NRC-24-0058, Status of License Renewal Commitments

Status of License Renewal Commitments

ML24278A065
Person / Time
Site:	Fermi
Issue date:	10/03/2024
From:	Domingos C DTE Electric Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-24-0058
Download: ML24278A065 (1)

Text

Christopher P. Domingos Site Vice President DTE Electric Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5025 Fax: 734.586.5295 Email: christopher.domingos@dteenergy.com 10 CFR 54 10 CFR 50.54 October 3, 2024 NRC-24-0058 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

FERMI 2 STATION, DOCKET NO. 50-341 STATUS OF LICENSE RENEWAL COMMITMENTS The purpose of this letter is to notify the U.S. Nuclear Regulatory Commission (NRC) of the completion of certain license renewal commitments (LRC) identified in the Reference and as required by Renewed License No. NPF-43 License Condition 2.C.(26) when implementation of these activities is complete. The table provided in the Enclosure identifies the LRCs status that DTE Electric Company is reporting as complete and includes the LRCs reported in the Reference. Several commitments were modified per 10CFR50.59, as allowed by License Condition 2.C.(26)(a), and the revised version is shown in the enclosure.

The Enclosure notes two exceptions to completed LRCs: Commitment No. 5, pertaining to Boraflex, and Commitment No. 20, pertaining to the Neutron-Absorbing Material Monitoring Program. Both are in the process of being completed and will be completed/implemented before March 20, 2025, with the implementation of License Amendment 220. Program documentation for these items is available for inspection at the NRC's convenience.

No new commitments are created by this letter or the enclosure.

If you have any questions or require additional information, please contact Mr. Eric Frank, Licensing Manager, at (734) 586-4772.

Reference:

1) NUREG-2210 "Safety Evaluation Report Related to the License Renewal of Fermi 2," dated December 2016 (ADAMS ML1690A241)

USNRC NRC-24-0058 Page2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on the :3 day of October, 2024

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Christopher P. Domingos Site Vice President

Enclosure:

Fermi 2: Completed License Renewal Commitment Table cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Theodore R. (T.R.) Went\\vorth II Manager - Radiological Protection Section, Materials Management Division David Asselin Supervisor - Radiological Protection Section Radiological Emergency Preparedness Unit

- Materials Management Division

Enclosure to NRC-24-0058 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Fermi 2: Completed License Renewal Commitment Table

Enclosure to NRC-24-0058 Page 1 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 1

DTE will make the following changes to the process for operating experience review.

a.

Procedures will be revised to add an aging type code to corrective action program documents that describe either plant conditions related to aging or industry operating experience related to aging.

b. Procedures will be revised to provide for training of personnel responsible for submitting, screening, assigning, evaluating, or otherwise processing plant-specific and industry operating experience concerning age-related degradation and aging management, as well as for personnel responsible for implementing AMPs, based on the complexity of the job performance requirements, and assigned responsibilities.

c.

Procedures will be revised to specify that evaluations of operating experience concerning age-related degradation will include consideration of the affected systems, structures or components, the environments, materials, aging effects, aging mechanisms, and aging management programs.

Completed 2

DTE currently performs periodic self-assessments on many aging management programs. DTE will enhance the Fermi 2 self-assessment process to provide for periodic evaluation of the effectiveness of each aging management program described in the updated final safety analysis report (UFSAR) supplement. For new aging management programs, the first evaluation will be performed within 5 years of implementing the program.

Completed 3

Implement the new Aboveground Metallic Tanks Program that will manage loss of material and cracking for outdoor tanks within the scope of license renewal that are sited on soil or concrete. Condensate storage tank (CST) internal inspections will be conducted in accordance with Table 4a of LR-ISG-2012-02. This program will also manage the bottom surfaces of the CST. Within the 10 years prior to the period of extended operation and every 10 years thereafter, a volumetric examination of a minimum 25 percent of the CST tank bottom interface with the concrete ring foundation will be performed to manage loss of material. The volumetric inspection will be on a 2-inch grid or less, depending on the technology utilized.

Completed

Enclosure to NRC-24-0058 Page 2 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 4

Enhance the Bolting Integrity Program as follows:

a.

Revise Bolting Integrity Program procedures to ensure consideration of actual yield strength when procuring bolting material. If procured, closure bolting with actual yield strength greater than or equal to 150 ksi is monitored for cracking.

b. Revise Bolting Integrity Program procedures to state that bolting for safety-related pressure-retaining components is inspected for leakage, loss of material, cracking, and loss of preload/loss of prestress. Closure bolting with actual yield strength greater than or equal to 150 ksi is monitored for cracking.

c.

Revise Bolting Integrity Program procedures to:

(1) implement applicable recommendations for pressure boundary bolting in NUREG-1339, Electric Power Research Institute (EPRI) NP-5769, and EPRI TR-104213; (2) state both American Society of Mechanical Engineers (ASME) Code class bolted connections and non-ASME Code class bolted connections are inspected at least once per refueling cycle; and (3) include volumetric examination per ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, for closure bolting with actual yield strength greater than or equal to 150 ksi regardless of code classification.

d. Revise Bolting Integrity Program procedures to inspect residual heat removal service water (RHRSW), emergency equipment service water (EESW), and emergency diesel generator service water (EDGSW) systems pump and valve bolting submerged in the RHRSW reservoir at least once every refueling cycle and to opportunistically inspect bolting threads during maintenance activities.

e.

Revise Bolting Integrity Program procedures to include the additional guidance and recommendations of EPRI NP-5769 for replacement of ASME pressure-retaining bolts and the guidance provided in EPRI TR-104213 for the replacement of other pressure-retaining bolts.

f.

Revise Bolting Integrity Program procedures to stipulate that administrative controls are in accordance with the Fermi 2 10 CFR Part 50 Appendix B Quality Assurance Program.

g. Revise Bolting Integrity Program procedures to perform opportunistic inspections for Control Center HVAC system safety-related pressure-retaining bolting in a lube oil external environment, including the bolting threads to ensure that loss of material in crevice locations that are not readily visible can be detected.

h. Revise Bolting Integrity Program procedures to perform opportunistic inspections for CTG system non-safety-related pressure-retaining bolting in a lube oil external environment.

