NRC-16-0003, Response to NRC Request for Additional Information for the Review of the License Renewal Application - Set 38

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Response to NRC Request for Additional Information for the Review of the License Renewal Application - Set 38
ML16022A220
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 02/01/2016
From: Polson K
DTE Electric Company, DTE Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-16-0003
Download: ML16022A220 (16)


Text

Keith J. Polson Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734,586.6515 Fax: 734,586.4172 Email: polsonk@dteenergy.com 3-DYE Energy*

10 CFR 54 January 22, 2016 NRC-16-0003 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, "Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 38 (TAC No.

MF4222)," dated January 14, 2016 (ML16011A044)

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 38 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).

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-16-0003 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 22, 2016 Keith Polson 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 38 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 1 to NRC-16-0003 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 38 to NRC-16-0003 Page 1 Set 38 RAI4.3.3-3a

Background

By letter dated September 24, 2015, the applicantprovided its response to RAI4.3.3-3. In this letter, the applicantstated that there are locations where the environmentally assistedfatigue (EAF)correctionfactors (Fe) were recalculatedusing average transienttemperaturesor maximum operatingtemperatures. The RAI response also states that these Fe, were recalculated in a manner consistent with NUREG/CR-6909, "Effect ofLWR CoolantEnvironments on the FatigueLife of Reactor Materials."

Appendix A of NUREG/CR-6909 states the following:

For the case of a constantstrain rate and a linear temperature response, an average temperature (i.e., average of the maximum and minimum temperaturesfor the transients) may be used to calculate Fe,. In general, the "average" temperature that should be used in the calculationsshouldproduce results that are consistentwith the results that would be obtainedusing the modified rate approach described in Section 4.2.14 of this report.

The maximum temperature can be used to perform the most conservative evaluation.

The method used to calculatethe "average temperature" is dependent on whether the minimum transient temperatureexceeds the temperaturethreshold value of the material. When the minimum temperature exceeds the thresholdtemperature, the maximum and minimum temperaturevalues of the stress cycle or load set pair are used to calculate the average temperature. When the minimum temperatureis below the threshold temperature, the maximum and thresholdtemperature are used to calculate the average temperature. Sections 4.2.4 and 5.2.7 ofNUREG/CR-6909provide examples of determiningaverage temperatures.

As noted above, NUREG/CR-6909 also states that the average temperature may be used to calculatethe Fe value for transientswith a constant strain rate and a linear temperature response, which are defined as "simple" transients. Use of an average temperature may not be appropriatefor more complex transientsthat have multiple or non-linear temperature variations. For complex transients,the modified rate approachshould be used to validate Fen calculations.

Based on the RAI response, the staff requested clarificationduring a telephone conference call held on December 15, 2015, on how the average transienttemperatureswere calculatedin the licensee's screeningand Fe, evaluations because it was not clear if the average transient temperatureswere calculated appropriatelyconsideringthe threshold temperature. In addition, it was not clear if use of the average temperatures were limited to simple transients. This clarfication is needed to verify consistency with NUREG/CR-6909.

to NRC-16-0003 Page 2 Issue During the telephone conference call held on December 15, 2015, the applicantand the staff discussed three methods to determine the average temperature values, used to calculate the Fen.

The stafffinds that two of these methods, one based on minimum transient temperaturesabove the temperature threshold and the other based on minimum transienttemperaturesbelow the temperaturethreshold, are consistent with the approachdescribed in NUREG/CR-6909. During the call the applicantstated that a third method used the minimum transient temperatureinstead of the threshold temperature to calculate the average temperature and, if the resulting temperaturewas less than the threshold temperature, then the threshold temperaturewas used to calculate the Fee. The stafffinds this thirdapproach to be not consistent with NUREG/CR-6909 methodology.

Request Assess the impact of revising the evaluations to use the correctdetermination of average temperature in a manner consistent with NUREG/CR-6909, andsubmit a description of the impact of this revision to the previous screeningand Fe, evaluation resultsfor staff review. This includes:

a) Identify all locations that used an average temperature to calculate the Fe,. This includes locations which are not identified as sentinel locations. For each location,provide the following:

i. The materialof construction.

ii. A description of how the average temperature was calculated.

iii. A description of all transientsassociatedwith the use of average temperatures andjustification that the transientsare simple transients.

b) For all other locations not identified in (a),provide the materialof construction and a description of what temperature was used to calculate the Fen,.

c) Describe whether the revised average temperature calculations impacts the selection of sentinel locations.

d) Confirm that any revised Fe,, and EAF cumulative usagefactor values (CUFe,) values are determined in a manner consistent with the guidance ofNUREG/CR-6909, as stated in LRA Section 4.3.3, A.2.2, and response to RAI 4.3.3-3.

Response

DTE provided the environmentally assisted fatigue (EAF) screening results of Fermi 2 locations in License Renewal Application (LRA) Table 4.3-8. The EAF screening results in LRA Table 4.3-8 were updated by DTE letter NRC-15-0068 dated June 26, 2015. The EAF methodology was discussed in the response to RAI Set 37 which was provided in DTE letter NRC-15-0089 dated September 24, 2015. The response to Set 37 discussed DTE's plans to re-evaluate EAF for certain component locations in future analyses. Some of those revised analyses have now been completed. For the purpose of responding to parts (a) and (b) of this RAI, the component to NRC-16-0003 Page 3 locations will be categorized into the response for parts (a) and (b) based on the analysis that was in effect at the time of the September 2015 response. Any changes to the evaluations since that time will be addressed in the discussion of the relevant component locations.

a) The following locations used an average temperature to calculate the Fe1 factor at the time of the September 2015 RAI response: SLC piping inside containment, feedwater nozzles, core AP nozzle, CRD nozzles, CRD assembly main flange, and RR pump cooler.

The requested information (i, ii, and iii) is provided for each component location below.

SLC piping inside containment:

i. The SLC piping inside containment material is stainless steel.

ii. Most of the transients and load pairs used the maximum service temperature at uprate conditions for the piping of 552.1°F. The startup and shutdown load set utilized an average service temperature. Previously, the average temperature was determined by the average of the maximum and minimum service temperatures.

