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=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 27, 2015
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 27, 2015  


LICENSEE: DTE Electric Company   FACILITY: Fermi 2  
LICENSEE: DTE Electric Company FACILITY: Fermi 2  


==SUBJECT:==
==SUBJECT:==
SUMMARY OF TELEPHONE CONFERENCE CALL HELD ON MARCH 16, 2015, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION, SET 27 PERTAINING TO THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)
SUMMARY OF TELEPHONE CONFERENCE CALL HELD ON MARCH 16, 2015, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION, SET 27 PERTAINING TO THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)  
The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company (DTE or the applicant) held a telephone conference call on March 16, 2015, to discuss and clarify the staff's draft requests for additional information (DRAIs) B.1.45-1, B.1.45-2, and B.1.45-3 concerning the Fermi 2 license renewal application. The telephone conference call was useful in clarifying the intent of the staff's DRAIs.
 
provides a listing of the participants and Enclosure 2 contains a listing of the DRAIs discussed with the applicant, including a brief description on the status of the items.
The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company (DTE or the applicant) held a telephone conference call on March 16, 2015, to discuss and clarify the staff's draft requests for additional information (DRAIs) B.1.45-1, B.1.45-2, and B.1.45-3 concerning the Fermi 2 license renewal application. The telephone conference call was useful in clarifying the intent of the staff's DRAIs.  
 
provides a listing of the participants and Enclosure 2 contains a listing of the DRAIs discussed with the applicant, including a brief description on the status of the items.  
 
The applicant had an opportunity to comment on this summary.  
The applicant had an opportunity to comment on this summary.  


       /RA/  Daneira Meléndez-Colón, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-341  
       /RA/  Daneira Meléndez-Colón, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-341  


==Enclosures:==
==Enclosures:==
: 1. List of Participants 2. Summary of Telephone Conference Call
: 1. List of Participants 2. Summary of Telephone Conference Call  


cc w/encls:  Listserv  
cc w/encls:  Listserv  


April 27, 2015 LICENSEE: DTE Electric Company FACILITY: Fermi 2  
April 27, 2015  
 
LICENSEE: DTE Electric Company  
 
FACILITY: Fermi 2  


==SUBJECT:==
==SUBJECT:==
SUMMARY OF TELEPHONE CONFERENCE CALL HELD ON MARCH 16, 2015, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION, SET 27 PERTAINING TO THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)
SUMMARY OF TELEPHONE CONFERENCE CALL HELD ON MARCH 16, 2015, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION, SET 27 PERTAINING TO THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)  
The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company (DTE or the applicant) held a telephone conference call on March 16, 2015, to discuss and clarify the staff's draft requests for additional information (DRAIs) B.1.45-1, B.1.45-2, and B.1.45-3 concerning the Fermi 2 license renewal application. The telephone conference call was useful in clarifying the intent of the staff's DRAIs.
 
The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company (DTE or the applicant) held a telephone conference call on March 16, 2015, to discuss and clarify the staff's draft requests for additional information (DRAIs) B.1.45-1, B.1.45-2, and B.1.45-3 concerning the Fermi 2 license renewal application. The telephone conference call was useful in clarifying the intent of the staff's DRAIs.  
 
Enclosure 1 provides a listing of the participants and Enclosure 2 contains a listing of the DRAIs discussed with the applicant, including a brief description on the status of the items.  
Enclosure 1 provides a listing of the participants and Enclosure 2 contains a listing of the DRAIs discussed with the applicant, including a brief description on the status of the items.  


The applicant had an opportunity to comment on this summary.  
The applicant had an opportunity to comment on this summary.  


       /RA/  Daneira Meléndez-Colón, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-341  
       /RA/  Daneira Meléndez-Colón, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation  
 
Docket No. 50-341  


==Enclosures:==
==Enclosures:==
: 1. List of Participants 2. Summary of Telephone Conference Call   
: 1. List of Participants 2. Summary of Telephone Conference Call  
 
cc w/encls: Listserv


cc w/encls:  Listserv DISTRIBUTION: See next page Accession Number: ML15082A188
DISTRIBUTION: See next page  
* Concurred via e-mail OFFICE LA:RPB1:DLR  PM:RPB1:DLR PM:RPB1:DLRBC:RPB1:DLR PM:RPB1:DLR NAME YEdmonds* DMeléndez-ColónJDaily YDiaz-SanabriaDMeléndez-ColónDATE 4/15/15 4/17/15 4/23/15 4/24/15 4/27/15                                                      OFFICIAL RECORD COPY  
 
