NRC-15-0012, Response to NRC Request for Additional Information for the Review of License Renewal Application - Set 18

Response to NRC Request for Additional Information for the Review of License Renewal Application - Set 18

ML15030A359
Person / Time
Site:	Fermi
Issue date:	01/30/2015
From:	Kaminskas V DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-15-0012, TAC MF4222
Download: ML15030A359 (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: kaminskasvidteenergy.com 10 CFR 54 January 30, 2015 NRC-15-0012 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 18 (TAC No.

MVF4222)," dated December 22, 2014 (ML14350B358)

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 18 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.

No new commitments are being made in this submittal.

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

USNRC NRC-15-0012 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 30, 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 18 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-15-0012 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 18

Enclosure to NRC-15-0012 Page 1 RAI B.L 31-1

Background

The applicantstated that license renewal application (LRA) aging managementprogram (AMP) B.1.31, "Non-EQ [EnvironmentalQualification]Insulated Cables and Connections,"

will be consistent with the programdescribed in NUREG-1801, Revision 2, "GenericAging Lessons Learned (GALL) Report" (GALL Report),Section XI El, "InsulationMaterialfor ElectricalCables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." No exceptions or enhancements were identified by the applicantfor LRA AMP B.1.31.

However, LRA AMP B.1.31, "Non-EQ InsulatedCables and Connections," states in the program descriptionthat adverse localized environments will be determined based on a plant spaces approach. Basis document, FERMI-RPT-12-LRD04, "AgingManagement Program Evaluation Results - Electrical," also states in the program description that an adverse localized environment is a plant specific condition that will be determined based on a plant spaces approach. In addition, the AMP basis document, underprogram element "parameters monitoredor inspected," states that, "[t]he adverse localized environment is a plant-specific condition that will be determined based on a plant spaces approach."

GALL Report AMP XI.E1, "InsulationMaterialfor ElectricalCables and Connections Not Subject to 10 CFR 50.49 Environmental QualificationRequirements," states in part:

Adverse localized environments can be identified through the use of an integrated approach. This approachmay include, but is not limited to, (a) the review of EnvironmentalQualification (EQ)zone maps that show radiationlevels and temperaturesfor variousplant areas, (b) consultationswith plant staff who are cognizant ofplant conditions, (c) utilization of infraredthermographyto identify hot spots on a real-time basis, and (d)the review of relevantplant-specific and industry operating experience.

NUREG-1800, Revision 2, "StandardReview Planfor Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR), Section 2.5.1, "Areas of Review," states in part:

For an electricaland I&C [instrumentationand control] system that is WSLR [within the scope of license renewal],an applicantmay not identify the specific electricalandI&C components that are subject to an AMR [aging managementreview]. For example, an applicant may not "tag" each specific length of cable that is "passive" and "long-lived,"

andperforms an intendedfunction as defined in 10 CFR 54.4(b). Instead, an applicant may use the so-called "plantspaces" approach.

Under the "plantspaces" approach,an applicantwould identify all "passive," "long-lived" electricalequipment within a specifiedplantspace as subject to an AMR,

Enclosure to NRC-15-0012 Page 2 regardlessof whether these components perform any intendedfunctions. For example, an applicantcould identify all "passive," "long-lived" electrical equipment located within the turbine building ("plant space") as subject to an AMR for license renewal. In the subsequent AMR, the applicantwould evaluate the environment of the turbine building to determine the appropriateaging management activitiesfor this equipment.

Issue LRA AMP B. 1.31 and FERMI-RPT-12-1 LRD04 (page48) suggest that the "plantspaces" approachthat reviews all buildings/areas,rooms within the scope of license renewalprovides a means to determinepotentialadverse localized environments. The "plantspaces" approachis referencedin SRP-LR, Section 2.5, as a scoping and screening approach. SRP-LR Section 2.5.1 states that based on the spaces approachan applicant could evaluateplant environments to determine the appropriateaging managementactivitiesfor the subject equipment.

The "plantspaces" approachproposed by the applicantis not referenced as an example of an integratedapproach in either GALL Report AMP XI El or the SRP-LR for the identification of an adverse localized environment. Additionally, the use of the "plantspaces" approachalone may not consider relevantplant specific and industry operatingexperience or other aspectsfor the identificationof an adverse localized environment as describedin GALL Report AMP XI El.

