Text

Response to Request for Additional Info Re Proposed License Amendment to Relocate Pressure and Temperature Curves to Pressure & Temperature Limits Report
	ML13191A748
Person / Time
Site:	Fermi
Issue date:	07/09/2013
From:	Conner J; DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML13191A907	List: NRC-13-0026, Response to Request for Additional Info Re Proposed License Amendment to Relocate Pressure and Temperature Curves to Pressure & Temperature Limits Report;
References
	DRF Section 0000-0153-5712 R1, NRC-13-0026 NEDO-33785, Rev 1
	Download: ML13191A748 (77)
	v • d • e

J. Tod Conner Site Vice President DTE Energy Company 6400 N. Dide Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.5295 Email: connerj@dteenergy.con DTE nergy-Proprietary Information - Withhold Under 10 CFR 2.390 10 CFR 50.90 July 9, 2013 NRC-13-0026 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, "Proposed License Amendment to Relocate Pressure and Temperature Curves to a Pressure Temperature Limits Report," NRC-12-0037, dated December 21, 2012 (ML13004A134)

Subject:

Response to Request for Additional Information regarding the Proposed License Amendment to Relocate the Pressure and Temperature Curves to a Pressure and Temperature Limits Report In Reference 2, DTE Electric Company (DTE) [Formerly, The Detroit Edison Company] submitted a license amendment request for Fermi 2 to relocate the Pressure and Temperature (P/T) Curves from the Technical Specifications to a Pressure and Temperature Limits Report (PTLR). In an email dated April 10, 2013 from Mr. Mahesh Chawla of NRC to Mr. Alan Hassoun of DTE (Accession No. ML13101A195), the NRC staff requested additional information to complete the review. Enclosure 1 to this letter provides DTE's response to the NRC staff request.

This submittal also incorporates a revision to the P/T curves contained in the PTLR provided in Enclosure 5 to Reference 2. During a review of information used for the development of the curves in Reference 2, it was identified that the fluence value used in calculating the 32 Effective Full Power Year (EFPY) curves was based on a total exposure period of less than 32 EFPY for the Water Level Instrumentation Enclosures 3 and 6 contain Proprietary Information - Withhold Under 10 CFR 2.390.

When separated from Enclosures 3 and 6, this document is decontrolled.

USNRC NRC-13-0026 Page 2 (WLI) nozzle. The total exposure period was based on the maximum anticipated exposure at the end of the current 40 year operating license. While the curves provided in reference 2 would remain conservative throughout the current operating license, Enclosures 3 and 5 of this submittal provide revised, more conservative P/T curves that utilize fluence values based on an exposure period of 32 EFPY.

Enclosures 3 and 5 also provides revised 24 EFPY curves that are calculated based on fluence values associated with actual and expected exposure periods, instead of scaled fluence values from ones calculated for the original 32 EFPY curves.

Additionally, some information provided in Enclosures 1, 6 and 7 of Reference 2 has been updated as part of this submittal based on the revised PTLR and other pertinent evaluations. Enclosure 2 provides a summary of information updated in this submittal. Enclosures 6 and 8 of this letter provide revised proprietary and nonproprietary versions of one of the responses provided in Enclosures 6 and 7 of Reference 2.

The NRC also requested a revision to an affidavit submitted with Reference 2.

Enclosure 9 provides a revised affidavit for withholding the Electric Power Research Institute (EPRI) proprietary information contained in Enclosure 6 of Reference 2.

This affidavit replaces the one previously provided in Enclosure 6 of Reference 2.

The following is a summary of Enclosures provided with this letter:

Enclosure 1: Response to Request for Additional Information Enclosure 2: Update of Information Provided in Reference 2 Enclosure 3: Revised PTLR (proprietary)

Enclosure 4: General Electric-Hitachi (GEH) Affidavit for Revised PTLR Enclosure 5: Revised PTLR (Nonproprietary)

Enclosure 6: Revised Response to Grand Gulf RAI 8 (Proprietary)

Enclosure 7: GEH Affidavit for Response to Grand Gulf RAI 8 Enclosure 8: Revised Response to Grand Gulf RAI 8 (Nonproprietary)

Enclosure 9: Revised EPRI Affidavit for Enclosure 6 of Reference 2 In accordance with 10 CFR 2.390, DTE requests withholding of Enclosures 3 and 6 from public disclosure. Enclosure 3 contains information that is considered proprietary by EPRI. An affidavit supporting this request is provided in Enclosure 4 and a nonproprietary version of Enclosure 3 is provided in Enclosure 5. Enclosures 6 is considered proprietary by General Electric-Hitachi (GEH). An affidavit supporting this request is included in Enclosure 7 and a nonproprietary version of Enclosure 6 is provided in Enclosure 8.

DTE has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 2. The additional information provided in this submittal has no effect on

USNRC NRC-13-0026 Page 3 the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Also, the additional information provided in this submittal has no effect on the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

No new commitments are being made in this submittal.

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

Zachary W. Rad of my staff at (734) 586-5076.

Sincerely, II cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-13-0026 Page 4 I, J. Todd Conner, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

Todd Conner Site Vice President Nuclear Generation On this 9th day of July, 2013 before me personally appeared J. Todd Conner, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public SHARON S. MARSHALL NOTARY PUBLIC, STATE OF MI COUNTY OF MONROE MY COMMISSION EXPIRES Jun 14, 2019 ACTING INCOUNTYOF /(or ot

Enclosure 1 to NRC-13-0026 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to Request for Additional Information to NRC-13-0026 Page 1 Response to Request for Additional Information Item 1: Use of Integrated Surveillance Program Data Page 2 of Enclosure I to the December 21, 2012, license amendment request states, "The latest informationfrom the Boiling Water Reactor Vessel andInternals Project (BWRVIP) Integrated Surveillance Program (ISP) that is applicableto Fermi 2 has been utilized."

Pleaseprovide additionalinformation:

" Provide specific reference detailsfor the latest information, to which the above statement refers. If it is not available to the NRC, please submit it.

" Explain how this information is applicable to Fermi 2.

" Explain how the information has been utilized.

Response

The integrated surveillance program (ISP) material data utilized in the preparation of the Pressure and Temperature Limits Report (PTLR) was obtained from BWRVIP-135, Revision 2.

BWRVIP-135, Revision 2 contains the most current and representative plate and weld specimens applicable to the Fermi 2 reactor pressure vessel (RPV). The information from BWRVIP-135, Revision 2 that is applicable to Fermi 2 was provided in the Fermi 2 response to Grand Gulf's RAI 6 which was included in Enclosure 6 of Reference 2. The plate specimen in the BWRVIP ISP Program is not the identical heat number as the Fermi 2 plate material but was determined to be the closest match in terms of material properties. The weld specimen in the BWRVIP ISP program is the exact heat/lot number as that used for the Fermi 2 vessel weld(s).

The ISP plate material is not the same heat as that identified as the Target Vessel Material in BWRVIP-135, Revision 2. Therefore, evaluation of this material for adjusted reference temperature (ART) is not applicable to the Fermi 2 Pressure and Temperature (P/T) curve analysis. This information is provided in the ART table for information only. However, the ISP weld material is the identical heat as that identified as the Target Vessel Material in BWRVIP-135, Revision 2. The evaluation of this material is presented in the "Integrated Surveillance Program" section of the ART table. The material properties identified in BWRVIP-135, Revision 2 are used; this includes the chemistry values and the calculated value of the adjusted Chemistry Factor (CF). The plant-specific material properties for the initial RTNDT and fluence are also used. This material represents the limiting ART for the beltline region, and is considered in development of the PT curves.

The ART values for 24 and 32 EFPY included in the PTLR were developed considering the latest BWRVIP-135, Revision 2 ISP published surveillance data available that is representative of the applicable materials in the Fermi 2 RPV. The surveillance data used in the Fermi 2 ART calculations was not obtained from actual Fermi 2 RPV test specimens. The ISP plate material is not from the identical heat and did not have the limiting ART. Therefore, the ART is not applicable for use in the Fermi 2 evaluation, was not considered in development of the P/T to NRC-13-0026 Page 2 curves, and is provided for information only. The ISP weld material is the identical heat to the material in the Fermi 2 RPV and has the limiting ART; this value is considered in the development of the P/T curves. The ISP information was utilized as described in the above paragraph.

Item 2: Assumptions Used in Fluence Calculations The information in the following table summarizes signficant assumptions regardingthe flux over discrete exposure periods, and is developed using data on Page 2 of Enclosure I to the December 21, 2012, license amendment request:

Object Exposure Period Power Level OperatingAssumption PIT Curve 12.04 EFPY[I] 3430 CLTP[2]

P/T Curve 19.96 EFPY 3952 EPU[3]

WLJ[4] Nozzle 3.228 EFPY 3293 OLTP[5]

WLI Nozzle 16.35 EFPY 3430 CLTP WLI Nozzle 10.59 3486 MUR[6]

1. Explain whether,for any of the above exposure periods, reactorvessel neutronfluence was calculatedusing any methods other than the referenced General Electric-Hitachi analytic methods describedin NEDC-32983P-A.

2. For the above exposure periods, explain whether a generalizedcore flux source was assumed, or whether cycle-specificflux distributionswere assumed.

3. A measurement uncertainty recapture (MUR) uprate relies largely on analyses that are unaffected by the increase in power level, because the assumedpower level includes an uncertainty that bounds both pre- andpost-MVUR core powers. Explain how the MUR assumptions in the fluence analysis differ from the CLTP assumptions, and whether the uncertainty analysisfor the reactor vessel neutronfluence is affected by these assumptions.

[]Effective fidl-power years

[2]Currentlicensed thermal power

[3]Extendedpower uprate

[4]Water level instrument

[5]Originallicensed thermalpower T6]Measurement uncertainty recapture to NRC-13-0026 Page 3

Response

1. Two flux models were created, the Cycle 6 CLTP (3430 MWt) rated thermal power (RTP) core and the EPU RTP (3952 MWt) core; both core models were generated in adherence to the General Electric-Hitachi (GEH) fluence method of NEDC-32983P-A (TAC No.

MC3788).

2. As stated above, two flux models were generated, one for CLTP RTP (3430 MWt) and one for EPU RTP (3952 MWt). Flux values at CLTP and EPU exposure intervals were taken directly from the CLTP and EPU cycle-specific flux models, respectively. Flux values at OLTP and MUR exposure intervals were derived by scaling the CLTP flux value with power adjustment factors.

3. The method used to evaluate the MUR flux value in the fluence analysis relies on scaling factors. The use of scaling factors is a general industry practice that has been accepted by the NRC during other power uprate amendments. A power adjustment factor was calculated as the ratio of MUR RTP/CLTP RTP, and this adjustment factor was applied to the CLTP flux value to derive the MUR flux value. As the MUR flux value was derived directly from the CLTP flux value, the MUR assumptions in the fluence analysis do not differ from the CLTP assumptions.

The CLTP flux value was calculated from a flux model generated in adherence to GEH fluence method of NEDC-32983P-A. Per Section 7.1 of NEDC-32983P-A, calculation uncertainties associated with power distribution have been assessed and are factored into the total analytically-determined calculation uncertainty for the GEH fluence calculation method.

These same uncertainties are considered applicable to all GEH flux models, therefore the same uncertainties applicable to the CLTP flux model would be considered applicable to a cycle-specific MUR flux model. Therefore, the uncertainty analysis for MUR reactor vessel neutron fluence is not affected by any assumed power level uncertainties associated with MUR core power.

As provided in the cover letter and Enclosure 2 to this letter, the Exposure Periods associated with the Water Level Instrumentation (WLI) nozzle stated in the question above have been revised as part of P/T curves revision described in this submittal.

Enclosure 2 to NRC-13-0026 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Update of Information Provided in Reference 2 to NRC-13-0026 Page 1 Update of Information Provided in Reference 2 This Enclosure provides updates to some information contained in Reference 2. These updates resulted from the revision of the Pressure and Temperature (P/T) curves and the Pressure and Temperature Limits Report (PTLR), and other related evaluations. The information previously provided, the location in Reference 2, and the updated information is provided below:

Information in Reference 2 Updated Information Enclosure 1 Page 2, 6t paragraph, last two sentences:

The fluence was determined for the Water The fluence was determined for the Water Level Instrumentation (WLI) nozzle, excluding Level Instrumentation (WLI) nozzle, excluding extended power uprate but including extended power uprate but including Measurement Uncertainty Recapture (MUR) Measurement Uncertainty Recapture (MUR) uprate, and is based on operation at Original uprate, and is based on operation at Original Licensed Thermal Power of 3293 MWt for Licensed Thermal Power of 3293 MWt for 3.228 EFPY, Current Licensed Thermal Power 3.4 EFPY, Current Licensed Thermal Power (CLTP) of 3430 MWt for approximately 16.35 (CLTP) of 3430 MWt for approximately 16.38 EFPY, and at MUR power of 3486 MWt for EFPY, and at MUR power of 3486 MWt for approximately 10.59 EFPY or through the 12.22 EFPY remainder of the 40 year license.

MUR is planned to be implemented after RF 16 MUR is planned to be implemented after RF 16 or beginning in Cycle 17. or beginning in Cycle 17.

Page 5, 3 rd paragraph, last two sentences:

Investigation by GEH determined that the Investigation by GEH determined that the currently licensed 24 EFPY P/T curves (B, currently licensed 24 EFPY P/T curves (B, core not critical and C, core critical) bound the core not critical and C, core critical) bound the requirements of the WLI nozzle up to 21 requirements of the WLI nozzle up to 20.1 EFPY (Curve A is not impacted). The plant EFPY (Curve A is not impacted). The plant will not reach 21 EFPY levels before the will not reach 20.1 EFPY levels before the sixteenth refueling outage (RF16), currently sixteenth refueling outage (RF16), currently scheduled for the first quarter of 2014. scheduled for the first quarter of 2014.