Accession Number: ML15082A188
* Concurred via e-mail OFFICE LA:RPB1:DLR  PM:RPB1:DLR PM:RPB1:DLRBC:RPB1:DLR PM:RPB1:DLR NAME YEdmonds* DMeléndez-ColónJDaily YDiaz-SanabriaDMeléndez-ColónDATE 4/15/15 4/17/15 4/23/15 4/24/15 4/27/15                                                      OFFICIAL RECORD COPY  


==SUBJECT:==
==SUBJECT:==
SUMMARY OF TELEPHONE CONFERENCE CALL HELD ON MARCH 16, 2015, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)
SUMMARY OF TELEPHONE CONFERENCE CALL HELD ON MARCH 16, 2015, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)  


DISTRIBUTION: E-MAIL: PUBLIC  RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRsrg Resource RidsNrrPMFermi2 Resource ----------------- D. Melendez-Colon Y. Diaz-Sanabria E. Keegan B. Wittick B. Harris, OGC D. Roth, OGC M. Kunowski, RIII B. Kemker, RIII V. Mitlyng, RIII P. Chandrathil, RIII TELEPHONE CONFERENCE CALL FERMI 2  LICENSE RENEWAL APPLICATION  LIST OF PARTICIPANTS MARCH 16, 2015  PARTICIPANTS AFFILIATIONSDaneira Meléndez-Colón U. S. Nuclear Regulatory Commission (NRC)William Holston NRCLynne Goodman DTE Electric Company (DTE) Kevin Lynn DTERondi Sloan DTE John Tibai  DTE Mark Alward DTE
DISTRIBUTION:
E-MAIL: PUBLIC  RidsNrrDlr Resource  


ENCLOSURE 1 SUMMARY OF TELEPHONE CONFERENCE CALL FERMI 2 LICENSE RENEWAL APPLICATION MARCH 16, 2015 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company (DTE or the applicant) held a telephone conference call on March 16, 2015, to discuss and clarify the following draft requests for additional information (DRAIs) concerning the Fermi 2 license renewal application (LRA). DRAI B.1.45-1   
RidsNrrDlrRpb1 Resource
 
RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource
 
RidsNrrDlrRsrg Resource RidsNrrPMFermi2 Resource -----------------
D. Melendez-Colon
 
Y. Diaz-Sanabria
 
E. Keegan
 
B. Wittick
 
B. Harris, OGC D. Roth, OGC M. Kunowski, RIII B. Kemker, RIII V. Mitlyng, RIII P. Chandrathil, RIII
 
TELEPHONE CONFERENCE CALL FERMI 2  LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS MARCH 16, 2015 PARTICIPANTS AFFILIATIONSDaneira Meléndez-Colón U. S. Nuclear Re gulatory Commission (NRC)William Holston NRC Lynne Goodman DTE Electric Com pany (DTE) Kevin Lynn DTERondi Sloan DTE John Tibai  DTE Mark Alward DTE
 
ENCLOSURE 1 SUMMARY OF TELEPHONE CONFERENCE CALL FERMI 2 LICENSE RENEWAL APPLICATION MARCH 16, 2015  
 
The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company (DTE or the applicant) held a telephone conference call on March 16, 2015, to discuss and clarify the following draft requests for additional information (DRAIs) concerning the Fermi 2 license renewal application (LRA).
DRAI B.1.45-1  
 
===Background===
:  As amended by letter dated February 5, 2015, LRA Section B.1.45 states an exception to the "corrective actions" program element. The exception states that the high pressure coolant injection (HPCI) system lube oil reservoir internal coating will not be repaired or replaced and cites Nuclear Maintenance Applications Center Terry Turbine Users Group recommendations as a basis.
Issue:
The staff noted that Electric Power Research Institute (EPRI) Technical Report 1007459, "Terry Turbine Maintenance Guide, HPCI Application," November 2002, Section 20.2.5, "Inspection and Maintenance," states, "[r]emove any damaged preservative paint coating. Do not attempt to repaint the surfaces of the oil reservoir." The exception states that coatings will not be replaced or repaired, while Technical Report 1007459 states that damaged preservative coatings should be removed. The staff does not take issue with the provision to not repaint the internal surfaces of the lube oil reservoir. However the staff lacks sufficient information to conclude that the HPCI turbine will be capable of performing its current licensing basis (CLB) intended function if degraded coatings are present.