Request Explain how the use of the "plantspaces" scoping and screening approach,as described in SRP-LR Section 2.5.1, "Areas of Review," was adopted to identify adverse localized environments consistent with the integratedapproachdescribedin GALL Report AMP XI El including the use of EQ zone map reviews, consultations with plant staff plantspecific and industry operatingexperience, inspection, and testing (e.g., thermography).

Response

License Renewal Application (LRA) Section B.1.31, "Non-EQ Insulated Cables and Connections," description will be clarified to describe how adverse localized environments can be identified using an integrated approach. The Fermi 2 method of identifying adverse localized environments, as revised, is consistent with NUREG-1801.

LRA Revisions:

LRA Section B.1.31 is revised as shown on the following page. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0012 Page 3 B.1.31 NON-EQ INSULATED CABLES AND CONNECTIONS Program Description The Non-EQ Insulated Cables and Connections Program is a new condition monitoring program that provides reasonable assurance that intended functions of insulated cables and connections exposed to adverse localized environments caused by heat, radiation' and moisture can be maintained consistent with the current licensing basis through the period of extended operation.

An adverse localized environment is a condition in a limited plant area that is significantly more severe than the plant design environment for the cable or connection insulation materials.

Accessible insulated cables and connections within the scope of license renewal installed in an adverse localized environment will be visually inspected for cable and connection jacket surface anomalies such as embrittlement, discoloration, cracking, melting, swelling, or surface contamination. The inspection of accessible cables will represent, with reasonable assurance, all cables and connections in the adverse localized environment.

cossiaof*4 the ~~

~ folo?,win Z' :-, o2 9do-kto:Adetrmi'°ne E ik chd's rmetG advers,,e d, m n4zed loca:l en-vironmentthe ,. pianEt nigues d evew ftgr -ng rj ence' The plant spaces approach provides for a review and wapIgdw of all buildings and rooms in the scope of license renewal to determine potential adverse localized environments. The determination of a potential adverse localized equipment environment will be based on the most limiting temperature, radiation, or moisture conditions for the cables and connection insulation material located at Fermi 2. The evaluation of an adverse localized equipment environment will be based on the most limiting temperature, radiation, or moisture conditions for the cables and connection insulation material located within that plant space that has a potential adverse localized equipment environment.

This program will visually inspect accessible cables in an adverse localized environment at least once every ten years, with the first inspection prior to the period of extended operation.

This program will be implemented prior to the period of extended operation.

1. Reduced insulation resistance from an environment of radiation and air (oxygen) includes radiolysis, photolysis of organics, or radiation induced oxidation. Photolysis is limited to UV sensitive materials.

Enclosure to NRC-15-0012 Page 4 RAI 3.5.2.2.1.3.1-1

Background

Section 54.21(a)(3) of Title 10 of the Code of FederalRegulations (10 CFR) Part54 requires the applicantto demonstrate that the effects of agingfor structures and components will be adequately managed so that the intendedfunction(s) will be maintainedconsistent with the currentlicensing basisfor the periodof extended operation. As described in SRP-LR, an applicantmay demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

The AMR item in LRA Table 3.5.2-1 (LRA page 3.5-64)for component type "[s]teel elements (inaccessibleareas): drywell shell; drywell head; drywell shell in sandpocket region" to manage the loss of materialdue to corrosionaging effect, makes reference to item 3.5.1-4 in LRA Table 3.5.1 andAMR item ILJB1.1.CP-63 in the GALL Report. Items 3.5.1-4 and 3.5.1-5 in LRA Table 3.5.1 refer to thefurther evaluation in LRA Section 3.5.2.2.1.3, item 1, that addresses loss of material due to generalpitting, and crevice corrosion that could occur in steel elements of inaccessibleareasfor all types of pressurizedwater reactor and boiling water reactor containments.

Issue AMR item IL B1.1.CP-63 does not appear to exist in the GALL Report. Further the component type descriptionfor the above mentioned AMR item in LRA Table 3.5.2-1 does not appear to include or address the inaccessibleportion of the drywell shell embedded in the concretefloor of the drywell.

Request

1. Identify the appropriateAMR item in the GALL Report and the correspondingitem in LRA Table 3.5.1 that would apply to the material,environment, and aging effect being managed by the AMR item in LRA Table 3.5.2-1 mentioned above for inaccessibleareas of the Fermi 2 steel drywell, including the portion of the shell embedded in concrete.

