NRC-14-0070, Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 1

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

ML14301A466
Person / Time
Site:	Fermi
Issue date:	10/24/2014
From:	Kaminskas V DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-14-0070, TAC MF4222
Download: ML14301A466 (21)

Text

Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasvadteenergy.com DTE Energy' 10 CFR 54 October 24, 2014 NRC-14-0070 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) DTE Electric Company Letter to NRC, "Fermi 2 License Renewal Application," NRC-14-0028, dated April 24, 2014 (ML14121A554)

3) NRC Letter, "Requests for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 1 (TAC No.

MF4222)," dated September 26, 2014 (ML14258A094)

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 1 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. The Enclosure to this letter provides the DTE response to the request for additional information.

No new commitments are being made in this submittal. A clarification has been made to a commitment previously identified in Section A.4 of the LRA as indicated in the Enclosure.

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

USNRC NRC-14-0070 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on ctober 2 2014 O

Vito A. Kaminskas Site Vice President Nuclear Generation

Enclosure:

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

Enclosure to NRC-14-0070 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 1

Enclosure to NRC-14-0070 Page 1 RAI 2.4-1

Background:

Table 2.3.2-2, "Residual Heat Removal System, " of the license renewal application (LRA), does not list expansion joint bellows as a component type subject to an Aging Management Review (AMR).

Issue:

However, Table 2.4-4, "Bulk Commodities," lists "compressible joints and seals" as a component type subject to an AMR.

Request:

Please confirm that this component type includes the use of expansion joint bellows. If installed in the residual heat removal system, provide the locations where they are covered, and whether they are subject to an AMR, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 54.21(a)(1)(i).

Response

There are no bellows in the Residual Heat Removal (RHR) system. In the License Renewal Application (LRA), containment penetration bellows are considered part of the related structure rather than the process system. This is why there is no entry for bellows in LRA Table 2.3,2-2 for the RHR system. Instead, the containment penetration bellows are described in LRA Section 2.4.1 (on page 2.4-7) and covered under the component type "penetration bellows" which is listed in LRA Table 2.4-1. The aging management review results for this component type are provided in LRA Table 3.5.2-1.

The bulk commodities listed in LRA Section 2.4.4 and shown in LRA Table 2.4-4 are those that are common to in-scope structures, systems, and components. Therefore, the entry in LRA Table 2.4-4 for "compressible joints and seals" is not related to the containment penetration bellows discussed above.

LRA Revisions:

None.

Enclosure to NRC-14-0070 Page 2 RAI 2.4-2

Background:

In the Updated Final Safety Analysis Report (UFSAR) Section 3.4.4, "Flood Protection," and Section 3.4.4.1, "Reactor Building Structure, " discuss the use of watertight seals and water stops for flood protection of Category I structures.

Issue:

However, a review of the tables in the LRA did not identify such components for in-scope structures as credited for flood protection and subject to an AMR.

Request:

If present, clarify the location within the LRA where they are covered and the corresponding AMR. If not included in the LRA, please justify their exclusion from the scope of license renewal, pursuant to 10 CFR 54.4.

Response

Consistent with discussions in Fermi 2 Updated Final Safety Analysis Report (UFSAR) Sections 3.4.4 and 3.4.4.1, watertight seals and water stops are credited for providing flood protection of Category I structures. Accordingly, they are included in the scope of license renewal, The watertight seals are elastomeric components used in doors and penetrations through the outside walls below the design flood elevation. They are included in License Renewal Application (LRA) Table 3.5.2-4 line items "Penetration seals" and "Seals and gaskets (doors, manways and hatches)" with an intended function of flood barrier (FLB). The water stops are polymer components embedded in concrete at construction joints. They are inaccessible and protected from the environment by concrete (in the same manner as reinforcing steel). The water stops are treated as a subcomponent of reinforced concrete as is reinforcing steel. Therefore, water stops are not listed as a separate line item in an LRA table.

LRA Revisions:

None.