==Background:==
As amended by letter dated February 5, 2015, LRA Section B.1.45 states an exception to the "corrective actions" program element. The exception states that the high pressure coolant injection (HPCI) system lube oil reservoir internal coating will not be repaired or replaced and cites Nuclear Maintenance Applications Center Terry Turbine Users Group recommendations as a basis. Issue:
The staff noted that Electric Power Research Institute (EPRI) Technical Report 1007459, "Terry Turbine Maintenance Guide, HPCI Application," November 2002, Section 20.2.5, "Inspection and Maintenance," states, "[r]emove any damaged preservative paint coating. Do not attempt to repaint the surfaces of the oil reservoir."  The exception states that coatings will not be replaced or repaired, while Technical Report 1007459 states that damaged preservative coatings should be removed. The staff does not take issue with the provision to not repaint the internal surfaces of the lube oil reservoir. However the staff lacks sufficient information to conclude that the HPCI turbine will be capable of performing its current licensing basis (CLB) intended function if degraded coatings are present.
Request:
Request:
State what actions would be taken to mitigate potential further degradation of degraded coatings on the internal surfaces of the high pressure coolant injection system lube oil reservoir. Discussion:
State what actions would be taken to mitigate potential further degradation of degraded coatings on the internal surfaces of the high pressure coolant injection system lube oil reservoir.
The staff provided clarification related to its request in draft RAI B.1.45-1. The applicant stated that its intention is to remove all degraded coating and not replace it. The applicant understands the staff's concerns and will provide a response to the RAI when issued.     
Discussion
:
The staff provided clarification related to its request in draft RAI B.1.45-1. The applicant stated that its intention is to remove all degraded coating and not replace it.
The applicant understands the staff's concerns and will provide a response to the RAI when issued.     


This request will be sent as a formal RAI.  
This request will be sent as a formal RAI.  


ENCLOSURE 2 DRAI B.1.45-2
ENCLOSURE 2 DRAI B.1.45-2  


==Background:==
===
Background===
:
As amended by letter dated February 5, 2015, LRA Section B.1.45 states exceptions to the "corrective actions" program element. The exceptions state that when delamination, peeling, or blistering is detected during coating inspections and the coatings will be returned to service, physical testing will consist of lightly tapping the coating, light hand scraping, light power tool cleaning, or adhesion testing. The exception also states that destructive adhesion testing will not be conducted. The exception further states that longer follow-up and re-inspection inspection intervals than those recommended in Aging Management Program (AMP) XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks," would be allowed as long as they were technically justified.


As amended by letter dated February 5, 2015, LRA Section B.1.45 states exceptions to the "corrective actions" program element. The exceptions state that when delamination, peeling, or blistering is detected during coating inspections and the coatings will be returned to service, physical testing will consist of lightly tapping the coating, light hand scraping, light power tool cleaning, or adhesion testing. The exception also states that destructive adhesion testing will not be conducted. The exception further states that longer follow-up and re-inspection inspection intervals than those recommended in Aging Management Program (AMP) XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks," would be allowed as long as they were technically justified.
Issue:
Issue:
The "corrective actions" program element of AMP XI.M42 recommends that where adhesion testing is not possible due to physical constraints alternative means of physical testing such as those described by the applicant would be acceptable. However, the exception does not limit these alternative methods to instances where adhesion testing is not possible. There are nondestructive adhesion tests which can be conducted; therefore, the justification for the exception is not sufficient because it is based on the conclusion that coatings would be removed down to the base metal if adhesion testing is conducted. In addition, no basis was provided for inspection intervals beyond those recommended in AMP XI.M42 Table 4a, "Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers,"
The "corrective actions" program element of AMP XI.M42 recommends that where adhesion testing is not possible due to physical constraints alternative means of physical testing such as those described by the applicant would be acceptable. However, the exception does not limit these alternative methods to instances where adhesion testing is not possible. There are nondestructive adhesion tests which can be conducted; therefore, the justification for the exception is not sufficient because it is based on the conclusion that coatings would be removed down to the base metal if adhesion testing is conducted. In addition, no basis was provided for inspection intervals beyond those recommended in AMP XI.M42 Table 4a, "Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers,"
beyond stating that a future evaluation would be conducted.  
beyond stating that a future evaluation would be conducted.  


