ML14072A008

Davis-Besse Nuclear Power Station, Unit 1, Reply to Request for Additional Information for the Review of License Renewal Application (TAC No. ME4640) and Amendment No. 49

ML14072A008
Person / Time
Site:	Davis Besse
Issue date:	03/11/2014
From:	Lieb R A FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-14-114, TAC ME4640
Download: ML14072A008 (17)

Text

FENOCTF5501 North State Route 2FirstEnergy Nuclear Operating Company Oak Harbor, Ohio 43449Raymond A. Lieb 419-321-7676 Vice President, Nuclear Fax: 419-321-7582 March 11,2014L-14-114 10 CFR 54ATTN: Document Control DeskU.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1Docket No. 50-346, License Number NPF-3Reply to Request for Additional Information for the Review of the Davis-Besse NuclearPower Station, Unit No. 1, License Renewal Application (TAC No. ME4640) andLicense Renewal Application Amendment No. 49By letter dated August 27, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML1 02450565),

FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of FederalRegulations, Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse).

By letter dated February 11, 2014(ML14029A201),

the Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the License Renewal Application (LRA).The Attachment provides the FENOC reply to the NRC request for additional information.

The NRC request is shown in bold text followed by the FENOC response.

The Enclosure provides Amendment No. 49 to the Davis-Besse LRA.There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, FleetLicense Renewal Project Manager, at 724-682-7139.

I declare under penalty of perjury that the foregoing is true and correct.

Executed onMarch _L1, 2014.Sincerely, Raym/nd A. Lieb Davis-Besse Nuclear Power Station, Unit No. 1L-14-114Page 2

Attachment:

Reply to Requests for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse),

License Renewal Application (LRA), Section B.2.7

Enclosure:

Amendment No. 49 to the Davis-Besse License Renewal Application cc: NRC DLR Project ManagerNRC Region III Administrator cc: w/o Attachment or Enclosure NRC DLR DirectorNRR DORL Project ManagerNRC Resident Inspector Utility Radiological Safety Board Attachment L-14-114Reply to Requests for Additional Information for the Review of theDavis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse),

License Renewal Application (LRA),Section B.2.7Page 1 of 4Question RAI 2011-03-1

Background:

The License Renewal Annual Update letter, dated September 20, 2013, amendedthe acceptance criteria for cathodic protection ground surveys to address thechanges in recommendations issued in License Renewal Interim Staff Guidance(LR-ISG)-2011-3, "Changes to the Generic Aging Lessons Learned (GALL) ReportRevision 2 Aging Management Program (AMP) XI.M41, 'Buried and Underground Piping and Tanks'."

As amended, the cathodic protection acceptance criteria arenegative 850 mV relative to a copper/copper sulfate reference electrode instantoff or negative 100 mV minimum polarization, and limiting critical potential notmore negative than 1200 mV.LR-ISG-2011-3 Table 6a, "Cathodic Protection Acceptance Criteria,"

recommends that, [t]he 100 mV polarization criterion is limited to electrically isolated pipingsections or areas of grounded piping where the effects of mixed potentials areshown to be minimal.

When the 100 mV criterion is utilized in lieu of the -850 mVCSE criterion for steel piping, or where copper or aluminum components areprotected, applicants must explain in the application why the effects of mixedpotentials are minimal and why the most anodic metal in the system is adequately protected.

Issue:A basis was not provided for the 100 mV polarization criterion to demonstrate that the effects of mixed potentials are minimal and the most anodic metal in thesystem is adequately protected.

Request:State the basis for use of the negative 100 mV minimum polarization criterion, orrevise the Buried Piping and Tanks Inspection Program to be consistent with thecathodic protection criteria stated in LR-ISG-2011-03.

RESPONSE RAI 2011-03-1 The cathodic protection system NACE International negative 100 mV minimumpolarization criterion is applied to the manways and vents located at the top of the two Attachment L-14-114Page 2 of 4emergency diesel generator fuel oil storage tanks (T-1 53-1 and T-1 53-2) because theirpolarization instant off values range from 15-150 mV below the -850 mV CSE criterion.