Enclosure to NRC-14-0070 Page 3 RAI 2.4-3

Background:

Section 2.4.2, "Water-Control Structures," of the LRA, and UFSAR Section 9.2.1, "General Service Water (GSW) System," state that... "Traveling screens and stationary racks are provided to keep floating debris from entering the GSW intake pit."

Issue:

However, such components are not included in Table 2.4-2, "Water-Control Structures," or Table 2.4-4, "Bulk Commodities."

Request:

If such components are relied upon and perform an intended function, please identify the section of the LRA where they are covered, as well as their applicable aging effects, and the Aging Management Program (AMP) related to these components. If not included in the LRA, please justify their exclusion from the scope of license renewal. Also, please clarify if there are any additional trash racks, basket strainers, traveling screens or any other debris prevention or removing mechanisms that are part of any in-scope structures, subject to 10 CFR 54.4.

Response

The General Service Water (GSW) pump house is described in License Renewal Application (LRA) Section 2.4.2. The traveling screens and stationary racks are also discussed in LRA Section 2.4.2 as part of a general discussion of what is contained within the GSW pump house.

The traveling screens and stationary racks (and any other debris prevention or removing mechanisms) are not considered part of the structure of the GSW pump house. These components are nonsafety-related and their failure could not impact any safety-related function since there is no safety-related equipment inside the GSW pump house. Therefore, the traveling screens and racks are not in-scope for 10 CFR 54.4 (a)(1) or (a)(2). The GSW system does not perform a function that demonstrates compliance with the Commission's regulations for fire protection, environmental qualification, pressurized thermal shock, anticipated transients without scram, and station blackout and is therefore not in scope for 10 CFR 54.4 (a)(3). For this reason, the components were not included in either LRA Tables 2.4-2 or 2.4-4.

The Residual Heat Removal (RHR) Complex and Shore Barrier are the other water-control structures addressed in LRA Section 2.4.2. There are no additional trash racks, basket strainers, traveling screens or other debris prevention or removal mechanisms that are part of these in-scope structures.

LRA Revisions:

None.

Enclosure to NRC-14-0070 Page 4 RAI 2.4-4

Background:

In UFSAR Section 6.2.5.2.5, "Containment Purge," states that "Debris screens have been provided for the purge valves inside the drywell to prevent debris from becoming entrained in the valves."

Issue:

However, Section 2.4.1, "Reactor/Auxiliary Building and Primary Containment, " of the LRA, does not discuss or include such component in Table 2.4-1, "Reactor/Auxiliary Building and Primary Containment Components Subject to Aging Management Review."

Request:

If such component is relied upon to perform an intended function, please identify the section of the LRA where it is covered, as well as the applicable aging effects and the AMP related to this component. If not included in the LRA, please justify its exclusion from the scope of license renewal, pursuant to 10 CFR 54.4.

Response

As indicated in the Updated Final Safety Analysis Report (UFSAR) Section 6.2.5.2.5, debris screens are provided for the purge valves inside the drywell to prevent debris from becoming entrained in the valves. There are two debris screens that are part of the Containment Atmospheric Control (CAC) system (T48).

The CAC system is described in License Renewal Application (LRA) Section 2.3.3.13. Debris screens are identified under the "strainer" component type in LRA Table 2.3.3-13. The aging management evaluation is provided in LRA Table 3.3.2-13 under the "strainer" component type.

As shown in LRA Table 3.3.2-13, strainers are stainless steel in an indoor air environment. Thus there is no aging effect requiring management. The material for the debris screens was determined to be stainless steel based on information from the vendor that the screens may be either carbon or stainless steel supplemented by photographs of the screens that showed a shiny surface indicative of stainless steel.

However, as described in LRA Section 2.3.3.13, one drywell exhaust isolation valve of the CAC system is reviewed as part of the Standby Gas Treatment (SGT) system in LRA Section 2.3.2.7.

One of the debris screens is located near this valve and was intended to be reviewed as part of the SGT as indicated on drawing LRA-M-2709. The discussion in LRA Section 2.32.7 does not include the debris screen and no "strainer" component type is included in LRA Tables 2.3.2-7 and 3.2.2-7, Therefore, LRA Tables 2.3.2-7 and 3.2.2-7 will be revised to include the "strainer" component type.