Request:  State: (a) why nondestructive adhesion testing cannot be performed when coatings are returned to service with delamination, peeling or blisters; (b) how lightly tapping the coating, light hand scraping, light power tool cleaning will be controlled (e.g., procedures, method qualification) such that consistent results can be obtained if nondestructive adhesion testing will not be performed; and (c) the basis and justification for any inspection intervals beyond those in AMP XI.M42 Table 4a.
Request:  State: (a) why nondestructive adhesion testing cannot be performed when coatings are returned to service with delamination, peeling or blisters; (b) how lightly tapping the coating, light hand scraping, light power tool cleaning will be controlled (e.g., procedures, method qualification) such that consistent results can be obtained if nondestructive adhesion testing will not be performed; and (c) the basis and justification for any inspection intervals beyond those in AMP XI.M42 Table 4a.  
Discussion:
 
The staff provided clarification related to its request in draft RAI B.1.45-2. The applicant noted that the recommended inspection intervals are described in the "acceptance criteria" program element and not on Table 4a of AMP XI.M42. The staff stated it will revise the RAI and incorporate this correction.   
Discussion
:
The staff provided clarification related to its request in draft RAI B.1.45-2.
The applicant noted that the recommended inspection intervals are described in the "acceptance criteria" program element and not on Table 4a of AMP XI.M42. The staff stated it will revise the RAI and incorporate this correction.   


The applicant understands the staff's concerns and will provide a response to the RAI. This request will be sent as a formal RAI with the correction noted.   
The applicant understands the staff's concerns and will provide a response to the RAI.
This request will be sent as a formal RAI with the correction noted.   


DRAI B.1.45-3
DRAI B.1.45-3  


==Background:==
===
Background===
:
As amended by letter dated February 5, 2015, LRA Section A.1.45 provides the Updated Final Safety Analysis Report (UFSAR) supplement for t he Coating Integrity Program. It states in part, "[b]aseline coating/lining inspections will occur in the 10-year period prior to the period of extended operation. Subsequent inspections are based on an evaluation of the effect of a coating/lining failure on in-scope component intended functions, potential problems identified during prior inspections, and service life history."


As amended by letter dated February 5, 2015, LRA Section A.1.45 provides the Updated Final Safety Analysis Report (UFSAR) supplement for the Coating Integrity Program. It states in part, "[b]aseline coating/lining inspections will occur in the 10-year period prior to the period of extended operation. Subsequent inspections are based on an evaluation of the effect of a coating/lining failure on in-scope component intended functions, potential problems identified during prior inspections, and service life history."
Issue:  The AMP XI.M42 "detection of aging effects" program element makes virtually the same


Issue:  The AMP XI.M42 "detection of aging effects" program element makes virtually the same statement; however, it expands on the statement by stating, "inspection intervals should not exceed that in Table 4a, 'Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers.' " The staff noted that based on the proposed wording in the UFSAR supplement subsequent inspections may not occur on recommended intervals or may not occur at all.  
statement; however, it expands on the statement by stating, "inspection intervals should not exceed that in Table 4a, 'Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers.' " The staff noted that based on the proposed wording in the UFSAR supplement subsequent inspections may not occur on recommended intervals or may not occur at all.  


Request:
Request:
State and justify the criteria that will be used to determine the maximum duration between coating inspections.
State and justify the criteria that will be used to determine the maximum duration between coating inspections.  
Discussion:
 
The staff provided clarification related to its request in draft RAI B.1.45-3. The applicant stated that it will provide clarification in the UFSAR supplement regarding inspection intervals.   
Discussion
:
The staff provided clarification related to its request in draft RAI B.1.45-3.
The applicant stated that it will provide clarification in the UFSAR supplement regarding inspection intervals.   
 
The applicant understands the staff's concerns and will provide a response to the RAI.   


