NRC-15-0006, Response to NRC Request for Additional Information for the Review of License Renewal Application - Set 11

Response to NRC Request for Additional Information for the Review of License Renewal Application - Set 11

ML15021A433
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-15-0006
Download: ML15021A433 (20)

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: kainskas @dteenergy.com 10 CFR 54 January 20, 2015 NRC-15-0006 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 11 (TAC No.

MF4222)," dated December 19, 2014 (ML14342A938)

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 11 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) except for RAI B.1.22-1. The DTE response to RAI B.1.22-1 will be provided separately as discussed in Reference 3.

No new commitments are being made in this submittal. However, revisions have been made to commitments previously identified in the LRA. The revised commitments are in Item 4, Bolting Integrity, in LRA Table A.4 as indicated in the responses to RAIs B.1.2-1 and B.1.2-2.

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

USNRC NRC-15-0006 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on Jgnuary 2Q, 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 11 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-15-0006 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-3 DTE Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 11

Enclosure to NRC-15-0006 Page 1 RAI B.1.2-1

Background

GenericAging Lessons Learned (GALL) Report aging managementprogram (AMP) XI.M18 "parametersmonitored or inspected" program element recommends that "boltingfor safety-relatedpressure retaining components [be] inspectedfor leakage, loss of material, cracking, and loss/of preload[...]. Boltingfor other pressure retainingcomponents is inspected for signs of leakage." GALL Report AMP XL M18 "detection of aging effects" program element recommends thatperiodic inspections of pressure-retainingclosure bolting be performed at least once per refueling cycle for signs of leakage to ensure the detection of age-relateddegradation due to loss of material and loss of preload.

License Renewal Application (LRA) Section B..2 states that the Bolting Integrity Program is an existing AMP, with enhancements, that will be consistent with GALL Report AMP XI.M18.

Issue LRA Section B.L2 states that the "Bolting Integrity Programmanages loss of preload,cracking, and loss of materialfor accessible [emphasis added] closure boltingfor safety-related and non-safety-relatedpressure components." It is not clearhow the effects of aging on inaccessible pressure-retainingclosure bolting within the scope of license renewal will be managed consistent with the recommendations in GALL Report AMP XL M18. In addition, if inaccessible bolting is not managed consistent with the recommendations in GALL reportAMP XL M18, the staff needs additionalinformation regardinghow inaccessible bolting will be age managed and under what conditions the applicantconsiders bolting to be inaccessible. The staff needs this information to determine whether the program is adequate to manage aging of these components.

Request (1) State whether the program will manage the aging effects for inaccessiblepressure-retaining closure bolting consistent with the recommendations in GALL Report AMP XI.M18.

(2) If inaccessible bolting will not be managed consistent with the recommendations in GALL Report AMP XI.M18:

a. Explain what is consideredinaccessible closure bolting at Fermi 2.

b. Explain how the effects of aging on inaccessible closure bolting within the scope of license renewal will be adequately managed such that their intendedfunctions will be maintainedfor the period of extended operation.

Enclosure to NRC-15-0006 Page 2

Response

1. Management of pressure-retaining bolting aging effects in accordance with the Bolting Integrity Program (LRA Section B.1.2) will not distinguish between accessible and inaccessible pressure-retaining bolting. Fermi 2 will monitor the integrity of safety-related and nonsafety-related (in scope) pressure retaining bolted joints by detection of visible leakage, evidence of past leakage, or other age-related degradation during maintenance activities and walkdowns in plant areas that contain systems within scope of license renewal.

This follows the recommendations in NUREG-1801 AMP XI.M18, which states that periodic inspection of pressure boundary components for signs of leakage ensures that age-related degradation of closure bolting is detected and corrected before component leakage becomes excessive. The LRA Bolting Integrity Program will be revised to remove the term "accessible."