Following the LRA revision described above, one of the debris screens will be addressed in the section and tables associated with the CAC system and the other will be addressed in the section

Enclosure to NRC-14-0070 Page 5 and tables associated with the SGT system. This will ensure consistency with the LRA drawings.

As described above, the debris screens are stainless steel in an indoor air environment such that there are no aging effects requiring management and thus no impact on any aging management program.

LRA Revisions:

LRA Tables 2.3.2-7 and 3.2.2-7 will be revised as shown on the following pages.

Enclosure to NRC-14-0070 Page 6 Table 2.3.2-7 Standby Gas Treatment System Components Subject to Aging Management Review Component Type Intended Function Bolting Pressure boundary Chamber Pressure boundary Damper housing Pressure boundary Duct Pressure boundary Fan housing Pressure boundary Filter housing Pressure boundary Flex connection Pressure boundary Flow element Pressure boundary Moisture separator Filtration Orifice Pressure boundary Piping Pressure boundary Pump casing Pressure boundary Sight glass Pressure boundary Strainer Filtration Tubing Pressure boundary Valve body Pressure boundary

Enclosure to NRC-14-0070 Page 7 Table 3.2.2-7 Standby Gas Treatment System Summary of Aging Management Evaluation Aging Effect Aging Component Intended Requiring Management NUREG-Table I Type Function Material Environment Management Pro ram 1801 Item Item Notes Pump casing Pressure Stainless Air - indoor (ext)

None None V.F.EP-18 3.2.1-63 A

caig boundary steel Pump casing Pressure Stainless Air-indoor (int)

None None V.F.EP-82 3.2.1-63 A

P g

boundary steel

(_____)_

Sight glass Pressure Glass Air-indoor (ext)

None None V.F.EP-15 32.1-60 A

boundary Air-indoor (ent)

None None V.J.P-48 3..1-11 A

Sight glass Pressure Glass Air - indoor (int)

None None VII.J.AP-48 3.3.1-117 C

boundary Sight glass Pressure Stainless Air-indoor (ext)

None None V.F.EP-18 3.2.1-63 A

boundary steel Sight glass bounary Stless Air - indoor (int)

None None V.FEP-82 3.2.1-63 A

Strainer Filtration Stainless Air-indoor (ext)

None None V.F.EP-18 3.2.1-63 A

steel Strainer Filtration Stainless Air -indoor (int)

None None V. F. EP-82 3.2.1-63 A

steel Tubing Pressure Stainless Air-indoor (ext)

None None V.F.EP-18 3.2.1-63 A

boundary steel Tubing Pressure Stainless Air-indoor (int)

None None V.F.EP-82 3.2.1-63 A

boundary steel__

Enclosure to NRC-14-0070 Page 8 RAI3.5.2.2.2.1-1

Background:

SRP-LR Section 3.5.3.2.2.1, item 1, associated with SRP-LR Table 3.5-1, item 42, states that loss of material and cracking due to freeze-thaw could occur in inaccessible concrete areas of Groups 1-3, 5, and 7-9 structures. Structure monitoring programs may not be sufficient for plants located in moderate to severe weathering conditions; for these situations further evaluation is needed. The SRP-LR further states that a plant-specific program is not required if documented evidence confirms that the existing concrete has air content between 3 and 8 percent and inspections have not identified degradation related to freeze-thaw.

Issue:

In LRA Table 3.5.1, item 3,5.1-42, the applicant stated that freeze-thaw does not require management. In the associated further evaluation section (3.5.2.2.2.1, item 1), the applicant stated that Fermi 2 Groups 1-3, 5, and 7-9 concrete structures are located in a region where weathering conditions are considered severe. The "severe weather" condition means that freeze-thaw is a credible aging mechanism that should be managed by the applicant. LR A Section 3.5.2.2.2.1, item 1, also states that Fermi 2 specications require an air-entraining agent to be used in concrete subject to weathering; therefore, the specifications provide a durable concrete that is not subject to freeze-thaw aging effects. Pursuant to 10 CFR 54.21(a)(3) the NRC requires the applicant to demonstrate that the effects of aging for structures and components subject to an AMR will be adequately managed so that the intended function will be maintained consistent with the current licensing basis for the period of extended operation.