Page 6, 8 th paragraph, first two sentences:

In 2011, it was determined that Fermi 2 should In 2011, it was determined that Fermi 2 should have been grouped with the plants requiring have been grouped with the plants requiring revision to their P/T curves based on WLI revision to their P/T curves based on WLI material properties. Investigation by GEH material properties. Investigation by GEH determined that the currently licensed 24 determined that the currently licensed 24 EFPY P/T curves bound the requirements of EFPY P/T curves bound the requirements of the WLI nozzle, but only up to 21 EFPY. the WLI nozzle, but only up to 20.1 EFPY.

to NRC-13-0026 Page 2 Information in Reference 2 Updated Information Enclosure 1 (continued)

Page 9, 3 rd paragraph, last two sentences:

Investigation by GEH determined that the Investigation by GEH determined that the currently licensed 24 EFPY P/T curves bound currently licensed 24 EFPY P/T curves bound the requirements of the WLI nozzle, but only the requirements of the WLI nozzle, but only up to 21 EFPY. The PTLR is based on up to 20.1 EFPY. The PTLR is based on revised Fermi 2 P/T curves. revised Fermi 2 P/T curves.

Enclosure 5 PTLR Replace with Enclosure 3 (GEH NEDC-33785P Rev 1, proprietary) and Enclosure 5 NEDO-33785 (GEH NEDO-33785, Rev 1, non-proprietary)

Revision 0 of this letter (NRC-13-0026)

October 2012 NEDO-33785 Revision 1 June 2013 Enclosure 6 Response to NRC RAI 8 (proprietary) Replace with response provided in Enclosure 6 of this letter (NRC-13-0026) to Enclosure 1 to 1-2RXPKK-13 317855-3 Page 8 of9 Page 2 of2 Enclosure 7 Response to NRC RAI 8 (nonproprietary) Replace with response provided in Enclosure 8 of this letter (NRC-13-0026) to 1-2RXPKK-13 Enclosure 2 to 317855-3 Page 8 of 9 Page 2 of 2

Enclosure 4 to NRC-13-0026 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 EPRI Affidavit for PTLR

Attachment 1 C1 RESEARCH INSTITUTE Kurt Edsinger Director, PWR &

BWR Materials June 19, 2013 Document Control Desk Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Request for Withholding of the following Proprietary Information included in:

"DTE Energy/Enrico Fermi Power Plant 2 Pressure and Temperature Limits Report Up to 24 and 32 Effective Full-Power Years" Contained in GE Hitachi Nuclear Energy Americas, NEDC-33785P, Revision 1.

DRF Section 0000-0153-5712 R1, dated June 2013 To Whom It May Concern:

This is a request under 10 C.F.R. §2.390(a)(4) that the U.S. Nuclear Regulatory Commission ("NR) withhold from public disclosure the report identified in the enclosed Affidavit consisting of the proprietary information owned by Electric Power Research Institute, Inc. ("EPR") identified inthe attached report. Proprietary and non-proprietary versions of the Report and the Affidavit insupport of this request are enclosed.

EPRI desires to disclose the Proprietary Information in confidence to assist the NRC review of the enclosed submittal to the NRC by DTE Energy. The Proprietary Information isnot to be divulged to anyone outside of the NRC or to any of its contractors, nor shall any copies be made of the Proprietary Information provided herein.

EPRI welcomes any discussions and/or questions relating to the information enclosed.

If you have any questions about the legal aspects of this request for withholding, please do not hesitate to contact me at (650) 855-2271. Questions on the content of the Report should be directed to Andy McGehee of EPRI at (704) 502-6440.

Sincerely, Together ... Shaping the Future of Electricity PALO ALTO OFFICE 3420 Hillview Avenue, Palo Alto, CA 94304-1395 USA " 650.855.2000 " Customer Service 800.313.3774 " www.epri.com

srmfi2 I HIES ELECTRIC POWER EARCH INSTITUTE AFFIDAVIT RE: Request for Withholding of the Following Proprietary Information Included In:

"DTE Energy/Enrico Fermi Power Plant 2 Pressure and Temperature Limits Report Up to 24 and 32 Effective Full-Power Years" Contained in GE Hitachi Nuclear Energy Americas, NEDC-33785P, Revision 1.

DRF Section 0000-0153-5712 R1, dated June 2013 1,Kurt Edsinger, being duly swom, depose and state as follows:

I am the Director of PWR and BWR Materials at Electric Power Research Institute, Inc. whose principal office is located at 3420 Hillview Avenue, Palo Alto, CA. ("EPRI") and I have been specifically delegated responsibility for the above-listed report that contains EPRI Proprietary Information that is sought under this Affidavit to be withheld "Proprietary Information". I am authorized to apply to the U.S. Nuclear Regulatory Commission ("NRC") for the withholding of the Proprietary Information on behalf of EPRI.

EPRI Information is identified by a solid underline inside double square brackets. ((This sentence is an example.)) {E} Tables containing EPRI proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation {E} refers to this affidavit as the basis for the proprietary determination.

EPRI requests that the Proprietary Information be withheld from the public on the following bases:

Withholding Based Upon Privileged And Confidential Trade Secrets Or Commercial Or Financial Information (see e.g., 10 C.F.R. A2.390(a)(4)):

a. The Proprietary Information is owned by EPRI and has been held in confidence by EPRI. All entities accepting copies of the Proprietary Information do so subject to written agreements imposing an obligation upon the recipient to maintain the confidentiality of the Proprietary Information. The Proprietary Information isdisclosed only to parties who agree, inwriting, to preserve the confidentiality thereof.

b. EPRI considers the Proprietary Information contained therein to constitute trade secrets of EPRI. As such, EPRI holds the Information in confidence and disclosure thereof is strictly limited to individuals and entities who have agreed, inwriting, to maintain the confidentiality of the Information.

c. The information sought to be withheld isconsidered to be proprietary for the following reasons. EPRI made a substantial economic investment to develop the Proprietary Information and, by prohibiting public disclosure, EPRI derives an economic benefit in the form of licensing royalties and other additional fees from the confidential nature of the Proprietary Information. If the Proprietary Information were publicly available to consultants and/or other businesses providing services in the electric and/or nuclear power industry, they would be able to use the Proprietary Information for their own commercial benefit and profit and without expending the substantial economic resources required of EPRI to develop the Proprietary Information.

d. EPR's classification of the Proprietary Information as trade secrets isjustified by the Uniform Trade Secrets Act which California adopted in 1984 and a version of which has been adopted by over forty states. The California Uniform Trade Secrets Act, California Civil Code §§3426 - 3426.11, defines a "trade secret" as follows:

"'Trade secret' means information, including a formula, pattern, compilation, program device, method, technique, or process, that:

(1)Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (2)Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy."

e. The Proprietary Information contained therein are not generally known or available to the public. EPRI developed the Information only after making a determination that the Proprietary Information was not available from public sources. EPRI made asubstantial investment of both money and employee hours in the development of the Proprietary Information. EPRI was required to devote these resources and effort to derive the Proprietary Information. As a result of such effort and cost, both in terms of dollars spent and dedicated employee time, the Proprietary Information ishighly valuable to EPRI.

f. A public disclosure of the Proprietary Information would be highly likely to cause substantial harm to EPRI's competitive position and the ability of EPRI to license the Proprietary Information both domestically and internationally. The Proprietary Information can only be acquired and/or duplicated by others using an equivalent investment of time and effort.

I have read the foregoing and the matters stated herein are true and correct to the best of my knowledge, information and belief. I make this affidavit under penalty of perjury under the laws of the United States of America and under the laws of the State of California.

Executed at 3420 Hillview Avenue, Palo Alto, CA. 94304 being the premises and place of business of Electric Power Research Institute, Inc.

Date:

Kurt Edsinger (State of California)

(County of Santa Clara)

Subs ed a d n o o rmed) before me on this day of , 20D by proved to me on the basi f satisfactory evidence to be the person(s) oappear be me Signature (Seal)

My Commission Expires 0day of 20J BERTE A. DAHL r NOTARY. 1233 n PUBLIC-CALIFORNIACO SWMACLAAA CO4Jvrr Mm. 20,2015 MYCm.Ev.

Enclosure 5 to NRC-13-0026 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Pressure and Temperature Limits Report (PTLR)

NONPROPRIETARY

) HITACHI GE Hitachi Nuclear Energy NEDO-33785 Revision 1 DRF Section 0000-0153-5712 Ri June 2013 Non-ProprietaryInformation - Class I (Public)

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

PROPRIETARY INFORMATION NOTICE This is a non-proprietary version of the document NEDC-33785P, Revision 1, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here (( )).

IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORT PLEASE READ CAREFULLY The design, engineering, and other information contained in this document is furnished for the purposes of supporting the Detroit Edison Energy license amendment request for pressure-temperature curves at Enrico Fermi Power Plant 2 in proceedings before the U.S. Nuclear Regulatory Commission (NRC). The only undertakings of GEH with respect to information in this document are contained in the contracts between GEH and its customers or participating utilities, and nothing contained in this document shall be construed as changing that contract.

The use of this information by anyone for any purpose other than that for which it is intended is not authorized; and with respect to any unauthorized use, GEH makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document.

No use of or right to copy any of this information contained in this document, other than by the NRC and its contractors in support of GEH's application, is authorized except by contract with GEH, as noted above. The information provided in this document is part of and dependent upon a larger set of knowledge, technology, and intellectual property rights pertaining to the design of standardized, nuclear powered, electric generating facilities. Without access and a GEH grant of rights to that larger set of knowledge, technology, and intellectual property rights, this document is not practically or rightfully usable by others, except by the NRC or through contractual agreements with Detroit Edison Energy, as set forth in the previous paragraph.

ii

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Revision Status Sheet Revision Description 0 Initial Issue This revision was prepared to incorporate an updated fluence for the Ni6 Water Level Instrumentation (WLI) nozzle. The Revision 0 report used a fluence for this component that was only valid for approximately 30 EFPY. The updated fluence is valid for 32 EFPY; fluence for 24 EFPY was also specifically calculated. The change in fluence resulted in a 1°F increase in the WLI nozzle 1 ART. The weight percent Nickel for Heat (( )) was incorrect. This revision corrects the %Ni from (( )) and the corresponding chemistry factor from (( )). This change caused a minor change in the ART for this plate material. It is noted that this material is not the limiting ART material and this change had no impact on the P-T curves. All changes have been identified with revision bars in the right margin.

iii

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Table of Contents ABBREVIATIONS & ACRONYMS..............................................................................................v 1.0 P urp o se ................................................................................................................................ 1 2 .0 App licability ......................................................................................................................... 1 3.0 Methodology ........................................................................................................................ 1 3 .1 C h em istry ......................................................................................................................... 2 3.2 Initial Reference Temperature of Nil Ductility Transition (RTNDT)....................................2 3.3 Adjusted Reference Temperature .................................................................................. 2 3.4 Surveillance Program ........................................................................................................ 2 3.5 Beltline Weld Flaw Indications ...................................................................................... 3 3.6 Future Changes ......................................................................... 3 4.0 O perating L im its .................................................................................................................. 3 5 .0 D iscu ssion ............................................................................................................................ 4 6 .0 References............................................................................................................................6 Appendix A Reactor Vessel Material Surveillance Program........................................................A-1 Appendix B Fermi 2 Reactor Pressure Vessel P-T Curve Supporting Plant-Specific Information B-1 Appendix C Fermi 2 Reactor Pressure Vessel P-T Curve Checklist .......................................... C-1 Table of Tables Table 1 Fermi 2 Tabulation of Curves - 24 EFPY ........................................................................... 13 Table 2 Fermi 2 Tabulation of Curves - 32 EFPY ........................................................................... 18 Table B-1 Fermi 2 Initial RTNDT Values for RPV Plate and Flange Materials ................................ B-3 Table B-2 Fermi 2 Initial RTNDT Values for RPV Nozzle Materials...............................................B-4 Table B-3 Fermi 2 Initial RTNDT Values for RPV Weld Materials ................................................. B-6 Table B-4 Fermi 2 Initial RTNDT Values for RPV Appurtenance and Bolting Materials ................. B-9 Table B-5 Fermi 2 Adjusted Reference Temperatures for up to 24 EFPY ................................ B-11 Table B-6 Fermi 2 Adjusted Reference Temperatures for up to 32 EFPY .................................... B-13 Table B-7 Fermi 2 RPV Beltline P-T Curve Input Values for 32 EFPY.......................................B-15 Table B-8 Fermi 2 Definition of RPV Beltline Region ................................................................ B-16 Table C-1 Fermi 2 Checklist ......................................................................................................... C-2 Table of Figures Figure 1 Fermi 2 Composite Curve A Pressure Test P-T Curves Effective for up to 24 EFPY ............ 7 Figure 2 Fermi 2 Composite Curve B Core Not Critical P-T Curves Effective for up to24 EFPY ...... 8 Figure 3 Fermi 2 Limiting Curve C Core Critical P-T Curve Effective for up to 24 EFPY..................9 Figure 4 Fermi 2 Composite Curve A Pressure Test P-T Curves Effective for up to 32 EFPY .......... 10 Figure 5 Fermi 2 Composite Curve B Core Not Critical P-T Curves Effective for up to 32 EFPY ... 11 Figure 6 Fermi 2 Limiting Curve C Core Critical P-T Curve Effective for up to 32 EFPY................12 Figure B-1 Fermi 2 Reactor Pressure Vessel..................... ........................... B-2 iv

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

ABBREVIATIONS & ACRONYMS Term Description

%Cu Weight percent Copper

%Ni Weight percent Nickel 1/4T 1/4 depth into the vessel wall from the inside diameter 3/4T % depth into the vessel wall from the inside diameter ART Adjusted Reference Temperature BAF Bottom of Active Fuel BWR Boiling Water Reactor BWR/6 BWR Product Line 6 BWRVIP BWR Vessel and Internals Project CE Combustion Engineering CF Chemistry Factor CMTR Certified Material Test Report CRD Control Rod Drive EFPY Effective Full Power Years EPU Extended Power Uprate FSAR Final Safety Analysis Report GEH GE Hitachi Nuclear Energy ID Inside Diameter ISP Integrated Surveillance Program LTR Licensing Topical Report MUR Measurement Uncertainty Recovery MWt Megawatt Thermal NDT Nil Ductility Transition n/cm 2 neutrons per square centimeter (measure of fluence)

NRC Nuclear Regulatory Commission P/T Pressure/Temperature P-T Pressure-Temperature PTLR Pressure and Temperature Limits Report RCS Reactor Coolant System RFO Refueling Outage RG Regulatory Guide RPV Reactor Pressure Vessel RTNDT Reference Temperature of Nil Ductility Transition RVID Reactor Vessel Integrity Database (by NRC)

SSP Supplemental Surveillance Program T Temperature TAF Top of Active Fuel TPO Thermal Power Optimization TS Technical Specification UFSAR Updated Final Safety Analysis Report US United States WLI Water Level Instrumentation v

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) 1.0 Purpose The purpose of the Enrico Fermi Power Plant 2 (Fermi 2) Pressure and Temperature Limits Report (PTLR) is to present operating limits relating to:

1. Reactor coolant system (RCS) Pressure versus temperature limits during heatup, cooldown and hydrostatic/class 1 leak testing;

2. RCS heatup and cooldown rates;

3. Reactor pressure vessel (RPV) to RCS coolant AT requirements during Recirculation Pump startups;

4. RPV bottom head coolant temperature to RPV coolant temperature AT requirements during recirculation pump startups;

5. RPV head flange bolt-up temperature limits.

This report has been prepared in accordance with the requirements of Technical Specification (TS) 5.6.8, "Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)".