Completed

Enclosure to NRC-24-0058 Page 3 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 5

Implement the Boraflex rack neutron absorbing insert installation approved in Amendment No. 220 so that the current Boraflex panels in the spent fuel pool will not be required to perform a neutron absorption function during the period of extended operation.

Not completed scheduled before 3/20/2025 6

Implement new Buried and Underground Piping Program that will manage the effects of aging on the external surfaces of buried and underground piping within the scope of license renewal. Soil testing will be conducted once in each 10-year period starting 10 years prior to the period of extended operation, if a reduction in the number of inspections recommended in Table XI.M41-2 of LR-ISG-2015-01 is taken based on a lack of soil corrosivity.

Completed 7

Enhance the BWR Vessel Internals Program as follows:

a.

The susceptibility to neutron or thermal embrittlement for reactor vessel internal components composed of cast austenitic stainless steel (CASS) and X-750 alloy will be evaluated.

b. BWR Vessel Internals Program procedures will be revised as follows. Portions of the susceptible components determined to be limiting from the standpoint of thermal aging susceptibility, neutron fluence, and cracking susceptibility (i.e.,

applied stress, operating temperature, and environmental conditions) will be inspected, using an inspection technique capable of detecting the critical flaw size with adequate margin. The critical flaw size will be determined based on the service loading condition and service-degraded material properties. The initial inspection will be performed either prior to or within 5 years after entering the period of extended operation. If cracking is detected after the initial inspection, the frequency of re-inspection will be justified based on fracture toughness properties appropriate for the condition of the component. The sample size for the initial inspection of susceptible components will be 100 percent of the accessible component population, excluding components that may be in compression during normal operations.

c.

BWR Vessel Internals Program procedures will be revised as follows. In accordance with an applicant action item for BWRVIP-25 safety evaluation: (a) install core plate wedges prior to the period of extended operation, or (b) complete a plant-specific analysis that justifies no inspections are required, or (c) complete a plant-specific analysis to determine acceptance criteria for continued inspection of core plate holddown bolts in accordance with BWRVIP-25.

For Option (b), the analysis will address loss of preload due to stress relaxation in the core plate rim hold-down bolts and quantify the loss of preload/stress relaxation that will occur in these bolts during the period of extended operation. The analysis will be submitted to the NRC 2 years prior to the period of extended operation. Additionally, the UFSAR will be revised to address the analysis if it is determined to meet the criteria for a time-limited aging analysis (TLAA) at least 2 years prior to the period of extended operation.

For Option (c), the analysis will address loss of preload due to stress relaxation in the core plate rim hold-down bolts and quantify the loss of preload/stress relaxation that will occur in these bolts during the period of extended operation. The analysis, inspection plan with acceptance criteria, and justification for the inspection plan will be submitted to the NRC 2 years prior to the period of extended operation.

Completed

Enclosure to NRC-24-0058 Page 4 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 7

(continued)

Additionally, the UFSAR will be revised to address the analysis if it is determined to meet the criteria for a TLAA at least 2 years prior to the period of extended operation.

d. Revise BWR Vessel Internals Program procedures such that the flaw evaluation methodology for the top guide grid beam will address the following three items if they have not been resolved generically during the NRC review and approval process of BWRVIP-183:

(1) Detected flaws evaluated using the methodology in BWRVIP-183 Section 4 will be demonstrated to be sufficiently far from geometric discontinuities (i.e., notches or slots) such that the stress condition in the vicinity of the flaw is consistent with that for a single edgecrack plate. Appropriately applied K values which account for the effects of geometric discontinuities will be used and justified in the flaw evaluation.

(2) The flaw evaluation methodology in BWRVIP-183 Section 4 will be used to justify continued operation on a cycle-by-cycle basis. Use of the flaw evaluation methodology to justify operation for more than once cycle will require NRC approval and would be based on plant specific operating experience including crack length measurements of detected top guide grid beam flaws to benchmark the accuracy of the flaw evaluation methodology.

(3) When applying the flaw evaluation methodology in BWRVIP-183 Section 4, a severed beam evaluation consistent with BWRVIP-183 Section 5 will also be performed. The severed beam analysis will demonstrate that even if a beam was a completely severed beam, it would not be expected to interfere with the ability of the control rod drive system to insert control rods.

e.

Revise BWR Vessel Internals Program procedures to perform opportunistic inspections of the differential pressure and standby liquid control line inside the reactor vessel when the line becomes accessible.

8 Enhance the Compressed Air Monitoring Program as follows:

a.

DELETED

b. Revise Compressed Air Monitoring Program procedures to include periodic and opportunistic inspections of accessible internal surfaces of piping, compressors, dryers, aftercoolers, and filters. In addition, include in the Compressed Air Monitoring Program procedures the applicable provisions recommended in EPRI NP-7079, EPRI TR-108147, and ASME OM-S/G-1998, Part 17 for air system contaminants, inspection frequency, inspection methods, and acceptance criteria for components subject to aging management review that are exposed to compressed air and components in the EDG starting air system and control air system.

Completed

Enclosure to NRC-24-0058 Page 5 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 9

Enhance the Containment Inservice Inspection (CII)-IWE Program as follows:

a.

Revise plant procedures to require inspection of the sand cushion drain lines to monitor the internal conditions of the drain lines (e.g., for moisture, sand, blockage) and ensure there is no evidence of blockage at least once prior to the period of extended operation and once every 10 years during the period of extended operation.

b. Revise plant procedures to specify the preventive actions delineated in NUREG-1339 and in EPRI NP-5769, NP-5067, and TR-104213 that emphasize proper selection of bolting material, installation torque or tension, and the use of lubricants and sealants for high strength bolting.

c.

Revise plant procedures to include the preventive actions for storage of American Society for Testing and Materials (ASTM) A325 and A490 bolting from Section 2 of Research Council for Structural Connections publication, "Specification for Structural Joints Using ASTM A325 or A490 Bolts."

d. [Deleted]

e.

[Deleted]

f.

