Page 16 RAI B.1.17-2

Background

GALL Report AMP X.M1, "Fatigue Monitoring," prevents fatigue time-limited aging analyses (TLAAs)from becoming invalid by assuring that the fatigue usage resulting from actual operational transients does not exceed the American Society of Mechanical Engineers (ASME)

Code Section III design limit of 1.0. Crack initiation is assumed to have started when the fatigue usage factor reaches a value of 1.0 (the Code design limit). The applicant's Fatigue Monitoring Program monitors the number of occurrences of plant transients in order to ensure that cumulative fttigue usage remains below component design limits based on fatigue crack initiation. However, LRA Table 4.1-1, "List of Fermi 2 TLAAs and Resolution," includes a flaw evaluation TLAA to be managed during the period of extended operation using the Fatigue Monitoring Program. The flaw evaluation TLAA is the main steam bypass lines discussed in LRA Section 4.76. Flaw evaluation involves flaw growth analyses; therefore the fatigue usage factor of 1.0 based on crack initiation has been exceeded or is not applicable.

GALL Report AMP X.M], "Fatigue Monitoring," recommends tracking the number of each plant design transient that signficantly contributes to the fatigue usage factor. The events being counted by the applicant's Fatigue Monitoring Program are included in LRA Table 4.3-1, "Analyzed Transients with Projects." The staff noted that Table 4.3-1 includes events that are being counted for the main steam bypass lines that are based on operating time as opposed to plant transients.

Issue (1) LRA Table 4.1-1 contains a flaw evaluation TLAA that will be managed by the Fatigue Monitoring Program during the period of extended operation. The applicant's Fatigue Monitoring Program tracks plant transients to ensure that cumulative fatigue usage remains below component design limits based on fatigue crack initiation. The applicant's Fatigue Monitoring Program does not have an enhancement to ensure that analyses other than cumulative fatigue usage remain valid and within acceptable limits during the period of extended operation. It is unclear to the staff if flaw evaluations and flaw growth analyses are within the scope of the applicant's Fatigue Monitoring Program.

Request (la) Identify all TLAAs that will use the Fatigue Monitoring Program to ensure that any analyses or design limit other than a fatigue usage factor for crack initiation is not exceeded during the period of extended operation.

(1b) Justify using the Fatigue Monitoring Program to ensure that any analysis or design limit is not exceeded, other than a fatigue usage factor for crack initiation.

Enclosure to NRC-15-0005 Page 17 (1c) If the Fatigue Monitoring Program is being used to ensure that any analysis or design limit other than a fatigue usage factor for crack initiation is not exceeded, update the AMP as appropriate.

Issue (2) LRA Table 4.3-1 contains events other than plant transients that will be tracked by the Fatigue Monitoring Program during the period of extended operation. The applicant's Fatigue Monitoring Program does not have an enhancement to track cycles other than plant transients. It is unclear to the staff if tracking events other than plant design transients are within the scope of the applicant's Fatigue Monitoring Program.

Request (2a) Identify all events and cycles that will be tracked by the Fatigue Monitoring Program during the period of extended operation that are not plant design transients.

(2b) Justify using the Fatigue Monitoring Program for tracking events and cycles that are not plant transients. State the basis for the adequacy of the Fatigue Monitoring Program's capability to track events and cycles that are not plant transients.

(2c) If events and cycles other than plant transients are being tracked during the period of extended operation, update the program elements of the Fatigue Monitoring Program to reflect the applicable events and cycles.

Response

(la)

"Determination of high energy line break locations" and the "Main steam bypass lines cumulative operating time" are the TLAAs identified for Fermi 2 that will use the Fatigue Monitoring Program to ensure that an analysis or design limit other than a fatigue usage factor for crack initiation is not exceeded during the period of extended operation.

Although the "Determination of high energy line break locations" TLAA is not a fatigue usage analysis that prevents crack initiation, it does entail fatigue usage analyses that determine cumulative usage factors (CUFs) based on assumed numbers of critical thermal and pressure transients. The "Main steam bypass lines cumulative operating time" is not a fatigue usage analysis. The evaluation included a flaw evaluation based on an assumed flaw and a vibration service life evaluation.

(lb & 2b) The Fatigue Monitoring Program monitors and tracks the number of critical thermal and pressure transients to ensure that the fatigue usage remains within allowable limits.