However, the 100mV minimum polarization criterion is being met at all locations on thefuel oil piping and tanks, including the tanks' manways and vents. The mixed potentials are minimal, and the tank is made of steel, so there are no other metals of concern.Each steel emergency diesel generator fuel oil storage tank is 12 feet in diameter and50 feet in length, and has a gross capacity of approximately 40,000 gallons.

The tanksare installed above grade elevation with tornado missile protection provided by atruncated pyramid of structural backfill built around the tanks (i.e., mound-buried).

Corrosion of the tanks is prevented by protective coatings and by cathodic protection.

The original impressed current cathodic protection system was installed in 2008 toprotect each underground emergency diesel generator fuel oil storage tank 1 -Y2"diameter supply pipeline.

The two pipelines run underground for approximately 442 feet,and extend from the diesel fuel oil storage tanks to the emergency diesel generators inthe Auxiliary Building.

The cathodic protection system was upgraded in April 2012 to provide cathodicprotection for the mound-buried emergency diesel generator fuel oil storage tanks. Theupgraded cathodic protection system was installed as designed and is operating properly.

However, the NACE -850 mV polarized potential criterion is being met at alllocations except the top of the mound, which is approximately 13 feet above grade. Forthe purposes of the Davis-Besse Buried Piping and Tanks Inspection

Program, theNACE 1 OOmV minimum polarization criterion will be used as the acceptance criterion forthe manways and vents at the top of the mound over the emergency diesel generator fuel oil storage tanks, as these locations have polarization values less than -850 mV. Atall other locations that are cathodically protected, the -850 mV polarized potential instant off acceptance criterion will be applied.To ensure that the manways and vents at the top of the mound over the emergency diesel generator fuel oil storage tanks are not degrading due to the lower polarization criterion, ultrasonic testing (UT) thickness measurements of the manways and vents foremergency diesel generator fuel oil storage tanks T1 53-1 and T1 53-2 will be performed prior to entering the period of extended operation and every 10 years during the periodof extended operation to ensure that the metal thickness in those areas remainssatisfactory.

Davis-Besse License Renewal Application, Table A-I, "Davis-Besse License RenewalCommitments,"

Commitment No. 3, and Section B.2.7, "Buried Piping and TanksInspection Program,"

are revised to clarify the cathodic protection system acceptance criteria.

See the Enclosure to this letter for the revision to the Davis-Besse LRA.

Attachment L-14-114Page 3 of 4Question RAI 2011-03-2

Background:

Commitment No. 44 states that cathodic protection will be provided for theemergency diesel fuel oil storage tanks prior to entering the period of extendedoperation.

In reference to tank inspections, Commitment No. 3, and theassociated enhancement, state, "[t]hese inspections are not required if it isdemonstrated that the tanks are cathodically protected in accordance with NACEInternational (NACE) Standard Practice SP0169-2007, "Control of ExternalCorrosion on Underground or Submerged Metallic Piping Systems,"

or NACEStandard Recommended Practice RP0285-2002, "Corrosion Control ofUnderground Storage Tank Systems by Cathodic Protection."

LR-ISG-2011-3, Table 4c, "Inspections of Buried Tanks for all Inspection Periods,"

recommends that tank inspections are not required if the tank is cathodically protected in accordance with the provisions of footnote 3 of the Table. If thetanks are not cathodically protected or the cathodic protection does not meet theavailability and effectiveness goals in footnote 3, they should be inspected inaccordance with Table 4c.Issue:The staff noted that, in the event that the emergency diesel fuel oil storage tanksare not cathodically protected (due to a future commitment change),

thecorrective action process will not necessarily lead to the tank inspections inTable 4c. In addition, if the cathodic protection system does not meet availability or effectiveness goals, it is not clear to the staff that tank inspections will beconducted.