Revise plant procedures to determine drywell shell thickness in the sand cushion areas before the period of extended operation and once in each 10-year interval during the period of extended operation. From the results (including prior results), develop a corrosion rate to demonstrate that the drywell shell will have sufficient wall thickness to perform its intended function through the period of extended operation.

g. Revise plant procedures to require corrective actions should moisture be detected or suspected in the inaccessible area on the exterior of the drywell shell, including:

Identify surfaces requiring augmented inspections for the period of extended operation in accordance with Subsection IWE-1240, as identified in Table IWE-2500-1, Examination Category E-C.

Use examination methods that are in accordance with Subsection IWE-2500.

Demonstrate through use of augmented inspections performed in accordance with Subsection IWE that corrosion is not occurring or that corrosion is progressing so slowly that the degradation will not jeopardize the intended function of the drywell shell through the period of extended operation.

Completed

Enclosure to NRC-24-0058 Page 6 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 10 Enhance Diesel Fuel Monitoring Program as follows:

a.

Revise Diesel Fuel Monitoring Program procedures to monitor and trend water and sediment, particulates, and levels of microbiological organisms in the EDG fuel oil storage tanks, EDG fuel oil day tanks, diesel fire pump fuel oil tank, and CTG fuel oil tank quarterly. In addition, revise program procedures to state that biocides or corrosion inhibitors may be added as a preventive measure or are added if periodic testing indicates biological activity or evidence of corrosion, respectively.

b. Revise the Diesel Fuel Monitoring Program procedures or preventative maintenance events to include a 10-year periodic cleaning and internal visual inspection of the EDG fuel oil storage tanks, EDG fuel oil day tanks and diesel fire pump fuel oil tank with the following instructions. The cleanings and internal inspections will be performed at least once during the 10-year period prior to the period of extended operation and at succeeding 10-year intervals. If visual inspection is not possible, perform a volumetric inspection. If evidence of degradation is observed during visual inspection, perform a volumetric examination of the affected area.

The schedule for the Preventive Maintenance (PM) event to perform diesel fire pump fuel oil tank draining, flushing, and inspection will continue at its frequency at the time of the enhancement implementation, until a PM evaluation of results from fuel oil samples and tank inspections indicates that the system will be capable of continuing to perform its function during the period of extended operation with a lower frequency, not less than once per 10-year interval for cleaning and internal visual inspection consistent with NUREG-1801.

Completed

Enclosure to NRC-24-0058 Page 7 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 11 Enhance External Surfaces Monitoring Program as follows:

a.

Revise External Surfaces Monitoring Program procedures to clarify that periodic inspections will be performed of systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(1) and (a)(3).

Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject systems will include structures, systems, and components (SSCs) that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

b. Revise External Surfaces Monitoring Program procedures to inspect 100 percent of accessible components at least once per refueling cycle and to ensure required walk downs include instructions to inspect for the following related to metallic components:

Corrosion (loss of material).

Leakage from or onto external surfaces (loss of material).

Worn, flaking, or oxide-coated surfaces (loss of material).

Corrosion stains on thermal insulation (loss of material).

Protective coating degradation (cracking, flaking, and blistering).

Leakage for detection of cracks on the external surfaces of stainless-steel components exposed to an air environment containing halides (cracking).

c.

Revise External Surfaces Monitoring Program procedures to include instructions for monitoring aging effects for flexible polymeric components through physical manipulations of the material, with a sample size for manipulation of at least 10 percent of the available surface area. Inspect accessible surfaces for the following:

Surface cracking, crazing, scuffing, dimensional changes (e.g., ballooning and necking).

Discoloration.

Exposure of internal reinforcement for reinforced elastomers.

Hardening as evidence by loss of suppleness during manipulation where the component and material are appropriate to manipulation.

Shrinkage, loss of strength.

d. Revise External Surfaces Monitoring Program procedures to specify the following for insulated components:

Periodic representative inspections will be conducted during each 10-year period.

For a representative sample of insulated indoor components exposed to condensation (because the component is operated below the dew point) and insulated outdoor components, insulation will be removed for visual inspection of the component surface. Inspections include a minimum of 20 percent of the in-scope piping length for each material type (e.g., steel, stainless steel, copper alloy, aluminum), or for components with a configuration which does not conform to a 1-foot axial length determination (e.g., valve, accumulator), 20 percent of the surface area. Alternatively, insulation will be removed and a minimum of 25 inspections performed that can be a combination of 1-foot axial length sections and individual components for each material type.

Completed

Enclosure to NRC-24-0058 Page 8 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 11 (Continued)

Inspection locations are based on the likelihood of corrosion under insulation (CUI). For example, CUI is more likely for components experiencing alternate wetting and drying in environments where trace contaminants could be present and for components that operate for long periods of time below the dew point.

Subsequent inspections will consist of an examination of the exterior surface of the insulation for indications of damage to the jacketing or protective outer layer of the insulation, if the following conditions are verified in the initial inspection:

o No loss of material due to general, pitting or crevice corrosion, beyond that which could have been present during initial construction, and o No evidence of cracking.

If the external visual inspections of the insulation reveal damage to the exterior surface of the insulation or there is evidence of water intrusion through the insulation (e.g., water seepage through insulation seams/joints), periodic inspections under the insulation will continue as described above.

Removal of tightly adhering insulation that is impermeable to moisture is not required unless there is evidence of damage to the moisture barrier. If the moisture barrier is intact, the likelihood of CUI is low for tightly adhering insulation. Tightly adhering insulation is considered to be a separate population from the remainder of insulation installed on in-scope components. The entire population of in-scope accessible piping component surfaces that have tightly adhering insulation will be visually inspected for damage to the moisture barrier with the same frequency as for other types of insulation inspections. These inspections will not be credited towards the inspection quantities for other types of insulation.

e.

Revise External Surfaces Monitoring Program procedures to include acceptance criteria for the parameters observed.

Metals should not have any indications of relevant degradation.

Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

Rigid polymers should have no erosion, cracking, crazing or chalking.

For insulation, no discoloration, staining, or surface irregularities from moisture intrusion.

f.