This is directly applicable to the TLAA for determination of high-energy line break locations because the Fatigue Monitoring Program is monitoring the number of transients to ensure the fatigue usage remains within an allowable limit. An exception is provided

Enclosure to NRC-15-0005 Page 18 in LRA Section B.1.17 because for high-energy line break locations, the CUF limit is not the design code limit and an additional corrective action is necessary. DTE monitors the time the main steam bypass is in operation to ensure that bypass operations are within the established limit. The Fatigue Monitoring Program has the necessary administrative infrastructure to readily monitor and track the operating time of the main steam bypass line. It is therefore an appropriate aging management program to track the main steam bypass lines cumulative operating time.

(2a)

The events listed in LRA Table 4.3-1 are plant design transients except the one listed under "Main steam bypass line time of operation at 30%-45% open (days)" [the corresponding TLAA is "Main steam line cumulative operating time"]. Although "Reactor recirculation pump "A" hot standby (hours idle with backflow)" and "Reactor recirculation pump "B" hot standby (hours idle with backflow)" monitor time instead of number of cycles, they are plant design transients. The time limit was determined by dividing the number of cycles that results in a fatigue usage of 1.0 for the pump shaft by the cycle rate. The cycle rate used for this calculation was determined from. test results.

(lc & 2c) An enhancement to the Fatigue Monitoring Program will be added to include the Main Steam Bypass line cumulative operating time.

The fatigue monitoring program may be revised in response to RAI Set 17 (ML14356A212) or after the Environmentally Assisted Fatigue calculations are performed to periodically assess fatigue rather than count cycles for specific components.

LRA Revisions:

LRA Sections A.1.17, A.4, and B.1.17 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0005 Page 19 A.1.17 Fatigue Monitoring Program The Fatigue Monitoring Program will be enhanced as follows.

After the EAF calculations are completed, revise the Fatigue Monitoring Program procedures to state that the program counting of the cycle limits maintains the cumulative fatigue usage below the design limit through the period of extended operation, with consideration of the reactor water environmental fatigue effects.

e Revise Fatigue /Ionitoring Program procedures so that the scope of the program includes monitorin the op eratin hours for the a in Stearn bypass oeration at the 30%-45% valve open position and perform trendin to ensure tha' the operatinjrne for the main stearj yjgas operation remains belov 'he design limit duri gtheperiood o extended operation.

Revise Fatioue Monitoring Program procedures to provide for corrective actions to reverit the operat time_forthe main steam by ass from exceedjng the analysis during 'the eriod of extended operation. Accptable corrective actions include rep ar of the component, replacement of the corponentor a more rigorous analvsis of the component to demonstrate that the service life will not be exceeded during the period of extended operation.

Enclosure to NRC-15-0005 Page 20 A.4 LICENSE RENEWAL COMMITMENT LIST No.

Program or Activity Commitment Implementation Source

_________Schedule 12 Fatigue Monitoring Enhance Fatigue Monitoring Program as follows:

Part (b): At least

.1.17 two years prior to

e. Revise Fatigue Monitoring Prograr procedures so that the March 20, 2025.

scope of the program includes rnonito ing the operating hours for the main steam bypass operation at the 30%-45% valve Remainder: Prior open sition and perform trendin to ensure that the oprating to September 20, time for the main steam bypass operation enains below ithe 2024.

design limit during the period of extended o eration.

f. Revise Fatigue Monitorg Program procedures to provide for correcive actions to prevent the operating tie for the main steam bypass from exceeding the analysis during the period of extended oeration.

cce table corrective actions include repair of the comoonent, replacement of the cornpoent, or a more rigorous analysis of the cornponent to demonstrate tlhat he service life will not be exceeded duringi theperiod of extended ooeration.

Enclosure to NRC-15-0005 Page 21 B.1.17 FATIGURE MONITORING Enhancements Element Affected Enhancement

6. Acceptance Criteria After the EAF calculations are completed, revise the Fatigue Monitoring Program procedures to state that the program counting of the cycle limits maintains the cumulative fatigue usage below the design limit through the period of extended operation, with consideration of the reactor water environmental fatigue effects.

1 Scope of Program Revise Fatigue Monitoring Prograr rocedures so

2. Preventive Actions that the scog Ofthe program includes monioringj 3_ Parameters Monitored or the operating hours for the main steam bypass Inspected operation at the 30%-45% valve open position and 4

Detection of AginqEfects perforrnreding to ensure that the operating time 5

Monitoring and Trending for the main stearn bpass operation remains below cAceaje eCrteria the design limit during the period of extencded

7. Corrective Actions ogeratiqr, Revise Fatigue Monitorinc Progarn procedures to provide for corrective actions to revent the operatin tirne for the main steam bypass from exceedingj tie analysis during the eijod of extended operation. Acceptable corrective actions include repair of the compent, replacement of the cornponent, or a more rigorous analysis of the component to demonstrate that the service life will not be exceeded durirgthe oeriocd extended ooeration.