2.0 Applicability This report is applicable to the Fermi 2 RPV for up to 24 and 32 Effective Full Power Years (EFPY).

The following TS is affected by the information contained in this report:

TS 3.4.10 RCS Pressure and Temperature (P/T) Limits 3.0 Methodology The limits in this report were derived from the Nuclear Regulatory Commission (NRC)-approved methods listed in TS 5.6.8, using the specific revisions listed below:

1. The neutron fluence was calculated per Licensing Topical Report, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluation, NEDC-32983P-A, Revision 2, January 2006, approved in Reference 6.1.

2. The pressure and temperature limits were calculated per GE Hitachi Nuclear Energy Methodology for Development of Reactor Pressure Vessel Pressure-TemperatureCurves, NEDC-33178P-A, Revision 1, June 2009, approved in Reference 6.2.

3. This revision of the pressure and temperature limits is to incorporate the following changes:

" Revision 1 of the PTLR e Application of GEH licensing topical report (LTR) for pressure-temperature (P-T) curves e Thermal power optimization (TPO) at 3486 MWt

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) e The water level instrumentation (WLI) nozzle that occurs in the beltline region was fabricated from carbon steel and has been considered in the adjusted reference temperature (ART) evaluation. The fluence at this location is based on a less conservative power history that excludes EPU and considers TPO after RFO16.

The fluence used considers operation at 3293 MWt for 3.4 EFPY, 3430 MWt for 16.38 EFPY, and 3486 MWt (TPO) for 12.22 EFPY.

3.1 Chemistry The N16 WLI nozzle is defined as being within the beltline region, and is evaluated for ART.

Insufficient information was located to determine the copper and nickel content for these SA508 Class 1 forging materials. All available boiling water reactor (BWR) fleet SA508 Class 1 forging information was reviewed; fourteen (14) copper and thirty-five (35) nickel data points were obtained. The copper and nickel content was determined using the Mean + 1a, resulting in 0.272 %Cu and 0.214 %Ni.

3.2 Initial Reference Temperature of Nil Ductility Transition (RTNDT)

The N16 WLI nozzle is evaluated for ART. The Combustion Engineering (CE) purchase specification for this material demonstrates a required test temperature of 10°F, consistent with the N16 certified material test reports (CMTR). However, insufficient information is available to determine the initial RTNDT. NRC MTEB 5-2, paragraph B.1.1(4) defines the method for determining initial RTNDT where limited Charpy V-Notch tests were performed at a single temperature, as is the case for the N16 material. Testing for one N16 material was performed at 10°F, with a minimum results of 30 ft-lbs and where the maximum results is less than 45 ft-lbs.

Therefore, MTEB 5-2 states that the RTNDT may be calculated as 20°F above the test temperature; hence, the initial RTNDT is determined to be 30°F. Testing for the second N16 material was performed at 10°F, but dropweight was not reported. The dropweight was considered to be 30°F, consistent with MTEB 5-2 guidance. Therefore, the initial RTNDT for this heat is the greater of the dropweight and T5oT - 60°F. The resulting initial RTNDT for this material is 30°F.

3.3 Adjusted Reference Temperature The ART values for 24 and 32 EFPY included in Appendix B are developed considering the latest BWR Vessel and Internals Project (BWRVIP) integrated surveillance program (ISP) published surveillance data available that is representative of the applicable materials in the Fermi 2 RPV (Reference 6.3). The surveillance data used in the Fermi 2 ART calculations is not obtained from actual Fermi 2 RPV test specimens. The ISP plate materials did not have the limiting ART. The ISP weld material has the limiting ART; this value is considered in the development of the P-T curves because the ISP material is the identical heat to the material in the Fermi 2 RPV.

3.4 Surveillance Program As discussed in Appendix A, Fermi 2 participates in the ISP. Two of the surveillance capsules, installed at plant startup, remain in the vessel, while the third capsule was removed at 2

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) approximately 8 EFPY, but was not tested. As Fermi 2 is not a host plant, the three (3) surveillance capsules have an ISP status designation of deferred (standby) per Reference 6.4.

Should actual surveillance capsules be withdrawn and tested from the Fermi 2 RPV (e.g., status change to be an ISP host plant under the BWRVIP ISP), compliance with 10 CFR 50 Appendix H requirements on reporting test results and evaluations on the effects to plant operations parameters (e.g., P-T limits, hydrostatic and leak test conditions) will be in accordance with Section 3 of Reference 6.3.

3.5 Beltline Weld Flaw Indications Three (3) flaw indications have been evaluated for the Fermi 2 vessel, occurring in Shell Ring #2, in weld 15-308 (axial weld). Flaw #124 requirements bound those of Flaw #127 and Flaw #128.

A fracture mechanics evaluation was conducted using techniques consistent with the philosophy of Section XI of the ASME Code. The indication, Flaw #124, was modeled with length equal to 4.24 inches (along the weld thickness direction) and width equal to 2 inches. The long end of the indication is located 0.7 inches from the inside diameter (ID) surface, which includes a clad thickness of 0.3125 inches.

At 32 EFPY, the hydrotest temperature is calculated to be 114.9°F at 1030 psig. For these conditions, the allowable value of K1 is 34.0 ksi-inl' 2 and does not bound the calculated value of K1, which is 35.7 ksi-inu1 2. Therefore, the beltline hydrotest P-T curve must be shifted to the right in order to increase the allowable value of K, resulting in a calculated value of K1 that is bounded by the allowable value of K1. For the 32 EFPY curve, an adjustment of 5°F was applied such that Curve A requires a temperature of 119.9*F at 1030 psig. Similarly, an adjustment of 13°F was applied for 24 EFPY.

For the limiting leak test condition at 32 EFPY, the highest calculated value of applied stress intensity factor was 35.7 ksi-in"2 and the allowable value of K was calculated to be 35.9 ksi-in" 2. Because the calculated value of K is less than the allowable value of K1, the indication is not expected to become a surface indication during future operation. The indication is acceptable in the as-is condition for operation up to 32 EFPY, including TPO/ measurement uncertainty recovery (MUR).

3.6 Future Changes Changes to the curves, limits, or parameters within this PTLR, based upon new irradiation fluence data of the RPV, or other plant design assumptions in the updated final safety analysis report (UFSAR), can be made pursuant to 10 CFR 50.59, provided the above methodologies are utilized. The revised PTLR shall be submitted to the NRC upon issuance.

4.0 Operating Limits The pressure-temperature (P-T) curves provided in this report represent steam dome pressure versus minimum vessel metal temperature and incorporate the appropriate non-beltline limits and irradiation embrittlement effects in the beltline region.

3

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

The operating limits for pressure and temperature are required for three categories of operation:

(a) hydrostatic pressure tests and leak tests, referred to as Curve A; (b) non-nuclear heatup/cooldown (core not critical), referred to as Curve B; and (c) core critical operation, referred to as Curve C.

Complete P-T curves were developed for 24 and 32 EFPY. The P-T curves are provided in Figures 1 through 6, and a tabulation of the curves is included in Table 1 (24 EFPY) and Table 2 (32 EFPY).

Other temperature limits applicable to the RPV and controlled by the TS are:

" Heatup and cooldown rate limit during Hydrostatic and Class 1 Leak Testing:

20 F/hour.

Normal operating heatup and cooldown rate limit: 100°F/hour.

" RPV bottom head coolant temperature to RPV coolant temperature AT limit during Recirculation Pump startup: <145°F.

" Recirculation loop coolant temperature to RPV coolant temperature AT limit during Recirculation Pump startup: 550°F.

" RPV flange and adjacent shell temperature limit: >72°F.

5.0 Discussion The procedures described in References 6.1 and 6.2 were used in the development of the P-T curves for Fermi 2.

The method for determining the initial reference temperature of nil-ductility transition (RTNDT) for all vessel materials is defined in Section 4.1.2 of Reference 6.2. Initial RTNDT values for all vessel materials considered are presented in tables in Appendix B of this report.

For Fermi 2, the limiting surveillance material, weld heat 13253/12008, was considered using Procedure 1 as defined in Appendix I of Reference 6.2. This procedure was used because the target vessel material and the surveillance material are identical heats.

For Fermi 2, there are four (4) thickness discontinuities in the vessel: (1) between the bottom head upper and lower torus, (2) between the bottom head torus and the support skirt attachment, (3) between the bottom head torus and Shell Ring #1, and (4) between Shell Ring #1 and Shell Ring #2. The P-T curves defined in Section 4.3 of Reference 6.2 are based upon an RTNDT of 30°F for the bottom head Curves A and C, 44.6°F for the bottom head Curve B, and 25°F for the upper vessel. The 24 EFPY beltline curves are based on an ART of 75°F, and the 32 EFPY beltline curves are based on an ART of 82°F. Curves based on these temperatures bound the requirements due to the flaws discussed in Section 3.5, and the beltline thickness discontinuities.

The ART of the limiting beltline material is used to adjust the beltline P-T curves to account for irradiation effects. Regulatory Guide (RG) 1.99, Revision 2, provides the methods for 4

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) determining the ART. The RG 1.99 methods for determining the limiting material and adjusting the P-T curves using ART are discussed in this section.

The vessel beltline copper and nickel values, with the exception of the N16 WLI nozzle, were obtained from plant-specific vessel purchase order records, CMTRs. The N16 nozzle is fabricated from SA508 Class 1 material; there is insufficient plant-specific chemistry information for these nozzles. Therefore, chemistry values using BWR fleet data and Mean + la have been considered. The copper (Cu) and nickel (Ni) values were used with Tables 1 and 2 of RG 1.99, to determine a chemistry factor (CF) per paragraph 1.1 of R.G 1.99 for welds and plates, respectively. ART values for 24 and 32 EFPY are presented in Appendix B. The ART tables also include plant-specific materials considering best estimate chemistry values obtained from Reference 6.3.

The P-T curves for the non-beltline region were conservatively developed for a BWR product line 6 (BWR/6) with nominal ID of 251 inches. The analysis is considered appropriate for Fermi 2 because the plant-specific geometric values are bounded by the generic analysis for the large BWR/6. The generic value was adapted to the conditions at Fermi 2 using plant-specific RTNDT values for the reactor pressure vessel.

The peak RPV ID fluence used in the P-T curve evaluation for Fermi 2 at 24 EFPY is 7.13e17 n/cm 2 and at 32 EFPY is 9.68e17 n/cm 2. These values were calculated using methods that comply with the guidelines of RG 1.190, (as discussed in Reference 6.1). This fluence applies to the lower-intermediate shell plates and longitudinal welds. The fluence is adjusted for the lower plates, associated longitudinal welds, and the girth weld based upon the axial fluence distribution calculated as part of the fluence evaluation; hence, the peak ID surface fluence for these components is 4.66e17 n/cm 2 for 24 EFPY and 6.23e17 n/cm 2 for 32 EFPY. Similarly, the fluence is adjusted for the N16 nozzle based upon the axial fluence distribution; hence the peak ID surface fluence used for this component is 1.30e17 n/cm 2 for 24 EFPY and 1.74e17 n/cm 2 for 32 EFPY. It is also noted that the fluence used for the N16 nozzle is based on a less conservative power history as noted in Section 3.0.

The P-T curves for the heatup and cooldown operating conditions at a given EFPY apply for both the 1/4T and 3/4T locations. When combining pressure and thermal stresses, it is usually necessary to evaluate stresses at the 1/4T location (inside surface flaw) and the 3/4T location (outside surface flaw). This is because the thermal gradient tensile stress of interest is in the inner wall during cooldown and the outer wall during heatup. However, as a conservative simplification, the thermal gradient stress at the 1/4T location is assumed to be tensile for both heatup and cooldown. This results in the approach of applying the maximum tensile stress at the 1/4T location. This approach is conservative because irradiation effects cause the allowable toughness, K1 , at 1/4T to be less than that at 3/4T for a given metal temperature. This approach causes no operational difficulties, because the BWR is at steam saturation conditions during normal operation, well above the heatup/cooldown curve limits.