2. Update the affected LRA tables, as applicable,based on the response to Request 1.

Response

1. The aging management review (AMR) line item in the NUREG-1801 (GALL Report) for component type "Steel elements (inaccessible areas): drywell shell; drywell head; drywell shell in sand pocket region" for an air-indoor uncontrolled environment and aging effect of loss of material in License Renewal Application (LRA) Table 3.5.2-1 was intended to be II.B1.l.CP-43 rather than II.B1.1.CP-63. This line item is listed in NUREG-1801 under Mark I steel containments. Fermi 2 has a Mark I steel containment. An alternate line item is

Enclosure to NRC-15-0012 Page 5 II.B3.1.CP-113, which is listed under Mark III steel containments. This alternate line item is appropriate because it includes concrete as an environment, which addresses the inaccessible portion of the Fermi 2 drywell shell that is embedded in concrete. Line item 3.5.1-4 of LRA Table 3.5.1 remains the appropriate reference for the Table 1 item. The environment is revised to include concrete and the referenced NUREG-1801 item is revised to II.B3.1.CP-113.

2. LRA Table 3.5.2-1 will be revised as described in the response above.

LRA Revisions:

LRA Table 3.5.2-1 is revised as shown on the following page. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0012 Page 6 Table 3.5.2-1 Reactor/Auxiliary Building and Primary Containment Summary of Aging Management Evaluation Table 3.5.2-1: Reactor/Auxiliary Building and Primary Containment Aging Effect Aging Component Intended Requiring Management NUREG- Table Type Function Material Environment Management Program 1801 Item i Item Notes Steel EN, MB, Carbon Air - indoor Loss of CIl-IWE 1 ms' 3.5.1-4 C elements PB, SSR steel uncontrolled material Containment 63 (inaccessible o ete Leak Rate li.3 areas):

drywell shell; drywell shell in sand pocket region

Enclosure to NRC-15-0012 Page 7 RAI3.5.2.2.1.3.1-2

Background

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

LRA Section 3.5.2.2.1.3.1 addresses the further evaluation, correspondingto LRA Table 3.5.1, items 3.5.1-4 and 3.5.1-5, and correspondingGALL Report items relatedto the loss of material due to general,pitting, and crevice corrosionof the inaccessible areas of the drywell shell and torus of Mark I steel containments. SRP-LR Section 3.5.2.2.1.3.1 states, in part, "[tjhe GALL Report recommendsfurther evaluation ofplant-specificprogramsto manage this aging effect if corrosion is indicatedfrom the IWE examinations."

Issue The further evaluation in LRA Section 3.5.2.2.1.3.1 does not address the plant-specific operating experience relatedto loss of materialdue to corrosion of the inaccessible areas of the drywell shell and torus of the Fermi 2 primary containment. The staff needs additionalinformation to determine whether or not a plant-specificAMP is necessary to manage the aging effect.

Request

1. Describe the plant-specific operatingexperience to-date relatedto the loss of materialdue to general,pitting,and crevice corrosion of the inaccessible areasof the Fermi 2 containment drywell shell and torus. Address its significance to justify whether or not a plant-specific program is necessary to manage the aging effect.

2. If a plant-specificAMP is needed, provide a description of the program. At a minimum, the description should include the AMP elements describedin Branch Technical PositionRLSB-1 in Appendix A.1 of the SRP-LR.

3. Update the affected LRA tables and sections, as appropriate.

Response

1. Torus: There are no inaccessible areas of the torus. Operating experience for the torus shell is addressed in the response to RAI 3.5.2.2.1.3.2-1.

Drywell: The drywell interior shell is accessible for inspections, except for beneath the

Enclosure to NRC-15-0012 Page 8 concrete floor. License Renewal Application (LRA) Section B.1.12, under operating experience, states that "only one corrosion pit was detected in the drywell shell. The pit, which measured 0.02" x 0.04" x 0.093" deep, was detected during ISI examinations in 2000.

The corrosion was attributed to a screw and uncoated washer that were in contact with an uncoated portion of the drywell shell in a beam seat area. The screw and washer were removed. The drywell shell in the area of the pit was coated in 2003." The exterior drywell shell is inaccessible, except for the drywell dome and to date there is no operating experience related to loss of material due to general, pitting, and crevice corrosion of the exterior of the drywell shell. As addressed in the response to RAI B.l.12-4 (NRC-15-0004, Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 14, dated January 15, 2015) UT measurements taken in 2014 of the drywell shell in the sand cushion area showed thicknesses above the design value, demonstrating no apparent loss after almost 30 years of operation.