The applicant understands the staff's concerns and will provide a response to the RAI.
This request will be sent as a formal RAI.}}
This request will be sent as a formal RAI.}}

Revision as of 03:49, 1 July 2018

Summary of Conference Call Held on March 16, 2015, Between the U.S. NRC and DTE Electric Company, Concerning Requests for Additional Information, Set 27 Pertaining to the Fermi 2 License Renewal Application (TAC No. MF4222)
ML15082A188
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 04/27/2015
From: Melendez-Colon D
License Renewal Projects Branch 1
To:
DTE Electric Company
Melendez-Colon D
References
DLR-15-0161, TAC MF4222
Download: ML15082A188 (7)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 27, 2015

LICENSEE: DTE Electric Company FACILITY: Fermi 2

SUBJECT:

SUMMARY OF TELEPHONE CONFERENCE CALL HELD ON MARCH 16, 2015, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION, SET 27 PERTAINING TO THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company (DTE or the applicant) held a telephone conference call on March 16, 2015, to discuss and clarify the staff's draft requests for additional information (DRAIs) B.1.45-1, B.1.45-2, and B.1.45-3 concerning the Fermi 2 license renewal application. The telephone conference call was useful in clarifying the intent of the staff's DRAIs.

provides a listing of the participants and Enclosure 2 contains a listing of the DRAIs discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

/RA/ Daneira Meléndez-Colón, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosures:

1. List of Participants 2. Summary of Telephone Conference Call

cc w/encls: Listserv

April 27, 2015

LICENSEE: DTE Electric Company

FACILITY: Fermi 2

SUBJECT:

SUMMARY OF TELEPHONE CONFERENCE CALL HELD ON MARCH 16, 2015, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION, SET 27 PERTAINING TO THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company (DTE or the applicant) held a telephone conference call on March 16, 2015, to discuss and clarify the staff's draft requests for additional information (DRAIs) B.1.45-1, B.1.45-2, and B.1.45-3 concerning the Fermi 2 license renewal application. The telephone conference call was useful in clarifying the intent of the staff's DRAIs.

Enclosure 1 provides a listing of the participants and Enclosure 2 contains a listing of the DRAIs discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

/RA/ Daneira Meléndez-Colón, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation

Docket No. 50-341

Enclosures:

1. List of Participants 2. Summary of Telephone Conference Call

cc w/encls: Listserv

DISTRIBUTION: See next page

Accession Number: ML15082A188

  • Concurred via e-mail OFFICE LA:RPB1:DLR PM:RPB1:DLR PM:RPB1:DLRBC:RPB1:DLR PM:RPB1:DLR NAME YEdmonds* DMeléndez-ColónJDaily YDiaz-SanabriaDMeléndez-ColónDATE 4/15/15 4/17/15 4/23/15 4/24/15 4/27/15 OFFICIAL RECORD COPY

SUBJECT:

SUMMARY OF TELEPHONE CONFERENCE CALL HELD ON MARCH 16, 2015, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DTE ELECTRIC COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE FERMI 2 LICENSE RENEWAL APPLICATION (TAC NO. MF4222)

DISTRIBUTION:

E-MAIL: PUBLIC RidsNrrDlr Resource

RidsNrrDlrRpb1 Resource

RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource

RidsNrrDlrRsrg Resource RidsNrrPMFermi2 Resource -----------------

D. Melendez-Colon

Y. Diaz-Sanabria

E. Keegan

B. Wittick

B. Harris, OGC D. Roth, OGC M. Kunowski, RIII B. Kemker, RIII V. Mitlyng, RIII P. Chandrathil, RIII

TELEPHONE CONFERENCE CALL FERMI 2 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS MARCH 16, 2015 PARTICIPANTS AFFILIATIONSDaneira Meléndez-Colón U. S. Nuclear Re gulatory Commission (NRC)William Holston NRC Lynne Goodman DTE Electric Com pany (DTE) Kevin Lynn DTERondi Sloan DTE John Tibai DTE Mark Alward DTE

ENCLOSURE 1 SUMMARY OF TELEPHONE CONFERENCE CALL FERMI 2 LICENSE RENEWAL APPLICATION MARCH 16, 2015

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of DTE Electric Company (DTE or the applicant) held a telephone conference call on March 16, 2015, to discuss and clarify the following draft requests for additional information (DRAIs) concerning the Fermi 2 license renewal application (LRA).

DRAI B.1.45-1

Background

As amended by letter dated February 5, 2015, LRA Section B.1.45 states an exception to the "corrective actions" program element. The exception states that the high pressure coolant injection (HPCI) system lube oil reservoir internal coating will not be repaired or replaced and cites Nuclear Maintenance Applications Center Terry Turbine Users Group recommendations as a basis.