For the core not critical curve (Curve B) and the core critical curve (Curve C), the P-T curves specify a coolant heatup and cooldown temperature rate of _ 100°F/hr for which the curves are 5

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) applicable. However, the core not critical and the core critical curves were also developed to bound transients defined on the RPV thermal cycle diagram and the nozzle thermal cycle diagrams. For the hydrostatic pressure and leak test curve (Curve A), a coolant heatup and cooldown temperature rate of < 20 0 F/hr must be maintained. The P-T limits and corresponding heatup/cooldown rates of either Curve A or B may be applied while achieving or recovering from test conditions. Curve A applies during pressure testing and when the limits of Curve B cannot be maintained.

For Fermi 2, weld heat 13253/12008 is the limiting material for the beltline region for 24 and 32 EFPY. The initial RTNDT for weld heat 13253/12008 material is -44°F. The generic pressure test P-T curve is applied to the Fermi 2 beltline curve by shifting the P vs. (T - RTNDT) values to reflect the ART value of 75°F for 24 EFPY and 82°F for 32 EFPY. Using the fluence discussed above, the P-T curves are beltline limited for Curves A, B, or C, for 24 or 32 EFPY. For 24 EFPY, Curve A is beltline limited above 900 psig; Curve B and Curve C are beltline limited above 710 psig. For 32 EFPY, Curve A is beltline limited above 840 psig; Curve B and Curve C are beltline limited above 580 psig.

In order to ensure that the limiting vessel discontinuity has been considered in the development of the P-T curves, the methods in Sections 4.3.2.1 and 4.3.2.2 of Reference 6.2 for the non-beltline and beltline regions, respectively, are applied.

6.0 References 6.1 Final Safety Evaluation Regarding Removal of Methodology Limitations for NEDC-32983P-A, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluation (TAC NO. MC3788), November 17, 2005.

6.2 Final Safety Evaluation for Boiling Water Reactors Owners' Group Licensing Topical Report NEDC-33178P, General Electric Methodology for Development of Reactor Pressure Vessel Pressure-Temperature Curves (TAC NO. MD2693), April 27, 2009.

6.3 BWR Vessel and Internals Project Integrated Surveillance Program (ISP) Data Source Book and Plant Evaluations, BWRVIP-135, Revision 2, EPRI, Palo Alto, CA, October 2009.

6.4 BWR Vessel and Internals Project, Updated BWR Integrated Surveillance Program (ISP)

Implementation Plan, BWRVIP-86, Revision 1, EPRI, Palo Alto, CA: September 2008.

1016575.

6.5 Pressure-Temperature Curves for DTE Energy Fermi Unit 2, NEDC-33133P-R4, Revision 4, Class III (GEH Proprietary Information), June 2013.

6

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) 1400 1300 INITIAL RTNDT VALUES ARE 1200 %-44"F FOR BELTLINE, 25"F FOR UPPER VESSEL, AND 1100 30°F FOR BOTTOM HEAD a 1000 BELTLINE CURVES

< ADJUSTED AS SHOWN:

w 9EFPY SHIFT (*F) 900 -24 119 O

F HEATUP/COOLDOWN V RATE OF COOLANT to 600 - - - ---- - - - - - - - -< 20*F/HR ci, C,)

500 w, - -- BOTTOM J HEAD UJI 68"F 400 - - - - - - - - - - -

CI: 312 PSIG w 300 z, FLANGE -- UPPER VESSEL 200 REGION AND BELTLINE I 72*F LIMITS

--- H BOTTOM HEAD 100 - -- CURVE 0

0 25 50 75 100 125 150 17'5 200 MINIMUM REACTOR VESSEL METAL TEMPERATURE (*F)

Figure 1 Fermi 2 Composite Curve A Pressure Test P-T Curves Effective for up to 24 EFPY 7

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) 1400 1300 NITIAL RTNDT VALUES 1200 - -- -- ARE

-44*F FOR BELTLINE, 25"F FOR UPPER VESSEL, 1100 AND 44.6*F FOR BOTTOM HEAD S1000 o / BELTLINE CURVES

/ ADJUSTED AS SHOWN:

= 900 EFPY SHIFT (*F) 0 24 106 c-800 w 700 HEATUP/COOLDOWN RATE OF COOLANT 600 <100°F/HR z

5 500 - -------

400 - - -- _- --

U)

BOTTOM 312 HEAD 312 PSIG PSI 300 - -" 68'F 200 --- UPPER VESSEL AND BELTLINE FLANGE LIMITS 100 -------- BOTTOM HEAD CURVE 0

0 25 50 75 100 125 150 175 200 MINIMUM REACTOR VESSEL METAL TEMPERATURE (*F)

Figure 2 Fermi 2 Composite Curve B Core Not Critical P-T Curves Effective for up to 24 EFPY 8

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) 1400 INITIAL RTNDT VALUES ARE 1300 ___ -44"F FOR BELTLINE, 25*F FOR UPPER VESSEL, AND 1200 30*F FOR BOTTOM HEAD 1100

0. 1000 BELTLINE CURVE ADJUSTED AS SHOWN:

EFPY SHIFT (*F)

-- 24 106 900 -

0 n 800 HEATUP/COOLDOWN RATE OF COOLANT

< 100°F/HR w 700 - -- - - -

300 z

H 500 w

400 - - -- Mnm Vese -N EL w

w 312 PSIG

c. 300 200 __ __ __ __ __

_______ BELTLINE AND 100 inimm VeselNON-BELTLINE 100 inimm VeselLIMITS Temperature 72*F 0

0 25 50 75 100 125 150 175 200 225 250 MINIMUM REACTOR VESSEL METAL TEMPERATURE (*F)

Figure 3 Fermi 2 Limiting Curve C Core Critical P-T Curve Effective for up to 24 EFPY 9

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) 1400 1300 INITIAL RTNDT VALUES ARE 10 -44*F FOR BELTLINE, 1200 25"F FOR UPPER VESSEL, AND 1100 30*F FOR BOTTOM HEAD cn c 1000 BELTLINE CURVES 0 1ADJUSTED AS SHOWN:

S9EFPY SHIFT (*F) 9 32 126 o

E 800 - - - - -- - - - - - - - - -

LU w

w 700 - - -- - - - - - - - - -

w 700 HEATUP/COOLDOWN C RATE OF COOLANT W 600 -- < 20"F/HR z,

500 BOTTOM HEAD 68*F 400 -----

U,,

w 312 PSIG 300 FLANGE - UPPER VESSEL 200 - REGION AND BELTLINE 72*F LIMITS

BOTTOM HEAD 100 CURVE 0

0 25 50 75 100 125 150 175 200 MINIMUM REACTOR VESSEL METAL TEMPERATURE (*F)

Figure 4 Fermi 2 Composite Curve A Pressure Test P-T Curves Effective for up to 32 EFPY 10

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) 1400 1300 NITIAL RTNDT VALUES ARE 1200 -44*F FOR BELTLINE, 25°F FOR UPPER VESSEL, 1100 AND 44.6*F FOR BOTTOM HEAD a 1000 Q ;BELTLINE CURVES ADJUSTED AS SHOWN:

= 900 EFPY SHIFT (°F) 0i 32 121 w 800 -

0r 700 o

HEATUP/COOLDOWN S60RATE OF COOLANT 600 < 100*F/HR z

I-I 500 -

w 400 -- -- - -- - - -

BOTTOM 312 PSIG I300 HEAD 200 UPPER VESSEL 2 AND BELTLINE FLANGE LIMITS 100 -E--- BOTTOM HEAD CURVE 0

0 25 50 75 100 125 150 175 200 MINIMUM REACTOR VESSEL METAL TEMPERATURE (*F)

Figure 5 Fermi 2 Composite Curve B Core Not Critical P-T Curves Effective for up to 32 EFPY 11

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public) 1400 INITIAL RTNDT VALUES ARE 1300 -44°F FOR BELTLINE, 25°F FOR UPPER VESSEL, AND 1200 =30*F FOR BOTTOM HEAD 1100 1000 BELTLINE CURVE ADJUSTED AS SHOWN:

EFPY SHIFT ("F) 32 121

= 900 00 U)800 HEATUP/COOLDOWN RATE OF COOLANT

> 0 < 100*F/HR Z 700 00 300 z

500 w

CO) 400 w

w 312 PSIG 30 2110 200

_______ ___ BELTLINE AND 100 inimm VeselNON-BELTLINE 100 inimm VeselLIMITS 0

0 25 50 75 100 125 150 175 200 225 250 MINIMUM REACTOR VESSEL METAL TEMPERATURE (°F)

Figure 6 Fermi 2 Limiting Curve C Core Critical P-T Curve Effective for up to 32 EFPY 12

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Table 1 Fermi 2 Tabulation of Curves - 24 EFPY BOTTOM UPPER RPV & BOTTOM IPER RPV & LIMITING PRESSURE HEAD BELHLINE AT BELTLINE AT 24 EFPY (PSIG) CURVE A 24CURVE B 24 FPY CURVE C (o) CURVE A CURVE CURVE B (of) 0 68.0 72.0 68.0 72.0 72.0 10 68.0 72.0 68.0 72.0 72.0 20 68.0 72.0 68.0 72.0 72.0 30 68.0 72.0 68.0 72.0 72.0 40 68.0 72.0 68.0 72.0 72.0 50 68.0 72.0 68.0 72.0 72.0 60 68.0 72.0 68.0 72.0 72.0 70 68.0 72.0 68.0 72.0 72.2 80 68.0 72.0 68.0 72.0 78.2 90 68.0 72.0 68.0 72.0 83.3 100 68.0 72.0 68.0 72.0 87.8 110 68.0 72.0 68.0 72.0 91.9 120 68.0 72.0 68.0 72.0 95.7 130 68.0 72.0 68.0 72.0 99.2 140 68.0 72.0 68.0 72.0 102.4 150 68.0 72.0 68.0 72.0 105.2 160 68.0 72.0 68.0 72.0 107.9 170 68.0 72.0 68.0 72.0 110.5 180 68.0 72.0 68.0 72.9 112.9 190 68.0 72.0 68.0 75.2 115.2 200 68.0 72.0 68.0 77.3 117.3 210 68.0 72.0 68.0 79.3 119.3 220 68.0 72.0 68.0 81.3 121.3 230 68.0 72.0 68.0 83.1 123.1 240 68.0 72.0 68.0 84.9 124.9 250 68.0 72.0 68.0 86.6 126.6 260 68.0 72.0 68.0 88.2 128.2 270 68.0 72.0 68.0 89.8 129.8 280 68.0 72.0 68.0 91.3 131.3 290 68.0 72.0 68.0 92.8 132.8 300 68.0 72.0 68.0 94.2 134.2 310 68.0 72.0 68.0 95.5 135.5 312.5 68.0 72.0 68.0 95.9 135.9 312.5 68.0 102.0 68.0 132.0 172.0 13

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UPPER RPV &, BOTTOM UPPER RPV & LIMITING PRESSURE HEAD BELTLLNE A H BELTLINE AT 24 EFPY (PSIG) CURVE A B 24CAECURVE ELhT A URE B B

24 EF'PY CUV C CURVE B 0 (of) CURVE (-I (OF) 320 68.0 102.0 68.0 132.0 172.0 330 68.0 102.0 68.0 132.0 172.0 340 68.0 102.0 68.0 132.0 172.0 350 68.0 102.0 68.0 132.0 172.0 360 68.0 102.0 68.0 132.0 172.0 370 68.0 102.0 68.0 132.0 172.0 380 68.0 102.0 68.0 132.0 172.0 390 68.0 102.0 68.0 132.0 172.0 400 68.0 102.0 68.0 132.0 172.0 410 68.0 102.0 68.0 132.0 172.0 420 68.0 102.0 68.0 132.0 172.0 430 68.0 102.0 68.0 132.0 172.0 440 68.0 102.0 68.0 132.0 172.0 450 68.0 102.0 68.0 132.0 172.0 460 68.0 102.0 68.0 132.0 172.0 470 68.0 102.0 68.0 132.0 172.0 480 68.0 102.0 68.0 132.0 172.0 490 68.0 102.0 68.0 132.0 172.0 500 68.0 102.0 68.0 132.0 172.0 510 68.0 102.0 68.0 132.0 172.0 520 68.0 102.0 68.0 132.0 172.0 530 68.0 102.0 68.0 132.0 172.0 540 68.0 102.0 68.0 132.0 172.0 550 68.0 102.0 69.5 132.0 172.0 560 68.0 102.0 71.3 132.0 172.0 570 68.0 102.0 73.0 132.0 172.0 580 68.0 102.0 74.6 132.0 172.0 590 68.0 102.0 76.2 132.0 172.0 600 68.0 102.0 77.8 132.0 172.0 610 68.0 102.0 79.3 132.0 172.0 620 68.0 102.0 80.7 132.0 172.0 630 68.0 102.0 82.1 132.0 172.0 640 68.0 102.0 83.5 132.0 172.0 650 68.0 102.0 84.8 132.0 172.0 660 68.0 102.0 86.1 132.0 172.0 14

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

BOTTOM UPPER RPV & BOTTOM UPPER RP & LIMITING POA PRSBR. EDLEAD ELTLINE AT BELTLINE AT 24 EFPY" PRESURE) CUREA 24 EFPY CURVE B CUREVE BURVE C (PSIG) CURVE A E CRVE BV (° 670 68.0 102.0 87.4 132.0 172.0 680 68.0 102.0 88.7 132.0 172.0 690 68.0 102.0 89.9 132.0 172.0 700 68.0 102.0 91.0 132.0 172.0 710 68.0 102.0 92.2 132.0 172.0 720 68.0 102.0 93.3 132.4 172.4 730 68.0 102.0 94.4 132.8 172.8 740 68.0 102.0 95.5 133.1 173.1 750 68.0 102.0 96.6 133.5 173.5 760 68.0 102.0 97.6 133.8 173.8 770 68.0 102.0 98.6 134.2 174.2 780 68.0 102.0 99.6 134.5 174.5 790 68.0 102.0 100.6 134.9 174.9 800 68.0 102.0 101.5 135.2 175.2 810 68.0 102.0 102.5 135.6 175.6 820 68.0 102.0 103.4 135.9 175.9 830 68.0 102.0 104.3 136.3 176.3 840 68.0 102.0 105.2 136.6 176.6 850 68.6 102.0 106.0 136.9 176.9 860 69.6 102.0 106.9 137.3 177.3 870 70.6 102.0 107.7 137.6 177.6 880 71.5 102.0 108.6 137.9 177.9 890 72.5 102.0 109.4 138.3 178.3 900 73.4 102.0 110.2 138.6 178.6 910 74.4 102.2 111.0 138.9 178.9 920 75.3 103.2 111.7 139.2 179.2 930 76.1 104.1 112.5 139.6 179.6 940 77.0 105.1 113.3 139.9 179.9 950 77.9 106.0 114.0 140.2 180.2 960 78.7 106.9 114.7 140.5 180.5 970 79.6 107.8 115.5 140.8 180.8 980 80.4 108.7 116.2 141.1 181.1 990 81.2 109.6 116.9 141.5 181.5 1000 82.0 110.4 117.6 141.8 181.8 1010 82.7 111.3 118.2 142.1 182.1 15