In 2010, the moisture seal at the drywell floor to the primary containment shell interface was inspected and repaired. During this time, an inspection was performed on the normally inaccessible primary containment shell interface in these areas. There was no identified loss of material due to general, pitting, or crevice corrosion of the primary containment shell interface.

2. A plant-specific AMP is not needed, as loss of material due to corrosion in inaccessible areas has not been identified. DTE will continue to inspect and monitor in accordance with the Containment Inservice Inspection - IWE Program.

3. LRA Section 3.5.2.2.1.3 Item 1 is revised as indicated below. Additionally, LRA Tables 3.5.1 and 3.5.2-1 are revised to reflect that there are no inaccessible areas of the torus.

LRA Revisions:

LRA Section 3.5.2.2.1.3 Item 1 and LRA Tables 3.5.1 and 3.5.2-1 are revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0012 Page 9 3.5.2.2.1.3 Loss of Material due to General, Pitting and Crevice Corrosion

1. Loss of material due to general, pitting, and crevice corrosion could occur in steel elements of inaccessible areas for all types of PWR and BWR containments.

The Fermi 2 containment is a BWR Mark I SCV. The containment is a carbon steel structure comprised of a drywell, a torus or suppression chamber, and a vent system connecting the drywell and the torus. A moisture barrier is provided where the steel shell becomes embedded in the concrete floor within the drywell. The SCV is inspected in accordance with the requirements of ASME Code Section XI, Subsection IWE. These inspections include a visual examination of the accessible interior and the exterior surfaces of the class MC components, parts and appurtenances of the SCV as well as visual inspection of the moisture barrier at the e

concrete-to-steel interface. T toru intrr anrio shel accessbl. The l rkot he li'cg r lyx°..tkd bge ;ietah t f'Lo_ Loss of

?cr material due to general, pitting and crevice corrosion of the steel elements of accessible areas is managed by the Containment Inservice Inspection - IWE Program and the Containment Leak Rate Program (10 CFR Part 50, Appendix J Program). Interior concrete is monitored for cracks under the Structures Monitoring Program.

To prevent corrosion of the lower part of the drywell shell, the interior and exterior surfaces are protected from contact with the atmosphere by complete concrete encasement. It is not credible for ground water to reach the drywell shell, assuming a crack inthe concrete, because the concrete at this location is greater than eight feet thick and poured in multiple horizontal planes. The sand cushion area contains drains to protect the exterior surface of the drywell shell at the sand cushion interface from water that might enter the air gap. The exterior of the drywell shell has a galvanic corrosion protection, and inspection activities ensure that excessive moisture levels on the exterior portion of the steel containment drywell shell are identified. Therefore, significant corrosion of the drywell shell is not expected.

O :i: ge coerogioa:3iticaea e s' -"

egliggestin3 de weit lugriatiisaloctle The continued monitoring of the Fermi 2 SCV structure for loss of material due to general, pitting, and crevice corrosion through the Containment Inservice Inspection

- IWE Program and the Containment Leak Rate Program provides reasonable assurance that loss of material in inaccessible areas of Fermi 2 containment will be detected prior to a loss of an intended function.

Enclosure to NRC-15-0012 Page 10 Table 3.5.1 Summary of Aging Management Programs for Structures and Component Supports Evaluated in Chapters II and III of NUREG-1801 Table 3.5.1: Structures and Component Supports Aging Further Item Aging Effect/ Management Evaluation Number Component Mechanism Programs Recommended Discussion 3.5.1-5 Steel (nb elements Loss d4 of material ISI (IWE) and 10 Yes, if corrosion is  : se i 4 i g (inaccessible due to general, CFR Part 50, indicated from the Tweaanetreis areas): liner; pitting and Appendix J IWE examinations. +sIeto- + e liner anchors; crevice corrosion a e k t r integral maae -4es- ta attachments, e-leaas Steel elements sj s ne-The-se-(inaccessible ueTd. hjOush eelstee areas): eIements r ' s j are suppression at2j esecinjr uoe 3H j chamber; The loss of material for drywell; drywell ja cessioe areas of head; embedded perd drywell shell; drywell shell; region head; and drywell shell in sand shielded by pocket region are addressed in diaphragm floor Item Number 3.5.1-4 (as (as applicable) applicable). Steel elements (inaccessible areas): liner; liner anchors; and integral attachments are applicable to PWR containments.