The staff considers the incorporation of these inspections intoCommitment No. 3 and No. 44, as necessary to ensure that aging can be managedthroughout the period of extended operation.

Request:State the basis for not including the recommended fuel oil storage tankinspections into the Buried Piping and Tanks Inspection Program in the eventthat the tanks are not cathodically protected, or the cathodic protection systemdoes not meet availability or effectiveness goals. Alternatively, reviseCommitment No. 3 and No. 44, and the associated enhancements to require thattank inspections meet the recommendations of Table 4c.

Attachment L-14-114Page 4 of 4RESPONSE RAI 2011-03-2 Cathodic protection was installed and operational for the in-scope buried emergency diesel generator fuel oil storage tanks and associated fuel oil supply piping from thestorage tanks to the emergency diesel generators in the Auxiliary Building on April 10,2012, greater than five years prior to entering the period of extended operation.

Also,the buried Service Water System piping and buried diesel fuel oil piping from theaboveground diesel oil storage tank to the Auxiliary Building have been cathodically protected.

Therefore, License Renewal Application Table A-I, "Davis-Besse LicenseRenewal Commitments,"

Commitment No. 44, is revised to state "Complete".

The Davis-Besse license renewal Buried and Underground Piping and Tanks Programwill be enhanced to include the following statement regarding fuel oil storage tankinspections:

Add a requirement that, IF the cathodic protection system for theemergency diesel generator fuel oil storage tanks (DB-T153-1 andDB-TI53-2) meets the availability criteria of Table 4c "Inspections ofBuried Tanks for all Inspection Periods,"

(i.e., footnotes 3.i, 3.ii and 3.iii)of LR-ISG-2011-03, Appendix A, "Revised GALL Report AMP XI.M4 1,"THEN no Table 4c inspections of tanks DB-T153-1 and DB-T153-2 arerequired.

Otherwise, perform inspections of tanks DB-T153-1 andDB-T153-2 in accordance with Table 4c of LR-ISG-2011-03.

License Renewal Application Table A-I, "Davis-Besse License Renewal Commitments,"

Commitment No. 3, and Section B.2.7, "Buried Piping and Tanks Inspection Program,"

are revised to include the tank inspection recommendations of LR-ISG-2011-03, Table 4c, as described above.See the Enclosure to this letter for the revision to the Davis-Besse LRA.

Enclosure Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse)

Letter L-14-114Amendment No. 49 to theDavis-Besse License Renewal Application Page 1 of 11License Renewal Application Sections AffectedTable A-1Section B.2.7The Enclosure identifies the change to the License Renewal Application (LRA) byAffected LRA Section, LRA Page No., and Affected Paragraph and Sentence.

Thecount for the affected paragraph,

sentence, bullet, etc. starts at the beginning of theaffected Section or at the top of the affected page, as appropriate.

Below each sectionthe reason for the change is identified, and the sentence affected is printed in italics withdeleted text #ned eu and added text underlined.

Enclosure L-14-114Page 2 of 11Affected LRA SectionTable A-1LRA Page No.Pages A-55thru A-57Affected Paragraph and SentenceCommitment No. 3,Based on the responses to NRC requests for additional information (RAI) 2011-03-1 and 2011-03-2, licenserenewal future Commitment No. 3 of LRA Table A-i, "Davis-Besse License Renewal Commitments,"

previously revised by FENOC letter dated September 20, 2013 (ML1 3269A027),

is revised to read:Table A-1Davis-Besse License Renewal Commitments Related LRAItem Commitment Implementation Source Section No./Number Schedule CmetComments3 Enhance the Buried Piping and Tanks Inspection Program to: Prior to LRA A. 1.7" Add 1) bolting for buried Fire Protection System piping, and April 22, 2017 and B.2.72) the emergency diesel fuel oil storage tanks (DB-T153-1, FENOC andDB-T1 53-2) to the scope of the program.