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BOTTOM IUPPER RPV & UPPER RPV & LIMITING PRESSURERESR HED24 IHEAD EFPY AT BELTLINE UV HEAD B CREBYI~

4 BELTLINE AT 24 EFPY (PSIG) CURVE A CURVEB CURVE C

(F)0) (OF) 1020 83.5 112.1 118.9 142.4 182.4 1030 84.3 112.9 119.6 142.7 182.7 1035 84.6 113.3 119.9 142.8 182.8 1040 85.0 113.7 120.2 143.0 183.0 1050 85.7 114.5 120.9 143.3 183.3 1055 86.1 114.9 121.2 143.4 183.4 1060 86.4 115.3 121.5 143.6 183.6 1070 87.2 116.0 122.1 143.9 183.9 1080 87.9 116.8 122.8 144.2 184.2 1090 88.6 117.5 123.4 144.5 184.5 1100 89.2 118.3 124.0 144.8 184.8 1105 89.6 118.6 124.3 144.9 184.9 1110 89.9 119.0 124.6 145.1 185.1 1120 90.6 119.7 125.2 145.4 185.4 1130 91.2 120.4 125.8 145.6 185.6 1140 91.9 121.1 126.3 145.9 185.9 1150 92.5 121.8 126.9 146.2 186.2 1160 93.1 122.4 127.5 146.5 186.5 1170 93.8 123.1 128.0 146.8 186.8 1180 94.4 123.7 128.6 147.1 187.1 1190 95.0 124.4 129.1 147.4 187.4 1200 95.6 125.0 129.7 147.6 187.6 1210 96.2 125.7 130.2 147.9 187.9 1220 96.8 126.3 130.8 148.2 188.2 1230 97.3 126.9 131.3 148.5 188.5 1240 97.9 127.5 131.8 148.8 188.8 1250 98.5 128.1 132.3 149.0 189.0 1260 99.0 128.7 132.8 149.3 189.3 1270 99.6 129.3 133.3 149.6 189.6 1280 100.1 129.8 133.8 149.8 189.8 1290 100.7 130.4 134.3 150.1 190.1 1300 101.2 131.0 134.8 150.4 190.4 1310 101.7 131.5 135.3 150.7 190.7 1320 102.3 132.1 135.8 150.9 190.9 1330 102.8 132.6 136.2 151.2 191.2 16

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BOTTOM UPPER RPV & BOTTO UPPER RPV &

U LIMITING BELTJANE AT BOTM BELTLIINE AT PRESSURE HEAD HEAD 24 EFPY (PSIG) CURVE 0 A 24 EFPY CURVE B C4RE CRVE C

( F) CURV'E .A. of) CI .B(F

(°F) (°F) 1340 103.3 133.2 136.7 151.5 191.5 1350 103.8 133.7 137.2 151.7 191.7 1360 104.3 134.2 137.6 152.0 192.0 1370 104.8 134.8 138.1 152.2 192.2 1380 105.3 135.3 138.5 152.5 192.5 1390 105.8 135.8 139.0 152.8 192.8 1400 106.3 136.3 139.4 153.0 193.0 17

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Table 2 Fermi 2 Tabulation of Curves - 32 EFPY BOTTOM UPPER RPV & BOTTOM UPPER RPV &

R HEAD PCESUERVED32 BELTLINE AT HEAD BELTLINE AT 32 EFPY FP 32 EFPY CUVC C (PS3G) CURVE A CURVE B CURVE (OF(CUVE (01)U °)CUVB(f 0 68.0 72.0 68.0 72.0 72.0 10 68.0 72.0 68.0 72.0 72.0 20 68.0 72.0 68.0 72.0 72.0 30 68.0 72.0 68.0 72.0 72.0 40 68.0 72.0 68.0 72.0 72.0 50 68.0 72.0 68.0 72.0 72.0 60 68.0 72.0 68.0 72.0 72.0 70 68.0 72.0 68.0 72.0 72.2 80 68.0 72.0 68.0 72.0 78.2 90 68.0 72.0 68.0 72.0 83.3 100 68.0 72.0 68.0 72.0 87.8 110 68.0 72.0 68.0 72.0 91.9 120 68.0 72.0 68.0 72.0 95.7 130 68.0 72.0 68.0 72.0 99.2 140 68.0 72.0 68.0 72.0 102.4 150 68.0 72.0 68.0 72.0 105.2 160 68.0 72.0 68.0 72.0 107.9 170 68.0 72.0 68.0 72.0 110.5 180 68.0 72.0 68.0 72.9 112.9 190 68.0 72.0 68.0 75.2 115.2 200 68.0 72.0 68.0 77.3 117.3 210 68.0 72.0 68.0 79.3 119.3 220 68.0 72.0 68.0 81.3 121.3 230 68.0 72.0 68.0 83.1 123.1 240 68.0 72.0 68.0 84.9 124.9 250 68.0 72.0 68.0 86.6 126.6 260 68.0 72.0 68.0 88.2 128.2 270 68.0 72.0 68.0 89.8 129.8 280 68.0 72.0 68.0 91.3 131.3 290 68.0 72.0 68.0 92.8 132.8 300 68.0 72.0 68.0 94.2 134.2 310 68.0 72.0 68.0 95.5 135.5 312.5 68.0 72.0 68.0 95.9 135.9 18

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UPPER RPV & UPPER RPV & LIMITING BO0TTOM BLLEAT BOTTOM BELTINE'\ AT LMTN PRESSURE HEAD BELTLINEEAD 32 EFPY (PSIG)

(PSIC)~CRV CURVE A 2EP CURVE B CURVERVE CUV C

( (F) ('F) 312.5 68.0 102.0 68.0 132.0 172.0 320 68.0 102.0 68.0 132.0 172.0 330 68.0 102.0 68.0 132.0 172.0 340 68.0 102.0 68.0 132.0 172.0 350 68.0 102.0 68.0 132.0 172.0 360 68.0 102.0 68.0 132.0 172.0 370 68.0 102.0 68.0 132.0 172.0 380 68.0 102.0 68.0 132.0 172.0 390 68.0 102.0 68.0 132.0 172.0 400 68.0 102.0 68.0 132.0 172.0 410 68.0 102.0 68.0 132.0 172.0 420 68.0 102.0 68.0 132.0 172.0 430 68.0 102.0 68.0 132.0 172.0 440 68.0 102.0 68.0 132.0 172.0 450 68.0 102.0 68.0 132.0 172.0 460 68.0 102.0 68.0 132.0 172.0 470 68.0 102.0 68.0 132.0 172.0 480 68.0 102.0 68.0 132.0 172.0 490 68.0 102.0 68.0 132.0 172.0 500 68.0 102.0 68.0 132.0 172.0 510 68.0 102.0 68.0 132.0 172.0 520 68.0 102.0 68.0 132.0 172.0 530 68.0 102.0 68.0 132.0 172.0 540 68.0 102.0 68.0 132.0 172.0 550 68.0 102.0 69.5 132.0 172.0 560 68.0 102.0 71.3 132.0 172.0 570 68.0 102.0 73.0 132.0 172.0 580 68.0 102.0 74.6 132.2 172.2 590 68.0 102.0 76.2 133.1 173.1 600 68.0 102.0 77.8 133.9 173.9 610 68.0 102.0 79.3 134.3 174.3 620 68.0 102.0 80.7 134.7 174.7 630 68.0 102.0 82.1 135.1 175.1 640 68.0 102.0 83.5 135.4 175.4 650 68.0 102.0 84.8 135.8 175.8 19

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BOTTOM UPERTIRPU UPPER RP & &A BOTTOti OTO UPPER RPVAT BELTLINVE & LIMITING PRESSURE HEAD BELTLINE AT HEAD B ELN 32 EFPY (PSIG) CURVE (OF) A CURVE A CURVE (OF) B CURV (0 \f) B(O, C

(°F) (°F) 660 68.0 102.0 86.1 136.2 176.2 670 68.0 102.0 87.4 136.6 176.6 680 68.0 102.0 88.7 136.9 176.9 690 68.0 102.0 89.9 137.3 177.3 700 68.0 102.0 91.0 137.7 177.7 710 68.0 102.0 92.2 138.0 178.0 720 68.0 102.0 93.3 138.4 178.4 730 68.0 102.0 94.4 138.8 178.8 740 68.0 102.0 95.5 139.1 179.1 750 68.0 102.0 96.6 139.5 179.5 760 68.0 102.0 97.6 139.8 179.8 770 68.0 102.0 98.6 140.2 180.2 780 68.0 102.0 99.6 140.5 180.5 790 68.0 102.0 100.6 140.9 180.9 800 68.0 102.0 101.5 141.2 181.2 810 68.0 102.0 102.5 141.6 181.6 820 68.0 102.0 103.4 141.9 181.9 830 68.0 102.0 104.3 142.3 182.3 840 68.0 102.0 105.2 142.6 182.6 850 68.6 102.8 106.0 142.9 182.9 860 69.6 103.9 106.9 143.3 183.3 870 70.6 105.0 107.7 143.6 183.6 880 71.5 106.1 108.6 143.9 183.9 890 72.5 107.2 109.4 144.3 184.3 900 73.4 108.2 110.2 144.6 184.6 910 74.4 109.2 111.0 144.9 184.9 920 75.3 110.2 111.7 145.2 185.2 930 76.1 111.1 112.5 145.6 185.6 940 77.0 112.1 113.3 145.9 185.9 950 77.9 113.0 114.0 146.2 186.2 960 78.7 113.9 114.7 146.5 186.5 970 79.6 114.8 115.5 146.8 186.8 980 80.4 115.7 116.2 147.1 187.1 990 81.2 116.6 116.9 147.5 187.5 1000 82.0 117.4 117.6 147.8 187.8 20

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O PPER RPV. & B1 PPER RPV & LIMITING BOTTOM BOTTOM. 32

-LILINMAT NGP IE) BELTINE AT BEEADN A PRESSURE HEAD ELEFPY AEAD L 32 EFPV (PSIG) CURVE A CURVE B CURVE C (Qr)'F)V'EA(oF (OF) B(0 F) 1010 82.7 118.3 118.2 148.1 188.1 1020 83.5 119.1 118.9 148.4 188.4 1030 84.3 119.9 119.6 148.7 188.7 1035 84.6 120.3 119.9 148.8 188.8 1040 85.0 120.7 120.2 149.0 189.0 1050 85.7 121.5 120.9 149.3 189.3 1055 86.1 121.9 121.2 149.4 189.4 1060 86.4 122.3 121.5 149.6 189.6 1070 87.2 123.0 122.1 149.9 189.9 1080 87.9 123.8 122.8 150.2 190.2 1090 88.6 124.5 123.4 150.5 190.5 1100 89.2 125.3 124.0 150.8 190.8 1105 89.6 125.6 124.3 150.9 190.9 1110 89.9 126.0 124.6 151.1 191.1 1120 90.6 126.7 125.2 151.4 191.4 1130 91.2 127.4 125.8 151.6 191.6 1140 91.9 128.1 126.3 151.9 191.9 1150 92.5 128.8 126.9 152.2 192.2 1160 93.1 129.4 127.5 152.5 192.5 1170 93.8 130.1 128.0 152.8 192.8 1180 94.4 130.7 128.6 153.1 193.1 1190 95.0 131.4 129.1 153.4 193.4 1200 95.6 132.0 129.7 153.6 193.6 j 1210 96.2 132.7 130.2 153.9 193.9 1220 96.8 133.3 130.8 154.2 194.2 1230 97.3 133.9 131.3 154.6 194.6 1240 97.9 134.5 131.8 155.1 195.1 1250 98.5 135.1 132.3 155.6 195.6 1260 99.0 135.7 132.8 156.0 196.0 1270 99.6 136.3 133.3 156.5 196.5 1280 100.1 136.8 133.8 157.0 197.0 1290 100.7 137.4 134.3 157.4 197.4 1300 101.2 138.0 134.8 157.9 197.9 1310 101.7 138.5 135.3 158.3 198.3 1320 102.3 139.1 135.8 158.8 198.8 21

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BOTTOM UPPER RPV & ILIMITING UBOERRPV BOTTOM A LILTITIE PRESSURE HEAD BELTL NE A 32~~inn REIN AT IED HA 32 EFPY AT BELTLINE 32 EFPY 32EP (PSIG) CURVE 0A CURNE B 7 CURVE C

( ) CURVE A (OF)CUVB (OF) (OF) (OF) (F 1330 102.8 139.6 136.2 159.2 199.2 1340 103.3 140.2 136.7 159.7 199.7 1350 103.8 140.7 137.2 160.1 200.1 1360 104.3 141.2 137.6 160.5 200.5 1370 104.8 141.8 138.1 161.0 201.0 1380 105.3 142.3 138.5 161.4 201.4 1390 105.8 142.8 139.0 161.8 201.8 1400 106.3 143.3 139.4 162.2 202.2 22

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Appendix A Reactor Vessel Material Surveillance Program In accordance with 10 CFR 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements, the first surveillance capsule was removed from the Fermi 2 reactor vessel after Cycle 7, during refueling outage (RFO) 7 in April 2000. This capsule was placed in the Spent Fuel Pool and has not been tested. The surveillance capsule contains flux wires for neutron fluence measurement, Charpy V-Notch impact test specimens and uniaxial tensile test specimens fabricated using materials from the vessel materials within the core beltline region.

