NRC-15-0007, Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 12

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 12

ML15028A533
Person / Time
Site:	Fermi
Issue date:	01/28/2015
From:	Kaminskas V DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-15-0007
Download: ML15028A533 (30)

Text

Vir'to A. Kamk as5k3 Site 'Vice Pretsiden, 6400 N.

ixe iway, Newport MI 48166 Tel:73486.515 Fax: 734.586.41 72 10 CFR 54 January 28, 2015 NRC-15-0007 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, datedApril 24, 2014 (ML14121A554)

3) NRC Letter, "Requests for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 12 (TAC No.

MF4222)," dated December 19, 2014 (ML14342A986)

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 12 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 RAIs 4.2.2-1 and 4.2.2-2. The DTE responses to RAIs 4.2.2-1 and 4.2.2-2 will be provided separately as discussed in Reference 3.

Two new commitments are being made in this submittal. The new commitments are enhancements in Item 11, External Surfaces Monitoring, in LRA Table A.4 as indicated in the responses to RAIs B.1.16-1 and B.1.16-2.

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

USNRC NRC-15-0007 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 28, 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 12 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-15-0007 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 12

Enclosure to NRC-15-0007 Page 1 RAI B.1.16-1

Background

Generic Aging Lessons Learned (GALL) Report aging management program (AMP) XI M36, "External Surfaces Monitoring of Mechanical Components, " recommends inspections for leakage to identify cracking of stainless steel external surfaces exposed to air environments containing halides.

License Renewal Application (LR A) Section B.1.16 identifies an enhancement to the External Surfaces Monitoring Program to revise the program procedures to ensure that walkdowns will include inspections for leakage to detect cracking in stainless steel components exposed to air containing halides. LRA Tables 3.3.2-3, 3.3.2-10, and 3.3.2-11 contain aging management review (AMR) items for cracking of gas filled outdoor stainless steel and aluminum components that are managed with the External Surfaces Monitoring Program.

Issue For components that have a gaseous internal environment, it is not clear to the staff how walkdowns of external surfaces will be able to detect leakage as an indicator of cracking.

Request State the inspection parameters and the inspection methods that will be used to determine whether cracking is present in the gas-filled, outdoor aluminum and stainless steel components in LRA Tables 3.3.2-3, 3.3.2-10, and 3.3.2-]1.

Response

License Renewal Application (LRA) Table 3.3.2-3, Service Water Systems The gas-filled components in LRA Table 3.3.2-3 for the service water system are part of the cooling tower fan overspeed protection subsystem. This subsystem uses bottled nitrogen supplied to a solenoid valve to power a mechanical brake on the fan motor. Nitrogen bottles at different pressures are provided for the four fans. The bottles and pressure control valves deliver pressurized nitrogen to different connections on the solenoid. Most of the valves and piping between the nitrogen bottles and the solenoid are stainless steel and are exposed to outdoor air.

Any leakage due to a crack would be detected by a reduction in nitrogen system pressure.

System pressure readings are taken daily by Operations to determine when a nitrogen bottle needs to be replaced. The system engineer trends the nitrogen bottle replacement frequencies and initiates an investigation should an adverse trend develop. Nitrogen system pressure daily readings and trending of the bottle changeout frequency will be conducted to detect leakage as an indicator of cracking.

Enclosure to NRC-15-0007 Page 2 LRA Table 3.3.2-10, Emergency Diesel Generator (EDG) System LRA Table 3.3.2-10 for the EDG system includes a stainless steel expansion joint exposed internally to exhaust gas and externally to outdoor air. If a crack develops in the expansion joint, the escaping hot gas would be expected to stain the surrounding material. Thus, since the acceptance criteria for the External Surfaces Monitoring Program includes a clean, shiny surface for stainless steel (consistent with NUREG-1801 AMP XI.M36), visual inspection per the External Surfaces Monitoring Program can be expected to detect the presence of leakage as an indication of cracking.

LRA Table 3.3.2-11, Heating, Ventilation and Air Conditioning (HVAC) Systems LRA Table 3.3.2-11 includes two aluminum filter housings, one per circuit, exposed externally to outdoor air and internally to the refrigerant gas on the dedicated shutdown air conditioning system. Visual inspection (using a soap solution or similar means) with the system pressurized would be capable of detecting leakage. A periodic visual inspection (e.g. checking for leakage using a soap solution or similar means) will be conducted to detect the presence of leakage as an indication of cracking.

The LRA will be revised to reflect this response.

LRA Revisions:

LRA Sections A.1.16, A.4, and B.1.16 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-0051) are not shown in underline or strike-through such that only the new changes due to RAI B.1.16-1 are shown as revisions.