The minimum service temperature of 100°F was below the threshold temperature of 150°C / 302F. Therefore, the calculation for that load set has been revised. The revised calculation (and its result) is described in the response to part (c) below.

iii. The startup and shutdown load set pair associated with this average temperature meets the definition of "simple" because, as defined in the design fatigue calculation, it has a constant strain rate and a linear temperature response.

Therefore, it is acceptable to use an average temperature.

Feedwater nozzles:

i. As indicated in LRA Table 4.3-8, the NUREG/CR-6260 generic location of feedwater (FW) nozzles consists of several specific Fermi 2 locations. The FW nozzle safe end has a carbon steel (CS) portion and a stainless steel (SS) portion.

These two portions are analyzed separately as shown in LRA Table 4.3-8. The nozzle-vessel intersection material is low alloy steel (LAS).

ii. For the FW nozzle safe end CS portion and the LAS nozzle-vessel intersection, the maximum design temperature of 575°F was used, not average temperature. For the FW nozzle safe end SS portion, the calculations previously used an average temperature. The average temperature was determined by the average of the maximum and minimum service temperatures for each transient, with the minimum service temperature taken at the threshold temperature of 302°F if it was below the threshold. Also, if the maximum temperature was below the threshold value, the threshold value was used.

iii. The average temperatures determined for the transients were used to determine the average temperature for each load pair at the FW nozzle SS safe end location. The resulting calculated CUFeI using this method was greater than 6 so additional action was needed as previously addressed in the footnote to LRA Table 4.3-8.

Upon further consideration, not all transients can be considered "simple" transients.

Therefore, the calculation for the FW nozzle SS safe end location has been revised to more conservatively use the design temperature of 575°F for all analyzed load to NRC-16-0003 Page 4 sets. The revised calculation (and its result) is described in the response to part (c) below.

Core AP nozzle:

i. The limiting core AP nozzle location material is a nickel-based alloy (NBA).

ii. The core AP nozzle calculation previously used average temperature. The average temperature was determined by the average of the maximum temperature at uprate conditions and the threshold temperature.

iii. As discussed in the response to RAI Set 37 which was provided in DTE letter NRC-15-0089, the fatigue calculation for the core AP nozzle conservatively used bundled transients. The fatigue calculation conservatively used the highest calculated alternating stress. The dominant transient of the lumped transient count was the startup/shutdown transient, which was considered a "simple" transient.

to The projected CUFe~ exceeded 1.0, so as discussed in the previous RAI response RAI Set 37, the transients have been separated. The revised calculation (and its result) is described in the response to part (c) below and conservatively uses the design temperature of 575°F.

CRD nozzles:

i. The limiting CRD nozzle location material is a nickel-based alloy (NBA).

ii. The CRD nozzle calculation previously used average temperature. The average temperature was determined by the average of the maximum and minimum temperatures at uprate conditions. If the average temperature was below the threshold temperature, the average temperature was increased to the threshold temperature. When the calculation was revised, as planned per the discussion in response to RAI Set 37 which was provided in DTE letter NRC-15-0089, the design temperature was used. The revised calculation (and its result) is described in the response to part (c) below.

iii. As discussed in the response to RAI Set 37, the fatigue calculation for the CRD nozzle conservatively used bundled transients. The fatigue calculation conservatively used the highest calculated alternating stress. The projected CUFe exceeded 1.0, so as discussed in the previous RAI response, the transients have been separated. The revised calculation (and its result) is described in the response to part (c) below and conservatively uses the design temperature of 575°F.

CRD assembly main flange:

i. The CRD assembly main flange material is stainless steel.

ii. The analysis for the CRD assembly main flange utilized an average temperature.

Previously, the average temperature was determined by the average of the maximum and minimum temperatures at power uprate. The minimum temperature used was below the threshold temperature. Therefore, the calculation for that load set has been revised. The revised calculation (and its result) is described in the response to part (c) below.

to NRC-16-0003 Page 5 iii. The dominant transient is the startup transient where temperature varies linearly and strain rate is constant. In the revised calculation described in the response to part (c), the startup transient is calculated with average temperature, and the remaining transients are calculated with maximum operating temperature at power uprate of 556.5°F.

RR pump cooler:

i. The RR pump cooler material is stainless steel.

ii. The RR pump cooler calculation previously used average temperature. Previously, the average temperature was determined by the average of the maximum and the threshold temperatures.

iii. The transient associated with this average temperature is the seal injection on-off-on transient. Originally, it was considered a "simple" transient. Upon further consideration, the transient does not meet the criteria for "simple" transients.

Therefore, the calculation has been revised to conservatively use the design temperature of 575°F. The revised calculation (and its result) is described in the response to part (c) below.

b) For the locations not identified in (a) listed in LRA Table 4.3-8, the material of construction and a description of what temperature was used to calculate Fen is provided in the table below.

Location Material Temperature Used Reactor vessel shell LAS Design temperature 575°F RR inlet nozzle liner SS Not part of reactor coolant pressure boundary, so not calculated RR inlet nozzle safe end SS Design temperature 575°F RR inlet nozzle nozzle-vessel LAS Design temperature 575F intersection RR outlet nozzle nozzle-vessel LAS Design temperature 575°F intersection RR outlet nozzle safe end SS Design temperature 575°F RR outlet nozzle LAS Bounded by nozzle-vessel intersection, so not calculated RR piping SS Design temperature 575°F RR valve SS Bounded by adjacent piping, so not calculated Core spray nozzle-vessel LAS Design temperature 575F intersection Core spray nozzle safe end NBA Design temperature 575°F Core spray valve CS Design temperature 575°F Core spray piping CS Design temperature 575F to NRC-16-0003 Page 6 Location' Material Temperature Used RHR valve CS Design temperature 575°F RHR piping CS Design temperature 575°F FW valve CS Design temperature 575°F FW piping CS Design temperature 575°F RWCU piping CS Design temperature 575°F RWCU valve CS Design temperature 575°F HPCI valve CS Design temperature 575°F Containment penetration X-13A/B, CS Design temperature 575°F RHR return weld 3 Containment penetration X-12 body, CS Design temperature 575°F RHR supply 3 Condensing chamber SS Maximum power uprate operating temperature 552.1 F (further analysis being performed since CUFen exceeds 1.0 as discussed in response to RAI Set 37)