However, the applicant did not provide documented evidence which confirms the existing concrete has air content of 3 to 8 percent, nor discuss results of past inspections that demonstrate freeze-thaw degradation is not an issue.

Request:

1. Confirm whether the air content values on Groups 1-3, 5, and 7-9 structures are between 3 and 8 percent.

2. If evidence is unavailable that demonstrates air content between 3 and 8 percent, provide an alternative technical basis for not proposing a plant-specific program or provide a description of a plant-specific program to manage the aging effects offreeze-thaw on Groups 1-3, 5, and 7-9 structures.

3. Describe the results of past inspections and whether or not past inspections have identified degradation that was attributed to freeze-thaw degradation.

Response

1. The above-grade concrete of Groups 1-3, 5, and 7-9 structures used an air-entraining agent such that air content values are between 3 and 8 percent. However, it could not be confirmed that the air content values are between 3 and 8 percent for below-grade inaccessible concrete of Groups 1-3, 5, and 7-9 structures. It was confirmed that the air

Enclosure to NRC-14-0070 Page 9 content values for below-grade inaccessible concrete areas of Groups 1-3, 5, and 7-9 structures are less than 3% by reviewing test results. This is consistent with the mix design for these below-grade locations, which does not call for the use of air entrainment admixture. Therefore, the air content of the below-grade concrete (less than 3%) is consistent with the original site-specific design.

2. As stated in License Renewal Application (LRA) Section 3.5.2.2.2.1, the Structures Monitoring Program, described in LRA Section B.1.42, will manage the aging effects due to freeze thaw (loss of material and cracking) in below-grade inaccessible concrete.

Accordingly, the 'discussion' column of LRA Table 3.5.1, item 3.5.1-42 shall be revised as indicated below in the "LRA Revisions" section. New items will then be added to LRA Tables 3.5.2-1 and 3.5.2-3 to reference the revised item 3.5.1-42. The discussion in LRA Section 3.5.2.2.2.1 will be revised to indicate that these aging effects are applicable.

Because the aging effects also apply to Group 6 structures, the discussion in LRA Section 3.5.2.2.2.3 will also be revised.

The nominal plant grade elevation at Fermi 2 is 583'. As is described in the Fermi 2 Updated Final Safety Analysis Report (UFSAR), the natural ground water level at the site is on the order of elevation 575' (October 2014 data shows 574'). The frost line as recognized in the Michigan Building Code is 42 inches below finish grade (Elevation 579'-6"). The fact that the groundwater table is approximately 4'-6" below the frost line shows that the soil above the frost line is in the unsaturated zone. The.only inaccessible.

below-grade structures that could be subject to freeze-thaw would be the 42 inches of concrete above the frost line. Because the soil in this zone is unsaturated, any effects of freeze-thaw would only be due to the natural moisture in the unsaturated soil. The above-grade portion of the same structure would be subject to year-round weathering events, and would experience higher levels of freeze-thaw degradation than the below-grade portion of the structure that is shielded by the unsaturated soil. Because of this, the approach for inspecting the above-grade structures for freeze-thaw degradation through the Structures Monitoring Program and correlating these above-grade findings to the condition of the below-grade structure is valid. As stated in LRA Section 3.5.2.2.2.1, the Structures Monitoring Program will manage the loss of material and cracking due to freeze-thaw in below-grade inaccessible concrete of Groups 1-3, 5, and 7-9 structures through inspection when accessible as a result of excavation activity, and inspections will be performed of inaccessible areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant degradation is occurring. It is possible that below-grade inaccessible concrete is in a soil or outdoor air environment. Regardless of the environment, the Structures Monitoring Program will manage the aging effects due to freeze-thaw. For this reason, the discussion in LRA Section 3.5.2.2.2.1, and corresponding descriptions of the enhancements in Appendices A and B, will be revised to remove discussion of the same environment when correlating accessible and inaccessible areas.