Revise External Surfaces Monitoring Program procedures to stipulate that administrative controls are in accordance with the Fermi 2 10 CFR Part 50 Appendix B Quality Assurance Program.

g. Revise External Surfaces Monitoring Program procedures to include instructions for detection of cracking of gas-filled stainless steel and aluminum components exposed to outdoor air.

h. Revise External Surfaces Monitoring Program procedures to:

(a) Visually inspect jacketed and nonjacketed insulation required to reduce heat transfer at a frequency consistent with NUREG-1801 Section XI.M36, as modified by LR-ISG-2012-02, to ensure that insulation degradation due to moisture intrusion has not occurred.

(b) Ensure procedures include instructions to inspect for signs of water intrusion. Inspect accessible surfaces for the following signs of water intrusion: discoloration, staining, or surface irregularities.

Enclosure to NRC-24-0058 Page 9 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 12 Enhance the Fatigue Monitoring Program as follows:

a.

Revise Fatigue Monitoring Program procedures to monitor and track critical thermal and pressure transients for components that have been identified to have a fatigue TLAA.

b. Develop environmentally assisted fatigue (EAF) usage calculations that consider the effects of the reactor water environment for a set of sample reactor coolant system components. This sample set will include the locations identified in NUREG/CR-6260 and additional plant-specific component locations in the reactor coolant pressure boundary if they are found to be more limiting than those considered in NUREG/CR-6260. Environmental correction factors will be determined using formulae consistent with those recommended in NUREG-1801, X.M1.

c.

Revise Fatigue Monitoring Program procedures to provide updates of the fatigue usage calculations on an as-needed basis if an allowable cycle limit is approached, or in a case where a transient definition has been changed, unanticipated new thermal events are discovered, or the geometry of components has been modified. For components with assumed minimal cycle counts, ensure that exemption assumptions are not exceeded.

d. After the EAF calculations are completed, revise the Fatigue Monitoring Program procedures to state that the program counting of the cycle limits maintains the cumulative fatigue usage below the design limit through the period of extended operation, with consideration of the reactor water environmental fatigue effects. Revise Fatigue Monitoring Program procedures to allow for use of cycle-based fatigue (CBF) or stress-based fatigue (SBF) monitoring methods (including environmental effects) if a components cumulative usage factor (CUF) value is projected to exceed 1.0 after EAF calculations are completed.

e.

Revise Fatigue Monitoring Program procedures so that the scope of the program includes monitoring the operating hours for the main steam bypass operation at the 30%-45% valve open position and perform trending to ensure that the operating time for the main steam bypass operation remains below the design limit during the period of extended operation.

f.

Revise Fatigue Monitoring Program procedures to provide for corrective actions to prevent the operating time for the main steam bypass from exceeding the analysis during the period of extended operation. Acceptable corrective actions include repair of the component, replacement of the component, or a more rigorous analysis of the component to demonstrate that the service life will not be exceeded during the period of extended operation.

Completed

Enclosure to NRC-24-0058 Page 10 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 13 Enhance the Fire Protection Program as follows:

a.

Revise Fire Protection Program procedures to perform visual inspections to manage loss of material of the Halon and CO2 fire suppression system.

b. Revise Fire Protection Program procedures to require visual inspections of in-scope:

Fire wrap and fire stop materials for loss of material, change in material properties, cracking/delamination, separation, increased hardness, shrinkage, and loss of strength.

Carbon steel penetration sleeves for loss of material.

Steel framing, roof decking, and floor decking for loss of material.

Concrete fire barriers including manways, manhole covers, handholes, and roof slabs for loss of material and cracking.

Railroad bay airlock doors for loss of material.

Inspections are performed at a frequency in accordance with the NRC-approved fire protection program or at least once every refueling cycle.

Completed

Enclosure to NRC-24-0058 Page 11 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 14 Enhance the Fire Water System Program as follows:

a. Revise Fire Water System Program procedures to ensure sprinkler heads are tested or replaced in accordance with National Fire Protection Association (NFPA) 25 (2011 Edition), Section 5.3.1.

b. Revise Fire Water System Program procedures to perform an inspection of wet fire water system piping condition at least once every 5 years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic or inorganic material that could result in flow obstructions or blockage of a sprinkler head. Where multiple wet-pipe systems are in a building, every other system shall be inspected in a 5-year period. Then, in the next 5-year period, the remaining systems in that building shall be inspected. (Refer to NFPA 25 (2011 Edition), Sections 14.2.1 and 14.2.2.) The inspection method used shall be capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling. Ensure procedures require a follow-up volumetric wall thickness evaluation where irregularities are detected.

c. Revise Fire Water System Program procedures to:

(a) ensure sprinkler heads are tested or replaced in accordance with NFPA 25 (2011 Edition) Section 5.3.1 and (b) the fire protection engineer approves the sprinkler testing laboratory.

d. Revise Fire Water System Program procedures to:

(a) specify that in accordance with NFPA 13.2.5.2 when there is a 10 percent reduction in full flow pressure when compared to the original acceptance test or previously performed tests, the cause of the reduction shall be identified and corrected as necessary; and (b) note the time to return to static pressure after performing a main drain test.

e. Revise Fire Water System Program procedures as needed to have test results reviewed and to notify the fire protection engineer of deficiencies identified or detected during testing.

f. Revise Fire Water System Program procedures to ensure piping is cleaned and sprinklers are replaced if obstructions are identified during internal inspections. Sprinklers loaded with dust may be cleaned using air rather than replaced.

g. Revise Fire Water System Program procedures to perform an internal inspection of wet fire water system piping conditions at least once every 5 years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of the branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinkler heads. Where multiple wet-pipe systems are in a building, every other system shall be inspected in a 5-year period. Then, in the next 5-year period, the remaining systems in that building shall be inspected.

h. [Deleted]

i. Revise Fire Water System Program procedures to perform at least once every 5 years either an internal inspection of the dry components downstream of the deluge valves for the hydrogen seal oil unit by removing a sprinkler toward the end of Completed

Enclosure to NRC-24-0058 Page 12 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 14 (Continued) one branch line and inspecting for evidence of loss of material and the presence of foreign organic and inorganic material that could result in flow obstructions or blockage of sprinklers, or Revise Fire Water System Program procedures to perform at least once every 5 years an air or smoke test to verify there is no flow obstruction or blockage of sprinklers.