1. Location names are based on "Fermi 2 Location" in LRA Table 4.3-8
2. CS=carbon steel, LAS=low alloy steel, NBA=nickel-based alloy, SS=stainless steel
3. Only the containment penetrations with the highest CUFe1 for the weld and the body were listed in LRA Table 4.3-8. EAF calculations were performed for several other penetrations where the weld and/or body were not considered bounded by the attached piping analysis. These locations were the feedwater penetration weld and body, RHR return penetration body, RWCU penetration body, and core spray penetration body. The design temperature of 575°F was used for calculations for the carbon steel feedwater penetration weld and body, the carbon steel RHR return penetration body, and the carbon steel RWCU penetration body. The core spray containment penetration X-16A/B carbon steel body was calculated using a maximum conservative operating temperature of 392°F since this penetration does not contain high temperature fluid.

c) The calculations for the following locations have been revised since the September 2015 RAI response: SLC piping inside containment, feedwater nozzles, core AP nozzle, CRD nozzles, CRD assembly main flange, and RR pump cooler. A discussion of the revised calculations is provided for each component location below.

SLC piping inside containment:

The startup and shutdown load set that utilizes an average temperature was revised to use an average temperature that is determined by the average of the maximum service temperature at power uprate and threshold temperature since the minimum temperature is below the threshold. This load set pair meets the definition of "simple" above because, as defined in the design fatigue calculation, it has a constant strain rate and a linear temperature response. The resultant average temperature is higher than used previously. The resultant CUFe is 0.658 which is larger than the value of 0.503 previously provided in DTE letter NRC-15-0068 dated June 26, 2015.

Although the CUFen value increased, it is still below 0.8. Therefore, this location is not a sentinel location, which is consistent with its previous evaluation.

to NRC-16-0003 Page 7 Feedwater nozzles:

The calculation for the FW nozzle safe end SS portion that used average temperature was revised to use the maximum design temperature of 575°F. In addition to the revision to the temperature value, the calculations for all three of the FW nozzle locations were revised to treat the hot standby transient and RCIC injection as unique transients. This revision was discussed as a future action in the September 2015 response and has now been completed. The resultant CUFe1 values for the safe end CS portion, safe end SS portion, and nozzle-vessel intersection are 0.083, 5.55, and 0.113, respectively. These values are all smaller than the respective values of 0.165, 6.37, and 0.115 that were previously provided in DTE letter NRC-15-0068 dated June 26, 2015. Although the change in temperature methodology for the SS nozzle safe end location increased the CUFe1 value compared to using an average temperature, the values did decrease overall due to the larger effect of treating the hot standby transient and RCIC injection as unique transients. The FW nozzles are NUREG/CR-6260 locations and will be retained as sentinel locations, consistent with the previous evaluation. Since CUFeI is still greater than 1.0 even after further evaluation, it is expected that stress-based fatigue monitoring will be required for the FW nozzles. Stress-based fatigue monitoring was discussed in DTE letter NRC-15-0068 dated June 26, 2015.

Core AP nozzle:

The core AP nozzle calculation that used an average temperature was revised to use the maximum design temperature of 575°F. In addition to the revision to the temperature value, the calculation was revised to unbundle the transients. This revision was discussed as a future action in the September 2015 response and has now been completed. The resultant CUFe1 value is 0.929. This value is smaller than the value of 1.48 that was previously provided in DTE letter NRC-15-0068 dated June 26, 2015. Although the change in temperature methodology increased the CUFen value compared to using an average temperature, the value did decrease overall due to the larger effect of unbundling the transients. While the CUFe value is now less than 1.0, it is still greater than 0.8. Therefore, this location will be retained as a sentinel location, consistent with the previous evaluation.

CRD nozzles:

The CRD nozzles calculation that used an average temperature was revised to use the maximum design temperature of 575°F. In addition to the revision to the temperature value, the calculation was revised to unbundle the transients. This revision was discussed as a future action in the September 2015 response and has now been completed. The resultant CUFen value is 0.191. This value is smaller than the value of 1.28 that was previously provided in DTE letter NRC-15-0068 dated June 26, 2015. Although the change in temperature methodology increased the CUFen value compared to using an average temperature, the value did decrease overall due to the larger effect of unbundling the transients. While the CUFen value is now less than 1.0 to NRC-16-0003 Page 8 and also less than 0.8, this location is a NUREG/CR-6260 location. Therefore, this location will be retained as a sentinel location, consistent with the previous evaluation.

CRD assembly main flange:

The calculation that utilized an average temperature was revised to use the maximum service temperature at power uprate of 556.5°F for all of the transients but one and an average temperature determined by the average of the maximum service temperature and threshold temperature since the minimum temperature is below the threshold for the startup transient. The resultant average temperature is higher than used previously. The resultant CUFei is 0.725 which is larger than the value of 0.329 previously provided in DTE letter NRC-15-0068 dated June 26, 2015. Although the CUFen value increased, it is still below 0.8. Therefore, this location is not a sentinel location, which is consistent with the previous evaluation.

RR pump cooler:

The calculation was revised to use the design temperature of 575°F. The calculation was also revised to appropriately account for the cooler being replaced in 1998, and so it will be in operation for a period of 47 years by 2045 when the plant reaches the end of the 60 year license renewal period. The postulated cycles were projected based on the 14 year period from cooler replacement in fall 1998 through 12/31/2012.

The resultant CUFe1 is 0.578 which is similar to the value of 0.581 previously provided in DTE letter NRC-15-0068 dated June 26, 2015. However, this location was selected as a sentinel location as indicated in DTE letter NRC-15-0068 dated June 26, 2015. Since it has a unique thermal transient, this location is retained as a sentinel location, which is consistent with its previous evaluation.

d) Based on the revised calculations described in the response to part (c) above, the revised Fen factors and CUFen values are determined in a manner consistent with the guidance of NUREG/CR-6909. NUREG/CR-6909 addresses the use of service temperature. In most cases, the design temperature, which is more conservative than service temperature, is used in the calculations. In others, the maximum operating or transient temperature is used, which corresponds to the service temperature. In two cases, an average temperature is used for transients with a constant strain rate and a linear temperature response, and the average temperature is determined by using the maximum service temperature at uprate conditions and threshold temperature (since the minimum temperature is below the threshold). As discussed in the response to part (b) above, the analysis for the condensing chamber is being revised, but the revised analysis will also determine the Fen factors and CUFe values in a manner consistent with the guidance of NUREG/CR-6909.

