Text

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 22
	ML15079A047
Person / Time
Site:	Fermi
Issue date:	03/19/2015
From:	Kaminskas V; DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC-15-0030
	Download: ML15079A047 (76)
	v • d • e

Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, I 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasv@dteenergy.com DTE Energy 10 CFR 54 March 19, 2015 NRC-15-0030 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 22 (TAC No.

MF4222)," dated February 20, 2015 (ML15035A130)

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 22 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. Enclosure 1 to this letter provides the DTE response to the request for additional information (RAI). Enclosure 2 to this letter includes additional LRA revisions that have been identified as a result of the September 29, 2014 NRC audit and due to DTE corrective action documents.

No new commitments are being made in this submittal. However, revisions have been made to commitments previously identified in the LRA. Revised commitments are in LRA Table A.4 Item 34, Structures Monitoring, as indicated in the response to RAI B.1.42-3a in Enclosure 1 and in LRA Table A.4 Item 35, Water Chemistry Control - Closed Treated Water Systems, as indicated in Enclosure 2.

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

USNRC NRC-15-0030 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on Yarch 19, 2015 Vito A. Kaminskas Site Vice President Nuclear Generation

Enclosures:

1. DTE Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 22

2. Additional License Renewal Application Revisions 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) to NRC-15-0030 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 22 to NRC-15-0030 Page 1 RAI 3.3.2.3-1a

Background

Request for Additional Information (RAI) 3.3.2.3-1 dated December 17, 2014, requested the basis for why loss of material due to pitting and crevice corrosion is not an applicable aging effect for stainless steel expansion joints exposed to diesel exhaust gas.

The response to RAI 3.3.2.3-1, dated January 15, 2015, states that "The stainless steel emergency diesel generator (EDG) exhaust expansion joints are oriented vertically, which precludes the potential for moisture collection necessary to concentrate contaminants." The response also states that because of this orientation, pitting and crevice corrosion are not applicable aging effects for these components. The response cites Electric Power Research Institute (EPRI) document TR-1010639, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools," Revision 4, which states that susceptibility to pitting and crevice corrosion for stainless steel in an air/gas environment requires a wetted surface and potential for concentrating contaminants.

Issue While vertically oriented smooth piping would allow for drainage and prevent any moisture from accumulating, the design of stainless steel expansion joints generally includes many vertical and horizontal segments, as well as crevices, which could prevent proper drainage and allow for moisture accumulation in any orientation. Therefore, it is unclear to the staff how the orientation of the EDG exhaust expansion joints precludes the collection of moisture that would allow for the concentration of contaminants needed for pitting and crevice corrosion to occur.

Request State the basis for why the EDG exhaust expansion joint's vertical orientation reasonably precludes the collection of moisture that would allow for the concentration of contaminants.

Alternatively, state how loss of material due to pitting and crevice corrosion will be managed in these components during the period of extended operation.

Response

Since there is a potential for horizontal surfaces or crevices to be present in the eight vertically oriented emergency diesel generator (EDG) exhaust stainless steel expansion joints, License Renewal Application (LRA) Table 3.3.2-10 will be revised to identify aging management programs to manage cracking due to stress corrosion cracking and loss of material due to pitting and crevice corrosion for the EDG exhaust expansion joints. In addition, the "Discussion" column of LRA Table 3.3.1 item 3.3.1-83 will be revised to state consistency with NUREG-1801.

to NRC-15-0030 Page 2 LRA Revisions:

LRA Tables 3.3.1 (item 3.3.1-83) and 3.3.2-10 are revised as shown on the following pages.

Additions are shown in underline and deletions are shown in strike-through.

to NRC-15-0030 Page 3 Table 3.3.1 Summary of Aging Management Programs for the Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Table 3.3.1: Auxiliary Systems Aging Item Aging Effect/

Management Further Evaluation Number Component Mechanism Programs Recommended Discussion 3.3.1-83 Stainless steel Cracking due to Chapter XI.M38, No This item was not u'Sd.

diesel engine stress corrosion "Inspection of The configuration of exhaust piping, cracking Internal Surfaces in etainless stee4iesel piping Miscellaneous engie-exhaust components, Piping and Ducting components precludes and piping Components" raoisture collection elements neessary to concentrate exposed to contaminates, So these diesel exhaust corponents are not susceptible to cracking.