2. Not applicable. Inaccessible bolting will be managed consistent with the recommendations in NUREG-1801 AMP XI.M18.

LRA Revisions:

LRA Section A.1.2, A.4, and B.1.2 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0006 Page 3 A.1.2 Bolting Integrity Program The Bolting Integrity Program manages loss of preload, cracking, and loss of material for aseessai-closure bolting for safety-related and nonsafety-related pressure-retaining components using preventive and inspection activities. This program does not include the reactor head closure studs or structural bolting. Preventive measures include material selection (e.g., use of materials with an actual yield strength of less than 150 kilo-pounds per square inch

[ksi]), lubricant selection (e.g., restricting the use of molybdenum disulfide), applying the appropriate preload (torque), and checking for uniformity of gasket compression where appropriate to preclude loss of preload, loss of material, and cracking. This program supplements the inspection activities required by ASME Section XI for ASME Class 1, 2, and 3 bolting. For ASME Class 1, 2, and 3 aseseb e--bolting and non-ASME Code class a bolts, periodic system walkdowns and inspection (at least once per refueling cycle) ensure identification of indications of loss of preload (leakage), cracking, and loss of material before leakage becomes excessive. Identified leaking bolted connections will be monitored at an increased frequency in accordance with the corrective action process. Applicable industry standards and guidance documents, including NUREG-1339, EPRI NP-5769, and EPRI TR-104213, are used to delineate the program.

The Bolting Integrity Program will be enhanced as follows.

Revise Bolting Integrity Program procedures to state that asseseeb-bolting for safety-related pressure-retaining components is inspected for leakage, loss of material, cracking, and loss of preload/loss of prestress. Closure bolting with actual yield strength greater than or equal to 150 ksi is monitored for cracking.

• Revise Bolting Integrity Program procedures to (1) implement applicable recommendations for pressure boundary bolting in NUREG-1339, EPRI NP-5769, and EPRI TR-104213; (2) state both ASME Code class aseeeatebolted connections and non-ASME Code class asees:lb.NLbolted connections are inspected at least once per refueling cycle; and (3) include volumetric examination per ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, for closure bolting with actual yield strength greater than or equal to 150 ksi regardless of code classification.

Enclosure to NRC-15-0006 Page 4 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source

_____ ________________________________________

_______________ Schedule ____

4 Bolting Integrity Enhance Bolting Integrity Program as follows: Prior to A.1.2 September 20,

b. Revise Bolting Integrity Program procedures to state that 2024.

ae -bolting for safety-related pressure-retaining components is inspected for leakage, loss of material, cracking, and loss of preload/loss of prestress. Closure bolting with actual yield strength greater than or equal to 150 ksi is monitored for cracking.

c. Revise Bolting Integrity Program procedures to (1) implement applicable recommendations for pressure boundary bolting in NUREG-1339, EPRI NP-5769, and EPRI TR-104213; (2) state both ASME Code class aeos seile-bolted connections and non-ASME Code class asesh-bolted connections are inspected at least once per refueling cycle; and (3) include volumetric examination per ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, for closure bolting with actual yield strength greater than or equal to 150 ksi regardless of code classification.

Enclosure to NRC-15-0006 Page 5 B.1.2 BOLTING INTEGRITY Program Description The Bolting Integrity Program manages loss of preload, cracking, and loss of material for ases+closure bolting for safety-related and nonsafety-related pressure-retaining components using preventive and inspection activities. This program does not include the reactor head closure studs or structural bolting. Preventive measures include material selection (e.g., use of materials with an actual yield strength of less than 150 kilo-pounds per square inch

[ksi]), lubricant selection (e.g., restricting the use of molybdenum disulfide [MoS2]), applying the appropriate preload (torque), and checking for uniformity of gasket compression where appropriate to preclude loss of preload, loss of material, and cracking. This program supplements the inspection activities required by ASME Section XI for ASME Class 1, 2, and 3 bolting. For ASME Class 1, 2, and 3 a ie bolting and non-ASME Code class ae ssl bolts, periodic system walkdowns and inspection (at least once per refueling cycle) ensure identification of indications of loss of preload (leakage), cracking, and loss of material before leakage becomes excessive. Identified leaking bolted connections will be monitored at an increased frequency in accordance with the corrective action process. Applicable industry standards and guidance documents are used to delineate the program, including NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants; EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants; and EPRI TR-104213, Bolted Joint Maintenance and Applications Guide.