LRA Revisions:

LRA Table 4.3-8 is revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to this same LRA table

Enclosure 1 to NRC-16-0003 Page 9 made in previous letters are not shown in underline or strike-through such that only the new changes due to RAI 4.3.3-3a are shown as revisions.

Note that one additional change was made to Table 4.3-8. Containment penetration X-13A/B, RHR return weld, had been incorrectly noted as a sentinel location. While the projected CUFen is higher than for the RHR return piping, the RHR containment penetration return weld was conservatively analyzed by bundling transients and applying the highest alternating stress to the total number of transient cycles. By comparison, the highest alternating stress for the RHR return piping is higher than the alternating stress used for the containment penetration weld. If the total number of transients were to be bundled for the RHR return piping and its highest alternating stress used to analyze both locations on a common basis, the RHR return piping would have larger usage than the penetration. Therefore, the RHR return piping containment penetration weld is not a sentinel location. The RHR return piping, which is also a NUREG/CR-6260 location, is a sentinel location. Therefore, the Fermi 2 location description for containment penetrations in LRA Table 4.3-8 is revised for clarification.

to NRC-16-0003 Page 10 Table 4.3-8 EAF Screening of Fermi 2 Locations NUREGICR-6260 Fermi 2 Generic Location Location Material' CUF Fen EAF CUF 1 Reactor vessel shell Reactor vessel LAS 0.021 7.21 0.153 and lower head shell 2 1 Reactor vessel shell CRD nozzle 2 NBA 0.052 3.65 0.191 and lower head -630 4--

3-453 2 Reactor vessel FW nozzle safe CS 0.043 1.88 0.081 0-464 feedwater nozzle end (CS 9087 plus 0.0014 portion) 2 rapid cycling =

0.083 0-465 2 Reactor vessel FW nozzle safe SS 0.495 11_.2 5.544 6--364 feedwater nozzle end (SS 09664 6-- plus 0.0014 portion) 2 g3 rapid cycling =

5.554 67374 2 Reactor vessel Nozzle-vessel LAS 0.01_52 6.10 0.0925 00942 feedwater nozzle intersection2 90454 plus 0.0206 rapid cycling =

0.113 0-445 3 Reactor recirculation RR inlet nozzle SS Note 5 piping (including inlet liner and outlet nozzles) 3 Reactor recirculation RR inlet nozzle SS 0.006 11.20 0.071 piping (including inlet safe end 2 and outlet nozzles) 3 Reactor recirculation RR inlet nozzle LAS 0.023 4.06 0.095 piping (including inlet nozzle-vessel and outlet nozzles) intersection 2 3 Reactor recirculation RR outlet LAS 0.112 4.06 0.453 piping (including inlet nozzle nozzle-and outlet nozzles) vessel intersection 2 3 Reactor recirculation RR outlet SS 0.021 11.2 0.240 piping (including inlet nozzle safe and outlet nozzles) end 2 to NRC-16-0003 Page 11 Table 4.3-8 EAF Screening of Fermi 2 Locations NUREG/CR-6260 Fermi 2 Generic Location Location Material' CUF Fen EAF CUF RR outlet LAS Bounded by nozzle nozzle-vessel intersection 3 Reactor recirculation RR piping 2 SS 0.018 11.2 0.199 piping (including inlet and outlet nozzles) 3 Reactor recirculation RR valve SS Bounded by piping (including inlet adjacent piping and outlet nozzles) 4 Core spray line reactor Core spray LAS 0.048 5.31 0.254 vessel nozzle and nozzle -vessel associated Class 1 intersection 2 piping 4 Core spray line reactor Core spray NBA 0.075 3.65 0.273 vessel nozzle and nozzle safe associated Class 1 end 2 piping 4 Core spray line reactor Core spray CS 0.0152 4.95 0.075 vessel nozzle and valve associated Class 1 piping 4 Core spray line reactor Core spray CS 0.0091 4.95 0.045 vessel nozzle and piping 2 associated Class 1 piping 5 Residual heat removal RHR valve CS 0.063 3.78 0.239 (RHR) nozzles and associated Class 1 piping 5 Residual heat removal RHR piping 2 CS 0.048 3.78 0.180 (RHR) nozzles and associated Class 1 piping to NRC-16-0003 Page 12 Table 4.3-8 EAF Screening of Fermi 2 Locations NUREG/CR-6260 Fermi 2 Generic Location Location Material' CUF Fen EAF CUF FW valve CS 0.063 3.78 0.239 6 Feedwater line Class 1 piping Feedwater line Class 1 FW piping 2 CS 0.0003 3.78 0.0012 6

piping

-- -- RWCU piping CS 0.014 3.78 0.052

-- -- RWCU valve CS 0.018 3.78 0.069

-- -- HPCI valve CS 0.053 1.88 0.099

-- -- SLCS piping SS 0.108 4.50 0.658 242 - 0.593 9.733

-- -- Containment penetrations:

Highest weld: CS 0.086 3.78 0.326 X-13A/B, RHR return weld2 Highest body CS 0.181 3.78 0.685 en-,entinel:

X-12 body, RHR supply

-- -- Condensing SS 0.385 9.73 3.754 chamber 2

-- -- Core AP NBA 0.255 3.65 0.929 nozzle 2 930 2-55 4-484

-- -- CRD assembly, SS 0.134 4.56 - 0.725 main flange 13 029 2-45

Enclosure 1 to NRC-16-0003 Page 13 Table 4.3-8 EAF Screening of Fermi 2 Locations NUREG/CR-6260 Fermi 2 Generic Location Location Material' CUF Fen EAF CUF

-- -- RR pump SS 0.052 11.2 0.578 cooler 2 0-4-50 &86 9-84

1. CS: carbon steel. LAS: low alloy steel. NBA: nickel-based alloy. SS: stainless steel.
2. This component is a sentinel location.
3. Fen was calculated for each transient or load pair based on average temperature or maximum service temperature at uprate conditions.
4. CUFen is above 1, so additional action will be needed, e.g. more detailed analysis or stress based monitoring.
5. Not part of reactor coolant pressure boundary, so no EAF evaluation is needed.