Consistent with NUREG-1801. Cracking due to stress corrosion cracking for stainless steel components exposed to diesel exhaust is managed by the Internal Surfaces in Miscellaneous Piping and Ducting Components Program.

to NRC-15-0030 Page 4 Table 3.3.2-10 Emergency Diesel Generator System Summary of Aging Management Evaluation Table 3.3.2-10: Emergency Diesel Generator System Aging Effect Aging Component Intended Requiring Management NUREG-Table Type Function Material Environment Management Programs 1801 Item 1 Item Notes Expansion Pressure Stainless Exhaust gas Cracking -

TLAA-metal H

joint boundary steel (int) fatigue fatigue Expansion Pressure Sta!nless Exhaust gas Cracking Internal VIl.H2.AP-3.3.1-A o:nt boundary steel

'int Surfaces in 123 83 Miscellaneous Piping and Ducting Cornponents Expansion Pressure Stainless Exha st :as Loss of Internal VIL H2.AP-3.3.1-A joint boundar steel (int) material Surfaces in 104 83 M iscella neous Piping and Ducting Components Expansion Pressure Stainless Raw water Loss of Service Water VII.H2.AP-3.3.1-A joint boundary steel (int) material Integrity 55 41 to NRC-15-0030 Page 5 RAI B.1.42-2a Back round In its response to RAI B. 1.42-2, dated December 26, 2014, the applicant stated: "the Structures Monitoring Program described in LRA Section B.1.42 is appropriate to serve as the plant-specific aging management program accounting for the extent of degradation experienced on concrete structural elements exposed to groundwater at Fermi 2. This is consistent with the recommendations for detection of aging effect in the GALL Report Sections XI.S6 and XIS7."

The applicant also stated that enhancement to the program element "detection of aging effects" states (as modified in the applicant response to RAI3.5.2.2.2.1-1 in letter NRC-14-0070 dated October 24, 2014):

"If normally inaccessible areas become accessible due to plant activities, an inspection of these areas shall be conducted. Additionally, inspections will be performed of inaccessible areas in environments where observed conditions in accessible areas indicate that significant degradation may be occurring in the inaccessible areas."

The "detection of aging effects" program element in Sections XIS6 and XIS7 of the Generic Aging Lessons Learned (GALL) Report states that for plants with aggressive ground water/soil and/or where concrete structural elements have experienced degradation, a plant-specific aging management program (AMP) accounting for the extent of degradation experience should be implemented to manage the concrete aging. The GALL Report also states that for plants with non-aggressive ground water/soil the program recommends: (a) evaluating the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas and (b) examining representative samples of the exposed portions of the below grade concrete, when excavated for any reason.

American Concrete Institute (ACI) 349.9.3R suggests, based on the groundwater water chemistry at the site, to evaluate the propensity to cause concrete degradation or steel reinforcement corrosion, and when aggressive groundwater environment exists it states that 'further evaluation at an increased frequency may be warranted."

Issue The plant-specific AMP and its enhancement to the program element of "detection of aging effects," as modified in the applicant's response to RAI 3.5.2.2.2.1-1 in letter NRC-14-0070 dated October 24, 2014, describes an AMP which actions are consistent with the GALL Report recommendation for concrete structural elements exposed to non-aggressive groundwater environment where significant age-related degradation from chemical attacks is not expected to occur as opposed to those structural elements exposed to an aggressive groundwater environment. As the staff noted in the audit report, the LRA AMP basis document indicates that the Fermi 2 concrete structures are subjected to an aggressive ground water/soil environment.

to NRC-15-0030 Page 6 No technical justification has been provided to demonstrate that recommendations applicable to non-aggressive groundwater environment (i.e., when "normally inaccessible areas become accessible due to plant activities" and "where observed conditions in accessible areas indicate that signficant degradation may be occurring in the inaccessible areas ") will be adequate to manage age related degradation due to aggressive groundwater environment in inaccessible areas of Fermi 2 below grade concrete structures. The staff is not clear whether the applicant has evaluated or has plans to evaluate the effects of its aggressive groundwater on inaccessible concrete to determine that the program will be adequate to ensure that no loss of intended fimction occurs during the period of extended operation.

Request Provide the technical bases that justfy the adequacy of the program element enhancement to the LRA Structures Monitoring Program, as modified in the applicant's response to RAI 3.5.2.2.2.1-1 in letter NRC-14-0070 dated October 24, 2014, in the RAI, to manage age related degradation due to aggressive groundwater environment in inaccessible areas of Fermi 2 below grade concrete structures during the period of extended operation.