j. Revise Fire Water System Program procedures to perform an inspection of the water distribution piping associated with charcoal filters for loss of material and foreign organic or inorganic material when the charcoal beds are replaced.

k. Revise Fire Water System Program procedures to perform an obstruction investigation whenever any of the criteria listed in NFPA Section 14.2.1.3 or 14.3.1 are met.

l. Perform a fire water system walkdown of the piping and components that are designed to be dry (e.g., downstream of deluge valves or manual isolations of dry fire water piping), but are periodically wetted, to determine if any piping sections are collecting water and are subject to both of the following augmented inspections:

In each 5-year interval, beginning 5 years prior to the period of extended operation, either (a) conduct a flow test or flush sufficient to detect potential flow blockage, or (b) conduct a visual inspection of 100 percent of the internal surface of piping segments that cannot be drained or piping segments that allow water to collect.

In each 5-year interval of the period of extended operation, inspect 20 percent of the length of piping segments that cannot be drained or piping segments that allow water to collect using volumetric techniques to measure wall thickness. Measurement points will be obtained so that each potential degraded condition can be identified (e.g., general corrosion, microbiologically induced corrosion (MIC)). The 20 percent of piping that will be inspected in each 5-year interval will be in different locations than previously inspected piping.

m. Revise Fire Water System Program procedures to include acceptance criteria that any indication of fouling is evaluated.

n. Revise Fire Water System Program procedures to specify that if the presence of sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected during pipe inspections, the material is removed and the source and extent of condition determined, corrected, and the condition entered into the corrective action program.

o. Revise Fire Water System Program procedures to replace sprinklers associated with representative tested sprinkler, if the representative test sprinkler fails to meet the test requirements.

p. Revise Fire Water System Program procedures to replace any sprinkler that shows signs of corrosion.

q. If the decreasing trend in fire water system flow tests is not resolved through the corrective action program prior to the period of extended operation, revise Fire Water System Program procedures to continue performing annual fire water system flow tests during the period of extended operation until such a time as trend data from fire water system flow tests indicates that the system will be capable of performing its intended function throughout the period of extended operation and, therefore, Technical Requirements Manual (TRM) frequency may be resumed.

r. Revise Fire Water System Program procedures to include formal documentation of the Control Center Heating, Ventilation, and Air Conditioning (CCHVAC) makeup and recirculation fire water supply drain down inspection for indications of flow blockage.

Enclosure to NRC-24-0058 Page 13 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 15 Enhance the Flow-Accelerated Corrosion Program as follows:

a.

Revise procedures to indicate that the Flow-Accelerated Corrosion Program also manages loss of material due to erosion mechanisms of cavitation, flashing, liquid droplet impingement, and solid particle erosion for any material in treated water or steam environments. Include in program procedures a susceptibility review based on internal operating experience, external operating experience, EPRI TR-1011231, and NUREG/CR-6031. Piping subject to erosive conditions is not excluded from inspections, even if it has been replaced with flow-accelerated corrosion-resistant material. Periodic wall thickness measurements of such piping should continue until the effectiveness of corrective actions is assured.

b. Revise Flow-Accelerated Corrosion Program procedures to specify that downstream components are monitored closely for wall thinning when susceptible upstream components are replaced with resistant materials Completed 16 Enhance the Inservice Inspection (ISI)-IWF Program as follows:

a.

Revise plant procedures to specify the preventive actions delineated in NUREG-1339 and EPRI NP-5769, NP-5067, and TR-104213 that emphasize proper selection of bolting material, installation torque or tension, and the use of lubricants and sealants for high-strength bolting.

b. Revise plant procedures to require structural bolting replacement and maintenance activities to include appropriate preload and proper tightening (torque or tension) as recommended in EPRI documents, ASTM standards, American Institute of Steel Construction (AISC) Specifications, as applicable.

c.

Revise plant procedures to include the preventive actions for storage of ASTM A325 and A490 bolting from Section 2 of Research Council for Structural Connections publication, "Specification for Structural Joints Using ASTM A325 or A490 Bolts."

d. Revise plant procedures to specify that detection of aging effects will include monitoring anchor bolts for loss of material, loose or missing nuts or bolts, and cracking of concrete around the anchor bolts.

e.

Revise plant procedures to identify the following unacceptable conditions:

Debris, dirt, or excessive wear that could prevent or restrict sliding of the sliding surfaces as intended in the design basis of the support.

Cracked or sheared bolts, including high-strength bolts, and anchors.

f.

Revise plant procedures to include the preventive action of using bolting material that has an actual measured yield strength less than 150 ksi, except in the case of like-for-like replacement of existing bolting material in the reactor pressure vessel skirt to ring girder bolted joint.

g. Revise plant procedures to include assessment of the impact on the inspection sample, in terms of sample size and representativeness, if components that are part of the sample population are re-worked.

Completed

Enclosure to NRC-24-0058 Page 14 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 17 Enhance the Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems (OVHLL)

Program as follows:

a.

Revise plant procedures to specify the monitoring of rails in the rail system for loss of material due to wear; monitor structural components of the bridge, trolley and hoists for deformation, cracking, and loss of material due to corrosion; and monitor structural connections/bolting for loose or missing bolts, nuts, pins, or rivets, and any other conditions indicative of loss of bolting integrity.

b. Revise plant procedures to specify inspection frequency requirements will be in accordance with ASME B30.2 or other appropriate standard in the ASME B30 series.

c.

Revise plant procedures to require that significant loss of material due to wear of rails in the rail system and any sign of loss of bolting integrity will be evaluated in accordance with ASME B30.2 or other appropriate standard in the ASME B30 series.

d. Revise plant procedures to specify that maintenance and repair activities will use the guidance provided in ASME B30.2 or other appropriate standard in the ASME B30 series.

Completed 18 Implement the new Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage fouling, cracking, loss of material, and change in material properties using representative sampling and opportunistic visual inspections of the internal surfaces of piping and components in environments other than open-cycle cooling water, closed treated water, and fire water. Program periodic surveillances or maintenance activities will be conducted when the surfaces are accessible for visual inspection.