Enclosure to NRC-15-0007 Page 3 A.1.16 External Surfaces Monitoring Program Inspections are performed at a frequency of at least once per refueling cycle by personnel qualified through plant-specific programs. Deficiencies are documented and evaluated under the Corrective Action Program. Surfaces that are not readily visible during plant operations and refueling outages are inspected when they are made accessible and at such intervals that would ensure the components' intended functions are maintained.

Where visual inspection or leakage_may no' effectivey etectgracino in as-filed stainless steel an aluminum comoonenits_exposed to outdoor air.

tlterngte defection metodse.g, perforrrance monoitoing or use asoa psolotion wit tte cot)ponent tresuried) will be tmployed.

Periodic representative surface condition inspections of the in-scope mechanical indoor components under insulation (with process fluid temperature below the dew point) and out-door components under insulation will be performed.

A.1.16 External Surfaces Monitoring Program The External Surfaces Monitoring Program will be enhanced as follows.

Revise External Surfaces Monitoring Program procedures to stipulate that administrative controls are in accordance with the Fermi 2 10 CFR 50 Appendix B Quality Assurance Program.

[Revise External Suiraces_

onitoring Prooram proced res to include instructions for detection of crachiqa sfg iled stainless sjeel and ailurminum comj ;onfs e osed to outdoor air.

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

Enclosure to NRC-15-0007 Page 4 A.4 LICENSE RENEWAL COMMITMENT LIST No.

Program or Activity Commitment Implementation Source Schedule S u c 11 External Surfaces Enhance External Surfaces Monitoring Program as follows:

Prior to

.1.16 Monitoring September 20, gmevisejExteirnal Surfaces Monitor igProg ran procedures to 2024.

include instructionsfor detection of crackin qtgas-_filecl stainless steel and aluinum r ononent's exposed to outdoor air.

Enclosure to NRC-15-0007 Page 5 B.1.16 EXTERNAL SURFACES MONITORING Program Description Inspections are performed at a frequency of at least once per refueling cycle by personnel qualified through plant-specific programs. Deficiencies are documented and evaluated under the Corrective Action Program. Surfaces that are not readily visible during plant operations and refueling outages are inspected when they are made accessible and at such intervals that would ensure the components' intended functions are maintained.

Where visual inspection for leakage nao not efectivelv detect clacjing in gas-filled stainess steel and aluminum componentse osed tootdoor air alternate detection mejthods ie.g performanceontri use f a solution with the coonent essurizedl vill e

empoed.

Periodic representative surface condition inspections of the in-scope mechanical indoor components under insulation (with process fluid temperature below the dew point) and out-door components under insulation will be performed.

B.1.16 EXTERNAL SURFACES MONITORING Enhancements Element Affected Enhancement 3Parmeters Monitored or Revise External Surfaces Moin orinorooram sInse cte;[

prgcedures to include instructions or detection of Detection oAqjnfe cts cracjing cAa filled stainless steel and alurinum components exoosed to outdoor air.

Enclosure to NRC-15-0007 Page 6 RAI B.1.16-2

Background

LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation," revised GALL Report AMP XI. M36, "External Surfaces Monitoring of Mechanical Components, " to include recommendations for managing reduced thermal insulation resistance due to moisture intrusion. LR-ISG-2012-02 states that one acceptable means of managing this aging effect is by performing visual inspections of insulation jacketing to ensure that there is no damage that would permit moisture in-leakage, provided that the jacketing had been installed with procedures that include configuration controls (e.g.,

minimum overlap, location of seams).

LRA Section B. 1.16 does not describe any inspection activities to ensure that thermal insulation retains its ability to reduce heat transfer. During the staff's audit ofthe External Surfaces Monitoring Program, the staff found that the program basis document, FERMI-RPT-12-LRD03, states that thermal insulation is not credited with an intended function of heat transfer reduction.

However, LRA Table 3.5.2-4 includes an AMR item for fiberglass, calcium silicate, Fiberfrax ceramic fiber Durablanket and Insulfrax insulation with an intended function of "providing insulating characteristics to reduce heat transfer." This insulation is managed for loss of material and change in material properties with the Structures Monitoring Program.

Issue Neither GALL Report AMP XI.S6, "Structures Monitoring," nor LRA Section B. 1.42, "Structures Monitoring," includes activities to manage reduced thermal insulation resistance due to moisture intrusion. Thus, it is not clear to the staff whether the Structures Monitoring Program is capable of effectively managing this aging effect.

Request For the thermal insulation in LRA Table 3.5.2-4, describe the insulation configuration and the activities in the Structures Monitoring Program that will be used to manage reduced thermal insulation resistance due to moisture intrusion. Specifically, identify whether the insulation is jacketed and, if so, whether the jacketing had been installed with procedures that include insulation configuration controls (e.g., minimum overlap, location of seams). In addition, describe the parameters that will be monitored or inspected to ensure that the thermal function of the insulation is maintained. As appropriate, revise the LRA to describe the activities that manage the thermal performance of the insulation.