Response

The technical bases to justify the adequacy of the program element enhancement to the License Renewal Application (LRA) Structures Monitoring Program, as modified in DTE's response to RAI 3.5.2.2.2.1-1 in letter NRC-14-0070 dated October 24, 2014, to manage age related degradation due to aggressive groundwater environment in inaccessible areas of Fermi 2 below-grade concrete structures during the period of extended operation is as follows.

As described in the Updated Final Safety Analysis Report (UFSAR), Fermi 2 site grade is 583.0 feet along the periphery of the power block (reactor/auxiliary building, RHR complex, turbine house, radwaste building, etc.). As described in UFSAR Sections 2.5.1.2.7 and 2.5.4.11.2, concrete mix design used in the construction of Fermi 2 below-grade concrete took into consideration the elevated sulfate levels in the natural ground water, using sulfate-resistant cement for all cement grout and below-grade concrete that will be in contact with the ground water. Specifically, Type II and Type V Portland cement conforming to the requirements of ASTM Designation C150-68, as well as Canadian Standards Association (CSA) A5-1971 cement, was used. Due to the fact that sulfate-resistant cement was utilized for below-grade concrete, potential degradation due to the aggressive groundwater environment would be minimal. The above-grade portion of the same structure would be subject to year-round weathering, and would experience higher levels of degradation than the below-grade portion of the structure that is protected by the sulfate-resistant cement.

In addition, the Fermi 2 reactor/auxiliary building is provided with a waterproof membrane for below-grade concrete. Therefore, below-grade concrete for the reactor/auxiliary building at Fermi 2 is not in direct contact with soil, subgrade, or backfill materials. In accordance with ACI 515.1R Table 4.2, providing a positive side waterproofing barrier system will prevent water from to NRC-15-0030 Page 7 entering the concrete. This waterproof barrier provides positive protection of the concrete if an aggressive groundwater environment is present. Due to this protective barrier, in addition to the sulfate resistant cement discussed previously, an aggressive groundwater environment is expected to play a negligible role in degradation of below-grade concrete.

Past inspections of the Fermi 2 structures under the Structures Monitoring Program have not revealed concrete structural aging effects attributed to aggressive chemical attack. Recent site projects where below-grade exterior walls of the structures were exposed also did not identify degradation attributed to aggressive chemical attack.

Because of this, the approach for inspecting the above-grade structures for degradation through the Structures Monitoring Program and correlating the condition of above-grade structure to the condition of the below-grade structure is valid. As such, the Structures Monitoring Program with enhancement of the element "detection of aging effects" (as modified in response to RAI 3.5.2.2.2.1-1 in letter NRC-14-0070 dated October 24, 2014) will be adequate to manage age-related degradation due to aggressive groundwater in inaccessible areas of Fermi 2 below-grade concrete structures during the period of extended operation.

LRA Revisions:

None.

to NRC-15-0030 Page 8 RAI B.1.42-3a

Background

In its response to RAI B.1.42-3, dated December 26, 2014, the applicant stated: "For clarification, the Fermi 2 Structures Monitoring Program enhancements referencing ACI 349.3R will be revised to specifically indicate use of the 2002 or later version," and provided applicable revisions to LRA Sections A.1.42, A.4, and B. 1.42 to indicate those changes.

The staff notes that the GALL Report provides guidance on page XI-3 to allow license renewal applicants to use later editions/revisions than specified in the GALL Report for these industry generated documents. The GALL Report guidance on page XI-3 states, in part, "If either of these methods is used as justification for adopting a later edition/revision than specified in the GALL Report, the applicant shall make available for the staff's review the information pertaining to the NRC endorsement/approval of the later edition/revision."

Issue The applicant response did not provide enough information to determine whether it plans to use a later version that has been approved by the NRC, and no information pertaining to a plant-specific NRC endorsement/approval of a later edition/revision ofACI 349.3R than the 2002 revision was identified.

Request

1. Identify the later version of ACI 349.3R that has been endorsed/approved by the NRC that will be used in the Structures Monitoring Program.

2. If a plant-specific NRC endorsement/approval has been provided, as discussed in the guidance on page XI-3 of the GALL Report, identify the plant-specific licensing action that contained the endorsement/approval.

