NRC-19-0042, Responses to Requests for Additional Information Regarding Relief Requests for the Inservice Inspection Program Fourth Ten-year Interval

Responses to Requests for Additional Information Regarding Relief Requests for the Inservice Inspection Program Fourth Ten-year Interval

ML19162A314
Person / Time
Site:	Fermi
Issue date:	06/11/2019
From:	Fessler P DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-19-0042
Download: ML19162A314 (10)

Text

Paul Fessler Senior Vice President and Chief Nuclear Officer DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4153 Fax: 734.586.1431 Email: paul.fessler@dteenergy.com June 11, 2019 NRC-19-0042 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Responses to Requests for Additional Information Regarding Relief Requests for the Inservice Inspection Program Fourth Ten-year Interval

Reference:

1) DTE Electric Letter to NRC, Submittal of the Inservice Inspection /

Nondestructive Examination Program Relief Requests for the Fourth Ten-year Interval, NRC-19-0016, dated February 28, 2019 (ML19059A327)

In Reference 1, DTE Electric Company (DTE) submitted several relief requests under 10 CFR 50.55a(z) for the Inservice Inspection (ISI) / Nondestructive Examination (NDE) program at Fermi 2.

In an email from Ms. Sujata Goetz to Mr. Jason Haas dated May 15, 2019, the NRC sent DTE a request for additional information (RAI) regarding relief request RR-A37 of Reference 1. The response to the RAI for relief request RR-A37 is provided in Enclosure 1.

In a separate email from Ms. Sujata Goetz to Mr. Jason Haas dated May 15, 2019, the NRC sent DTE a RAI regarding relief request RR-A39 of Reference 1. The response to the RAI for relief request RR-A39 is provided in Enclosure 2.

No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Mr. Jason R.

Haas, Manager - Nuclear Licensing, at (734) 586-1769.

USNRC NRC-19-0042 Page 2 Sincerely Paul Fessler Senior Vice President and CNO

Enclosures:

1. Response to Request for Additional Information for Relief Request RR-A37

2. Response to Request for Additional Information for Relief Request RR-A39 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 (kindschl@michigan.gov)

Enclosure 1 to NRC-19-0042 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to Request for Additional Information for Relief Request RR-A37 to NRC-19-0042 Page 1 Response to Request for Additional Information for Relief Request RR-A37 By letter dated February 28, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19059A327), DTE Energy Company (the licensee) requested relief from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code for Fermi 2 Power Plant. The licensee proposed alternative, RR-A37, allows for examination of nozzle-to-vessel welds and inner radii in accordance with the requirements of ASME BPV Code Case N-702 in lieu of Table IWB-2500-1 during the fourth, fifth, and sixth inservice inspection (ISI) intervals at Fermi 2 Power Plant. The licensee proposed alternative also allows the licensee to perform a VT-1 (visual) examination in lieu of a UT (ultrasonic) examination for the inner radii in accordance with the requirements of ASME BPV Code Case N-648-1. Pursuant to Title 10 of the Code of Federal Regulations (10 CFR)

Part 50.55a(z)(1), the licensee requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is necessary to complete its review of the licensee proposed alternative. The NRC staffs request for additional information (RAI) is provided below.

RAI-1

Code Case N-648-1 was conditionally approved in Regulatory Guide (RG) 1.147, Revision 18, lnservice Inspection Code Case Acceptability,Section XI, Division 1, dated March 2017.

However, the licensee proposed alternative states that the VT-1 examination may be performed in accordance with a later approved revision of Code Case N-648 subject to the conditions of Regulatory Guide 1.147.

NRC staff has determined that the requirement in 10 CFR 50.55a(z) that proposed alternatives must be submitted and authorized prior to implementation, precludes the NRC from authorizing the use of a later approved revision of Code Case N-648-1. Therefore, the NRC requests that the licensee supplement the February 28, 2019, proposed alternative request licensee, either:

address only Revision 1 of Code Case N-648, or provide a basis by which the NRC could interpret the 10 CFR 50.55a(z) requirement must be submitted and authorized prior to implementation so as to permit the use of a later approved revision.