Enhancements Element Affected Enhancement

3. Parameters Monitored or Revise Bolting Integrity Program procedures to state Inspected that -Pass4boltingfor safety-related pressure retaining components is inspected for leakage, loss of material, cracking, and loss of preload/loss of prestress. Closure bolting with actual yield strength

> 150 ksi is monitored for cracking.

4. Detection of Aging Effects Revise Bolting Integrity Program procedures to (1) implement applicable recommendations for pressure boundary bolting in NUREG-1339, EPRI NP-5769, and EPRI TR-104213; (2) state both ASME Code class ae -bolted connections and non-ASME Code class seeei 49-bolted connections are inspected at least once per refueling cycle; and (3) include volumetric examination per ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, for closure bolting with actual yield strength > 150 ksi regardless of code classification.

Enclosure to NRC-15-0006 Page 6 RAI B.1.2-2

Background

GALL Report AMP XLM18 provides recommendations to manage loss of material and loss of preloadof pressure-retainingclosure bolting. GALL Report AMP XL M18 includes preventive measures to minimize loss of preload,such as proper torqueing of bolts and checking for uniformity of gasket compression. GALL Report AMP XIM18 also recommends periodic inspections (at least once per refueling cycle) of closure boltingfor signs of leakage to ensure the detection of age-relateddegradationdue to loss of materialand loss of preload.

LRA Section B.1.2 states that the Bolting Integrity Programis an existing program, with enhancements, that will be consistent with GALL Report AMP XL M18. LRA Section B.1.2 describes an enhancement to the Bolting Integrity Programto revise the proceduresto inspect the residualheat removal service water (RHRSW), emergency equipment service water (EESW),

and emergency diesel generatorservice water (EDGSW)systems pump and valve bolting submerged in the RHRSW reservoir at least once per refueling outage.

Issue During its onsite review of the program basis documents, the staff noted that the applicant's program lacked information regardinghow the inspections will detect the applicableaging effects. It is not clear how the submerged closure bolting will be inspected such that loss of material and loss of preloadcan be detected prior to loss of intendedfunction. Given the fact that a submerged environment limits the ability to detect leakage of submerged bolted connections, it is not clear how the programwill detect loss of materialand loss of preloadfor submerged bolted connections.

Request For the submerged bolting in the RHRSW, EESW, and EDGSW systems and other submerged closure bolting within the scope of license renewal, describe how the program will detect both loss of material and loss of preload. Also, describe how the proposed bolting inspections will detect loss of material in crevice locations (e.g., threaded regions or the shank below the bolt heads) that are not readily visible.

Response

License Renewal Application (LRA) Table 3.3.2-3 indicates that the service water systems contain bolting that is submerged in a raw water (ext) environment. The submerged bolting in the service water systems consists of the residual heat removal service water (RHRSW),

emergency equipment service water (EESW), and emergency diesel generator service water (EDGSW) pump and valve bolting. The aging effects requiring management, loss of material

Enclosure to NRC-15-0006 Page 7 and loss of preload, are managed by the Bolting Integrity Program (LRA Section B.1.2). These aging effects are managed as follows.

• As described in LRA Section B.1.2, the Bolting Integrity Program preventive measures include material selection, lubricant selection, applying the appropriate preload (torque),

and checking for uniformity of gasket compression where appropriate. These preventive measures are consistent with NUREG-1801, Section XLM18, and minimize the potential for both loss of material and loss of preload.

o As a result of Fermi 2 operating experience in 2003 described in LRA Section B.1.2, the submerged bolts on all RIIRSW pumps were replaced and other submerged bolts were replaced as needed. New material was selected for the replacement bolts and the service water chemical addition process was changed to reduce corrosion. In addition, a preventive maintenance activity was established for pump refurbishment or replacement.