Response

1. During review of the Fermi 2 Structures Monitoring Program (SMP) against the program description in NUREG-1801 (GALL Report),Section XI.S6, the provisions of the 2002 version of ACI 349.3R were considered to assess consistency with the NUREG-1801 aging management program. To be consistent with the code version used to assess the consistency with GALL Report,Section XI.S6, the Fermi 2 SMP enhancements noted in the responses to RAIs B.1.42-3 (DTE letter NRC-14-0082 dated December 26, 2014) and 3.5.2.2.2.1-3 (DTE letter NRC-15-0008 dated January 26, 2015) are revised to reflect only the 2002 version of ACT 349.3R (ACI 349.3R-02).

to NRC-15-0030 Page 9

2. Not applicable since DTE is not relying on plant-specific NRC endorsement/approval of a later version of ACI 349.3R.

LRA Revisions:

LRA Sections A.1.42, A.4, and B.1.42 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 December 26, 2014 letter (NRC-14-0082) and January 26, 2015 letter (NRC-15-0008) are not shown in underline or strike-through such that only the new changes due to RAI B.1.42-3a are shown as revisions.

to NRC-15-0030 Page 10 A.1.42 Structures Monitoring Program The Structures Monitoring Program will be enhanced as follows.

Revise plant procedures to include the following parameters to be monitored or inspected:

For concrete structures, base inspections on quantitative requirements of industry codes (i.e., ACI 349.3R-02-o4r4e), standards and guidelines (i.e.,

ASCE 11) and consideration of industry and plant-specific operating experience.

Revise plant procedures to include the following for detection of aging effects:

i Personnel (Inspection Engineer and Program Administrator or Responsible Engineer) involved with the inspection and evaluation of structures and structural components, including masonry walls and water-control structures, meet the qualifications guidance identified in ACI 349.3R-02-r4ater.

Revise plant procedures to prescribe quantitative acceptance criteria based on the quantitative acceptance criteria of ACI 349.3R-02--dater and information provided in industry codes, standards, and guidelines including ACI 318, ANSI/ASCE 11, and relevant AISC specifications. Industry and plant-specific operating experience will also be considered in the development of the acceptance criteria.

The following testing and evaluation will be performed prior to the period of extended operation to confirm that previously identified conditions are not the result of leaching of calcium hydroxide and carbonation that could impact the intended function(s) of the concrete structure.

Available water/mineral deposit samples will be tested for mineral and iron content to assess the effect of the water in-leakage on the reinforced concrete elements involved.

o. The results of the testing and Structures Monitoring Program inspections will be used to determine corrective actions per the Corrective Action Program.

Possible corrective actions include, but are not limited to, more frequent inspections, sampling and analysis of the in-leakage water for mineral and iron content, testing core bore samples, and evaluation of the affected area using evaluation and acceptance criteria of ACI 349.3R-02-4atei.

to NRC-15-0030 Page 11 A.4 LICENSE RENEWAL COMMITMENT LIST No.

Program or Activity Commitment Implementation Source Schedule 34 Structures Monitoring Enhance Structures Monitoring Program as follows:

Prior to A.1.42 September 20,

g.

Revise plant procedures to include the following parameters 2024.

to be monitored or inspected:

Testing and For concrete structures, base inspections on quantitative evaluation for requirements of industry codes (i.e., ACI 349.3R-02-er possible leaching ateF), standards and guidelines (i.e., ASCE 11) and in previously consideration of industry and plant-specific operating identified experience.

conditions will commence in

j.

Revise plant procedures to include the following for 2015.

detection of aging effects:

Personnel (Inspection Engineer and Program Administrator or Responsible Engineer) involved with the inspection and evaluation of structures and structural components, including masonry walls and water-control structures, meet the qualifications guidance identified in ACI 349.3R-02-er-4ateF.

k. Revise plant procedures to prescribe quantitative acceptance criteria based on the quantitative acceptance criteria of ACI 349.3R-02-r4ateF and information provided in industry codes, standards, and guidelines including ACI 318, ANSI/ASCE 11, and relevant AlSC specifications. Industry and plant-specific operating experience will also be considered in the development of the acceptance criteria.

to NRC-15-0030 Page 12 No.

Program or Activity Commitment Impemention Source

n. The following testing and evaluation will be performed prior to the period of extended operation to confirm that previously identified conditions are not the result of leaching of calcium hydroxide and carbonation that could impact the intended function(s) of the concrete structure.

Available water/mineral deposit samples will be tested for mineral and iron content to assess the effect of the water in-leakage on the reinforced concrete elements involved.