Issue:

The staff noted that Electric Power Research Institute (EPRI) Technical Report 1007459, "Terry Turbine Maintenance Guide, HPCI Application," November 2002, Section 20.2.5, "Inspection and Maintenance," states, "[r]emove any damaged preservative paint coating. Do not attempt to repaint the surfaces of the oil reservoir." The exception states that coatings will not be replaced or repaired, while Technical Report 1007459 states that damaged preservative coatings should be removed. The staff does not take issue with the provision to not repaint the internal surfaces of the lube oil reservoir. However the staff lacks sufficient information to conclude that the HPCI turbine will be capable of performing its current licensing basis (CLB) intended function if degraded coatings are present.

Request:

State what actions would be taken to mitigate potential further degradation of degraded coatings on the internal surfaces of the high pressure coolant injection system lube oil reservoir.

Discussion

The staff provided clarification related to its request in draft RAI B.1.45-1. The applicant stated that its intention is to remove all degraded coating and not replace it.

The applicant understands the staff's concerns and will provide a response to the RAI when issued.

This request will be sent as a formal RAI.

ENCLOSURE 2 DRAI B.1.45-2

=

Background===

As amended by letter dated February 5, 2015, LRA Section B.1.45 states exceptions to the "corrective actions" program element. The exceptions state that when delamination, peeling, or blistering is detected during coating inspections and the coatings will be returned to service, physical testing will consist of lightly tapping the coating, light hand scraping, light power tool cleaning, or adhesion testing. The exception also states that destructive adhesion testing will not be conducted. The exception further states that longer follow-up and re-inspection inspection intervals than those recommended in Aging Management Program (AMP) XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks," would be allowed as long as they were technically justified.

Issue:

The "corrective actions" program element of AMP XI.M42 recommends that where adhesion testing is not possible due to physical constraints alternative means of physical testing such as those described by the applicant would be acceptable. However, the exception does not limit these alternative methods to instances where adhesion testing is not possible. There are nondestructive adhesion tests which can be conducted; therefore, the justification for the exception is not sufficient because it is based on the conclusion that coatings would be removed down to the base metal if adhesion testing is conducted. In addition, no basis was provided for inspection intervals beyond those recommended in AMP XI.M42 Table 4a, "Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers,"

beyond stating that a future evaluation would be conducted.

Request: State: (a) why nondestructive adhesion testing cannot be performed when coatings are returned to service with delamination, peeling or blisters; (b) how lightly tapping the coating, light hand scraping, light power tool cleaning will be controlled (e.g., procedures, method qualification) such that consistent results can be obtained if nondestructive adhesion testing will not be performed; and (c) the basis and justification for any inspection intervals beyond those in AMP XI.M42 Table 4a.

Discussion

The staff provided clarification related to its request in draft RAI B.1.45-2.

The applicant noted that the recommended inspection intervals are described in the "acceptance criteria" program element and not on Table 4a of AMP XI.M42. The staff stated it will revise the RAI and incorporate this correction.

The applicant understands the staff's concerns and will provide a response to the RAI.

This request will be sent as a formal RAI with the correction noted.

DRAI B.1.45-3

=

Background===

As amended by letter dated February 5, 2015, LRA Section A.1.45 provides the Updated Final Safety Analysis Report (UFSAR) supplement for t he Coating Integrity Program. It states in part, "[b]aseline coating/lining inspections will occur in the 10-year period prior to the period of extended operation. Subsequent inspections are based on an evaluation of the effect of a coating/lining failure on in-scope component intended functions, potential problems identified during prior inspections, and service life history."

Issue: The AMP XI.M42 "detection of aging effects" program element makes virtually the same

statement; however, it expands on the statement by stating, "inspection intervals should not exceed that in Table 4a, 'Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers.' " The staff noted that based on the proposed wording in the UFSAR supplement subsequent inspections may not occur on recommended intervals or may not occur at all.

Request:

State and justify the criteria that will be used to determine the maximum duration between coating inspections.

Discussion

The staff provided clarification related to its request in draft RAI B.1.45-3.

The applicant stated that it will provide clarification in the UFSAR supplement regarding inspection intervals.

The applicant understands the staff's concerns and will provide a response to the RAI.

This request will be sent as a formal RAI.

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