RESPONSE

10 CFR 50.55a(b)(5), Conditions on inservice inspection Code cases, states that Licensees may apply the ASME BPV Code Cases listed in NRC Regulatory Guide 1.147, as incorporated by reference in paragraph (a)(3)(ii) of this section, without prior NRC approval. 10 CFR 50.55a paragraph (a)(3)(ii) lists NRC Regulatory Guide (RG) 1.147, Revision 18, dated March 2017 as the version incorporated by reference. RG 1.147, Revision 18, lists Code Case N-648-1 as a conditionally acceptable Section XI code case in Table 2.

to NRC-19-0042 Page 2 The submittal of relief request RR-A37 stated that the VT-1 visual examination, if performed, will be in accordance with Code Case N-648-1 or a later approved revision subject to the conditions of Regulatory Guide 1.147. The intent of this sentence was to describe that Fermi 2 has the ability under the provisions of 10 CFR 50.55a(b)(5)(ii) to apply later versions of Code Case N-648-1 (or any Code Case) once they have been incorporated in Regulatory Guide 1.147.

The statement was not meant to imply or in any way credit future NRC approval of any later version of Code Case N-648-1 (or any Code Case).

To eliminate the potential for confusion over the later approved revision phrase, DTE is clarifying that VT-1 visual examination, if performed, will be in accordance with Code Case N-648-1, consistent with Table 2 in RG 1.147, Revision 18. This version of the Code Case is listed as Reference 4 in relief request RR-A37. DTE is not requesting NRC review and approval of relief request RR-A37 with any dependence on any future versions of Code Case N-648-1.

The impacted portions of relief request RR-A37 are discussed below.

The last paragraph of Section 5 (on page 6 of Enclosure 2 to NRC-19-0016) is revised as follows:

Additionally, Code Case N-702 permits a VT-1 examination to be used in lieu of the volumetric examination for the inner radii (i.e., Item No. B3.100, Nozzle Inside Radius Section). This VT-1 examination is outlined in Code Case N-648-1 (Reference 4).

Fermi 2 will perform either volumetric examination or VT-1 examination of the inner radius as required by Code Case N-702. The VT-1 visual examination, if performed, will be in accordance with Code Case N-648-1 or a later approved revision subject to the conditions of Regulatory Guide 1.147.

The second paragraph of Section 6 (on page 6 of Enclosure 2 to NRC-19-0016) is revised as follows:

In the event Fermi 2 elects to perform a VT-1 of the nozzle inner radii as permitted by Code Case N-702, the VT-1 will be performed in accordance with Code Case N-648-1 including the conditions contained in Regulatory Guide 1.147 or a later revision, as approved and subject to the condition(s) of Regulatory Guide 1.147. Fermi will not use the VT-1 examination option unless coverage greater than 90% of the exam surface area is demonstrated or visual exam surface area is demonstrated to be greater than achievable by volumetric exam.

Enclosure 2 to NRC-19-0042 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to Request for Additional Information for Relief Request RR-A39 to NRC-19-0042 Page 1 Response to Request for Additional Information for Relief Request RR-A39 By letter dated February 28, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19059A327), DTE Electric Company (DTE, the licensee), submitted a relief request, RR-A39, to apply alternative examination methods to certain American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, inservice inspection (ISI) requirements for Class 1 components at the Fermi 2.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.55a(z)(1), the licensee requested to use certain Boiling Water Reactor Vessel and Internals Project (BWRVIP) inspection and evaluation (l&E) guidelines, in lieu of specific ASME Code,Section XI, inspection requirements (i.e., vessel interior, interior attachments within beltline region, interior attachments beyond beltline region, and core support structure), on the basis that the alternative provides an acceptable level of quality and safety.

The staff requires additional information to complete its review of the licensees request, as detailed below.

RAI-1

The submittal refers to both BWRVIP-48-Revision 1 and BWRVIP-48-A. BWRVIP-48, Revision 1 does not appear on EPRIs web site, or in the NRCs ADAMS. The License Renewal Application for Fermi 2 referenced BWRVIP-48-A.