The results of the testing and Structures Monitoring Program inspections will be used to determine corrective actions per the Corrective Action Program. Possible corrective actions include, but are not limited to, more frequent inspections, sampling and analysis of the in-leakage water for mineral and iron content, testing core bore samples, and evaluation of the affected area using evaluation and acceptance criteria of ACI 349.3R-02-er to NRC-15-0030 Page 13 B.1.42 STRUCTURES MONITORING Program Description The Structures Monitoring Program provides for aging management of structures and structural components, including structural bolting, within the scope of license renewal. The program was developed based on guidance in RG 1.160, Revision 2, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and NUMARC 93-01, Revision 2, "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," to satisfy the requirement of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The scope of the Structures Monitoring Program includes structures within the scope of license renewal as delineated in 10 CFR 54.4. The scope of the program also includes the condition monitoring of masonry walls and water-control structures as described in the Masonry Wall Program (Section B.1.25) and in the NRC RG 1.127, "Inspection of Water-Control Structures Associated with Nuclear Power Plants," aging management program (Section B.1.39).

The structures and structural components are inspected by qualified personnel. Concrete structures are inspected for indications of deterioration and distress, using guidelines provided in ACI 201.1R, "Guide for Making a Condition Survey of Existing Buildings," and ACI 349.3R-02 r-4aer, "Evaluation of Existing Nuclear Safety-Related Concrete Structures." Masonry walls are inspected for cracking. Elastomers will be monitored for hardening, shrinkage and loss of sealing. Rock/stone embankment structures will be inspected for loss of material and loss of form. Component supports will be inspected for loss of material and reduction in anchor capacity due to local concrete degradation. Exposed surfaces of bolting are monitored for loss of material and loose or missing nuts and bolts. The program is augmented by plant procedures to ensure that the selection of bolting material, installation torque or tension, and the use of lubricants and sealants are appropriate for the intended purpose. These procedures will be enhanced to include the guidance of NUREG-1339 and EPRI TR-104213, NP-5067, and NP-5769 to ensure proper specification of bolting material, lubricant, and installation torque.

Enhancements Element Affected Enhancement

3. Parameters Monitored or Revise plant procedures to include the following Inspected parameters to be monitored or inspected:

For concrete structures, base inspections on quantitative requirements of industry codes (i.e., ACI 349.3R-02-er4ate ), standards and guidelines (i.e., ASCE 11) and consideration of industry and plant-specific operating experience.

to NRC-15-0030 Page 14 Element Affected Enhancement

4. Detection of Aging Effects Revise plant procedures to include the following:

Personnel (Inspection Engineer and Program Administrator or Responsible Engineer) involved with the inspection and evaluation of structures and structural components, including masonry walls and water-control structures, meet the qualifications guidance identified in ACI 349.3R-02-r-4.

6. Acceptance Criteria Revise plant procedures to prescribe quantitative acceptance criteria based on the quantitative acceptance criteria of ACI 349.3R-02-r4ater and information provided in industry codes, standards, and guidelines including ACI 318, ANSI/ASCE 11 and relevant AISC specifications. Industry and plant-specific operating experience will also be considered in the development of the acceptance criteria.

4. Detection of Aging Effects The following testing and evaluation will be

7. Corrective Actions performed prior to the period of extended operation to confirm that previously identified conditions are not the result of leaching of calcium hydroxide and carbonation that could impact the intended function(s) of the concrete structure.

Available water/mineral deposit samples will be tested for mineral and iron content to assess the effect of the water in-leakage on the reinforced concrete elements involved.

o The results of the testing and Structures Monitoring Program inspections will be used to determine corrective actions per the Corrective Action Program. Possible corrective actions include, but are not limited to, more frequent inspections, sampling and analysis of the in-leakage water for mineral and iron content, testing core bore samples, and evaluation of the affected area using evaluation and acceptance criteria of ACI 349.3R-02-e-4at&r.

to NRC-15-0030 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Additional License Renewal Application Revisions to NRC-15-0030 Page 1 Additional revisions to the License Renewal Application (LRA) were identified. The purpose of the revisions is discussed below. These revisions are shown on the following pages. Additions are shown in underline and deletions are shown in strike-through.

1) As part of a Fermi 2 condition assessment resolution document (CARD), it was identified that the LRA was inconsistent in the use of terms piping and tubing. In Section IX.B of NUREG-1801, the definition of piping includes tubing as an example of piping.

Therefore, in the context of the LRA, there is no significant functional difference between piping and tubing. However, some systems in the LRA identify piping and tubing as separate components and line items. In order to ensure that the LRA term usage is consistent throughout the LRA and also consistent with Fermi 2 documentation, selected LRA tables are revised to add tubing (e.g. in cases where only piping was previously identified) or to add piping (e.g. in cases where only tubing was previously identified).