For further evaluation, see Section 3.5.2.2.1.3 Item 1.

Enclosure to NRC-15-0012 Page 11 Table 3.5.2-1 Reactor/Auxiliary Building and Primary Containment Summary of Aging Management Evaluation Table 3.5.2-1: Reactor/Auxiliary Building and Primary Containment Aging Effect Aging Component Intended Requiring Management NUREG- Table Type Function Material Environment Management Program 1801 Item I Item Notes eRA e4' matea Ce n me £" 5

Enclosure to NRC-15-0012 Page 12 RAI 3.5.2.2.1.3.2-1

Background

Section 54.21(a)(3) of10 CFR requires the applicantto demonstrate that the effects of agingfor structuresand components will be adequately managed so that the intendedfunction(s) will be maintainedconsistent with the current licensingbasisfor the periodof extended operation. As described in SRP-LR, an applicantmay demonstrate compliance with 10 CFR 54.21(a)(3) by referencingthe GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

LRA Section 3.5.2.2.1.3.2 addressesthe further evaluation, correspondingto LRA Table 3.5.1, item 3.5.1-6, and GALL Report item II B.1.. CP-48, related to the loss of materialdue to general,pitting, and crevice corrosionof the steel torus shell of Mark I containments. SRP-LR Section 3.5.2.2.1.3.2 states, in part, "[t]he GALL Report recommendsfurther evaluation of plant-specificprograms to manage this aging effect if corrosion is signficant."

Issue The further evaluation in LRA Section 3.5.2.2.1.3.2 does not address the plant-specific operating experience relatedto loss of materialdue to corrosion of the torus shell. The staff needs additionalinformation to determine whether or not a plant-specificAMP is necessary to manage the aging effect.

Request

1. Describe the plant-specificoperatingexperience to-date related to the loss of materialdue to general,pitting,and crevice corrosionof the interior (submergedareasand vapor space areas)and exterior surfaces of the Fermi 2 steel torus shell. Address its significance to justf whether or not a plant-specificprogramof the torus is necessary to manage this aging effect.

2. If a plant-specificAMP is needed,provide a description of the program. At a minimum, the descriptionshould include the AMP elements describedin Branch Technical PositionRLSB-1 in Appendix A.1 of the SRP-LR

3. Update the affected LRA tables and sections, as appropriate.

Response

1. License Renewal Application (LRA) Section B.1.12, under operating experience, states that "one, %-inch diameter pit was identified in the torus wetted area during the history of the plant. The pit, a corrosion pit, was 0.0285 inches in depth." It also states that "an inspection was performed in 2012, when 100 percent of the torus wetted and vapor space was inspected

Enclosure to NRC-15-0012 Page 13 by qualified NDE inspectors. No pitting of the torus primary containment boundary was identified, and that during 2012, broken blisters, mechanical damage, and pinpoint rust areas were identified and repaired in the wetted areas of the torus. In the vapor region, all flaking paint was removed from the torus ring header, torus vacuum breaker valves, nitrogen supply lines, monorail rail, and torus walkway and handrail. Flaking or cracked coating was removed and protective coating was re-applied to the torus shell." No loss of material due to general, pitting, or crevice corrosion of the exterior surface of the Fermi 2 steel torus shell has been identified to date.

2. No plant-specific AMP is needed, since no significant corrosion has been experienced. The torus shell is monitored through the Containment Inservice Inspection - IWE Program.

3. LRA Section 3.5.2.2.1.3 Item 2 is revised as indicated below.

LRA Revisions:

LRA Section 3.5.2.2.1.3 Item 2 is revised as shown on the following page. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0012 Page 14 3.5.2.2.1.3 Loss of Material due to General, Pitting and Crevice Corrosion

2. Loss of material due to general, pitting, and crevice corrosion could occur in steel torus shell of Mark I containments.