Enclosure to NRC-14-0070 Page 10

3. Past inspections of the Fermi 2 structures under the Structures Monitoring Program have not revealed concrete structural degradation attributed to freeze-thaw. Recent site projects where below-grade exterior walls of the structures were exposed also did not identify degradation attributed to the freeze-thaw mechanism.

LRA Revisions:

LRA Section 3.5.2.2.2.1 item 1, LRA Section 3.5.2.2.2.3 item 1, LRA Table 3.5.1 item 3.5.1-42, LRA Table 3.5.2-1, LRA Table 3.5.2-3, LRA Appendix A.1.42, LRAAppendix A.4, and LRA Appendix B.1.42 will be revised as shown on the following pages.

Enclosure to NRC-14-0070 Page 11 3.5.2.2.2,1 Aging Management of Inaccessible Areas

1. Loss of Material (Spalling, Scaling) and Cracking Due to Freeze-Thaw in Below-Grade Inaccessible Concrete Areas of Groups 1-3, 5, and 7-9 Structures The Fermi 2 Groups 1-3, 5 and 7-9 concrete structures are located in a region where weathering conditions are considered severe as shown in ASTM C33-90, Fig. 1. The concrete structures are designed in accordance with ACI 318-63 and/or ACI 318-71 and constructed in accordance with the recommendations in ACI 318-63 and ACI 318-71 using ingredients/materials conforming to ACI, CSA, Michigan Department of State Highways, and ASTM standards. The concrete mix uses Portland cement conforming to ASTM C150 (Types II and V) or CSA Standard A5 along with flyash (ASTM C618). Concrete aggregates conform to the requirements of Michigan Department of State Highways Standard Specifications for Road and Bridge Construction, Article 8.02. Fine aggregates are of the natural sand designation 2NS. Coarse aggregates are of the designation 6AA; these requirements equal or exceed those of ASTM Specification C33. The type and size of aggregate, slump, cement and additives have been established to produce durable concrete in accordance with ACl. Additional4ywaterdeeme able4ange defined nig,9ee--4e-sedde oet Fermi 2 specifications provide a durable concrete4hat-is-net subjGt to4Feethawaging-effects.

Nevertheless theThe Structures Monitoring Program will manage loss of material (spalling, scaling) and cracking due to freeze-thaw in below-grade inaccessible concrete of Groups 1-3, 5 and 7-9 structures. These structures will be inspected when accessible as a result of excavation for any reason. Additionally, inspections will be performed of inaccessible areas in environments where observed conditions in accessible areas exposed-te the same env4ifonmert-indicate that significant degradation ismay be occurring in the inaccessible areas.

Enclosure to NRC-14-0070 Page 12 3.5.2.2.2.3 Aging Management of Inaccessible Areas for Group 6 Structures For inaccessible areas of certain Group 6 structures, aging effects are covered by inspections in accordance with the Structures Monitoring Program.

1. Loss of Material (Spalling, Scaling) and Cracking Due to Freeze-thaw in Below-Grade Inaccessible Concrete Areas of Group 6 Structures Fermi 2 is located in a region where weathering conditions are considered severe as shown in ASTM C33-90, Fig. 1. The Group 6 concrete structures are designed in accordance with ACl 318-63 or ACI 318-71 and constructed in accordance with the recommendations in ACI 318-63 and ACl 318-71 using ingredients/materials conforming to ACI, CSA, Michigan Department of State Highways and ASTM standards. The concrete mix uses Portland cement conforming to ASTM 0150 (Types I and V) or CSA Standard A5 along with flyash (ASTM C618). Concrete aggregates conform to the requirements of Michigan Department of State Highways Standard Specifications for Road and Bridge Construction, Article 8.02.

Fine aggregates are of the natural sand designation 2NS. Coarse aggregates are of the designation 6AA; these requirements equal or exceed those of ASTM Specification C33.