As described in the Fermi 2 Updated Final Safety Analysis Report (UFSAR) Section 4.2.6, Inspection and Testing, the BWRVIP ISP will determine the removal schedule for the remaining Fermi 2 surveillance capsules. The Fermi 2 material surveillance program is administered in accordance with the BWRVIP ISP. The ISP combines the US BWR surveillance programs into a single integrated program. This program uses similar heats of materials in the surveillance programs of BWRs to represent the limiting materials in other vessels. It also adds data from the BWR Supplemental Surveillance Program (SSP). Per the BWRVIP ISP, Fermi 2 is not a host plant; all surveillance capsules are classified as "Deferred".

A-I

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Appendix B Fermi 2 Reactor Pressure Vessel P-T Curve Supporting Plant-Specific Information B-I

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TOP HEAD

~-TOP HEAD FLANGE

-- SHELL PLANGE

~-SHELL #4

--- -- -SHELL 93 ACTIVE FUEL

'GIRTH WELD soT Tm oFSHELL #1 ACi V FU0EL (BAF) 216 BOTTOM HEAD SUPPORT SKIRT Figure B-1 Fermi 2 Reactor Pressure Vessel B-2

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Table B-1 Fermi 2 Initial RTNDT Values for RPV Plate and Flange Materials Drop 60 Component Heat Temp Charpy Energy (T 0r- ) Weight RThT Cn IT(ft-Ib) (F) NDT ( F)

Top Head & Flange Shell Flange G3701 AWH 1.13 2V-708 10 89 89 90 -20 10 10 Top Head Flange G3702 ACR 108 10 196 191 101 -20 10 10 Top Head Dollar C3732 C5445-1 10 79 86 79 -20 -10 -10 Top Head Lower Torus Plates G3731-1 C5445-2 10 95 91 97 -20 -10 -10 G3731-2 C5445-2 10 97 96 101 -20 -10 -10 Top Head Upper Torus Plates G3730 C5445-1 10 107 85 102 -20 -10 -10 Shell Courses Upper Shell Plates G3703-1 C4568-1 40 68 65 56 10 -10 10 G3703-2 C4564-2 40 64 49 54 12 -10 12 G3703-3 C4560-2 10 53 63 52 -20 -10 -10 G3703-4 C4554-2 40 74 75 87 10 -10 10 Upper Intermediate Plates G3704-1 C4574-1 10 70 68 66 -20 -10 -10 G3704-2 C4578-2 10 59 45 52 -10 -10 -10 G3704-3 C4578-1 10 44 56 68 -8 -10 -8 Lower Intermediate Plates G3703-5 C4564-1 10 60 45 59 -10 -20 -10 G3705-1 B8614-1 10 62 64 56 -20 -20 -20 G3705-2 C4574-2 10 48 49 60 -16 -30 -16 G3705-3 C4568-2 10 46 67 63 -12 -30 -12 Lower Shell Plates G3706-1 C4540-2 10 64 76 74 -20 -10 -10 G3706-2 C4560-1 10 85 79 99 -20 -10 -10 G3706-3 C4554-1 10 59 65 68 -20 -10 -10 Bottom Head Bottom Head Dollar G3708 C3424-1 10 41 48 57 -2 -10 -2 Bottom Head Upper Torus Plates G3711-1 C4526-1 -40 57 60 55 -70 -10 -10 G3712-1 C4504-3 -40 70 64 56 -70 -10 -10 Bottom Head Lower Torus Plates C3709-1 C5050-2 10 58 70 83 -20 -10 -10 C3710-1 C4504-1 10 74 70 74 -20 -10 -10 C3710-2 C4504-2 40 40 48 42 30 10 30 Note: Minimum Charpy values are provided for all materials.

B-3

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Table B-2 Fermi 2 Initial RTNDT Values for RPV Nozzle Materials Test Drop Heat or Temp Charpy Energy (Tsor60) Weight RTNrt Component Heat/Flux/Lot (ft-tb) (°F) NDT (F)

Recirculation Outlet Nozzle G3717-1 AJF 181 10 77 96 59 -20 -20 -20 G3717-2 AJF 193 10 91.5 89 85 -20 -30 -20 Recirculation Inlet Nozzle G3718-1 AV3505 9A-9239 10 54 45 38 4 0 4 G3718-2 AV3505 9A-9240 10 34 32 36 16 -10 16 G3718-3 AV3502 9A-9365 10 35 32 36 16 20 20 G3718-5 AV3503 9A-9368 10 42 36 60 8 -30 8 G3718-6 AV3503 9A-9369 10 49 40 49 0 -30 0 G3718-7 AV3504 9A-9371 10 58 28 37 24 -40 24 G3718-8 AV3857 9D-9407 10 48 32 46 16 20 20 G3718-9 AV3857 9D-9406 10 47 64 58 -14 10 10 G3718-10 AV3857 9D-9408 10 82 46 55 -12 10 10 G5218-4 AV3934 9E-9011 10 47 60 88 -14 40 40 Steam Outlet Nozzle G3714-1 AV3496 9A-9234 10 66 36 85 8 10 10 G3714-2 AV3507 9A-9235 10 74 75 36 8 0 8 G3714-3 AV3510 9A-9236 10 36 34 32 16 10 16 G3714-4 AV3511 9A-9237 10 52 32 42 16 10 16 Feedwater Nozzle G3715-1 AV3508 9A-9228 10 82 91 58 -20 0 0 G3715-2 AV3508 9A-9229 10 68 58 50 -20 0 0 G3715-3 AV3508 9A-9230 10 62 67 76 -20 -30 -20 G3715-4 AV3509 9A-9232 10 60 42 64 -4 -10 -4 G3715-5 AV3509 9A-9231 10 38 54 50 4 0 4 G3715-6 AV3504 9B-9202 10 39 46 34 12 -10 12 Core Spray Nozzle G3720-1 AV2997 9A-9363 10 67 52 96 -20 -10 -10 G3720-2 AV2997 9A-9364 10 70 99 84 -20 -10 -10 Instrumentation Nozzle G3811-1 Q2Q14W 969C-1 10 54 59 73 -20 10 10 G3811-2 Q2Q14W 969C-2 10 54 59 73 -20 10 10 Top Head Vent Nozzle G3810 Q2Q6W 986C 10 92 95 88 -20 10 10 Jet Pump Nozzle G3719-1 EV-9806 8L-9211A 10 99 124 105 -20 -20 -20 G3719-2 EV-9806 8L-9211B 10 99 124 105 -20 -20 -20 CRD HYD Return Nozzle G3716 AV3138 8L-9104 10 42 40 48 0 10 10 Core AP Nozzle Alloy 600 G3738 NX9492 [2]

Replacement Instrument Nozzle [3]

G3806 2127273 10 36 43 30 20 30 30 G3806R 6397860 10 250 230 247 -20 30 30 B-4

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High Pressure Leak Detector Nozzle G4546 10[1]

Drain Nozzle G3739 QIQ1VW 738T 10 39 25 32 30 40 40 CRD Stub Tube G3736-1 through -5 Alloy 600 [2]

(1) Information for this heat is not available; the purchase specification requirement are used for evaluation of this component.

(2) Alloy 600 components do not require fracture toughness evaluation.

(3) Dropweight data was not available; therefore NRC MTEB 5-2 was applied for the determination of dropweight.

Notes: Minimum Charpy values are provided for all materials.

The Replacement Instrument nozzle material data was reviewed; it was found that the previously reported value of 40F was unnecessarily conservative, and has been reduced to a maximum of 30°F.

B-5

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Table B-3 Fermi 2 Initial RTNDT Values for RPV Weld Materials Drop Test l rop Component Heat or Heat/Flux/Lot Temp Charpy Enoergy Tsirr6) Weight RT)

(ft-lb) ( F) NDT (F)

Beltline-Axial Lower Shell 13253 Linde 1092 2-307 A, B, C Lot 3833 10 79 79 82 -50 - -50 12008 Linde 1092 Lot 3878 10 62 47 62 -44 - -44 Lower-Intermediate Shell 33A277 Linde 124 15-308 A, B, C, D Lot 3878 10 83 94 87 -50 - -50 Beltline-Girth Lower-Intermediate Shell 10137 Linde 0091 1-313 Lot 3999 10 101 108 107 -50 - -50 Non-Beltline-Axial Upper-Intermediate Shell 20291 & 12008 Linde 1092 2-308 A through C Lot 3833 10 62 47 62 -44 - -44 HADH 10 112 110 114 -50 - -50 EOAG 10 173 1.33 135 -50 - -50 Upper Shell 1-308 A through D 34B009 Linde 124 Lot 3687 10 55 65 57 -50 - -50 34B009 Linde 124 Lot 3688 10 69 70 63 -50 - -50 Bottom Head Upper Torus Meridional Welds 1-306 A through K HADH 10 112 110 114 -50 - -50 Bottom Head Lower Torus Meridional Welds 2-306 A through G LACH-2 10 125 119 119 -50 - -50 HADH 10 112 110 114 -50 - -50 Top Head Upper Torus Meridional Welds 2-319 A through E EOEJ 10 136 170 150 -50 - -50 Top Head Lower Torus Meridional Welds 1-319 A through H DOAJ 10 166 146 158 -50 - -50 AOFJ 10 112 105 115 -50 - -50 EOEJ 10 136 170 150 -50 - -50 Non-Beltline-Girth Top Head Assembly 3-319, 4-319, 5-319 33A277 Linde 0091 Lot 3977 10 111 106 113 -50 - -50 90099 Linde 0091 Lot 3977 10 56 30 52 -10 - -10 Shell Flange to Upper Shell 13-308 21935 Linde 1092 Lot 3889 10 51 70 74 -50 - -50 B-6

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Drop Heat or HeatFlux/Lot Tep Charpy Energy T_,T-60) Weight RTND Component C pn e(ft-lb) (F) NDT (°F)

Upper Shell to Upper-Intermediate Shell 305424 Linde 1092 4-308-A Lot 3889 10 82 87 92 -50 - -50 Upper-Intermediate Shell to Lower-Intermediate Shell 1P3571 Linde 1092 Lot 3958 4-308-B Tandem 10 79 68 64 -50 - -50 1P3571 Linde 1092 Lot 3958 Single 10 40 46 46 -30 - -30 Lower Shell to Bottom Head 9-307 90099 Linde 0091 Lot 3977 10 56 30 52 -10 - -10 90136 Linde 0091 Lot 3998 10 110 109 107 -50 - -50 Bottom Head Assembly 1P2809 Linde 1092 3-306, 5-306, 6-306 Lot 3854 10 102 102 103 50 - -50 Support Skirt to Bottom Head 4-309 21935 Linde 1092 Lot 3869 10 62 59 60 -50 - -50 Nozzle Welds Recirculation Outlet LOBI 10 123 104 115 -50 - -50 5-314 A & B CBAI 10 GBAI 10 120 105 128 -50 - -50 Recirculation Inlet 13-314 A through K LOEH 10 113 123 140 -50 - -50 13-314D (Replacement) BBAI 10 97 100 77 -50 - -50 LACH 10 125 119 119 -50 - -50 HOGI 10 91 93 94 -50 - -50 IAGI 10 142 157 170 -50 - -50 Steam Outlet FAGI 10 135 121 136 -50 - -50 8-316 A through D LACH 10 125 119 119 -50 - -50 Feedwater Nozzle FACI 10 4-316 A through F HOGI 10 91 93 94 -50 - -50 LOEH 10 113 123 140 -50 - -50 COFI 10 96 97 89 -50 - -50 Core Spray Nozzles TAGI 10 142 157 170 -50 - -50 14-316 A & B BBAI 10 97 100 77 -50 - -50 Top Head Instrument Nozzle 14-318 A & B ABEA 10 BOIA 10 99 110 113 -50 - -50 Top Head Vent Nozzle ABEA 10 2-318 BOIA 10 99 110 113 -50 - -50 Jet Pump Nozzle LACH 10 125 119 119 -50 - -50 19-314 A & B LOEH 10 113 123 140 -50 - -50 CRD HYD Return Nozzle 15-315 IAGI 10 142 157 170 -50 - -50 Core AP Nozzle 9-315 Inconel 182 B-7

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Drop Test Component Heat or Heat/Flux/Lot Temp Charpy Energy TSor-6 0 ) N gt RTr

()F)

Instrument Nozzles 4-315 A through F Inconel 182 Drain Nozzle 17-315 CAFJ 10 85 101 108 -50 - -50 Stub Tubes 1-310 Inconel 182 Appurtenance Welds Stabilizer Brackets ICJJ 10 121 120 128 -50 - -50 10-324 A through H DBIJ 10 129 117 122 -50 - -50 HOCJ 10 165 174 140 -50 - -50 GBCJ 10 126 143 121 -50 - -50 Steam Dryer Hold Down Brackets to Top Head 10-319 KAHJ 10 108 116 107 -50 - -50 Basin Seal Skirt 6-324 A through D IBEJ 10 160 151 145 -50 - -50 LOAJ 10 152 125 104 -50 - -50 7-324 A through D; 8-324 HOKJ 10 110 177 154 -50 - -50 KACJ 10 102 81 108 -50 - -50 Thermocouple Pads 1-325 GBJJ 10 203 160 239 -50 - -50 2-325 COEJ 10 129 95 81 -50 - -50 3-325; 4-325; 6-325 FCJJ 10 180 224 171 -50 - -50 BBJJ 10 107 102 53 -50 - -50 COCA 10 120 139 137 -50 - -50 HOKJ 10 110 177 154 -50 - -50 FOIA 10 182 224 218 -50 - -50 7-325; 8-325 BOLH 10 159 138 123 -50 - -50 Top Head Lifting Lugs GBCJ 10 126 143 121 -50 - -50 8-319 A through D DBIJ 10 129 117 122 -50 - -50 Note: Minimum Charpy values are provided for all materials.