Response

LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation," revised GALL Report AMP XLM36, "External

Enclosure to NRC-15-0007 Page 7 Surfaces Monitoring of Mechanical Components," to include recommendations for managing reduced thermal insulation resistance due to moisture intrusion. The scope of the ISG was limited to steam and power conversion systems (SRP Items 3.4.1-64/65 and GALL Items VIII.LS.403/404). There is no insulation in these systems that is credited for limiting heat transfer, so there were no inspection activities to ensure that thermal insulation retains its ability to reduce heat transfer in LRA Section B.1.16.

A Fermi 2 insulation installation specification includes instructions for jacketing installation which includes guidance on minimum overlap and location of seams. Any installed insulation jacketing would be installed in accordance with this specification.

Systems other than steam and power conversion systems may contain insulation, both jacketed and non-jacketed, that provides insulating characteristics to reduce heat transfer. Thus, the AMR item in Table 3.5.2-4 for fiberglass, calcium silicate, Fiberfrax, Fiberfrax ceramic fiber Durablanket, and Insulfrax insulation with an intended function of providing "insulating characteristics to reduce heat transfer" will be revised to include insulation degradation due to moisture intrusion as an aging effect requiring management and will reference the External Surfaces Monitoring Program as the aging management program. In addition, an enhancement will be added to the External Surfaces Monitoring Program (LRA Sections A.1.16, A.4, and B.1.16) to include a description of inspection activities to ensure that thermal insulation retains its ability to reduce heat transfer. The specific population of insulation required to reduce heat transfer will be determined during External Surfaces Monitoring Program implementation.

LRA Revisions:

LRA Tables 2.0-1 and 3.5.2-4 and LRA Sections A. 1.16, A.4, and B.1.16 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through.

Note that previous changes to these same LRA sections made in the July 30, 2014 letter (NRC-14-0051) are not shown in underline or strike-through such that only the new changes due to RAI B.1.16-2 are shown as revisions.

Enclosure to NRC-15-0007 Page 8 Table 2.0-1 Component Intended Functions: Abbreviations and Definitions Abbreviation Intended Function Definition IN Insulation Insulate and support an electrical conductor (electrical) or provide insulating characteristics to reduce heat transfer fatraucstwal4.

Enclosure to NRC-15-0007 Page 9 Table 3.5.2-4 Bulk Commodities Summary of Aging Management Evaluation Table 3.5.2-4: Bulk Commodities Structure and/or Component Aging Effect Aging or Intended Requiring Management NUREG-Table 1 Commodity Function Material Environment Management Programs 1801 Item Item Notes Insulation IN, SNS Fiberglass, Air-indoor Loss of Sutwee J

(includes calcium uncontrolled

material, Monite4ng jacketing, wire

silicate, Change in External mesh, tie Fiberfrax, material Surfaces wires, straps, fiberfrax properties, ontoirg-clips) ceramic Degqra ation fiber due to moisture durablanket, intrusion Insulfrax

Enclosure to NRC-15-0007 Page 10 A.1.16 External Surfaces Monitoring Program Inspections are performed at a frequency of at least once per refueling cycle by personnel qualified through plant-specific programs. Deficiencies are documented and evaluated under the Corrective Action Program. Surfaces that are not readily visible during plant operations and refueling outages are inspected when they are made accessible and at such intervals that would ensure the components' intended functions are maintained. Ins ections of ins lated comronens where the insulation is reguired to reuce heat transfer will be jerformed to e nsure insulation degradation due to moisture intrusion has not occurred.

Periodic representative surface condition inspections of the in-scope mechanical indoor components under insulation (with process fluid temperature below the dew point) and out-door components under insulation will be performed.

A.1.16 External Surfaces Monitoring Program The External Surfaces Monitoring Program will be enhanced as follows.

Revise External Surfaces Monitoring Program procedures to stipulate that administrative controls are in accordance with the Fermi 2 10 CFR 50 Appendix B Quality Assurance Program.

v Revise External Surfaces Moniorino Prograprocedures to nclide instructions for monjtorig of insulation reguired to reduce heat transfer to ensure insulaton deorad ation due to moisture intrusion has not occurredThese _instructions wil include insgectior gidance for both jacjsete and non-tiacetedinsulation.

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

Enclosure to NRC-15-0007 Page 11 A.4 LICENSE RENEWAL COMMITMENT LIST No.