The type and size of aggregate, slump, cement and additives have been established to produce durable concrete in accordance with ACI. Ad w

r were withi+-the-aeeepte Wications-require-anar-entraining agent4t-be used in concrete to wethrig Fermi 2 specifications provide a durable concrete that is not sject tof thaw aging effects.

Thefeforerlosefatef#ra-spa asnkI r

agd 44FeeZe-thawObelew-gradeineee si ooiee-nete are nlt aging effft hat re-aginganag1ement-Nvtr4hees-heThe RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program manages loss of material (spalling, scaling) and cracking due to freeze-thaw in below-grade (above the frost line) concrete for Fermi 2 Group 6 concrete structures. These structures will be inspected when accessible as a result of excavation for any reason. Additionally, inspections will be performed of inaccessible areas in environments where observed conditions in accessible areas exposed4e-the-same eaviomenindicate that significant degradation s-may be occurring in the inaccessible areas.

Enclosure to NRC-14-0070 Page 13 Table 3.5.1: Structures and Component Supports Aging Further Item Aging Effect/

Management Evaluation Number Component Mechanism Programs Recommended Discussion Safety-Related and Other Structures; and Component Supports 3.5.1-42 Groups 1-3, 5, 7-9:

Loss of Further Yes, for plants Isted aging ^#fct° for Fermi 2 concrete Concrete material evaluation is located in f.

(inaccessible (spalling, required for moderate to Frmi 2 Gonerete is desined and areas):

scaling) and plants that are severe sr foundation cracking due to located in weathering with air entrainment. Conrete freeze-thaw moderate to conditions st severe st weathering et conditions suitable for strength development an (weathering index >100 which is characteristic of concrete day-inch/yr) having low pcrncabilit T

design (NUREG-1557) ermi 2 prevents the eefet of this aging from curring theefore this aging nffet does not reire management Aging effect are not significant for acceccible and inacce-s'sRibe areas.

Anonetheless, the conrG ete fun dation comonnt s nclde inthThe Structures Monitoring Program manages to

-i verif thasnce of ths the listed aging effects.

For further discussion, see Section 3.5.2.2.2.1 Item 1.

Enclosure to NRC-14-0070 Page 14 Table 3.5.2-1: Reactor/Auxiliary Building and Primary Containment Aging Effect Aging Component Intended Requiring Management NUREG-Table 1 Type Function Material Environment Management Program 1801 Item Item Notes Concrete EN, FLB, Concrete Air - outdoor Loss of material Structures IllI.A2.TP-23 3.5.1-64 A

(accessible MB, SNS, Monitoring areas): exterior SRE, SSR above-and below-grade; foundation Concrete EN, FLB, Concrete Air - outdoor Cracking Structures IIl.A2.TP-25 3.5.1-54 A

(accessible MB, SNS, Monitoring areas): exterior SRE, SSR above-and below-grade; foundation Concrete EN FLB, Concrete Air - outdoor Loss of material Structures Ill.A1.TP-108 3.5.1-42 E

(inaccessible MB SNS, spalling, scalinq)

Monitoring lIl.A2.TP-108 areas):

SRE, SSR and cracking due to IlLA3.TP-108 foundation freeze-thaw IIl.A5.TP-108 Drywell floor SSR Concrete Air - indoor Cracking, loss of Structures llL.A2.TP-26 3.5.1-66 A

slab uncontrolled bond, loss material Monitoring (spalling, scaling)

Drywell floor SSR Concrete Air-indoor Increase in porosity Structures Ill.A2.TP-28 3.5.1-67 A

slab uncontrolled and permeability, Monitoring cracking, loss of material (spalling, scaling)

Enclosure to NRC-14-0070 Page 15 Table 3.5.2-3: Turbine Building, Process Facilities and Yard Structures Structure and/or Aging Effect Aging Component or Intended Requiring Management NUREG-Table 1 Commodity Function Material Environment Management Program 1801 Item Item Notes Concrete EN, FLB, Concrete Air - outdoor Loss of material Structures Ill.A3.TP-23 3.5.1-64 A

(accessible MB, SNS, (spalling, scaling)

