Text

License Renewal Application Response to LR-ISG-2015-01
	ML16104A188
Person / Time
Site:	Fermi
Issue date:	04/12/2016
From:	Polson K; DTE Electric Company, DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	LR-ISG-2015-01, NRC-16-0027
	Download: ML16104A188 (11)
	v • d • e

Keith J. Poison Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.4172 Email: polsonk@dteenergy.com

. DTE Energy-April 12, 2016 10 CFR 54 NRC-16-0027 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) License Renewal Interim Staff Guidance, LR-ISG-2015-01, "Changes to Buried and Underground Piping and Tank Recommendations,"

dated January 28, 2016 (ML15308A021)

Subject:

Fermi 2 License Renewal Application Response to LR-ISG-2015-01 In Reference 2, DTE Electric Company (DTE) submitted an application for a renewed operating license for Fermi 2 pursuant to 10 CFR 51 and 10 CFR 54. In Reference 3, the NRC staff issued LR-ISG-2015-01 regarding buried and underground piping and tanks. Enclosure 1 to this letter provides a summary review of LR-ISG-2015-01. to this letter provides the License Renewal Application (LRA) revisions developed to address LR-ISG-2015-01. The revised sections of the LRA include Section 2.1.3, Appendix A, Appendix B, and associated tables.

No new commitments are being made in this submittal. However, a revision is being made to a commitment previously identified in the LRA. The revised commitment is to change a table number (based on the corresponding change in LR-ISG-2015-01) for the Buried and Underground Piping Program as indicated in LRA Table A.4 Item 4 in .

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

USNRC NRC-16-0027 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on April 12, 2016 Keith J. Polson Site Vice President Nuclear Generation

Enclosures:

1. Fermi 2 LRA Supplement for LR-ISG-2015 General Description

2. Fermi 2 LRA Supplement for LR-ISG-2015 LRA Revisions cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschlamichigan.gov)

Enclosure 1 to NRC-16-0027 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Fermi 2 LRA Supplement for LR-ISG-2015 General Description to NRC-16-0027 Page 1

Background

On January 28, 2016, the NRC issued License Renewal Interim Staff Guidance (LR-ISG) 2015-01 Changes to Buried Piping and Underground Tank Recommendations. The aging management program XI.M41, Buried and Underground Piping and Tanks in LR-ISG-2015-01 supersedes the version in LR-ISG-2011-03, which had been addressed in the Fermi 2 License Renewal Application (LRA).

A review has been completed, and revised LRA sections have been developed to reflect the guidance of LR-ISG-2015-01. The LRA revisions are provided in Enclosure 2.

The Fermi 2 Buried and Underground Piping Program will be consistent with LR-ISG-2015-01 with one exception. DTE identified two stainless steel pipes between the Condensate Storage Tank vault and the Turbine Building that may not have been coated. Per Table XI.M41-1 in LR-ISG-2015-01, footnote a, applicants are to provide justification when buried stainless steel pipe is not coated. Since documentation does not specifically identify these buried pipes are coated, DTE will assume they are not coated unless or until they are demonstrated to be coated.

Program Exception NUREG-1801, Table XI.M41-1, as provided by LR-ISG-2015-01, includes the preventive action of coating buried stainless steel pipes. There are two stainless steel pipes buried between the Condensate Storage Tank vault and the Turbine Building, which may not be coated.

NUREG-1801, Table XI.M41-2, as provided by LR-ISG-2015-01, recommends periodic inspections of buried piping and underground tanks. Fermi 2 Buried and Underground Piping Program will manage the effects of aging on the external surfaces of buried and underground piping within the scope of license renewal. To justify the exception of the stainless steel pipe possibly not being coated, an inspection will be performed of both of these buried stainless steel pipes that are routed between the CST and the Turbine Building every 10 years, commencing in the 10 years prior to the period of extended operation, rather than performing one inspection of stainless steel buried piping every 10 years per NUREG-1801, Table XI.M41-2. Justification for the exception is provided in LRA Section B.1.4 markup contained in Enclosure 2.

LRA Revisions LRA Sections 2.3.1, Appendix A, Appendix B, and associated tables are revised as shown in . Additions are shown in underline and deletions are shown in strike-through. Note that previous changes made to these same LRA sections made in previous letters are not shown in underline or strike-through such that only the new changes due to this letter are shown as revisions.