Program or Activity Commitment Implementation Source Schedule 11 External Surfaces Enhance External Surfaces Monitoring Program as follows:

Prior to

.1.16 Monitoring September 20,

h. Revise External Surfaces Monitorjng Progra m-rogedure2 Jo 2024.

include instructions for monitoring p itnsulation reguired to reduce heat transfer to ensure insulation degradation due to moistre initrusion as not occurred. These instructions will include nspaeoon cguaicance for bothjttacceted and non:

jacketed insulation.

Enclosure to NRC-15-0007 Page 12 B.1.16 EXTERNAL SURFACES MONITORING Program Description Inspections are performed at a frequency of at least once per refueling cycle by personnel qualified through plant-specific programs. Deficiencies are documented and evaluated under the Corrective Action Program. Surfaces that are not readily visible during plant operations and refueling outages are inspected when they are made accessible and at such intervals that would ensure the components' intended functions are maintained. Inspections of insulated compompntswhere the insulation isreqired to recuce heat transfer will be per ormed to ensure insisation degradation due to moisture intrusion has not occurred.

Periodic representative surface condition inspections of the in-scope mechanical indoor components under insulation (with process fluid temperature below the dew point) and out-door components under insulation will be performed.

B.1.16 EXTERNAL SURFACES MONITORING Enhancements Element Affected Enhancement 4

Detection of Agjng Effects Revise External Surfaces Monitoring Proqrar procedures to include instructions for monitoringof insjlajion reguired to reduce heat transfer to ensure insulaton de radalon due t moisture intrusion has not occurred. These instructions will Include nspeotjon quldajrnce for jbothrackete and non-iacketed insulation.

Enclosure to NRC-15-0007 Page 13 RAI B.1.20-1

Background

GALL Report AMP XI M17, "Flow-Accelerated Corrosion," states that the program relies on implementation of the Electric Power Research Institute (EPRI) guidelines in Nuclear Safety Analysis Center (NSAC)-202L, "Recommendations for an Effective Flow Accelerated Corrosion Program." GALL Report AMP XJ.M17 also states that the program should use a predictive code, such as CHECWORKST"', to provide assurance that aging effects caused by flow-accelerated corrosion are adequately managed The NSAC-202L guidelines state that the application of appropriate quality assurance measures is essential to an effective Flow-Accelerated Corrosion Program.

LRA Section B.1.20 states that the Flow-Accelerated Corrosion Program is consistent with GALL Report AMP XI.M17 and relies on implementation of the guidelines in NSAC-202L.

Based on documents provided during the staff's onsite audit, the applicant implements the program through Engineering Support Conduct Manual, MES26, "Flow-Accelerated Corrosion Prediction, Detection, and Correction," which states that predictive analyses are performed using the CHECTWORKSTM software. MES26 Section 6.7, "Outage Screening /Acceptance Criteria," requires component thicknesses to be estimated at the next refueling outage based on Enclosure B, "Wear and Estimated Life Calculations." This enclosure requires re-examination, repair, or replacement if the wall thickness is less than the design minimum value, and it provides three options for calculating the flow-accelerated corrosion wear rate to determine the projected thickness at future refueling outages. The first option states that wear can be calculated using the CHECWORKSm computer software, whereas the other two options calculate wear using wall thicknesses measurements based on engineering evaluations of ultrasonic testing data.

Issue Based on discussions held during the staff's onsite audit, the Flow-Accelerated Corrosion Program evaluates wall thinning for both safety-related and nonsafety-related components.

According to the applicants designation, CHECWORKSM is categorized as a Class B software and therefore it is not appropriate for safety-related design work. For safety-related components, only results from software categorized as Class A may be used to demonstrate that the design wall thickness will be met at the next refueling outage. Otherwise, the other options included in the Flow-Accelerated Corrosion Program, which use(s) wall thickness measurements based on an engineering evaluation of ultrasonic testing data, are to be used for safety-related applications.

Request For safety-related components that are included in the Flow-Accelerated Corrosion Program, demonstrate how the wear values calculated by computer software (i.e., CHECTWORKS ) are

Enclosure to NRC-15-0007 Page 14 independently checked and verified Alternatively, where the design minimum value of the predicted wall thickness is being verified through the use of MES26, Enclosure B, Option 1, justify the use of Class B computer software for safety-related design work.

Response

DTE revised MES26, "Flow-Accelerated Corrosion Prediction, Detection, and Correction" in December 2014. The process for component evaluation was modified to draw a distinction between ANSI B31.1 and ASME Section III, Class 1, 2, and 3 components. More specifically, MES26 now requires that ASME components are evaluated using methods which do not utilize CHECWORKS calculation results to allow for independent verification by a qualified checker.

In addition, ASME components are clearly identified as such, to ensure that the appropriate methodology is used for analysis. A new enclosure listing all lines containing ASME Class 1, 2, or 3 components was created to help in identifying ASME components.