Keith J. Polson Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734,586.6515 Fax: 734,586.4172 Email: polsonk@dteenergy.com 3-DYE Energy*

10 CFR 54 January 22, 2016 NRC-16-0003 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, "Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 38 (TAC No.

MF4222)," dated January 14, 2016 (ML16011A044)

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 38 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).

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-16-0003 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 22, 2016 Keith Polson 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 38 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 1 to NRC-16-0003 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 38 to NRC-16-0003 Page 1 Set 38 RAI4.3.3-3a

Background

By letter dated September 24, 2015, the applicantprovided its response to RAI4.3.3-3. In this letter, the applicantstated that there are locations where the environmentally assistedfatigue (EAF)correctionfactors (Fe) were recalculatedusing average transienttemperaturesor maximum operatingtemperatures. The RAI response also states that these Fe, were recalculated in a manner consistent with NUREG/CR-6909, "Effect ofLWR CoolantEnvironments on the FatigueLife of Reactor Materials."

Appendix A of NUREG/CR-6909 states the following:

For the case of a constantstrain rate and a linear temperature response, an average temperature (i.e., average of the maximum and minimum temperaturesfor the transients) may be used to calculate Fe,. In general, the "average" temperature that should be used in the calculationsshouldproduce results that are consistentwith the results that would be obtainedusing the modified rate approach described in Section 4.2.14 of this report.

The maximum temperature can be used to perform the most conservative evaluation.

The method used to calculatethe "average temperature" is dependent on whether the minimum transient temperatureexceeds the temperaturethreshold value of the material. When the minimum temperature exceeds the thresholdtemperature, the maximum and minimum temperaturevalues of the stress cycle or load set pair are used to calculate the average temperature. When the minimum temperatureis below the threshold temperature, the maximum and thresholdtemperature are used to calculate the average temperature. Sections 4.2.4 and 5.2.7 ofNUREG/CR-6909provide examples of determiningaverage temperatures.

As noted above, NUREG/CR-6909 also states that the average temperature may be used to calculatethe Fe value for transientswith a constant strain rate and a linear temperature response, which are defined as "simple" transients. Use of an average temperature may not be appropriatefor more complex transientsthat have multiple or non-linear temperature variations. For complex transients,the modified rate approachshould be used to validate Fen calculations.

Based on the RAI response, the staff requested clarificationduring a telephone conference call held on December 15, 2015, on how the average transienttemperatureswere calculatedin the licensee's screeningand Fe, evaluations because it was not clear if the average transient temperatureswere calculated appropriatelyconsideringthe threshold temperature. In addition, it was not clear if use of the average temperatures were limited to simple transients. This clarfication is needed to verify consistency with NUREG/CR-6909.

to NRC-16-0003 Page 2 Issue During the telephone conference call held on December 15, 2015, the applicantand the staff discussed three methods to determine the average temperature values, used to calculate the Fen.

The stafffinds that two of these methods, one based on minimum transient temperaturesabove the temperature threshold and the other based on minimum transienttemperaturesbelow the temperaturethreshold, are consistent with the approachdescribed in NUREG/CR-6909. During the call the applicantstated that a third method used the minimum transient temperatureinstead of the threshold temperature to calculate the average temperature and, if the resulting temperaturewas less than the threshold temperature, then the threshold temperaturewas used to calculate the Fee. The stafffinds this thirdapproach to be not consistent with NUREG/CR-6909 methodology.

Request Assess the impact of revising the evaluations to use the correctdetermination of average temperature in a manner consistent with NUREG/CR-6909, andsubmit a description of the impact of this revision to the previous screeningand Fe, evaluation resultsfor staff review. This includes:

a) Identify all locations that used an average temperature to calculate the Fe,. This includes locations which are not identified as sentinel locations. For each location,provide the following:

i. The materialof construction.

ii. A description of how the average temperature was calculated.

iii. A description of all transientsassociatedwith the use of average temperatures andjustification that the transientsare simple transients.

b) For all other locations not identified in (a),provide the materialof construction and a description of what temperature was used to calculate the Fen,.

c) Describe whether the revised average temperature calculations impacts the selection of sentinel locations.

d) Confirm that any revised Fe,, and EAF cumulative usagefactor values (CUFe,) values are determined in a manner consistent with the guidance ofNUREG/CR-6909, as stated in LRA Section 4.3.3, A.2.2, and response to RAI 4.3.3-3.

Response

DTE provided the environmentally assisted fatigue (EAF) screening results of Fermi 2 locations in License Renewal Application (LRA) Table 4.3-8. The EAF screening results in LRA Table 4.3-8 were updated by DTE letter NRC-15-0068 dated June 26, 2015. The EAF methodology was discussed in the response to RAI Set 37 which was provided in DTE letter NRC-15-0089 dated September 24, 2015. The response to Set 37 discussed DTE's plans to re-evaluate EAF for certain component locations in future analyses. Some of those revised analyses have now been completed. For the purpose of responding to parts (a) and (b) of this RAI, the component to NRC-16-0003 Page 3 locations will be categorized into the response for parts (a) and (b) based on the analysis that was in effect at the time of the September 2015 response. Any changes to the evaluations since that time will be addressed in the discussion of the relevant component locations.

a) The following locations used an average temperature to calculate the Fe1 factor at the time of the September 2015 RAI response: SLC piping inside containment, feedwater nozzles, core AP nozzle, CRD nozzles, CRD assembly main flange, and RR pump cooler.

The requested information (i, ii, and iii) is provided for each component location below.

SLC piping inside containment:

i. The SLC piping inside containment material is stainless steel.

ii. Most of the transients and load pairs used the maximum service temperature at uprate conditions for the piping of 552.1°F. The startup and shutdown load set utilized an average service temperature. Previously, the average temperature was determined by the average of the maximum and minimum service temperatures.

The minimum service temperature of 100°F was below the threshold temperature of 150°C / 302F. Therefore, the calculation for that load set has been revised. The revised calculation (and its result) is described in the response to part (c) below.

iii. The startup and shutdown load set pair associated with this average temperature meets the definition of "simple" because, as defined in the design fatigue calculation, it has a constant strain rate and a linear temperature response.