Recent Fermi 2 inspections of the submerged bolting have detected both loss of material and loss of preload. These inspection results were entered into the corrective action program. The bolting was determined to have maintained its intended function. This demonstrates that the inspections are capable of detecting both of these aging effects prior to loss of intended function.

o Quarterly surveillance runs of the RHRSW, EESW, and EDGSW pumps are performed.

The pump performance parameters are trended to determine if corrective actions are needed. Pump degradation during surveillance runs would lead to pump repair or refurbishment. During this maintenance, the associated bolting would be inspected, including the bolting threads. To ensure that loss of material in crevice locations that are not readily visible can be detected, the LRA will be revised to include these opportunistic inspections of the submerged bolting threads as part of the Bolting Integrity Program.

• Periodic visual inspections of submerged bolting, at least once every refueling outage, will be performed as described in the enhancement in LRA Section B.1.2.

The activities described above are adequate to manage both loss of material and loss of preload for submerged bolting, including bolting in locations that are not readily visible.

LRA Revisions:

LRA Section A.1.2, A.4, and B. 1.2 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0006 Page 8 A.1.2 Bolting Integrity Program The Bolting Integrity Program will be enhanced as follows.

• Revise Bolting Integrity Program procedures to inspect RHRSW, EESW, and EDGSW systems' pump and valve bolting submerged in the RHRSW reservoir at least once every refueling outagendtoopruiicay in t ing threads during maintenance activities.

Enclosure to NRC-15-0006 Page 9 A.4 LICENSE RENEWAL COMMITMENT LIST No. Program or Activity Commitment Implementation Source

________________________________________ Schedule Suc 4 Bolting Integrity Enhance Bolting Integrity Program as follows: Prior to A.1.2 September 20,

d. Revise Bolting Integrity Program procedures to inspect 2024.

RHRSW, EESW, and EDGSW systems' pump and valve bolting submerged in the RHRSW reservoir at least once every refueling outage and to opportunistically inspect bolting threads durincrmaintenance activities.

Enclosure to NRC-15-0006 Page 10 B.1.2 BOLTING INTEGRITY Enhancements Element Affected Enhancement

4. Detection of Aging Effects Revise Bolting Integrity Program procedures to inspect RHRSW, EESW, and EDGSW systems' pump and valve bolting submerged in the RHRSW reservoir at least once every refueling outage andto appQ unjsticaly_nspeclolgtrreads d urin maintenance activities.

Enclosure to NRC-15-0006 Page 11 RAI B.1.2-3

Background

GALL Report AMPs XL M18 and XI. S3 state that molybdenum disulfide (MoS2 ) should not be used as a lubricantdue to its potential contributionto stress corrosion cracking (SCC),

especiallyfor high-strengthbolts (actualyield strength greater than or equal to 150 ksi). GALL Report AMP XL S6, states thatpreventive actions emphasize proper selection of lubricantsto prevent or minimize cracking of high-strengthbolting. The GALL Report also states that the applicant is to evaluate applicableoperating experience to support the conclusion that the effects of aging are adequately managed.

LRA Sections B.L2, B.1.22, and B..42 state that the Bolting Integrity, Inservice Inspection -

IWF, and Structures Monitoring Programsare existing AMPs, with enhancements and an exception, that will be consistent with GALL Report AMPs XI.M18, XI. S3, and XLS6.