Enclosure 2 to NRC-16-0027 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Fermi 2 LRA Supplement for LR-ISG-2015 LRA Revisions to NRC-16-0027 Page 1 2.1.3 Interim Staff Guidance Discussion LR-ISG-2011-03 Generic Aging Lessons Learned (GALL) Report Revision 2 [Aging Management Program] AMP XI.M41, "Buried and Underground Piping and Tanks" This ISG provides expanded guidance for managing the effects of aging of buried and underground piping and tanks within the scope of license renewal. This guidance is presented as revisions to NUREG-1800 (Ref 2.1-2) and NUREG-1801 (Ref. 2.1-3). The revised guidance has been considered in the integrated plant assessment and is reflected in the aging management results presented in Section 3. and the The aging management program description presented in Appendix B (Section B.1.4) guidance was superseded in LR-ISG-2015-01.

LR-ISG-2011-05 Ongoing Review of Operating Experience LR-ISG-2012-01 Wall Thinning due to Erosion Mechanisms LR-ISG-2012-02 Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation LR-ISG-2013-01 Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In Scope Piping, Piping Components, Heat Exchangers, and Tanks LR-ISG-2015-01 Changes to Buried and Underground Piping and Tank Recommendations This ISG provides revised guidance to managing aging effects associated with the external surfaces of buried and underground components. This revised guidance is reflected in the aging management program presented in Appendix A and Appendix B (Section B.1.4).

to NRC-16-0027 Page 2 A.1.4 Buried and Underground Piping Program The Buried and Underground Piping Program is a new program that will manage the effects of aging on the external surfaces of buried and underground piping components within the scope of license renewal. The program will manage aging effects of loss of material and cracking for the external surfaces of buried and underground piping fabricated of aluminum, carbon steel, gray cast iron, and stainless steel through preventive and mitigative measures (e.g., coatings, backfill quality, and cathodic protection) and periodic inspection activities during opportunistic or directed excavations. There are no underground or buried tanks for which aging effects would be managed by the Buried and Underground Piping Program. Fermi 2 utilizes a cathodic protection system. Fermi 2 has performed preliminary laboratory soil composition analyses on samples removed from the site to evaluate the potential corrosivity of the soil for use in life cycle management.

Soil testing will be conducted once in each ten-year period starting ten years prior to the period of extended operation, if a reduction in the number of inspections recommended in Table 4a XI.M41-2 of NUREG-1801, XI.M41, is taken based on a lack of soil corrosivity.

If the 100 mV criterion is applied for cathodic protection for specific piping When using the 100 mV, -750 mV or -650 mV polarization criteria as an alternative to the -850 mV criterion, for steel piping, electric resistance probes (ERPs) will be installed in select locations as determined by a Cathodic Protection Specialist. The ERPs will be made of the most anodic metal in the system to ensure adequate protection of the most anodic system metal. Concurrent with the ERPs, permanent reference cells and reference metal will be installed. Installation of the permanent reference cells at pipe depth and near the piping of interest will allow for an accurate measurement of pipe-to-soil potential, minimizing the influence of mixed metals. Where used, the electrical resistance probes will be uncoated and placed in the immediate vicinity of the buried piping it is representing. For each installation application, two probes will be installed; one connected to the cathodic protection system and one left unprotected. The test probe left unprotected (not connected to the pipe) will be free of the mixed metals influence.

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

to NRC-16-0027 Page 3 A.4 LICENSE RENEWAL COMMITMENT LIST Implementation No. Program or Activity Commitment Source Schedule 6 Buried and Implement new Buried and Underground Piping Program that will Prior to September A.1.4 Underground manage the effects of aging on the external surfaces of buried and 20, 2024, or the end Piping underground piping within the scope of license renewal. Soil testing will of the last refueling be conducted once in each ten-year period starting ten years prior to the outage prior to period of extended operation, if a reduction in the number of inspections March 20, 2025, recommended in Table 4A XI.M41-2 of NUREG 1801, XI.M41, is taken whichever is later.