Therefore, it is acceptable to use an average temperature.

Feedwater nozzles:

i. As indicated in LRA Table 4.3-8, the NUREG/CR-6260 generic location of feedwater (FW) nozzles consists of several specific Fermi 2 locations. The FW nozzle safe end has a carbon steel (CS) portion and a stainless steel (SS) portion.

These two portions are analyzed separately as shown in LRA Table 4.3-8. The nozzle-vessel intersection material is low alloy steel (LAS).

ii. For the FW nozzle safe end CS portion and the LAS nozzle-vessel intersection, the maximum design temperature of 575°F was used, not average temperature. For the FW nozzle safe end SS portion, the calculations previously used an average temperature. The average temperature was determined by the average of the maximum and minimum service temperatures for each transient, with the minimum service temperature taken at the threshold temperature of 302°F if it was below the threshold. Also, if the maximum temperature was below the threshold value, the threshold value was used.

iii. The average temperatures determined for the transients were used to determine the average temperature for each load pair at the FW nozzle SS safe end location. The resulting calculated CUFeI using this method was greater than 6 so additional action was needed as previously addressed in the footnote to LRA Table 4.3-8.

Upon further consideration, not all transients can be considered "simple" transients.

Therefore, the calculation for the FW nozzle SS safe end location has been revised to more conservatively use the design temperature of 575°F for all analyzed load to NRC-16-0003 Page 4 sets. The revised calculation (and its result) is described in the response to part (c) below.

Core AP nozzle:

i. The limiting core AP nozzle location material is a nickel-based alloy (NBA).

ii. The core AP nozzle calculation previously used average temperature. The average temperature was determined by the average of the maximum temperature at uprate conditions and the threshold temperature.

iii. As discussed in the response to RAI Set 37 which was provided in DTE letter NRC-15-0089, the fatigue calculation for the core AP nozzle conservatively used bundled transients. The fatigue calculation conservatively used the highest calculated alternating stress. The dominant transient of the lumped transient count was the startup/shutdown transient, which was considered a "simple" transient.

to The projected CUFe~ exceeded 1.0, so as discussed in the previous RAI response RAI Set 37, the transients have been separated. The revised calculation (and its result) is described in the response to part (c) below and conservatively uses the design temperature of 575°F.

CRD nozzles:

i. The limiting CRD nozzle location material is a nickel-based alloy (NBA).

ii. The CRD nozzle calculation previously used average temperature. The average temperature was determined by the average of the maximum and minimum temperatures at uprate conditions. If the average temperature was below the threshold temperature, the average temperature was increased to the threshold temperature. When the calculation was revised, as planned per the discussion in response to RAI Set 37 which was provided in DTE letter NRC-15-0089, the design temperature was used. The revised calculation (and its result) is described in the response to part (c) below.

iii. As discussed in the response to RAI Set 37, the fatigue calculation for the CRD nozzle conservatively used bundled transients. The fatigue calculation conservatively used the highest calculated alternating stress. The projected CUFe exceeded 1.0, so as discussed in the previous RAI response, the transients have been separated. The revised calculation (and its result) is described in the response to part (c) below and conservatively uses the design temperature of 575°F.

CRD assembly main flange:

i. The CRD assembly main flange material is stainless steel.

ii. The analysis for the CRD assembly main flange utilized an average temperature.

Previously, the average temperature was determined by the average of the maximum and minimum temperatures at power uprate. The minimum temperature used was below the threshold temperature. Therefore, the calculation for that load set has been revised. The revised calculation (and its result) is described in the response to part (c) below.

to NRC-16-0003 Page 5 iii. The dominant transient is the startup transient where temperature varies linearly and strain rate is constant. In the revised calculation described in the response to part (c), the startup transient is calculated with average temperature, and the remaining transients are calculated with maximum operating temperature at power uprate of 556.5°F.

RR pump cooler:

i. The RR pump cooler material is stainless steel.

ii. The RR pump cooler calculation previously used average temperature. Previously, the average temperature was determined by the average of the maximum and the threshold temperatures.

iii. The transient associated with this average temperature is the seal injection on-off-on transient. Originally, it was considered a "simple" transient. Upon further consideration, the transient does not meet the criteria for "simple" transients.

Therefore, the calculation has been revised to conservatively use the design temperature of 575°F. The revised calculation (and its result) is described in the response to part (c) below.

b) For the locations not identified in (a) listed in LRA Table 4.3-8, the material of construction and a description of what temperature was used to calculate Fen is provided in the table below.

Location Material Temperature Used Reactor vessel shell LAS Design temperature 575°F RR inlet nozzle liner SS Not part of reactor coolant pressure boundary, so not calculated RR inlet nozzle safe end SS Design temperature 575°F RR inlet nozzle nozzle-vessel LAS Design temperature 575F intersection RR outlet nozzle nozzle-vessel LAS Design temperature 575°F intersection RR outlet nozzle safe end SS Design temperature 575°F RR outlet nozzle LAS Bounded by nozzle-vessel intersection, so not calculated RR piping SS Design temperature 575°F RR valve SS Bounded by adjacent piping, so not calculated Core spray nozzle-vessel LAS Design temperature 575F intersection Core spray nozzle safe end NBA Design temperature 575°F Core spray valve CS Design temperature 575°F Core spray piping CS Design temperature 575F to NRC-16-0003 Page 6 Location' Material Temperature Used RHR valve CS Design temperature 575°F RHR piping CS Design temperature 575°F FW valve CS Design temperature 575°F FW piping CS Design temperature 575°F RWCU piping CS Design temperature 575°F RWCU valve CS Design temperature 575°F HPCI valve CS Design temperature 575°F Containment penetration X-13A/B, CS Design temperature 575°F RHR return weld 3 Containment penetration X-12 body, CS Design temperature 575°F RHR supply 3 Condensing chamber SS Maximum power uprate operating temperature 552.1 F (further analysis being performed since CUFen exceeds 1.0 as discussed in response to RAI Set 37)

1. Location names are based on "Fermi 2 Location" in LRA Table 4.3-8
2. CS=carbon steel, LAS=low alloy steel, NBA=nickel-based alloy, SS=stainless steel
3. Only the containment penetrations with the highest CUFe1 for the weld and the body were listed in LRA Table 4.3-8. EAF calculations were performed for several other penetrations where the weld and/or body were not considered bounded by the attached piping analysis. These locations were the feedwater penetration weld and body, RHR return penetration body, RWCU penetration body, and core spray penetration body. The design temperature of 575°F was used for calculations for the carbon steel feedwater penetration weld and body, the carbon steel RHR return penetration body, and the carbon steel RWCU penetration body. The core spray containment penetration X-16A/B carbon steel body was calculated using a maximum conservative operating temperature of 392°F since this penetration does not contain high temperature fluid.

c) The calculations for the following locations have been revised since the September 2015 RAI response: SLC piping inside containment, feedwater nozzles, core AP nozzle, CRD nozzles, CRD assembly main flange, and RR pump cooler. A discussion of the revised calculations is provided for each component location below.