LRA Revisions:

None.

Enclosure to NRC-15-0007 Page 15 RAI B.I.20-2

Background

Section 54.21(a) of 10 CFR requires an integrated plant assessment to demonstrate that the effects of aging will be adequately managed such that the intended functions will be maintained consistent with the CLB for the period of extended operation. NUREG-1800, Revision 2, "Standard Review Plan for License Renewal Applications for Nuclear Power Plants" (SRP-LR)

Section A.1.2.3.1 states that the scope of the program should include the specific structures and components that are being managed by the program. During its review of documents provided during the onsite audit, the staff noted that the "scope of program "program element description in FERMI-RPT-12-LRD03, "Aging Management Program Evaluation Report, Non-Class 1 Mechanical, " Section 4.8, refers to Program Notebook PEP19, "Flow-Accelerated Corrosion,"

as one of the sources of information for the Flow-Accelerated Corrosion Program. The staff also noted that PEP19 discusses outage scope selection and specifies the "Feedwater Heater Shell Susceptibility Review" as one of the items to be reviewed.

Issue LRA Table 3.4.2-2 includes items for piping and valve bodies that are being managed by the Flow-Accelerated Corrosion Program. However; for carbon steel heat exchanger shells internally exposed to steam, this table only states that loss of material is being managed by the Water Chemistry Control - BWR Program. Although the applicant appears to manage the feedwater shells for loss of material through its Flow-Accelerated Corrosion Program, the LRA only states that these components are being managedfor loss of material through the Water Chemistry Control - BWR Program. Therefore, it is not clear as to how the effects of aging will be adequately managed for these components.

Request Clarify whether the feedwater heater shells are being managed for loss of material by the Flow-Accelerated Corrosion Program. If they are not, justify why the Water Chemistry Control -

BWR Program alone will adequately manage loss of material for these components. If the feedwater heater shells are being managed by the Flow-Accelerated Corrosion Program, mod the appropriate portions of the LRA and program documents to accurately reflect which AMP(s) will apply to these components.

Response

The Flow-Accelerated Corrosion Program at Fermi 2 manages feedwater heater shell loss of material through performing periodic shell inspection. The License Renewal Application (LRA) and program documents will be revised to reflect this response.

Enclosure to NRC-15-0007 Page 16 LRA Revisions:

LRA Table 3.4.2-2 is revised as shown on the following page. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0007 Page 17 Table 3.4.2-2 Feedwater and Standby Feedwater System Summary of Aging Management Evaluation Table 3.4.2-2: Feedwater and Standby Feedwater System Aging Effect Aging Component Intended Requiring Management NUREG-1801 Table 1 Type Function Material Environment Management Programs Item Item Notes Heat Pressure Carbon Steam (int)

Loss of material Water VIIl.A.SP-71 3.4.1-14 C, 401 exchanger boundary steel Chemistry (shell)

Control -

BWR Hleat Pressure Carbon Steam (in t)

Los of material Flow-VIlI.D2.S-16 3.4,1-5 C

exchangr bouniadr steel Accelerated shell)

Tqrrosion Heat Pressure Carbon Steam (int)

Loss of material Water VIII.A.SP-71 3.4.1-14 C, 401 exchanger boundary steel Chemistry (tube sheet)

Control -

BWR

Enclosure to NRC-15-0007 Page 18 RAI B.1.24-1

Background

Fermi 2's CLB includes its response, dated January 26, 1990, to Generic Letter (GL) 89-13, "Service Water System Problems Affecting Safety-Related Equipment." GL 89-13 addresses issues related to transferring heat from safety-related components to the ultimate heat sink and includes both the air side and water side of applicable air-to-water heat exchangers. For testing of heat transfer capability, GL 89-13 specifies a minimum test frequency of every 5 years. Fermi 2's Engineering Support Conduct Manual MES52, "GL 89-13 Safety-Related Service Water Monitoring Program, "provides a cross-reference of GL 89-13 activities to ongoing Fermi 2 activities and includes a table with the air-side preventive maintenance tasks for various engineered safety features (ESF) fan coil units.

LRA Table 3.3.2-11, "Heating, Ventilation, and Air Condition Systems," includes AMR items for reduction of heat transfer due to fouling in heat exchanger fins and tubes exposed to indoor air, outdoor air, and condensation environments. LRA Table 3.3.2-11 states that these components will be managed by the Internal Surfaces in Miscellaneous Piping and Ducting Components Program. LRA Section B. 1.24 describes the Internal Surfaces in Miscellaneous Piping and Ducting Components Program as a new program that will use sampling and opportunistic visual inspections and states that a representative sample of 20 percent of a population will be inspected every 10 years during the period of extended operation. Based on discussions with Fermi 2 personnel during the staff's onsite audit of the program, these AMR items represent the air side of the ESF fan coil units.