Completed 19 Implement the new Metal Enclosed Bus Inspection Program to provide for the inspection of the internal and external portions of metal enclosed bus to identify age-related degradation of the bus and bus connections, the bus enclosure assemblies, the bus insulation and the bus insulators.

Completed 20 Enhance Neutron-Absorbing Material Monitoring Program as follows:

a.

Prior to the period of extended operation, revise Neutron-Absorbing Material Monitoring Program procedures to establish an inspection frequency, justified with plant-specific operating experience, of at least once every 10 years, based on the condition of the neutron-absorbing material.

b. Revise Neutron-Absorbing Material Monitoring Program procedures to perform trending of coupon testing results to determine the rate of degradation. Ensure the predicted boron-10 areal density will be sufficient to maintain the subcritical conditions required by technical specifications until the next coupon test.

Not Completed Scheduled before 3/20/2025

Enclosure to NRC-24-0058 Page 15 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 21 Implement the new Non-EQ Cable Connections Program, a one-time inspection program that consists of a representative sample of electrical connections within the scope of license renewal, which is inspected or tested at least once prior to the period of extended operation to confirm that there are no aging effects requiring management during that period. Cable connections included in this program are those connections susceptible to age-related degradation resulting in in-creased resistance of connection due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, or oxidation that are not subject to the environmental qualification requirements of 10 CFR 50.49.

Completed 22 Implement the new Non-EQ Inaccessible Power Cables (400 V to 13.8 kV) Program, a condition monitoring program that will manage the aging effect of reduced insulation resistance on inaccessible power (400 V to 13.8 kV) cables that have a license renewal intended function. The program calls for inaccessible or underground (e.g., in conduit, duct bank, or direct buried) power (greater than or equal to 400 V) cables exposed to significant moisture, to be tested at least once every 6 years to provide an indication of the condition of the conductor insulation, with the first tests occurring before the period of extended operation. The program will include periodic inspections for water accumulation in manholes within the scope of this program.

Completed 23 Implement the new Non-EQ Instrumentation Circuits Test Review Program, a performance monitoring program that will manage the aging effects of applicable cables in the following systems or sub-systems.

Neutron monitoring Intermediate range channels (IRM)

Average power range monitors (includes local power range monitors [LPRM] detector strings)

Process radiation monitoring Control center emergency air inlet radiation monitors Fuel pool ventilation exhaust radiation monitors Main steam line radiation monitors The Non-EQ Instrumentation Circuits Test Review Program calls for the review of calibration results or findings of surveillance tests on electrical cables and connections used in circuits with sensitive, high-voltage, low-level current signals, such as radiation monitoring and nuclear instrumentation, to provide an indication of the existence of aging effects based on acceptance criteria related to instrumentation circuit performance. The review of calibration results or findings of surveillance tests is performed at least once every 10 years. In cases where cables are not included as part of calibration or surveillance program testing circuit, a proven cable test (such as insulation resistance tests, time domain reflectometry tests, or other testing judged to be effective in determining cable system insulation condition as justified in the application) is performed. The test frequency is based on engineering evaluation and is at least once every 10 years.

Completed

Enclosure to NRC-24-0058 Page 16 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 24 Implement the new Non-EQ Insulated Cables and Connections Program, a condition monitoring program that provides reasonable assurance that the intended functions of insulated cables and connections exposed to adverse localized environments caused by heat, radiation, moisture, and chemical contamination (i.e., bird droppings) can be maintained consistent with the current licensing basis through the period of extended operation. The program consists of accessible insulated electrical cables and connections installed in adverse localized environments to be visually inspected at least once every 10 years.

Completed 25 Enhance the Oil Analysis Program as follows:

a.

Revise Oil Analysis Program procedures to identify components within the scope of the program.

b. Revise Oil Analysis Program procedures to provide a formalized analysis technique for particulate counting.

c.

Revise Oil Analysis Program procedures to include the sampling and testing requirements of equipment manufacturers or industry standards.

Completed 26 Implement the new One-Time Inspection Program that will consist of a one-time inspection of selected components to accomplish the following:

Verify the effectiveness of an aging management program that is designed to prevent or minimize aging to the extent that it will not cause the loss of intended function during the period of extended operation. The aging effects evaluated are loss of material, cracking, and fouling.

Confirm the insignificance of an aging effect for situations in which additional confirmation is appropriate using inspections that verify degradation is not occurring.

Trigger additional actions that ensure the intended functions of affected components are maintained during the period of extended operation.

Completed 27 Implement the new One-Time Inspection - Small-Bore Piping Program that will augment ASME Code,Section XI (2013 Edition) requirements and be applicable to small-bore ASME Code Class 1 piping and components with a nominal pipe size diameter less than 4 inches (NPS 4) and greater than or equal to 1 inch (NPS 1) in systems that have not experienced cracking of ASME Code Class 1 small-bore piping.

Completed

Enclosure to NRC-24-0058 Page 17 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 28 Enhance the Periodic Surveillance and Preventive Maintenance Program as follows:

a.

Revise the Periodic Surveillance and Preventive Maintenance Program procedures as necessary to incorporate the identified activities in LRA Section A.1.35.

b. Revise the Periodic Surveillance and Preventive Maintenance Program procedures to state that acceptance criterion is no indication of relevant degradation and to incorporate the following:

Examples of acceptance criteria for metallic components No excessive corrosion (loss of material)

No leakage from or onto internal surfaces (loss of material)

No excessive wear (loss of material)

No flow blockage due to fouling No loss of piping component structural integrity Examples of acceptance criteria for elastomeric components Flexible polymers should have a uniform surface texture and color with no cracks and no dimension change, no abnormal surface conditions with respect to hardness, flexibility, physical dimensions, and color.

c.