Please clarify whether the examinations of the interior attachments will be conducted in accordance with BWRVIP-48-A or BWRVIP-48, Revision 1. If conducted to BWRVIP-48, Revision 1, describe the differences in examination requirements between BWRVIP-48-A and BWRVIP-48, Revision 1, for the components for which this guideline is being credited. If BWRVIP-48-A is the correct reference, please amend the submittal to reference BWRVIP-48-A only.

RESPONSE

BWRVIP-48, Revision 1, Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines, is currently under BWRVIP Assessment Committee and Research Integration Committee review. BWRVIP-48, Revision 1 has not yet been made available to the NRC.

BWRVIP-48, Revision 1 was included in relief request RR-A39 for the fourth interval based on its anticipated issuance prior to its required usage for examinations at Fermi 2. The change revises the reinspection requirement for the core spray piping bracket-to-vessel pads from EVT-1 of 100% of welds and heat-affected zones every 4 cycles to EVT-1 of 100% of welds and heat-affected zones every 10 years to align BWRVIP-48 with the inspection guidance contained in BWRVIP-18, BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines, Revision 2-A, for which the NRC has already approved that same inspection schedule. Thus, no new examination guidance is contained in BWRVIP-48, Revision 1; this is an administrative change to NRC-19-0042 Page 2 to align with the inspection schedule with newer NRC-approved guidance for the same component.

However, since BWRVIP-48, Revision 1 is not currently available to the NRC, DTE is clarifying that BWRVIP-48-A will be utilized for examinations of interior attachments. DTE is not requesting NRC review and approval of relief request RR-A39 with any dependence on any future versions of BWRVIP-48, including Revision 1. The impacted portions of relief request RR-A39 are discussed below.

A row in the table in Section 5 (on page 3 of Enclosure 3 to NRC-19-0016) is revised as follows:

BWRVIP Guidelines Used for Section XI Code Examinations (Part of this Request)

BWRVIP-47-A BWR Lower Plenum Inspection and Flaw Evaluation Guidelines BWRVIP-48-AR1(2) Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines BWRVIP-49-A Instrument Penetration Inspection and Flaw Evaluation Guidelines Several rows in Table 1 (on page 10 of Enclosure 3 to NRC-19-0016) are revised as shown on page 4 of this RAI response.

The header row of Table 2 (on page 12 of Enclosure 3 to NRC-19-0016) is revised as follows:

Vessel Attachment Description Weld Filler Inspection Performed to Results (2)

Welds Material date Code B-N-2 /

(Weld No.s) BWRVIP-48-AR1 and -38 (1)

The beginning of the second paragraph of Section 1 of Attachment 1 (on page 13 of Enclosure 3 to NRC-19-0016) is revised as follows:

Portions of the various examinations required by the applicable BWRVIP Guidelines listed in this request require entry to accessible areas of the reactor vessel during each refueling outage. Examination of Core Spray Piping and Spargers (BWRVIP-18-A-R2),

Top Guide (BWRVIP-26-A), Jet Pump Welds and Components (BWRVIP-41-R3),

Interior Attachments (BWRVIP-48-AR1), Core Shroud Welds (BWRVIP-76-R1-A),

Shroud Support (BWRVIP-38) and Lower Plenum Components (BWRVIP-47-A) provides such access.

The subsection header in Section 2 of Attachment 1 (on page 14 of Enclosure 3 to NRC-19-0016) is revised as follows:

Comparison to BWRVIP Requirements - Jet Pump Riser Braces (BWRVIP-41-R3) and BWRVIP-48-AR1) to NRC-19-0042 Page 3 The third bulleted item in Section 2 of Attachment 1 (on page 14 of Enclosure 3 to NRC-19-0016) is revised as follows:

BWRVIP-48-AR1 specifically defines the susceptible regions of the attachment that are to be examined The second paragraph below the bulleted list in Section 2 of Attachment 1 (on page 14 of Enclosure 3 to NRC-19-0016) is revised as follows:

The ASME Code Section XI, 2013 Edition, VT-1 visual examination method requires that a letter character with a height of 0.044 inches can be read. The BWRVIP EVT-1 visual examination method requires the same 0.044-inch resolution on the examination surface and additionally the performance of a cleaning assessment and cleaning as necessary. While the jet pump riser brace configuration varies depending on the vessel manufacturer, BWRVIP-48-AR1 includes diagrams for each configuration and prescribes examination for each configuration including Fermi 2 (Combustion Engineering).