Issue Because the Internal Surfaces in Miscellaneous Piping and Ducting Components Program only includes a minimum 20 percent sample that will be inspected every 10 years, it is not clear to the staff whether the program's inspection frequency for the air side of the ESF room coolers will be consistent with GL 89-13.

Request Provide additional information on the aging management activities for the ESF fan coil units included in MES52. Identify the AMR item(s) and the AMPs for these components and discuss the associated inspection frequency. Provide justification if the inspectionfrequency for each ESF fan coil unit will not be consistent with GL 89-13.

Response

The Fermi 2 Engineering Support Conduct Manual MES52 provides the Generic Letter (GL) 89-13 Safety-Related Service Water Monitoring Program. Enclosure B of MES52 contains a table of the frequent, regular maintenance of engineered safety feature (ESF) fan coil units. The

Enclosure to NRC-15-0007 Page 19 aging management review (AMR) items associated with these ESF fan coil units are found in License Renewal Application (LRA) Table 3.3.2-11 under the following items.

Component Intended Aging Effect AgingrManagement Type Function Material Environment Requiring Agingraagmen Management Heat Internal Surfaces in exchanger Heat transfer Copper alloy et) indoor Fouling Miscellaous Piping Components Heat Internal Surfaces in exchanger Heat transfer Copper alloy it) indoor Fouling Miscella eous Piping Components Heat Internal Surfaces in exchanger Heat transfer Stainless Air - indoor Fouling Miscellaneous Piping (tubes) steel (ext) and Ducting Components For each of the ESF fan coil units in the table in MES52, a preventive maintenance (PM) activity for the air side of the heat exchanger is also provided. The inspection frequencies of these PMs were verified to meet the committed to frequency of at least once every 5 years. Therefore, the inspection frequencies meet the requirements of GL 89-13. As indicated in the table above, all of the AMR items are managed by the Internal Surfaces in Miscellaneous Piping and Ducting Components Program. As described in LRA Sections A.1.24 and B.1.24, the program includes inspections of a representative sample of 20 percent of the population or a maximum of 25 components at least once every 10 years. Therefore, the inspection frequencies from MES52 will also meet the requirements of the Internal Surfaces in Miscellaneous Piping and Ducting Components Program in addition to the requirements of GL 89-13.

LRA Revisions:

None.

Enclosure to NRC-15-0007 Page 20 RAI B.134-1

Background:

GALL Report AMP XJ.M35, "One-Time Inspection of ASME Code Class ] Small-Bore Piping,"

states, under the "detection of aging effects "program element, that "[tJhis inspection should be performed at a sufficient number of locations to ensure an adequate sample. This number, or sample size, is based on susceptibility inspectability, dose considerations, operating experience, and limiting locations of the total population of ASME Code Class ] small-bore piping locations." LRA Sections B.L34 and A.].34 do not provide the total number of in-scope small-bore piping welds.

Issue:

The LRA does not provide the weld population. It is not clear to the staff how the inspection sample will be selected and thus whether a sufficient number of locations will be inspected to ensure that cracking will be adequately managed.

Request:

Provide the population of in-scope small-bore piping welds for each weld type (e.g., butt welds and socket welds). Based on the population, justi the adequacy of the selected sample size for each type of weld.

Response

There are approximately 4200 total in-scope small-bore piping welds. Of these, approximately 200 are butt welds and approximately 4000 are socket welds. Electric Power Research Institute (EPRI) TR-107514, Age Related Degradation Inspection Method and Demonstration, describes a sampling program, which provides a 90% confidence level that 90% of a given population is not experiencing degradation. The mathematical analysis performed in EPRI TR-107514 states that as the population size approaches infinity, the sample size required is 24.35, which is rounded up to 25. Based on this TR-107514 analysis, 25 is the maximum number of inspections for each weld type (either full penetration weld inspections or partial penetration (socket) weld inspections) recommended for the Fermi 2 small bore weld population associated with the One-Time Inspection - Small-Bore Piping Program. This is consistent with the descriptions in License Renewal Application (LRA) Sections A.1.34 and B.1.34 that the One-Time Inspection -

Small Bore Piping Program will inspect ten percent of the population or a maximum of 25 welds of each weld type.

LRA Revisions:

None.