Revise Periodic Surveillance and Preventive Maintenance Program procedures to require periodic determination of wall thickness for selected piping components.

d. Revise Periodic Surveillance and Preventive Maintenance Program procedures to require wall thickness measurements using ultrasonic testing (UT) or other suitable techniques at selected locations to be periodically performed to identify loss of material due to multiple corrosion mechanisms (MCM) in system piping components. The selected locations are based on pipe configuration, flow conditions, and operating history to represent a cross-section of potential MCM sites. The selected locations are periodically reviewed to validate their relevance and usefulness and are modified accordingly. Prior to the period of extended operation, select a method (or methods) from available technologies for inspecting internal surfaces of buried piping that provide(s) suitable indication of piping wall thickness for a representative set of buried piping locations.

e.

Revise Periodic Surveillance and Preventive Maintenance Program procedures to compare wall thickness measurements to nominal wall thickness or previous measurements to determine rates of corrosion degradation. Compare wall thickness measurements to code minimum wall thickness plus margin for corrosion during the refueling cycle (Tmarg) to determine acceptability of the component for continued use.

Perform subsequent wall thickness measurements as needed for each selected location based on the rate of corrosion and expected time to reach Tmarg. Perform a minimum of five MCM degradation inspections per year until the rate of MCM corrosion occurrences no longer meets the criteria for recurring internal corrosion.

Completed

Enclosure to NRC-24-0058 Page 18 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 29 Enhance the Protective Coating Monitoring and Maintenance Program as follows:

a.

Revise plant procedures to include in the program Service Level I coating applied to steel and concrete surfaces of the steel containment vessel (e.g., steel containment vessel shell, structural steel, supports, penetrations, and concrete walls and floors).

b. Revise plant procedures to include information and instructions for monitoring Service Level I coating systems to be used for the inspection of coatings in accordance with guidelines identified in ASTM D5163-08.

c.

Revise plant procedures to specify the parameters monitored or inspected in accordance with subparagraph 10.2 of ASTM D5163-08.

d. Revise plant procedures to establish the inspection frequency in accordance with paragraph 6 of ASTM D5163-08.

e.

Revise plant procedures to develop an inspection plan and specify inspection methods to be used as identified in accordance with subparagraph 10.1 of ASTM D5163-08.

f.

Revise plant procedures to specify that the nuclear coating specialist qualification recommendations and duties be as defined in ASTM D7108. As a minimum, qualification of inspection personnel (protective coating surveillance personnel) who perform these inspections shall be as specified in ASTM D4537.

g. Revise plant procedures to specify a protective coatings program owner (inspection coordinator and inspection results evaluator) or equivalent to nuclear coating specialist defined in ASTM D5163-08, is responsible for the overall plant coatings program and has general duties and responsibilities similar to those defined for a nuclear coating specialist in Section 5 of ASTM D7108-05.

h. Revise plant procedures to specify that detection of aging effects will include visual inspections of coatings near sumps or screens associated with the ECCS.

i.

Revise plant procedures to specify instruments and equipment needed for inspection in accordance with subparagraph 10.5 of ASTM D5163- 08.

j.

Revise plant procedures to specify that upon the completion of a planned refuel outage, a coatings outage summary report will be prepared of the coating work performed in Service Level I areas during the outage. The summary report prioritizes repair areas as areas that must be repaired during the same outage or postponed to future outages, keeping the coatings under surveillance during the interim period.

k. Revise plant procedures to specify that the last two performance monitoring reports pertaining to the coating systems will be reviewed prior to the inspection or monitoring process.

l.

Revise plant procedures to describe the characterization, documentation, and testing of defective or deficient coating surface in accordance with subparagraphs 10.2.1 through 10.2.6, 10.3, and10.4 of ASTM D5163-08.

m. Revise plant procedures to specify that the coatings outage summary report will be evaluated and approved by the protective coatings program owner.

Completed

Enclosure to NRC-24-0058 Page 19 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 30 Enhance the Reactor Head Closure Studs Program as follows:

a.

Revise Reactor Head Closure Studs Program procedures to ensure that replacement studs are fabricated from bolting material with actual measured yield strength of less than 150 kilopounds per square inch (ksi).

b. Revise Reactor Head Closure Studs Program procedures to include a statement that excludes the use of molybdenum disulfide (MoS2) on the reactor vessel closure studs and also refers to recommendations in Regulatory Guide 1.65, Rev. 1.

Completed 32 Implement the new Selective Leaching Program that will demonstrate the absence of selective leaching in a selected sample of components (i.e., 20 percent of the population with maximum of 25 components) fabricated from gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc or greater than 8 percent aluminum exposed to raw water, treated water, waste water, or soil.

Completed 33 Enhance the Service Water Integrity Program as follows:

a.

Revise Service Water Integrity Program procedures to include inspection to determine if loss of material due to erosion is occurring in the system.

b. Revise Service Water Integrity Program procedures to stipulate that administrative controls are in accordance with the Fermi 2 10 CFR Part 50 Appendix B Quality Assurance Program.

Completed

Enclosure to NRC-24-0058 Page 20 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 34 Enhance the Structures Monitoring Program as follows:

a.

Revise plant procedures to add the following structures to the program.

CST and condensate return tank foundations and retaining barrier CTG-11-1 fuel oil storage tank foundation Independent spent fuel storage installation (ISFSI) rail transfer pad Manholes, handholes, and duct banks Shore barrier Transformer and switchyard support structures and foundations

b. Revise plant procedures to specify that the following inscope structures are included in the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program (Section A.1.39):

General service water pump house Residual heat removal complex Shore barrier

c.

Revise plant procedures to ensure that masonry walls located in in-scope structures are in the scope of the Masonry Wall Program (Section A.1.25).

d. Revise plant procedures to include a list of structural components and commodities within the scope of license renewal to be monitored in the program.

e.

Revise plant procedures to include periodic sampling and chemical analysis of groundwater.

f.

Revise plant procedures to include the following preventive actions:

Preventive actions delineated in NUREG-1339 and EPRI NP-5769, NP-5067, and TR-104213 that emphasize the proper selection of bolting material, installation torque or tension, and the use of lubricants and sealants for high-strength bolting.