Letters" Conduct annual ground potential surveys of the cathodic L-11-153, NRC RAesprotection system. Monitor cathodic protection voltage and L-13-160, B.2. 7-1 fromcurrent monthly to determine the effectiveness of cathodic and NRC Letterprotection systems and, thereby, the effectiveness of corrosion L-13-304 datedmitigation.

Trend voltage,

current, and ground potential readings and April 20, 2011,and evaluate for adverse changes.

L-14-114* Require that the activity of the jockey fire pump or equivalent A. 1-1 fromparameter be monitored on at least a monthly interval.

NRC Letter Enclosure L-14-114Page 3 of 11Table A-1Davis-Besse License Renewal Commitments Item IRelated LRAImplementationRead AItem Commitment Imple Source Section No./Number ScheduleComments Conduct a flow test by the end of the next refueling outagewhen unexplained changes in jockey pump activity areobserved.

• Require that the directed buried pipe inspection locations beselected based on risk.* Require that the minimum number of buried in-scope pipinginspections during the 30-40, 40-50, and 50-60 year operating period is one steel-piping segment.

Perform the directed buriedsteel pipe and-tank-inspections each ten year interval basedupon table 4a, "Inspections of Buried Pipe," in the XI.M41 agingmanagement program described in LR-ISG-2011-03.

Eachinspection will have a minimum of 10 feet of piping inspected.

" Require that, IF the cathodic protection system for theemergency diesel generator fuel oil storage tanks (DB-T153-1 and DB-T153-2) meets the availability criteria of Table 4cdatedMarch 26,2013,and2011-03-1 and2011-03-2 fromNRC LetterdatedFebruary 11,2014"Inspections of Buried Tanks for all Inspection Periods,"

"iJe.,footnotes 3.i, 3.ii and 3.iii) of LR-ISG-2011-03, Appendix A."Revised GALL Report AMP XI.M4 1." THEN no Table 4cinspections of tanks DB-T153-1 and DB-T153-2 are required.

Otherwise, perform inspections of tanks DB- T153-1 and DB-T153-2 in accordance with Table 4c of LR-ISG-2011-03.4-he EDG Fuel OilStorage Tank-s(DB T153I anI;d DB T153 2)bein..e.t,-d per- to entoing the period of extended opertion,.

The ;4SPeNcti 1on 11 '-i' ; thera visual in;petion of at least 25%

Enclosure L-14-114Page 4 of 11Table A-1Davis-Besse License Renewal Commitments Item Implementation IRelated LRAIter Commitment Sheme Source Section No./Number ScheduleComments of each tank and inclUde at l-a-St cornoM portion of the tank topand boefo, or, an intorntal inpoction con.iting of U)roaswenomnts with at least one square foolof the sufaco o9f thio tanksA. ThosoA inpectionS arc not reqUired iaccordanGo wthý NACE Intornationa!

(4A CE Standard PrFactico SP 166920_07, "Control of EWornal Corro4ion on Und, rgroudor- Submorgod Motal.. P-ping Systems,"

or NACE StandarReommndod Pra-cdie RP0285 _21002L,

.... qon C.ontrol oUndorground Storage Tank Syetems by Cathodic Protetion-."

• Require that ultrasonic testing (UT) thickness measurements ofthe manways and vents for emergency diesel generator fuel oilstorage tanks T153-1 and T153-2 will be performed prior toentering the period of extended operation and every 10 yearsduring the period of extended operation to ensure that the metalthickness in those areas remains satisfactory.

• Add a mq..... Require that underground piping in thedecay heat removal and low pressure injection system locatedin the borated water piping trench will be visually inspected during the 30-40, 40-50, and 50-60 year operating periods toconfirm the absence of aging effects.* Require that if adverse indications are detected, the inspection sample sizes, within the affected piping categories, are initially doubled and if adverse conditions are discovered in the Enclosure L-14-114Page 5 of 11Table A-1Davis-Besse License Renewal Commitments Item Ii Related LRAIter Commitment Implementation Source Section No./Number ScheduleComments expanded sample, the size of the follow-on inspections isdetermined by establishing the extent of condition and extent ofcause, consistent with the FENOC Corrective Action Program.Scheduling of additional examinations is based on the severityof the degradation identified and commensurate with theconsequences of a leak or loss of function, but in all cases, theexpanded sample inspection should be completed within the10-year interval in which the original adverse indication wasidentified.