Issue LRA Sections B. 1.2 and B.1.22 state that "[p]lantproceduresprohibit the use of lubricants containing molybdenum disulfide [MoS2 ]." The staff also noted that the LRA AMP basis document for the StructuresMonitoring Programstates thatplantproceduresprevent the use of MoS2 as a lubricantfor bolting. During its onsite audit, the staff confirmed that the bolting procedures had been revised to prohibit the use of MoS 2, however; it is not clear whether MoS 2 lubricantshave been used at Fermi 2 before plant procedureswere revised to prohibit their use.

Request State whether MoS 2 lubricantshave been used on any high-strength closure bolts or any high-strength structural bolts in sizes greaterthan 1 inch nominal diameter, within the scope of the Bolting Integrity, Inservice Inspection - IWF, and StructuresMonitoringPrograms. If these lubricantshave been used on high-strength bolts in the past, explain how the affected bolts will be managedfor age-relateddegradationduring the period of extended operation.

Response

Molybdenum disulfide (MoS 2) was restricted for use at Fermi 2 in accordance with the Chemical Controls procedure MCE02 Revision 2 on May 27, 1997, and no exception to this restriction has been approved.

Maintenance procedure for Bolting and Torquing 35.000.240, requires that the bolts be cleaned of old lubricant, inspected and lubricated with Fel-Pro N-5000, N-7000 or Dag Dispersion 156, which do not contain MoS 2 . A similar requirement is in the original maintenance procedure for Bolting and Torquing Guidelines Mi-M055 Revision 0, approved November 1983, prior to plant startup, which specifies the use of Fel-Pro N-5000 or Dag Dispersion 156 or approved

Enclosure to NRC-15-0006 Page 12 equivalents. This procedure references NUREG-0943, "Threaded-Fastener Experience in Nuclear Power Plants," dated January 1983, as a source for the content of the procedure.

NUREG-0943 discusses industry experience indicating that lubricants containing MoS 2 are a cause for threaded-fastener degradation and failures.

Control of bolting thread lubrication is also described in Pipe Erection specification 3071-031. It specifies the use of Fel-Pro thread lubricant N-5000, N-1000, Dag Dispersion 156 or Crane company screw thread lubricant, high temp thread compound or Edison approved equal for thread lubrication, none of which contain MoS 2. A similar requirement for use of Crane company screw thread lubricant, high temp thread compound or Edison approved equivalent is in Pipe Erection specification 3071-031 Revision A that was approved May 1975, and was used during plant construction.

In addition, DTE's 1992 internal response to NRC Generic Letter 91-17, titled "Generic Safety Issue 29, Bolting Degradation or Failure in Nuclear Power Plants," determined that Fermi 2 had adequate programs to control the procurement, receipt, inspection, and installation of threaded fasteners. Part of this review included the recommendations of NUREG-1339 which warned against the potential detrimental effects of MoS 2 .

The maintenance procedure and piping specification described above established control of the use of thread lubricant during the construction and maintenance of the plant. The site's 1992 review and response to Generic Letter 91-71 indicated that the site had adequately addressed all industry issues contributing to bolting degradation at that time. In addition, the site's chemical control procedures restrict the use of MoS 2 on site. Taken together, the information in the discussion above provides reasonable assurance that MoS 2 has not been used on high strength bolts at Fermi 2.

LRA Revisions:

None.

Enclosure to NRC-15-0006 Page 13 RAI B.1.22-2

Background

The LRA states that the Inservice Inspection - IWF Program,with enhancements, is consistent with GALL Report AMP XL S3, "ASME Section XI, Subsection IWF." GALL Report AMP XL S3, "ASME Section XI, Subsection IWF," states that the ASME Code,Section XI, Subsection IWF, constitutes an existing mandatedprogram applicable to managing aging of ASME Class 1, 2, 3 and metal containment (MC) component supports. The "monitoringand trending" program element, states that examinations of Class 1, 2, 3, and MC component supports and related hardware (i.e., structuralbolting, high strength structuralbolting, supportanchorage to the building structure, accessible sliding surfaces, constantand variable load spring hangers, guides, stops, and vibration isolationelements) that reveal unacceptable conditions which exceed the acceptance criteriaand require corrective measures are extended to include additionalexaminations in accordance with ASME Code Section XI, Subsection IWF-2430. The ASME Code Section XI, Subsection IWF, states that to the extent practical,the same supports selected for examinationduring the first inspection interval shall be examined during each successive inspection interval.