based on a lack of soil corrosivity. Initial directed inspections and soil testing (if the reduction in inspections based on soil testing is taken) will be performed within the ten years prior to March 20, 2025.

to NRC-16-0027 Page 4 Table B-3 Fermi 2 Program Consistency with NUREG-1801 NUREG-1801 Comparison Consistent with Programs with NUREG- Programs with Exception to Plant-Program Name 1801 Enhancement NUREG-1801 Specific Buried and Underground Piping X X to NRC-16-0027 Page 5 B.1.4 BURIED AND UNDERGROUND PIPING Program Description The Buried and Underground Piping Program is a new program that will manage the effects of aging on the external surfaces of buried and underground piping within the scope of license renewal. The program will manage aging effects of loss of material and cracking for the external surfaces of buried and underground piping fabricated of aluminum, carbon steel, gray cast iron, and stainless steel through preventive and mitigative measures (e.g., coatings, backfill quality, and cathodic protection) and periodic inspection activities during opportunistic or directed excavations. There are no underground or buried tanks for which aging effects would be managed by the Buried and Underground Piping Program. Fermi 2 utilizes a cathodic protection system. Fermi 2 has performed preliminary laboratory soil composition analyses on samples removed from the site to evaluate the potential corrosivity of the soil for use in life cycle management.

Soil testing will be conducted once in each ten-year period starting ten years prior to the period of extended operation, if a reduction in the number of inspections recommended in Table 4a XI.M41-2 of NUREG-1801,Section XI.M41 is taken based on a lack of soil corrosivity.

If the 100 mV criterion is applied for cathodic protection for specific piping When using the 100 mV, -750 mV or -650 mV polarization criteria as an alternative to the -850 mV criterion, for steel piping, electric resistance probes (ERPs) will be installed in select locations as determined by a Cathodic Protection Specialist. The ERPs will be made of the most anodic metal in the system to ensure adequate protection of the most anodic system metal. Concurrent with the ERPs, permanent reference cells and reference metal will be installed. Installation of the permanent reference cells at pipe depth and near the piping of interest will allow for an accurate measurement of pipe-to-soil potential, minimizing the influence of mixed metals. Where used, the electrical resistance probes will be uncoated and placed in the immediate vicinity of the buried piping it is representing. For each installation application, two probes will be installed; one connected to the cathodic protection system and one left unprotected. The test probe left unprotected (not connected to the pipe) will be free of the mixed metals influence.

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

NUREG-1801 Consistency The Buried and Underground Piping Program will be consistent with the program described in NUREG-1801,Section XI.M41, Buried and Underground Piping and Tanks, as modified by LR-ISG-2011-03, Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program XI.M41, Buried and Underground Piping and Tanks., and as subsequently modified by LR-ISG-2015-01, Changes to Buried and Underground Piping and Tank Recommendations, with one exception.

to NRC-16-0027 Page 6 Exceptions to NUREG-1801 None The Buried and Underground Piping program has the following exception.

Element Affected Exception

2. Preventive Actions NUREG-1801, Table XI.M41-1 recommends that coatings be provided for buried stainless steel piping based on the environmental conditions (e.g.

stainless steel in chloride containing environments) and that justification be provided when coatings are not provided. There are two stainless steel pipes between the Condensate Storage Tank vault and the Turbine Building that may not have been coated.1 Exception Note

1. The two stainless steel pipes are not coated in the Condensate Storage Tank (CST) underground vault. Though the general specification requires coating, specific documentation on these pipes does not identify that they are coated, including whether the buried portions (i.e. outside the vault) are coated. To justify the exception of the stainless steel pipe possibly not being coated, an inspection will be performed of both of these stainless steel pipes that are routed between the CST and the Turbine Building every 10 years, commencing in the 10 years prior to the period of extended operation. This will result in two inspections being performed every 10 years rather than performing only one inspection of stainless steel buried piping every 10 years per NUREG-1801, Table XI.M41-2.

If during the first inspection, the stainless steel piping is determined to be coated, then future inspection will be at a rate of one inspection per 10 year interval, consistent with Table XI.M41-2 and therefore this exception would no longer be required. Fermi 2s groundwater monitoring program provides additional means of monitoring for degradation of piping in this area.

Enhancements None