Further inspections are conducted in locations withsimilar materials and environment, or the piping is replaced on aschedule based upon either the station's need to return thesystem to service for non-Technical Specification-related systems or the allowed outage time for Technical Specification-related systems.* Require that an inspection of buried Fire Protection Systembolting will be performed when the bolting becomes accessible during opportunistic or focused inspections.

• Require that the inspections of buried piping be conducted usingvisual (VT-3 or equivalent) inspection methods.

Excavation shallbe a minimum of 10 linear feet of piping, with all surfaces of thepipe exposed.

Enclosure L-14-114Page 6 of 11Table A-1Davis-Besse License Renewal Commitments Item IImplementation Related LRAIter Commitment ISheme Source Section No./Number j Schedule CmetComments* Include the following acceptance criteria in the programprocedure:

o The cathodic protection survey acceptance criteria forprotected piping and tanks, with the exception of themanways and vents at the top of the mound over emergency diesel generator fuel oil storage tanks T153-1 and T153-2,are the -850 m V relative to a copper/copper sulfatereference electrode (CSE), instant off and limiting criticalpotential not more negative than 1200 miV. For the manwaysand vents at the top of the mound over tanks T153-1 andT153-2, the acceptance criterion is the 100 mV minimumpolarization testing criteria listed in NACE SP0169 2007,The eathedic proetotion cw~,'ay aGcaptanco criteriai

-garc tho950 mY realaiv to a coppor/copP9 parcfate roforonco oloctFodo (CSE,, instant eff or 1600 mV mginimumpelaFration

' in" _c "itoia Aisted in NAI = SP 160 2007 andlimitig critial potonta no mon oativo than 1200 rnVo For coated piping or tanks, there should be either noevidence of coating degradation or the type and extent ofcoating degradation should be insignificant as evaluated byan individual possessing a NACE Coating Inspector Program Level 2 or 3 inspector qualification or an individual has attended the Electric Power Research Institute (EPRI)Comprehensive Coatings Course and completed the EPRI Enclosure L-14-114Page 7 of 11Table A-1Davis-Besse License Renewal Commitments ItemImplmenttionRelated LRAItem Commitment Implementation Source Section No./Number Schedule CmetCommentsBuried Pipe Condition Assessment and Repair TrainingComputer-Based Training Course. Where damage to thecoating has been evaluated as significant and the damagewas caused by nonconforming

backfill, an extent of condition evaluation should be conducted to ensure that the as-leftcondition of backfill in the vicinity of observed damage willnot lead to further degradation; o If metallic piping or tanks show evidence of corrosion, theremaining wall thickness in the affected area is determined to ensure that the minimum wall thickness is maintained; and,o Changes in jockey pump activity or equivalent parameter that cannot be attributed to causes other than leakage fromburied piping are not occurring.

Enclosure L-14-114Page 8 of 11Affected LRA SectionLRA Page No.Affected Paragraph and SentenceTable A-1Page A-69Commitment No. 44The actions required by license renewal future Commitment No. 44 in LRA Table A-i, "Davis-Besse LicenseRenewal Commitments,"

updated by FENOC Letter dated March 26, 2013 (ML13114A254),

have been completed.

The Implementation Schedule is revised to read "COMPLETE",

as follows:Table A-1Davis-Besse License Renewal Commitments Im Related LRAItem Commitment Implementation Source Section No./Number Schedule CmetComments44 Cathodically protect the EDG fuel oil storage tanks (DB-T153-1 PFerto FENOC Responses toand DB-T153-2) and the in-scope fuel oil and Service Water -,.÷othbor 22, 2016 Letters NRC RAIsburied piping in accordance with NACE SP0169-2007 or COMPLETE L-11-203, B.2.7-1 fromNACE RP0285-2002.