The staff noted that there is recent industry operating experience in which degradedconditions were found during ASME Code,Section XI, Subsection IWF, examinations of Class 1, 2, 3, and MC component supports and related hardware. Engineeringevaluationdetermined that the as-found component/hardwarewas acceptable-as-is,but the component/hardwarewas still re-worked to as-new condition. Since it was determined that the as-found condition did not affect the support's capability to perform its designfunction or exceed the threshold of IWF-3400 acceptance criteria,the licensee did not apply ASME Code, Sections IWF-2420 and IWF-2430for successive or additionalexaminations.

Issue The staff's concern with respect to aging management is that if ASME Code,Section XI, Subsection IWF supports that are part of the inspection sample are reworked to as-new condition, they are no longer typical of the other supports in the population. Subsequent ASME Code,Section XI, Subsection IWF, inspections of the same sample would not represent the age related degradationof the rest of the population. The applicant'sLRA and associated basis documents provide no discussion of how this issue would be addressed,or if the IWF sample would be changed or expanded if a support within the originalsample was reworked.

Request For situations in which corrective actions are not requiredper the ASME Code,Section XI, Subsection IWF, acceptance criteriabut a component in the IWF sample is re-worked such that it no longer represents age-relateddegradationof the entire population,describe how the

Enclosure to NRC-15-0006 Page 14 Inservice Inspection - IWF Programwill continue to be effective in managing aging of similar/adjacentcomponents that are not included in the IWF inspection sample.

Response

NUREG-1801 accepts ASME Section XI, IWF as an acceptable way to manage the effects of aging. IWF is a sampling program where the sample is prorated based on the class, type of support, and number of components in a covered system. The Fermi 2 IWF component support inspection program is based on the examination percentages specified in ASME Section XI.

This includes 25% of Class 1, 15% of Class 2, and 10% of Class 3 supports. This equates to more than 250 supports being examined each 10-year interval. The Fermi 2 examination procedure requires that discrepancies are reported in the site corrective action program (CAP).

This would include both code and elective maintenance as all maintenance requires a condition assessment resolution document (CARD) from the CAP to initiate a work order. Both the Code and Fermi 2 CAP require sample expansion or extent of condition examinations as appropriate.

The Code re-examination of these components will determine if the condition that caused the condition is still active. Correction of some conditions over the life of the plant is expected but will not impair the ability of the IWF Program to manage the effects of aging. Modifying the program to add new component locations when a condition has been addressed is not necessary.

This is because the aging mechanisms will likely be caused by local environment or operational conditions such as vibration or humidity. The programmatic requirements for sample expansion or extent of condition will address that. The Code sample population size is large enough that correction of some conditions will not prevent the program from adequately managing the effects of aging.

LRA Revisions:

None.

Enclosure to NRC-15-0006 Page 15 RAI 2.5-1

Background

Title 10 of the Code of FederalRegulations (10 CFR) Section 54.4(a)(3) requires that all SSCs relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the U.S. NuclearRegulatory Commission regulationsfor station blackout (10 CFR 50.63) be included within the scope of license renewal.

Fermi 2 (LRA), Section 2.1.1.3.5, "Commission's Regulationsfor Station Blackout (10 CFR 50.63)," states that "plantelectrical and [instrumentationand control] systems are included in the scope of license renewal by default. Consequently, electricalequipment that supports the requirements of 10 CFR 50.63 is included in the scope of the license renewal." Section 2.1.1.3.5 also states that, "[t]he individualscoping evaluations in Section 2.4 contain the results of the reviewfor the Fermi 2 structures."