Enclosure to NRC-15-0007 Page 21 RAI B.1.41-1

Background

Section 54.21(a) of 10 CFR requires an integrated plant assessment to demonstrate that the effects of aging will be adequately managed such that the intended functions will be maintained consistent with the CLB for the period of extended operation. SRP-LR Section A.1.2.1 states that the determination of applicable aging effects should be based on degradation mechanisms that have occurred LRA Section B.1.41 states that the Service Water Integrity Program manages loss of material and fouling of various components exposed to a service water environment as described in the applicant's response to GL 89-13, "Service Water System Problems Affecting Safety-Related Equipment." The "detection of aging effects" program element in FERMI-RPT-12-LRD03, "Aging Management Program Evaluation Report Non-Class 1 Mechanical,"

Section 4.12, states that the Service Water Integrity Program manages loss of material in various components and fouling in various heat exchangers. However, LRA Table 3.3.2-3 indicates that loss of material is the only aging effect that is managed for the flow control nozzles exposed to raw water in the service water system. Fouling is not identified as an aging effect requiring management for these nozzles.

The applicant currently implements preventive maintenance task No. H145 to periodically perform visual inspections of the mechanical draft cooling tower spray nozzles to verify that the nozzles are not plugged and that spray patterns are adequate. Based on information provided during the onsite audit, previous preventive maintenance activities have identified plugged nozzles on multiple occasions. The staff also noted that there may be other aging management activities associated with other components related to the applicant's commitments in response to GL 89-13 that were not included in the LRA (e.g., residual heat removal reservoir inspections).

Issue Although the applicant has performed inspections to manage fouling of the spray nozzles in the mechanical draft cooling towers, the activities to manage this aging effect are currently not described in the LRA. Consequently, it is not clear to the staff as to whether the applicant's integrated plant assessment demonstrates that the effects of aging will be adequately managed for these components. In addition, it is not clear whether the LRA reflects all of the aging management activities that are implemented in accordance with the GL 89-13 commitments.

Request Given that plugging/fouling of mechanical draft cooling tower spray nozzles has occurred at Fermi 2, either include fouling of these spray nozzles as an aging effect requiring management (by updating the IRA and associated program basis documents, as appropriate), or justify how the nozzles' intended functions will be maintained consistent with current licensing basis without managing fouling. In addition, identify whether there are any activities to manage aging effects

Enclosure to NRC-15-0007 Page 22 in other components associated with the response to GL 89-13 that were not included in the LRA. If any such activities are identified, either include these activities as additional aging management review items (by updating the LRA and associated program basis documents), or justify why the intended functions of the components associated with these activities will be maintained consistent with the current licensing basis without managing the aging effects.

Response

For the mechanical draft cooling tower spray nozzles, fouling is an aging effect requiring management. License Renewal Application (LRA) Table 3.3.2-3 will be revised to add fouling.

Note that LRA Sections A.1.41 and B.1.41 do address that the program manages loss of material and fouling, so no changes are necessary to LRA Sections A.1.41 and B.1.41.

A review of other residual heat removal (RHR) reservoir associated components with aging management activities performed per the Fermi 2 response to GL 89-13 identified that RHR reservoir inspections of components include the RHR service water (RHRSW), emergency equipment service water (EESW), and diesel generator service water (DGSW) pump casing and associated bolting, RHR cross-tie valves and piping. These are included in LRA Table 3.3.2-3 under the following items.

Component Intended Aging Effect AgingManagement Type Function Material Environment Requiring Agingraagmen Management Bolting Pressure Cabnsel Raw water Loss of boundary Carbon steel R

wxt) material Bolting Integrity Bolting Pressure Carbon steel Raw water Loss of Bolting Integrity boundary (ext) preload Pressure Stainless Raw water Loss of Bolting boundary steel (ext) material Bolting Integrity Bolting Pressure Stainless Raw water Loss of Bosting Integrity Boling boundary steel (ext) preloadBotnItery Piping Pressure Carbon steel Raw water Loss of Service Water boundary (ext) material Integrity Pressure Raw water Loss of Service Water boundary (ext) material Integrity Pressure Raw water Loss of Service Water Valve body boundary Carbon(ext) material Integrity A review of existing activities for other components associated with the Fermi 2 response to GL 89-13 identified that other components being managed for aging are included in the LRA aging management tables. Inspection of concrete associated with the RR reservoir walls and floor is included in LRA Table 3.5.2-2 under the RG 1.127 Aging Management Program.