SLC piping inside containment:

The startup and shutdown load set that utilizes an average temperature was revised to use an average temperature that is determined by the average of the maximum service temperature at power uprate and threshold temperature since the minimum temperature is below the threshold. This load set pair meets the definition of "simple" above because, as defined in the design fatigue calculation, it has a constant strain rate and a linear temperature response. The resultant average temperature is higher than used previously. The resultant CUFe is 0.658 which is larger than the value of 0.503 previously provided in DTE letter NRC-15-0068 dated June 26, 2015.

Although the CUFen value increased, it is still below 0.8. Therefore, this location is not a sentinel location, which is consistent with its previous evaluation.

to NRC-16-0003 Page 7 Feedwater nozzles:

The calculation for the FW nozzle safe end SS portion that used average temperature was revised to use the maximum design temperature of 575°F. In addition to the revision to the temperature value, the calculations for all three of the FW nozzle locations were revised to treat the hot standby transient and RCIC injection as unique transients. This revision was discussed as a future action in the September 2015 response and has now been completed. The resultant CUFe1 values for the safe end CS portion, safe end SS portion, and nozzle-vessel intersection are 0.083, 5.55, and 0.113, respectively. These values are all smaller than the respective values of 0.165, 6.37, and 0.115 that were previously provided in DTE letter NRC-15-0068 dated June 26, 2015. Although the change in temperature methodology for the SS nozzle safe end location increased the CUFe1 value compared to using an average temperature, the values did decrease overall due to the larger effect of treating the hot standby transient and RCIC injection as unique transients. The FW nozzles are NUREG/CR-6260 locations and will be retained as sentinel locations, consistent with the previous evaluation. Since CUFeI is still greater than 1.0 even after further evaluation, it is expected that stress-based fatigue monitoring will be required for the FW nozzles. Stress-based fatigue monitoring was discussed in DTE letter NRC-15-0068 dated June 26, 2015.

Core AP nozzle:

The core AP nozzle calculation that used an average temperature was revised to use the maximum design temperature of 575°F. In addition to the revision to the temperature value, the calculation was revised to unbundle the transients. This revision was discussed as a future action in the September 2015 response and has now been completed. The resultant CUFe1 value is 0.929. This value is smaller than the value of 1.48 that was previously provided in DTE letter NRC-15-0068 dated June 26, 2015. Although the change in temperature methodology increased the CUFen value compared to using an average temperature, the value did decrease overall due to the larger effect of unbundling the transients. While the CUFe value is now less than 1.0, it is still greater than 0.8. Therefore, this location will be retained as a sentinel location, consistent with the previous evaluation.

CRD nozzles:

The CRD nozzles calculation that used an average temperature was revised to use the maximum design temperature of 575°F. In addition to the revision to the temperature value, the calculation was revised to unbundle the transients. This revision was discussed as a future action in the September 2015 response and has now been completed. The resultant CUFen value is 0.191. This value is smaller than the value of 1.28 that was previously provided in DTE letter NRC-15-0068 dated June 26, 2015. Although the change in temperature methodology increased the CUFen value compared to using an average temperature, the value did decrease overall due to the larger effect of unbundling the transients. While the CUFen value is now less than 1.0 to NRC-16-0003 Page 8 and also less than 0.8, this location is a NUREG/CR-6260 location. Therefore, this location will be retained as a sentinel location, consistent with the previous evaluation.

CRD assembly main flange:

The calculation that utilized an average temperature was revised to use the maximum service temperature at power uprate of 556.5°F for all of the transients but one and an average temperature determined by the average of the maximum service temperature and threshold temperature since the minimum temperature is below the threshold for the startup transient. The resultant average temperature is higher than used previously. The resultant CUFei is 0.725 which is larger than the value of 0.329 previously provided in DTE letter NRC-15-0068 dated June 26, 2015. Although the CUFen value increased, it is still below 0.8. Therefore, this location is not a sentinel location, which is consistent with the previous evaluation.

RR pump cooler:

The calculation was revised to use the design temperature of 575°F. The calculation was also revised to appropriately account for the cooler being replaced in 1998, and so it will be in operation for a period of 47 years by 2045 when the plant reaches the end of the 60 year license renewal period. The postulated cycles were projected based on the 14 year period from cooler replacement in fall 1998 through 12/31/2012.

The resultant CUFe1 is 0.578 which is similar to the value of 0.581 previously provided in DTE letter NRC-15-0068 dated June 26, 2015. However, this location was selected as a sentinel location as indicated in DTE letter NRC-15-0068 dated June 26, 2015. Since it has a unique thermal transient, this location is retained as a sentinel location, which is consistent with its previous evaluation.

d) Based on the revised calculations described in the response to part (c) above, the revised Fen factors and CUFen values are determined in a manner consistent with the guidance of NUREG/CR-6909. NUREG/CR-6909 addresses the use of service temperature. In most cases, the design temperature, which is more conservative than service temperature, is used in the calculations. In others, the maximum operating or transient temperature is used, which corresponds to the service temperature. In two cases, an average temperature is used for transients with a constant strain rate and a linear temperature response, and the average temperature is determined by using the maximum service temperature at uprate conditions and threshold temperature (since the minimum temperature is below the threshold). As discussed in the response to part (b) above, the analysis for the condensing chamber is being revised, but the revised analysis will also determine the Fen factors and CUFe values in a manner consistent with the guidance of NUREG/CR-6909.