LRA Section 2.3.3.9, "Combustion Turbine Generator," states that the combustion turbine generator(CTG) system is used as an alternatesource of power for station blackout (SBO) and for safe shutdown and perform a function that demonstrates compliance with the Commission's regulationsfor SBO (10 CFR 50.63). LRA Table 2.2-4, "Structures Within the Scope of License Renewal," lists CTG No. 11-1 Unit as a structure within the scope of the license renewal.

Issue LRA Table 2.3.3-9, "Combustion Turbine GeneratorSystem Components Subject to Aging ManagementReview," does not list any electricalsystems or components that are subject to an aging management review (AMR). The electricalsystems and components associatedwith the CTG No. 11-1 Unit are not mentioned in LRA Section 2.5, "Scoping and Screening Results:

Electricaland Instrumentationand Controls Systems," and Section 3.6, "Electricaland Instrumentationand Control Systems." In addition, Table 2.5-1, "Electricaland Instrumentationand Control Systems Components Subject to Aging ManagementReview," does not list CTG No. 11-1 Unit electricalcomponents as part of the AMR.

Request The staff requests that the applicant verify whether the CTG No. 11-1 Unit system electrical components are within the scope of license renewal in accordance with 10 CFR 54.4(a)(3) and subject to an AMR in accordancewith 10 CFR 54.21(a)(1). If the CTG system electrical components are not within the scope of license renewal and not subject to an AMR, please provide justificationfor the exclusion.

Enclosure to NRC-15-0006 Page 16

Response

License Renewal Application (LRA) Section 2.3.3.9 states, "CTG 11-1 is used as the alternate AC source for a station blackout event and to support response by the dedicated shutdown panel to an Appendix R fire."

The CTG 11-1 unit system electrical components are within the scope of license renewal in accordance with 10 CFR 54.4(a)(3) and are subject to AMR in accordance with 10 CFR 54.21(a)(1). The following passive commodities associated with station blackout (SBO) are subject to aging management review.

. Control circuit cables and connections (under the type "cable connections")

+ High-voltage insulators e Medium-voltage cables and connections (under the type "cable connections")

. Metal-enclosed bus (MEB)

+ Switchyard bus and connections These five passive commodities are included within the component/commodity types in LRA Table 2.5-1. LRA Table 2.5-1 will be revised to clarify that high-voltage insulators and switchyard bus and connections are included for SBO and for SBO recovery.

LRA Revisions:

LRA Table 2.5-1 is revised as shown on the following page. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0006 Page 17 Table 2.5-1 Electrical and Instrumentation and Control Systems Components Subject to Aging Management Review Structure and/or Component/Commodity Intended Function' Cable connections (metallic parts) Conducts electricity Conductor insulation for inaccessible power (400 V to 13.8 kV) cables (e.g., installed underground in conduit, duct bank or Insulation (electrical) direct buried) not subject to 10 CFR 50.49 EQ requirements Insulation material for electrical cables and connections (including terminal blocks, fuse holders, etc.) not subject to Insulation (electrical) 10 CFR 50.49 EQ requirements Insulation material for electrical cables not subject to 10 CFR Insulation (electrical) 50.49 EQ requirements used in instrumentation circuits Insulation material for EIC penetration cables and connections Insulation (electrical) not subject to 10 CFR 50.49 EQ requirements Fuse holders (not part of active equipment): insulation material Insulation (electrical)

Fuse holders (not part of active equipment): metallic clamps Conducts electricity High voltage insulators (for SBOand SBO recovery) Insulation (electrical)

Metal enclosed bus: bus/connections Conducts electricity Metal enclosed bus: enclosure assemblies (elastomers, Conducts electricity external surfaces)

Metal enclosed bus: insulation, insulators Insulation (electrical)

Switchyard bus and connections (for SBO and SBO recovery) Conducts electricity Transmission conductors and connections (for SBO recovery) Conducts electricity

1. Intended functions are defined in Table 2.0-1.