The first paragraph in Section 3 of Attachment 1 (on page 15 of Enclosure 3 to NRC-19-0016) is revised as follows:

The ASME Code Section XI requires a VT-3 examination of accessible reactor interior surface attachment welds beyond the beltline each 10-year interval. In the boiling water reactor, this includes the core spray piping primary and supplemental support bracket welds-to-vessel wall, the upper surveillance specimen support bracket welds-to-vessel wall, the feedwater sparger support bracket welds-to-reactor vessel wall, the steam dryer support and hold down bracket welds-to-reactor vessel wall, the guide rod support bracket weld-to-reactor vessel wall, the shroud support plate-to-vessel wall, and shroud support gussets. BWRVIP-48-AR1 requires as a minimum the same VT-3 examination method as the Code for some of the interior attachment welds beyond the beltline region, and in some cases specifies an enhanced visual examination technique EVT-1 for these welds.

The subsection header in Section 3 of Attachment 1 (on page 15 of Enclosure 3 to NRC-19-0016) is revised as follows:

Comparison to BWRVIP Requirements - Core Spray Piping Bracket Welds (BWRVIP-48-AR1)

The second bulleted item in Section 3 of Attachment 1 (on page 15 of Enclosure 3 to NRC-19-0016) is revised as follows:

The BWRVIP examination requirement is an EVT-1 inspection of 100% of the primary and supplemental core spray piping bracket to vessel ID attachment welds and heat-affected zones on both the vessel and bracket sides of the welds every 4 refueling cycles 10 years. The BWRVIP examination method EVT-1 has superior flaw detection and sizing capability, the examination frequency is greater than the Code requirements, and the same flaw evaluation criteria are used to NRC-19-0042 Page 4 ASME Item ASME Applicable BWRVI ASME ASME BWRVIP BWRVIP No. Table Component Exam BWRVIP P Exam Exam Scope Frequency Exam Scope Frequency IWB-2500-1 Type Document Type B13.20 Interior Attachments within Accessible VT-1 Each 10- BWRVIP-48-A Riser Brace EVT-1 25% during each Beltline - Riser Braces Welds year R1, Table 3-2 Attachment subsequent 6 years Interval Lower Surveillance BWRVIP-48-A Bracket VT-1 Each 10-Year Specimen Holder Brackets R1, Table 3-2 Attachment Interval B13.30 Interior Attachments Accessible VT-3 Each 10- BWRVIP-48-A Bracket VT-3 Each 10-Year beyond Beltline - Steam Welds year R1, Table 3-2 Attachment Interval Dryer Hold-down Brackets interval Guide Rod Brackets BWRVIP-48-A Bracket VT-3 Each 10-Year R1, Table 3-2 Attachment Interval Steam Dryer Support BWRVIP-48-A Bracket EVT-1 Each 10-Year Brackets R1, Table 3-2 Attachment Interval Feedwater Sparger BWRVIP-48-A Bracket EVT-1 Each 10-Year Brackets R1, Table 3-2 Attachment Interval Core Spray Piping Brackets BWRVIP-48-A Bracket EVT-1 Every 4 Refuel R1, Table 3-2 Attachment Cycles Each 10-Year Interval Upper Surveillance BWRVIP-48-A Bracket VT-3 Each 10-Year Specimen Holder Brackets R1, Table 3-2 Attachment Interval Shroud Support BWRVIP-38, Weld H-9 EVT-1 or Maximum of 6 3.1.3.2, Figures UT years for EVT-1, (Weld H9) 3-2 and 3-5 Maximum of 10 years for UT