The Fermi 2 containment is a BWR Mark I SCV. The containment is a carbon steel structure comprised of a drywell, a torus or suppression chamber, and a vent system connecting the drywell and the torus. The SCV, which includes the steel torus shell, is inspected in accordance with the requirements of ASME Code Section XI, Subsection IWE. These inspections include a visual examination of the accessible interior and the exterior surfaces of the class MC components, parts and appurtenances of the SCV, including the steel torus shell. Loss of material due to general, pitting and crevice corrosion of the steel elements of accessible areas is managed by the Containment Inservice Inspection - IWE Program and the Containment Leak Rate Program (10 CFR Part 50, Appendix J Program).

tifdad rt ae of thous loss of mta due to The continued monitoring of the Fermi 2 SCV, including the steel torus shell, for loss of material due to general, pitting, and crevice corrosion through the Containment Inservice Inspection - IWE Program and the Containment Leak Rate Program provides reasonable assurance that loss of material of the SCV, including the steel torus shell, will be detected prior to a loss of an intended function.

Enclosure to NRC-15-0012 Page 15 RAI 3.5.2.2.1.3.3-1

Background

Section 54.21(a)(3) of 10 CFR requiresthe applicantto demonstrate that the effects of agingfor structuresand components will be adequately managedso that the intendedfunction(s) will be maintainedconsistent with the current licensing basisfor the period of extended operation. As describedin SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

LRA Section 3.5.2.2.1.3.3 addressesthe further evaluation, correspondingto LRA Table 3.5.1, item 3.5.1-7, and GALL Report item IIB.1.1.CP-109, relatedto the loss of materialdue to general,pitting, andcrevice corrosionof torus ring girders and downcomers of Mark I containments. SRP-LR Section 3.5.2.2.1.3.3 states, in part, "[tlhe GALL Report recommends further evaluation ofplant-specificprograms to manage this aging effect if corrosion is signficant."

Issue The further evaluation in LRA Section 3.5.2.2.1.3.3 does not address the plant-specific operating experience relatedto loss of materialdue to corrosion of the torus ring girders and downcomers from the existing containmentInservice Inspection program (i.e., ISI program). The staff needs additionalinformation to determine whether or not a plant-specificAMP is necessary to manage the aging effect.

Request

1. Describe the plant-specific operatingexperience to-date relatedto the loss of material due to general,pitting, and crevice corrosion of the Fermi 2 steel torus ring girdersand downcomers. Address its significance to justfy whether or not a plant-specificprogram is necessary to manage this aging effect.

2. If a plant-specificAMP is needed,provide a description of the program. At a minimum, the descriptionshould include the AMP elements describedin Branch Technical Position RLSB-1 in Appendix A. 1 of the SRP-LR.

3. Update the LRA tables and sections, as appropriate.

Response

1. To date, operating experience has identified no loss of material due to general, pitting and crevice corrosion of the Fermi 2 steel torus ring girders and downcomers. DTE will continue

Enclosure to NRC-15-0012 Page 16 to monitor and inspect in accordance with the Containment Inservice Inspection - IWE Program.

2. A plant-specific AMP is not needed since corrosion has not been identified warranting a plant-specific AMP.

3. License Renewal Application (LRA) Section 3.5.2.2.1.3 Item 3 is revised as indicated below.

LRA Revisions:

LRA Section 3.5.2.2.1.3 Item 3 is revised as shown on the following page. Additions are shown in underline and deletions are shown in strike-through.

Enclosure to NRC-15-0012 Page 17 3.5.2.2.1.3 Loss of Material due to General, Pitting and Crevice Corrosion

3. Loss of material due to general, pitting, and crevice corrosion could occur in steel torus ring girders and downcomers of Mark I containments, downcomers of Mark II containments, and interior surface of suppression chamber shell of Mark IlIl containments.

The Fermi 2 containment is a BWR Mark I SCV. The containment is a carbon steel structure comprised of a drywell, a torus or suppression chamber, and a vent system connecting the drywell and the torus. The SCV, which includes the steel torus ring girders and downcomers, is inspected in accordance with the requirements of ASME Code Section XI, Subsection IWE. These inspections include a visual examination of the accessible interior and the exterior surfaces of the class MC components, parts and appurtenances of the SCV, including the steel torus ring girders and downcomers. Loss of material due to general, pitting and crevice corrosion of the steel elements of accessible areas is managed by the Containment Inservice Inspection - IWE Program. 3"en in xerience jas jgenjea f matertj The continued monitoring of the Fermi 2 SCV, including the steel torus ring girders and downcomers, for loss of material due to general, pitting, and crevice corrosion through the Containment Inservice Inspection - IWE Program provides reasonable assurance that loss of material of the SCV, including the steel torus ring girders and downcomers, will be detected prior to a loss of an intended function.