B-8

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Table B-4 Fermi 2 Initial RTNDT Values for RPV Appurtenance and Bolting Materials Drop Test 6 Tet(T41,11 0J) Weight RTI hn Components Heat Temp Charpy Energy (ft-lb) ( t RF

( F)

Misc Appurtences Support Skirt Forging S8530 AHC 178 10 81 100 102 -20 30 30 Shroud Support Alloy 600 G3726 580608-IX (1)

Stabilizer Brackets C-6-1 A4516-1 40 58 49 53 12 10 12 C-6-2 C5313-2 10 57 45 52 -10 -30 -10 Guide Rod Brackets G3772 Stainless Steel (1)

Steam Dryer Support Lugs G3775 Stainless Steel (1 Steam Dryer Hold Down Brackets G4871 C2588-2D 10 122 129 107 -20 - -20 D5591 C6195-4 10 83 69 61 -20 - -20 Core Spray Brackets G3774 Stainless Steel (1)

Basin Seal Skirt G3818 C2588-2B 10(2)

C3819 22A459 10(2)

Surveillance Specimen Brackets G3776 Stainless Steel (1)

G3777 Stainless Steel (1)

Feedwater Sparger Brackets G3773 Stainless Steel (1)

Top Head Lifting Lugs G3732 40 (2)

Test Min Lat LST Components Heat Temp Charpy Energy (ft-lb)

Closure Studs G3778-1 14677 10 50 50 52 - 70 G3778-2 67156 10 55 54 55 - 70 G3778-3 -3 10 - - - - 70 Closure Nuts G3779-1 48192 10 58 59 54 - 70 G3779-2 (3 10 - - - - 70 Closure Washers Closure Washers G5252 (3) 10 - - - - 70 Bushings G4853 (3 10 - - - - 70 B-9

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(1) Information for this heat is not available; the purchase specification requirements are used for evaluation of this component.

(2) Alloy 600 and Stainless Steel components do not require fracture toughness evaluation.

(3) Information for this component is not available; ASME code requirements are applied.

Note: Minimum Charpy values are provided for all materials.

B-10

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Table B-5 Fermi 2 Adjusted Reference Temperatures for up to 24 EFPY Lower-Intermediate Shell Plates, Axial Welds Thickness in inches= 6.125 24 EFPY Peak I.D. fluence= 7.13E+17 n/cm 2 2

24 EFPY Peak % T fluence= 4.94E+17 n/cm Water Level Instrumentation Nozzle 2

Thickness in inches= 6.125 24 EFPY Peak 1.D. fluence= 1.30E+17 n/cm 24 EFPY Peak % T fluence= 9.00E+16 n/cm2 Lower Shell Plates and Axial Welds & Lower to Lower-Intermediate Girth Weld Thickness in inches= 7.125 2

24 EFPY Peak ID. fluence= 4.66E+17 n/cm 2

24 EFPY Peak % T fluence= 3.04E+17 n/cm Initial 24 EFPY 24 EFPV 24 EFPY Ad justed %/T Fluence Margin Component Heat or Heat/Lot %Cu %Ni CF RATdr .\RFen ac Shift ART CF (1) n/cmZ R F (F) °FF °F Plant Specific Chemistries Plates:

Lower Shell G3706-1 C4540-2 0.08 0.62 51 -10 3.04E+17 11 0 6 11 23 13 G3706-2 C4560-1 0.11 0.57 74 -10 3.04E+17 16 0 8 16 33 23 G3706-3 C4554-1 0.12 0.56 82 -10 3.04E+17 18 0 9 18 36 26 Lower-Intermediate Shell G3703-5 C4564-1 0.09 0.55 58 -10 4.94E+17 17 0 8 17 34 24 G3705-1 B8614-1 0.12 0.61 83 -20 4.94E+17 24 0 12 24 48 28 G3705-2 C4574-2 0.10 0.55 65 -16 4.94E+17 19 0 9 19 38 22 G3705-3 C4568-2 0.12 0.61 83 -12 4.94E+17 24 0 12 24 48 36 WELDS:

Lower Shell Axial Tandem 13253, 12008 1092 2-307 A, B, C Lot 3833 0.26 0.87 224 -44 3.04E+17 50 0 25 50 99 55 Lower-Intermediate Shell Axial 15-308 A, B, C, D 33A277, 124 Lot 3878 0.32 0.50 188.5 -50 4.94E+17 55 0 27 55 110 60 Lower to Lower-Intermediate Girth 1-313 10137, 0091 Lot 3999 0.23 1.00 236 -50 3.04E+17 52 0 26 52 104 54 B-11

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

NOZZLES:

N16 (Water Level Instrumentation) 2127273 0.272 0.214 136 30 9.00E+16 14 0 7 14 28 58 N16 (Water Level Instrumentation) 6397860 0272 0.214 136 30 9.00E+16 14 0 7 14 28 58 N16 Weld Inconel (

INTEGRATED SURVEILLANCE PROGRAM (":

BWRVIP-135 R2 Plate ) (( -12 4.94E+17 (( 37 Weld ' )) -44 3.04E+17 )) 62 (1) Adjusted CF calculated per RG 1.99 Position 2.1.

(2) Non-ferritic materials such as Inconel do not require fracture toughness evaluation.

(3) Procedures defined in RG 1.99 are applied to determine the ART considering the ISP.

(4) The ISP plate is not the identical heat and is presented using the ISP chemistry and CF and applied to the limiting Fermi 2 plate, which is Heat C4568-2. ISP indicates that C4554-1 is also a limiting plate, however due to the reduced fluence at the lower shell, this material is no longer limiting.

(5) The ISP weld is the identical heat and is presented using the ISP chemistry and adjusted CF with the vessel weld Initial RTNDT and fluence. 6o is presented as calculated, but multiplied by 0.5 for the Margin calculation as defined in RG 1.99, Position 2.1.

B-12

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Table B-6 Fermi 2 Adjusted Reference Temperatures for up to 32 EFPY Lower-Intermediate Shell Plates, Axial Welds 2

Thickness in inches= 6.125 32 EFPY Peak ID. fluence= 9.68E+17 n/cm 2

32 EFPY Peak % T fluence= 6.70E+17 n/cm Water Level Instrumentation Nozzle Thickness in inches= 6.125 32 EFPY Peak ID. fluence= 1.74E+17 n/cm 2 2

32 EFPY Peak % T fluence= 1.20E+17 n/cm Lower Shell Plates and Axial Welds & Lower to Lower-Intermediate Girth Weld 2

Thickness in inches= 7.125 32 EFPY Peak ID. fluence- 6.23E+17 n/cm 2

32 EFPY Peak % T fluence= 4.06E+17 n/cm Initial 32 EFPY . 32 EFPY 32 EFP1 Adjusted %T Fluence Margin, Component .Heat or Heat/Lot %Cu %Ni CF RlTr 2 ARTNr Q1 (Y Shift ART CF (1) n/cm F S(F) F o. F Plant Specific Chemistries Plates:

Lower Shell G3706-1 C4540-2 0.08 0.62 51 -10 4.06E+17 13 0 7 13 27 17 G3706-2 C4540-1 0.11 0.57 74 -10 4.06E+17 19 0 10 19 38 28 G3706-3 C4554-1 0.12 0.56 82 -10 4.06E+17 21 0 11 21 43 33 Lower-Intermediate Shell G3703-5 C4564-1 0.09 0.55 58 -10 6.70E+17 20 0 10 20 40 30 G3705-1 B8614-1 0.12 0.61 83 -20 6.70E+17 28 0 14 28 57 37 G3705-2 C4574-2 0.10 0.55 65 -16 6,70E+17 22 0 11 22 44 28 G3705-3 C4568-2 0.12 0.61 83 -12 6.70E+17 28 0 14 28 57 45 WELDS:

Lower Shell Axial Tandem 13253, 12008 1092 2-307 A, B, C Lot 3833 0.26 0.87 224 -44 4.06E+17 59 0 28 56 115 71 Lower-Intermediate Shell Axial 15-308 A, B, C, D 33A277, 124 Lot 3878 0.32 0.50 188.5 -50 6.70E+17 64 0 28 56 120 70 Lower to Lower-Intermediate Girth 1-313 10137, 0091 Lot 3999 0.23 1.00 236 -50 4.06E+17 62 0 28 56 118 68 NOZZLES:

N16 (Water Level Instrumentation) 2127273 0.272 0.214 136 30 1.20E+17 17 0 8 17 34 64 N16 (Water Level Instrumentation) 6397860 0.272 0.214 136 30 1.20E+17 17 0 8 17 34 64 N16 Weld Inconel (2)

B-13

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

IEGRATED SURVEILLANCE PROGRAM "':

BW'RVIP-135 R2 Plate (4 (( -12 6.70E+17 (( 46 Weld (5) )) -44 4.06E+17 )) 76 (1) Adjusted CF calculated per RG 1.99 Position 2.1.

(2) Non-ferritic materials such as Inconel do not require fracture toughness evaluation.

(3) Procedures defined in RG 1.99 are applied to determine the ART considering the ISP.

(4) The ISP plate is not the identical heat and is presented using the ISP chemistry and CF and applied to the limiting Fermi 2 plate, which is Heat C4568-2. ISP indicates that C4554-1 is also a limiting plate, however due to the reduced fluence at the lower shell, this material is no longer limiting.

(5) The ISP weld is the identical heat and is presented using the ISP chemistry and adjusted CF with the vessel weld Initial RTNTr and fluence. ao is presented as calculated, but multiplied by 0.5 for the Margin calculation as defined in RG 1.99, Position 2.1.

B-14

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Table B-7 Fermi 2 RPV Beltline P-T Curve Input Values for 32 EFPY A = -44+ 121+5=82°F (Based on ART value, which is conservative by 1 F, and an adjustment Adjusted RTN Initial RTND +Shift of 5°F to assure protection of the existing Flaw #124 in the axial weld of Shell Ring #2: see Section 3.0 for details.)

Vessel Height H= 861.6 inches Bottom of Active Fuel Height B = 216.3 inches Vessel Radius (to base metal) R= 127 inches Minimum Vessel Thickness (without clad) t= 6.125 inches Note: The ART for 24 EFPY is 62°F as shown in Table B-5. Flaw #124 is protected by adjusting the ART value by 13°F for 24 EFPY as noted in Section 3.0.

B-15

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Table B-8 Fermi 2 Definition of RPV Beltline Region1 )

Elevation Component (inches from RPV "0")

Shell # 2 - Top of Active Fuel (TAF) 366.3 Shell # 1 - Bottom of Active Fuel (BAF) 216.3 Shell # 2 - Top of Extended Beltline Region (32 EFPY) 374.7 Shell # 1 - Bottom of Extended Beltline Region (32 EFPY) 210.5 Circumferential Weld Between Shell #1 and Shell #2 244.5 Centerline of Recirculation Outlet Nozzle in Shell # 1 161.5 Top of Recirculation Outlet Nozzle N1 in Shell # 1 193.7 Centerline of Recirculation Inlet Nozzle N2 in Shell # 1 181.0 Top of Recirculation Inlet Nozzle N2 in Shell # 1 197.5 Centerline of Water Level Instrumentation Nozzle in Shell # 2 366.0 Bottom of Water Level Instrumentation Nozzle in Shell # 2 364.8 (1) The beltline region is defined as any location where the peak neutron fluence is expected to exceed or equal 1.0e17 n/cm.

Based on the above, it is concluded that none of the Fermi 2 reactor vessel plates, nozzles, or welds, other than those included in the Adjusted Reference Temperature Table, are in the beltline region.

B-16

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Appendix C Fermi 2 Reactor Pressure Vessel P-T Curve Checklist C-1

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Table C-1 provides a checklist that defines pertinent points of interest regarding the methods and information used in developing the Fermi 2 Pressure-Temperature Limits Report. This table demonstrates that all important parameters have been addressed in accordance with the P-T curve LTR (Reference 6.2), and includes comments, resolutions, and clarifications as necessary.

Table C-1 Fermi 2 Checklist Parameter Completed Comments/Resolutions/Clarifications Initial RTNDT Initial RTNDT has been determined for The N16 water level instrumentation Fermi 2 for all vessel materials including nozzle is considered within the beltline plates, flanges, forgings, studs, nuts, bolts, region. This forging was fabricated welds. from SA508 Class I carbon steel.

Additional details regarding this material Include explanation (including and its properties are provided in Section methods/sources) of any exceptions, 3.0 of this PTLR.

resolution of discrepant data (e.g.,

deviation from originally reported values). All other information remains unchanged from previous submittals.

Appendix B contains tables of all Initial RTNDT values for Fermi 2.

Has any non-Fermi 2 initial RTNDT Plate heat (( )) information information (e.g., ISP, comparison to other was obtained from the ISP database.

plant) been used? This material is not the identical heat to the target vessel plate material and, in accordance with the ISP guidance; this data was not used in determining the limiting ART.

If deviation from the P-T curve LTR Details regarding the determination of process occurred, sufficient supporting the initial RTNDT of the N16 nozzle is information has been included (e.g., provided in Section 3.0 of this PTLR.

Charpy V-Notch data used to determine an Initial RTNDT). No other deviations from the P-T curve LTR process.

C-2

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Table C-1 Fermi 2 Checklist, Continued Parameter Completed Comments/Resolutions/Clarifications All previously published Initial RTNDT RVID was reviewed for the beltline values from sources such as the GL88-01, materials; all initial RTNDT values agree; Reactor Vessel Integrity Database (RVID), no further review was performed FSAR, etc., have been reviewed.