Monitoring areas): exterior SRE and cracking above-and below-grade; foundation Concrete EN, FLB, Concrete Air - outdoor Cracking Structures Ill.A3.TP-25 3.5.1-54 A

(accessible MB, SNS, Monitoring areas): exterior SRE above-and below-grade; foundation Concrete EN, FLB, Concrete Air - outdoor Loss of material Structures lIl.A3.TP-108 3.5.1-42 E

(inaccessible MB. SNS, (spalling, scaling)

Monitoring Ill.A8.TP-108 areas):

SRE and cracking due to foundation freeze-thaw Cable tunnel SRE Concrete Soil Cracking, loss of Structures Ill.A3.TP-212 3.5.1-65 A

bond, and loss Monitoring material (spalling, scaling)

Cable tunnel SRE Concrete Air-indoor Cracking, loss of Structures lIl.A2.TP-26 3.5.1-66 A

uncontrolled bond, and loss Monitoring material (spalling, scaling)

Enclosure to NRC-14-0070 Page 16 A.1.42 Structures Monitoring Program Revise plant procedures to include the following for detection of aging effects:

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

> Visual inspection of elastomeric material should be supplemented by feel or touch to detect hardening if performance 'of the intended function of the elastomeric material is suspect. Include instructions to augment the visual examination of elastomeric material with physical manipulation of at least ten percent of available surface area.

Structures will be inspected at least once every five years.

Submerged structures will be inspected at least once every five years.

If normally inaccessible areas become accessible due to plant activities, an inspection of these areas shall be conducted. Additionally, inspections will be performed of inaccessible areas in environments where observed conditions in accessible areas expesed-to4he-seme-enirme n-eindicate that significant degradation is-may be occurring in the inaccessible areas.

> Sampling and chemical analysis of ground water at least once every five years. The Structures Monitoring Program owner will review the results and evaluate any anomalies and perform trending of the results.

Masonry walls will be inspected at least once every five years, with provisions for more frequent inspections in areas where significant aging effects (i.e., missing blocks, cracking, etc.) is observed to ensure there is no loss of intended function between inspections.

Inspection of water-control structures should be conducted under the direction of qualified personnel experienced in the investigation, design, construction, and operation of these types of facilities.

> Inspections of water-control structures on an interval not to exceed five years.

Perform special inspections of water-control structures immediately (within 30 days) following the occurrence of significant natural phenomena, such as large floods, earthquakes, hurricanes, tornadoes, and intense local rainfalls.

Enclosure to NRC-14-0070 Page 17 A.4 LICENSE RENEWAL COMMITMENT LIST Implementation No.

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

Prior to September A.1.42 20, 2024

j.

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

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

Visual inspection of elastomeric material should be supplemented by feel or touch to detect hardening if performance of the intended function of the elastomeric material is suspect. Include instructions to augment the visual examination of elastomeric material with physical manipulation of at least ten percent of available surface area.

Structures will be inspected at least once every five years.

Submerged structures will be inspected at least once every five years.

If normally inaccessible areas become accessible due to plant activities, an inspection of these areas shall be conducted.

Additionally, inspections will be performed of inaccessible areas in environments where observed conditions in accessible areas exposed to the came envionment indicate that significant degradation is-may be occurring in the inaccessible areas.

Sampling and chemical analysis of ground water at least once every five years. The Structures Monitoring Program owner will review the results and evaluate any anomalies and perform trending of the results.

Enclosure to NRC-14-0070 Page 18 B.1.42 STRUCTURES MONITORING Element Affected Enhancement

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

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

Visual inspection of elastomeric material should be supplemented by feel or touch to detect hardening if performance of the intended function of the elastomeric material is suspect. Include instructions to augment the visual examination of elastomeric material with physical manipulation of at least ten percent of available surface area.

Structures will be inspected at least once every five years.

Submerged structures will be inspected at least once every five years.

If normally inaccessible areas become accessible due to plant activities, an inspection of these areas shall be conducted. Additionally, inspections will be performed of inaccessible areas in environments where observed conditions in accessible areas expesed4-te4he-sam-e envroment-indicate that significant degradation s-mav be occurring in the inaccessible areas.