LRA Revisions:

LRA Table 4.3-8 is revised as shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. Note that previous changes to this same LRA table

Enclosure 1 to NRC-16-0003 Page 9 made in previous letters are not shown in underline or strike-through such that only the new changes due to RAI 4.3.3-3a are shown as revisions.

Note that one additional change was made to Table 4.3-8. Containment penetration X-13A/B, RHR return weld, had been incorrectly noted as a sentinel location. While the projected CUFen is higher than for the RHR return piping, the RHR containment penetration return weld was conservatively analyzed by bundling transients and applying the highest alternating stress to the total number of transient cycles. By comparison, the highest alternating stress for the RHR return piping is higher than the alternating stress used for the containment penetration weld. If the total number of transients were to be bundled for the RHR return piping and its highest alternating stress used to analyze both locations on a common basis, the RHR return piping would have larger usage than the penetration. Therefore, the RHR return piping containment penetration weld is not a sentinel location. The RHR return piping, which is also a NUREG/CR-6260 location, is a sentinel location. Therefore, the Fermi 2 location description for containment penetrations in LRA Table 4.3-8 is revised for clarification.

to NRC-16-0003 Page 10 Table 4.3-8 EAF Screening of Fermi 2 Locations NUREGICR-6260 Fermi 2 Generic Location Location Material' CUF Fen EAF CUF 1 Reactor vessel shell Reactor vessel LAS 0.021 7.21 0.153 and lower head shell 2 1 Reactor vessel shell CRD nozzle 2 NBA 0.052 3.65 0.191 and lower head -630 4--

3-453 2 Reactor vessel FW nozzle safe CS 0.043 1.88 0.081 0-464 feedwater nozzle end (CS 9087 plus 0.0014 portion) 2 rapid cycling =

0.083 0-465 2 Reactor vessel FW nozzle safe SS 0.495 11_.2 5.544 6--364 feedwater nozzle end (SS 09664 6-- plus 0.0014 portion) 2 g3 rapid cycling =

5.554 67374 2 Reactor vessel Nozzle-vessel LAS 0.01_52 6.10 0.0925 00942 feedwater nozzle intersection2 90454 plus 0.0206 rapid cycling =

0.113 0-445 3 Reactor recirculation RR inlet nozzle SS Note 5 piping (including inlet liner and outlet nozzles) 3 Reactor recirculation RR inlet nozzle SS 0.006 11.20 0.071 piping (including inlet safe end 2 and outlet nozzles) 3 Reactor recirculation RR inlet nozzle LAS 0.023 4.06 0.095 piping (including inlet nozzle-vessel and outlet nozzles) intersection 2 3 Reactor recirculation RR outlet LAS 0.112 4.06 0.453 piping (including inlet nozzle nozzle-and outlet nozzles) vessel intersection 2 3 Reactor recirculation RR outlet SS 0.021 11.2 0.240 piping (including inlet nozzle safe and outlet nozzles) end 2 to NRC-16-0003 Page 11 Table 4.3-8 EAF Screening of Fermi 2 Locations NUREG/CR-6260 Fermi 2 Generic Location Location Material' CUF Fen EAF CUF RR outlet LAS Bounded by nozzle nozzle-vessel intersection 3 Reactor recirculation RR piping 2 SS 0.018 11.2 0.199 piping (including inlet and outlet nozzles) 3 Reactor recirculation RR valve SS Bounded by piping (including inlet adjacent piping and outlet nozzles) 4 Core spray line reactor Core spray LAS 0.048 5.31 0.254 vessel nozzle and nozzle -vessel associated Class 1 intersection 2 piping 4 Core spray line reactor Core spray NBA 0.075 3.65 0.273 vessel nozzle and nozzle safe associated Class 1 end 2 piping 4 Core spray line reactor Core spray CS 0.0152 4.95 0.075 vessel nozzle and valve associated Class 1 piping 4 Core spray line reactor Core spray CS 0.0091 4.95 0.045 vessel nozzle and piping 2 associated Class 1 piping 5 Residual heat removal RHR valve CS 0.063 3.78 0.239 (RHR) nozzles and associated Class 1 piping 5 Residual heat removal RHR piping 2 CS 0.048 3.78 0.180 (RHR) nozzles and associated Class 1 piping to NRC-16-0003 Page 12 Table 4.3-8 EAF Screening of Fermi 2 Locations NUREG/CR-6260 Fermi 2 Generic Location Location Material' CUF Fen EAF CUF FW valve CS 0.063 3.78 0.239 6 Feedwater line Class 1 piping Feedwater line Class 1 FW piping 2 CS 0.0003 3.78 0.0012 6

piping

-- -- RWCU piping CS 0.014 3.78 0.052

-- -- RWCU valve CS 0.018 3.78 0.069

-- -- HPCI valve CS 0.053 1.88 0.099

-- -- SLCS piping SS 0.108 4.50 0.658 242 - 0.593 9.733

-- -- Containment penetrations:

Highest weld: CS 0.086 3.78 0.326 X-13A/B, RHR return weld2 Highest body CS 0.181 3.78 0.685 en-,entinel:

X-12 body, RHR supply

-- -- Condensing SS 0.385 9.73 3.754 chamber 2

-- -- Core AP NBA 0.255 3.65 0.929 nozzle 2 930 2-55 4-484

-- -- CRD assembly, SS 0.134 4.56 - 0.725 main flange 13 029 2-45

Enclosure 1 to NRC-16-0003 Page 13 Table 4.3-8 EAF Screening of Fermi 2 Locations NUREG/CR-6260 Fermi 2 Generic Location Location Material' CUF Fen EAF CUF

-- -- RR pump SS 0.052 11.2 0.578 cooler 2 0-4-50 &86 9-84

1. CS: carbon steel. LAS: low alloy steel. NBA: nickel-based alloy. SS: stainless steel.
2. This component is a sentinel location.
3. Fen was calculated for each transient or load pair based on average temperature or maximum service temperature at uprate conditions.
4. CUFen is above 1, so additional action will be needed, e.g. more detailed analysis or stress based monitoring.
5. Not part of reactor coolant pressure boundary, so no EAF evaluation is needed.