L-11-218, NRC Letterand datedL-13-160 April 20, 2011,and as modified perL-14-114 telecon with theNRC held onJune 7, 2011,andA.1-1 fromNRC Letter Enclosure L-14-114Page 9 of 11Table A-1Davis-Besse License Renewal Commitments Item Implementation Related LRANumber Commitment Schedule Source Section No.!CommentsdatedMarch 26, 2013 Enclosure L-14-114Page 10 of 11Affected LRA Section LRA Page No. Affected Paragraph and SentenceB.2.7 Page B-41 Enhancements

-bulleted items"Detection of Aging Effects" and"Acceptance Criteria" In response to RAIs 2011-03-1 and 2011-03-2, LRA Section B.2.7, "Buried Pipingand Tanks Inspection Program,"

subsection titled "Enhancements,"

bulleteditems "Detection of Aging Effects" (4th and new 5th paragraphs) and "Acceptance Criteria" (1st sub-bullet),

previously revised by FENOC letter datedSeptember 20, 2013 (ML1 3269A027),

are revised to read as follows:Detection of Aging EffectsAdd a requirement that, IF the cathodic protection system for theemergency diesel generator fuel oil storage tanks (DB-T153-1 and DB-T153-2) meets the availability criteria of Table 4c "Inspections of BuriedTanks for all Inspection Periods,"

(i.e., footnotes 3.i, 3.ii and 3.iii) of LR-ISG-2011-03, Appendix A, "Revised GALL Report AMP XI.M4 1," THEN noTable 4c inspections of tanks DB-T153-1 and DB-T153-2 are required.

Otherwise, perform inspections of tanks DB-T153-1 and DB-T153-2 inaccordance with Table 4c of LR-ISG-2011-03.

the emer.gency dieegenerator f4ei oil storage tanks (B T-153-I and D9 T-153-2) wil beinspected prior to the f operation.

The npetion will baeither- a visual insec-tionP ofat least 25% of each tank and include; at feas;some porioen of the tank tp an boffoem or-, an internal inspectio consisting of UT measurements wit at least one moeasureenp;

,square foot of the sur-face of the tanks. These inspections arant euieif it is deosrtdthat the tank-s are cathodicaly protected inacco.__;rd-An ceWith NIACE- Ihternation-al

('NAGCE Standard Pr~actice SP 1!692007, "C~ontrol of External Corsino UndergroGund or Submerged Metalli Piping Systems;"

or- NAC4E Stand-ardRoomone PrFactice RP0285 2002m, "Corrosion Control of Undergroeund Storage Tank Systmby Cathodic Protection."

Add a requirement that ultrasonic testing (UT) thickness measurements ofthe manways and vents for emergency diesel -generator fuel oil stora-getanks T153-1 and TI153-2 will be performed prior to entering the period ofextended operation and every 10 years during the period of extendedoperation to ensure that the metal thickness in those areas remainssatisfactory.

Enclosure L-14-114Page 11 of 11Acceptance CriteriaThe program procedure will be enhanced to state that:o The cathodic protection survey acceptance criteria for protected pipingand tanks, with the exception of the manways and vents at the top ofthe mound over emergency diesel generator fuel oil storage tanksT153-1 and T153-2, are the -850 mV relative to a copper/copper sulfate reference electrode (CSE), instant off and limitinq criticalpotential not more negative than 1200 mV. For the manways and ventsat the top of the mound over tanks T153-1 and T153-2, the acceptance criterion is the 100 mV minimum polarization testing criteria listed inNACE SP0169 2007. The cathodc n su.y ..c. ..ptanccriteria ame the 85 Fn e-lative to a GWppeFIWPper sulft Feference

,lect,,de (CSE), instant off -or 10 minimum p.,,,olrization testingcrterfia listed in NAE SPQDI16 2007- and limtinWgcritical potential notmore negativo than 1200 mgV-