Enclosure to NRC-15-0007 Page 23 LRA Revisions:

LRA Table 3.3.2-3 is revised as shown on the following page. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0007 Page 24 Table 3.3.2-3 Service Water Systems Summary of Aging Management Evaluation Table 3.3.2-3: Service Water Systems Aging Effect Aging Component Intended Requiring Management NUREG-1801 Table 1 Type Function Material Environment Management Programs Item Item Notes Nozzle Flow control Copper Raw water (int)

Loss of material Service VII.C1.AP-196 3.3.1-36 A

alloy Water VII.C1.A-409 3.3.1-126 E

Integrity Nozle Fow control Cop er Paw water(int ojjnq Service VICi.AP-196 33A-33 A

lloy Water Orifice Pressure Stainless Condensation Loss of material External G

boundary steel (ext)

Surfaces Flow control Monitoring

Enclosure to NRC-15-0007 Page 25 RAI 4.2.2-3

Background

LRA Table 4.2-2 describes the ARTs of the reactor vessel beltline components. The staff also noted that the following reference indicates that due to insufficient material information, the applicant determined the initial RTNDT (i.e., unirradiated reference temperature) ofN16 water level instrumentation nozzles using NRC Branch Technical Position MTEB 5-2, paragraph B. 1.1(4).

• Section 3.2 of GE Hitachi Nuclear Energy Report, NEDO-33785, Revision 1, "DTE Energy/Enrico Fermi Plant 2 Pressure and Temperature Limits Report Up To 24 and 32 Effective Full-Power Years," October 2012 (ADAMS Accession Number ML13004A135)

The reference document above also indicates that testing for one N16 nozzle material, performed at a single temperature (10 °F), generated a minimum Charpy V-notch energy of 30 ft-lbs. This reference further indicates that the initial RTvDT of the N16 nozzles was determined to be 30 F, which is 20 °F above the test temperature, based on NRC Branch Technical Position MTEB 5-2, paragraph B.1.1(4). The NRC position, which the applicant used, is currently referred to as NRC Branch Technical Position (BTP) 5-3, paragraph 1.1(4), as described in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR Edition, " Chapter 5.

Issue A recent letter from AREVA Inc. to the NRC (ADAMS Accession No. ML14038A265), dated January 30, 2014, addresses a potential non-conservatism in NRC BTP 5-3, paragraph 1.1(4).

The letter indicates that unirradiated RTNDT as estimated according to paragraph 1.1(4) may not result in a conservative bounding estimate of unirradiated RTNDT. The LRA and onsite documentation do not clearly address how the applicant will resolve this concern about the potential non-conservatism in the initial RTNDT of N16 water level instrumentation nozzles.

Request Explain why the initial RTDT of N16 nozzles in LRA Section 4.2.2 is adequate given the potential non-conservatism in NRC BTP 5-3, paragraph 1.1(4). As part of the response, confirm whether the applicant's ART analysis uses a potentially non-conservative BTP 5-3 position (i. e., position 1.1(3)(a), 1.1(3)(b) or 1.1(4)) to determine initial RTNDT for any other reactor vessel materials.

Response

DTE is aware of the potential non-conservatism inherent to NRC Branch Technical Position (BTP) 5-3 Paragraph B.1.1(4) when used to determine initial RTNDT for beltline materials. BTP 5-3 B.1.1(4) was used to determine initial RTNDT for the N16 water level instrumentation nozzle,

Enclosure to NRC-15-0007 Page 26 as insufficient information was available to determine initial RTNDT with another method (limited Charpy V-Notch tests performed at a single temperature). The N16 nozzle is the only nozzle at Fermi 2 affected by BTP 5-3 B.1.1(4). At this time, there is no information that suggests that the plant is not operating within its approved licensing basis. An industry-wide effort is being organized by the BWRV1P and PWR Materials Reliability Program to evaluate this potential issue and determine if any actions are necessary.

LRA Revisions:

None.

Enclosure to NRC-15-0007 Page 27 RAI 3.1.2.1.1-1

Background

LRA Table 3. L1, item 3.1.1-105, addresses steel piping, piping components and piping elements exposed to concrete. The GALL Report recommends no aging effect requiring management or AMP if certain concrete attributes and plant-specific operating experience are met for this component group. The LRA states that this item is not used because there are no steel reactor coolant pressure boundary (RCPB) piping components exposed to concrete. However, in reference to small bore field-run RCPB piping, UFSAR Section 5.2.1.19 states, "[h]ydrostatic testing, prior to erection, is required for any pipe spool that is embedded in concrete or installed in an inaccessible location.

Issue While the UFSAR does not state that steel piping is embedded in concrete, it is not clear to the staff whether an oversight had occurred during the development of the LRA.

Request Reconcile the statement associated with LRA Table 3.1.1, item 3.1.1-105, with UFSAR Section 5.2.1.19. If RCPB piping is embedded in concrete, state how the applicable aging effects will be managed or the basis for why there are no aging effects.

Response

The reactor coolant pressure boundary (RCPB) piping is not embedded in the drywell floor, sacrificial shield, reactor pedestal, or biological shield - pipe penetrations have gaps and the piping is free to move thermally. The sentence in the Updated Final Safety Analysis Report (UFSAR) is a general specification. No Fermi 2 RCPB piping is embedded in concrete.

LRA Revisions:

None.