The affected LRA tables are listed below.

a) Add line items for "tubing" to the following LRA tables:

2.3.2-8-1 and 3.2.2-8-1

2.3.3-17-1 and 3.3.2-17-1

2.3.3-17-4 and 3.3.2-17-4

2.3.3-17-5 and 3.3.2-17-5

2.3.3-17-6 and 3.3.2-17-6

2.3.3-17-7 and 3.3.2-17-7

2.3.3-17-11 and 3.3.2-17-11

2.3.3-17-13 and 3.3.2-17-13

2.3.3-17-15 and 3.3.2-17-15

2.3.3-17-17 and 3.3.2-17-17

2.3.3-17-20 and 3.3.2-17-20

2.3.3-17-21 and 3.3.2-17-21

2.3.3-17-33 and 3.3.2-17-33 2.3.4-3-1 and 3.4.2-3-1

2.3.4-3-2 and 3.4.2-3-2

2.3.4-3-3 and 3.4.2-3-3

2.3.4-3-5 and 3.4.2-3-5

2.3.4-3-6 and 3.4.2-3-6 o 2.3.4-3-8 and 3.4.2-3-8 b) Add line items for "piping" to LRA Tables 2.3.3-17-22 and 3.3.2-17-22.

c) Revise LRA Table 3.4.1 item number 3.4.1-39 to change the "Discussion" column to indicate the item is used.

2) As part of the extent of condition review of the CARD described above, some additional line items were identified as being inadvertently omitted from the LRA. LRA Table 3.2.2-4 is revised to add a line item for "piping" and LRA Table 3.3.2-6 is revised to add line items for "manifold."

to NRC-15-0030 Page 2

3) In response to a program owner question on the population of piping within the Buried and Underground Piping Program, small sections of nonsafety-related underground piping stubs were identified as being inadvertently omitted from the LRA. LRA Table 3.2.2-8-1 is revised to add a line item for "piping".

4) In a July 30, 2014 letter (NRC-14-0051), DTE provided a supplement to the LRA to address portions of LR-ISG-2012-02, such as "Corrosion Under Insulation." Subsequent to that submittal, some additional insulated piping components were identified as having been inadvertently omitted. LRA Table 3.3.2-17-11 is revised to add line items for "insulated piping components." LRA Table 3.3.1 item number 3.3.1-132 is revised to change the "Discussion" column to include copper alloy for consistency with its usage in other LRA tables. [Note that the previous changes to the "Discussion" column of item number 3.3.1-132 made in the July 30, 2014 letter (NRC-14-0051) are not shown in underline or strike-through such that only the new changes are shown as revisions.]

5) During the NRC aging management program (AMP) audit that was held during the week of September 29, 2014, the NRC asked for clarification regarding the "Notes" column for the masonry walls component type in LRA Table 3.5.2-1. DTE agreed that the note should be revised and agreed to provide the change at a later date. Therefore, LRA Table 3.5.2-1 is revised as was previously discussed with the NRC.

6) As part of preparation for the upcoming NRC inspection in April 2015, the Environmental Qualification (EQ) of Electric Components Program owner identified a need for clarification in LRA Section B.1.15. The "Operating Experience" subsection of LRA Section B.1.15 is revised to clarify the date that a project began.

7) During advance planning for implementation, as documented as part of a Fermi 2 CARD, it was identified that the name/description of a component in an enhancement in the Water Chemistry Control - Closed Treated Water Systems Program (LRA Sections A.1.44 and B.1.44) was not correct. Therefore, LRA Sections A.1.44, A.4, and B.1.44 are revised to correct the name/description of the component. As part of the extent of condition review associated with this CARD, it was determined that the line items associated with this component were inadvertently omitted from the LRA. Therefore, LRA Table 3.3.2-17-11 is revised to add additional line items. In addition, it was determined that the closed treated water system associated with this nonsafety-related component is very small. As a result, DTE will take exception to the NUREG-1801 frequency for sampling and analysis for this component. LRA Section B.1.44 and Table B-3 are revised to add an exception.

to NRC-15-0030 Page 3 Table 2.3.2-8-1 Residual Heat Removal System Nonsafety-Related Components Affecting Safety-Related Systems Components Subject to Aging Management Review Component Type Intended Functiona Bolting Pressure boundary Piping Pressure boundary Pump casing Pressure boundary Lubing Pressure boundary Valve body Pressure boundary