Preventive actions for storage of ASTM A325 and A490 bolting from Section 2 of Research Council for Structural Connections publication, Specification for Structural Joints Using ASTM A325 or A490 Bolts.

g. Revise plant procedures to include the following parameters to be monitored or inspected:

For concrete structures, base inspections on quantitative requirements of industry codes (i.e., American Concrete Institute (ACI) 349.3R-02), standards and guidelines (i.e., American Society of Civil Engineers (ASCE) 11) and consideration of industry and plant-specific operating experience.

For concrete structures and components, include loss of material, loss of bond, increase in porosity and permeability, loss of strength, and reduction in concrete anchor capacity due to local concrete degradation.

For chemical analysis of groundwater, monitor pH, chlorides, and sulfates.

Monitor gaps between the structural steel supports and masonry walls that could potentially affect wall qualification.

Completed

Enclosure to NRC-24-0058 Page 21 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 34 (Continued)

h. Revise plant procedures to include the following components to be monitored for the associated parameters:

Structural bolting and anchors/fasteners (nuts and bolts) for loss of material, loose or missing nuts and/or bolts, and cracking of concrete around the anchor bolts.

Elastomeric vibration isolators and structural sealants for cracking, loss of material, loss of sealing, and change in material properties (e.g., hardening).

i.

Revise plant procedures to provide technical guidance for torque value requirements for specified bolting material subject to plant operating environments.

j.

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

Personnel (Inspection Engineer and Program Administrator or Responsible Engineer) involved with the inspection and evaluation of structures and structural components, including masonry walls and water-control structures, meet the qualifications guidance identified in ACI 349.3R-02.

Visual inspection of elastomeric material should be supplemented by feel or touch to detect hardening if performance of the intended function of the elastomeric material is suspect. Include instructions to augment the visual examination of elastomeric material with physical manipulation of at least 10 percent of available surface area.

Structures will be inspected at least once every 5 years.

Submerged structures will be inspected at least once every 5 years.

If normally inaccessible areas become accessible due to plant activities, an inspection of these areas shall be conducted. Additionally, inspections will be performed of inaccessible areas in environments where observed conditions in accessible areas indicate that significant degradation may be occurring in the inaccessible areas.

Sampling and chemical analysis of groundwater at least once every 5 years. The Structures Monitoring Program owner will review the results and evaluate any anomalies and perform trending of the results.

Masonry walls will be inspected at least once every 5 years, with provisions for more frequent inspections in areas where significant aging effects (e.g., missing blocks, cracking) is observed to ensure there is no loss of intended function between inspections.

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

Inspections of water-control structures on an interval not to exceed 5 years.

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

k. Revise plant procedures to prescribe quantitative acceptance criteria based on the quantitative acceptance criteria of ACI 349.3R-02 and information provided in industry codes, standards, and guidelines including ACI 318, American National Standards Institute (ANSI)/ASCE 11, and relevant AISC specifications. Industry and plant-specific operating experience will also be considered in the development of the acceptance criteria.

Enclosure to NRC-24-0058 Page 22 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 34 (Continued)

l.

Revise plant procedures to include acceptance criteria for masonry wall inspections that ensure observed aging effects (cracking, loss of material or gaps between the structural steel supports and masonry walls) do not invalidate the walls evaluation basis or impact its intended function.

m. Revise Structures Monitoring Program procedures to include testing and evaluation of water/mineral deposits where in-leakage is observed in concrete elements. Testing and evaluation will determine whether leaching of calcium hydroxide and carbonation are occurring that could impact the intended function(s) of the concrete structure.

n. The following testing and evaluation will be performed prior to the period of extended operation to confirm that previously identified conditions are not the result of leaching of calcium hydroxide and carbonation that could impact the intended function(s) of the concrete structure.

Available water/mineral deposit samples will be tested for mineral and iron content to assess the effect of the water in-leakage on the reinforced concrete elements involved.

The results of the testing and Structures Monitoring Program inspections will be used to determine corrective actions per the corrective action program. Possible corrective actions include, but are not limited to, more frequent inspections, sampling and analysis of the inleakage water for mineral and iron content, testing core bore samples, and evaluation of the affected area using evaluation and acceptance criteria of ACI 349.3R-02.

Enclosure to NRC-24-0058 Page 23 of 23 Fermi 2: Completed License Renewal Commitment Table Commitment No.

Summary/Description Status 35 Enhance the Water Chemistry Control - Closed Treated Water Systems Program as follows:

a.

Revise the Water Chemistry Control - Closed Treated Water Systems Program procedures to include the following systems.

Process sampling system sample cooler loops CCHVAC chill water system

b. Revise the Water Chemistry Control - Closed Treated Water Systems Program procedures to provide chemical treatment, including a corrosion inhibitor for the following systems in accordance with industry guidelines and vendor recommendations.

Process sampling system sample cooler loops CCHVAC chill water system

c.

Revise Water Chemistry Control - Closed Treated Water Systems Program procedures to specify water chemistry parameters monitored and the acceptable range of values for these parameters in accordance with EPRI Closed Cooling Water Chemistry Guideline, industry guidance, or vendor recommendations.

d. Revise Water Chemistry Control - Closed Treated Water Systems Program procedures to inspect accessible components whenever a closed treated water system boundary is opened. Ensure that a representative sample of piping and components is inspected at a frequency of at least once every 10 years. These inspections will be conducted in accordance with applicable ASME Code requirements, industry standards, or other plant-specific inspection guidance by qualified personnel using procedures that are capable of detecting corrosion, fouling, or cracking. If visual examination identifies adverse conditions, then additional examinations, including UT, are conducted.

Components inspected will be those with the highest likelihood of corrosion, fouling, or cracking. A representative sample is 20 percent of the population (defined as components having the same material, environment, and aging effect combination) with a maximum of 25 components.

Perform treated water sampling and analysis of the closed treated water systems per industry standards and in no case greater than quarterly unless justified with an additional analysis. The process sampling system sample cooler loops will be sampled and tested annually.

Completed 36 Implement the Coating Integrity Program as described in LRA Section B.1.45.

Completed 37 Enhance the BWR CRD Return Line Nozzle Program as follows:

a.

Revise BWR CRD Return Line Nozzle Program procedures as necessary to ensure that UT examinations will be used to detect applicable aging effects.

Completed