Adjusted Reference Temperature (ART)

Sigma I (a1, standard deviation for Initial Sigma I is equal to 0 for all materials.

RTNDT) is 0°F unless the RTNDT was obtained from a source other than CMTRs.

If a1 is not equal to 0, reference/basis has been provided.

Sigma A (aA, standard deviation for ARTNDT) is determined per RG 1.99, Rev. 2 Chemistry has been determined for all Sufficient information was not available vessel beltline materials including plates, to determine the chemistry content for forgings (if applicable), and welds for the N16 water level instrumentation Fermi 2. nozzle materials. BWR fleet data was obtained and %Cu and %Ni were Include explanation (including determined using Mean + lY. More methods/sources) of any exceptions, information is provided in Section 3.0 of resolution of discrepant data (e.g., this PTLR.

deviation from originally reported values).

One deviation from previously reported values was identified. The %Ni value for ISP plate heat (( )) was previously reported as (( )).

This has been corrected to (( ))

Ni in accordance with BWRVIP-135, Revision 2. The corresponding CF has been corrected from (( )) to

(( )). This change does not affect the P-T curves.

Non-Fermi 2 chemistry information (e.g., Plate heat (( )) and weld heat ISP, comparison to other plant) used has (( )) have been been adequately defined and described. evaluated using best estimate chemistry from the ISP.

For any deviation from the P-T curve LTR No deviations from the P-T curve LTR process, sufficient information has been process.

included.

All previously published chemistry values RVID was reviewed; all initial RTNDT from sources such as the GL88-01, Reactor values agree; no further review was Vessel Integrity Database (RVID), FSAR, performed etc., have been reviewed.

C-3

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Parameter Completed Comments/Resolutions/Clarifications The fluence used for determination of ART and any extended beltline region was obtained using an NRC-approved methodology.

C-4

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Table C-1 Fermi 2 Checklist, Continued Parameter Completed Comments/Resolutions/Clarifications The fluence calculation provides an axial distribution to allow determination of the vessel elevations that experience fluence of 1.0e17 n/cm 2 both above and below active fuel.

The fluence calculation provides an axial distribution to allow determination of the fluence for intermediate locations such as the beltline girth weld (if applicable) or for any nozzles within the beltline region.

All materials within the elevation range where the vessel experiences a fluence

>1.0e17 n/cm 2 have been included in the ART calculation. All initial RTNDT and chemistry information is available or explained.

Discontinuities The discontinuity comparison has been performed as described in Section 4.3.2.1 of the P-T curve LTR. Any deviations have been explained.

Discontinuities requiring additional components (such as nozzles) to be considered part of the beltline have been adequately described. It is clear which curve is used to bound each discontinuity.

Appendix G of the P-T curve LTR The thickness discontinuity evaluation describes the process for considering a demonstrated that no additional thickness discontinuity, both beltline and adjustment is required; the curves bound non-beltline. If there is a discontinuity in the discontinuity stresses.

the Fermi 2 vessel that requires such an evaluation, the evaluation was performed.

The affected curve was adjusted to bound the discontinuity, if required.

C-5

NEDO-33785 Revision 1 Non-Proprietary Information-Class I (Public)

Table C-1 Fermi 2 Checklist, Continued Parameter Completed Comments/Resolutions/Clarifications Appendix H of the P-T curve LTR defines the basis for the CRD Penetration curve discontinuity and the appropriate transient application. The Fermi 2 evaluation bounds the requirements of Appendix H.

Appendix J of the P-T curve LTR defines the basis for the Water Level Instrumentation Nozzle curve discontinuity and the appropriate transient application.

The Fermi 2 evaluation bounds the requirements of Appendix J.

C-6

Enclosure 7 to NRC-13-0026 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 GEH Affidavit for Response to Grand Gulf RAI 8

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Linda C. Dolan, state as follows:

(1) 1 am the Manager of Regulatory Compliance, of GE-Hitachi Nuclear Energy Americas LLC

("GEH"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 of GEH letter, 317855-3, "GEH Revised Response to GGNS PT Curve RAI 8," dated June 17, 2013. The GEH proprietary information in Enclosure 1, which is entitled "GEH Response to GGNS PT Curve RAI 8," is identified by a dotted underline inside double square brackets. ((This.

sentence is an example.9)) In each case, the superscript notation 3 refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. Sec. 552(b)(4), and the Trade Secrets Act, 18 U.S.C.

Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. Cir. 1983).

(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;

b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;

d. Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.

(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my Affidavit for Enclosure 1 of 317855-3 Page 1 of 3

GE-Hitachi Nuclear Energy Americas LLC knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH. Access to such documents within GEH is limited to a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary or confidentiality agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains the detailed GEH methodology for pressure-temperature curve analysis for the GEH Boiling Water Reactor (BWR). These methods, techniques, and data along with their application to the design, modification, and analyses associated with the pressure-temperature curves were achieved at a significant cost to GEH.

The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience databases that constitute a major GEH asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.

The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their Affidavit for Enclosure 1 of 317855-3 Page 2 of 3

GE-Hitachi Nuclear Energy Americas LLC own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this 17 th day of June 2013.

Linda C. Dolan Manager, Regulatory Compliance GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.

Wilmington, NC 28401 Linda.Dolan@ge.com Affidavit for Enclosure 1 of 317855-3 Page 3 of 3

Enclosure 8 to NRC-13-0026 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revised Response to Grand Gulf RAI 8 NONPROPRIETARY

Enclosure 2 317855-3 GEH Response to GGNS PT Curve RAI 8 Non-Proprietary Information-Class I (Public)

Non-Proprietary Notice This is a non-proprietary version of Enclosure 1 of 317855-3 which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here (( R to 317855-3 Page 2 of 2 NRC RAI 8 identifies nozzle N12 as a beltline water level instrument nozzle and notes that an evaluation was conducted using the limiting material propertiesfor the adjoining shell ring, which appears to be appropriateas nozzle N12 is identifiedas austenitic. Provide details of this evaluation which demonstrates that the drill hole for the beltline water level instrument nozzle is not limiting.

GEH Response The Fermi 2 N16 water level instrumentation nozzle is fabricated from SA508 Class 1 carbon steel material. Therefore, the N16 nozzle was evaluated for ART. Appendix J of NEDC-33178P-A provides detailed results of an analysis performed for the water level instrumentation nozzle that provides the required stresses for the drill hole in the shell plate.

These stresses were used to generate a specific curve applicable for the water level instrumentation nozzle to assure that this location is bounded in the PT curves.

The fluence utilized for the N16 WLI nozzle is based on a less conservative power history that excludes Extended Power Uprate (EPU) and considers Thermal Power Optimization (TPO) after RFO16. The 32 EFPY peak surface fluence of 1.74e17 n/cm2 considers operation at 3293 MWt for 3.4 EFPY, 3430 MWt for 16.38 EFPY, and 3486 MWt (TPO) for 12.22 EFPY.

For Fermi 2, the water level instrumentation nozzles are ((

)) for.24 EFPY. For Curve B at 24 EFPY, the water level instrumentation nozzle is ((

)). For 32 EFPY, the water level instrumentation nozzles are (( )). For Curve B, the water level instrumentation nozzle is ((

)).

Similarly, for Curve C, the water level instrumentation nozzle is ((

Enclosure 9 to NRC-13-0026 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revised EPRI Affidavit for Enclosure 6 of Reference 2

Attachment 1

~I~f2 IIELECTRIC POWER RESEARCH INSTITUTE NEIL WILMSHURST Vice President and Chief Nuclear Officer May 13, 2013 Document Control Desk Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Request for Withholding of the following Proprietary Information Included in:

"Proposed License Amendment to Revise and Relocate Pressure Temperature Curves to a Pressure Temperature Limits Report," Contained in Enclosure 1 of GE-Hitachi Nuclear Energy Americas LLC

("GEH") letter, 1-2RXPKK-13, "GEH Responded to GGNS PT Curve RAls," dated October 19, 2012 To Whom It May Concern:

This isa request under 10 C.F.R. §2.390(a)(4) that the U.S. Nuclear Regulatory Commission ("NRC") withhold from public disclosure the report identified in the enclosed Affidavit consisting of the proprietary information owned by Electric Power Research Institute, Inc. ("EPRI") identified inthe attached report. Proprietary and non-proprietary versions of the Report and the Affidavit in support of this request are enclosed.

EPRI desires to disclose the Proprietary Information in confidence to assist the NRC review of the enclosed submittal to the NRC by DTE Energy. The Proprietary Information isnot to be divulged to anyone outside of the NRC or to any of its contractors, nor shall any copies be made of the Proprietary Information provided herein.

EPRI welcomes any discussions and/or questions relating to the information enclosed.

If you have any questions about the legal aspects of this request for withholding, please do not hesitate to contact me at (704) 704-595-2732. Questions on the content of the Report should be directed to Andy McGehee of EPRI at (704) 502-6440.

Sincerely, Together . . . Shaping the Future of Electricity 1300 West W.T. Harris Boulevard, Charlotte, NC 28262-8550 USA

704.595.2732

Mobile 704.490.2653 . nwilmshurst@epri.com

Cl52I I ELECTRIC POWER ESEARCH INSTITUTE AFFIDAVIT RE: Request for Withholding of the Following Proprietary Information Included In:

"Proposed License Amendment to Revise and Relocate Pressure Temperature Curves to a Pressure Temperature Limits Report," Contained inEnclosure 1of GE-Hitachi Nuclear Energy Americas LLC

("GEH") letter, 1-2RXPKK-13, "GEH Responded to GGNS PT Curve RAIs," dated October 19, 2012 1,Neil Wilmshurst, being duly sworn, depose and state as follows:

I am the Vice President and Chief Nuclear Officer at Electric Power Research Institute, Inc. whose principal office is located at 3420 Hillview Avenue, Palo Alto, California ("EPR!") and I have been specifically delegated responsibility for the above-listed report that contains EPRI Proprietary Information that is sought under this Affidavit to be withheld "Proprietary Information". I am authorized to apply to the U.S. Nuclear Regulatory Commission ("NRC") for the withholding of the Proprietary Information on behalf of EPRI.

EPRI Information is identified by a solid underline inside double square brackets. ((This sentence is an example.)) {E} Tables containing EPRI proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation {E} refers to this affidavit as the basis for the proprietary determination.

EPRI requests that the Proprietary Information be withheld from the public on the following bases:

Withholding Based Upon Privileged And Confidential Trade Secrets Or Commercial Or Financial Information:

a. The Proprietary Information is owned by EPRI and has been held in confidence by EPRI. All entities accepting copies of the Proprietary Information do so subject to written agreements imposing an obligation upon the recipient to maintain the confidentiality of the Proprietary Information. The Proprietary Information isdisclosed only to parties who agree, in writing, to preserve the confidentiality thereof,

b. EPRI considers the Proprietary Information contained therein to constitute trade secrets of EPRI. As such, EPRI holds the Information in confidence and disclosure thereof isstrictly limited to individuals and entities who have agreed, inwriting, to maintain the confidentiality of the Information.

c. The information sought to be withheld is considered to be proprietary for the following reasons. EPRI made a substantial economic investment to develop the Proprietary Information and, by prohibiting public disclosure, EPRI derives an economic benefit in the form of licensing royalties and other additional fees from the confidential nature of the Proprietary Information. If the Proprietary information were publicly available to consultants and/or other businesses providing services inthe electric and/or nuclear power industry, they would be able to use the Proprietary Information for their own commercial benefit and profit and without expending the substantial economic resources required of EPRI to develop the Proprietary Information.

d. EPRI's classification of the Proprietary Information as trade secrets isjustified by the Uniform Trade Secrets Act which California adopted in 1984 and a version of which has been adopted by over forty states. The California Uniform Trade Secrets Act, California Civil Code §§3426 - 3426.11, defines a "trade secret" as follows:

"'Trade secret' means information, including a formula, pattern, compilation, program device, method, technique, or process, that:

(1)Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (2)Isthe subject of efforts that are reasonable under the circumstances to maintain its secrecy."

e. The Proprietary Information contained therein are not generally known or available to the public. EPRI developed the Information only after making a determination that the Proprietary Information was not available from public sources. EPRI made a substantial investment of both money and employee hours inthe development of the Proprietary Information. EPRI was required to devote these resources and effort to derive the Proprietary Information, As a result of such effort and cost, both interms of dollars spent and dedicated employee time, the Proprietary Information ishighly valuable to EPRI.

f. A public disclosure of the Proprietary Information would be highly likely to cause substantial harm to EPRI's competitive position and the ability of EPRI to license the Proprietary Information both domestically and internationally. The Proprietary Information can only be acquired and/or duplicated by others using an equivalent investment of time and effort.

I have read the foregoing and the matters stated herein are true and correct to the best of my knowledge, information and belief. I make this affidavit under penalty of perjury under the laws of the United States of America and under the laws of the State of California.

Executed at 1300 W WT Harris Blvd being the premises and place of business of Electric Power Research Institute, Inc.

Date: 6 '3-2 cI Neil Wilmshurst (State of North Carolina)

(County of Mecklenburg)

Subscribed and sworn to (or affirmed) before me on this a tay of '7/ , 2013 by

_ /_/_________ , proved to me on the basis of satididtory evidence to be the person(s) who appeared before me.

Signature S// / oe (Seal)

My Commission Expires Aday of d 20/,

v t e Letter Sequence Request
TAC:MF0446, (Approved, Closed)
Initiation Request Acceptance Administration Withholding Request Acceptance, Withholding Request Acceptance Questions 10 April 2013 10 September 2013 Answers 17 October 2013 Results Approval Other: NRC-12-0037, Proposed License Amendment to Relocate Pressure and Temperature Curves to a Pressure Temperature Limits Report
MONTHYEAR2013-04-10 [Table View]

NRC-13-0026, Response to Request for Additional Info Re Proposed License Amendment to Relocate Pressure and Temperature Curves to Pressure & Temperature Limits Report

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