View source for NRC-23-0011, License Renewal Commitment 7c: Transmittal of Core Plate Hold-Down Bolt Analysis

{{Adams
| number = ML23066A212
| issue date = 03/07/2023
| title = License Renewal Commitment 7c: Transmittal of Core Plate Hold-Down Bolt Analysis
| author name = Dietrich P
| author affiliation = DTE Electric Company
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000341
| license number = NPF-043
| contact person = 
| case reference number = NRC-23-0011
| document report number = 007N5355NP
| package number = ML23066A211
| document type = Legal-Affidavit, Letter type:NRC, Report, Technical
| page count = 1
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Electric Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Email: peter.dietrich@dteenergy.com DTE March 7, 2023                                                                                        10 CFR 54 NRC-23-0011 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 License Renewal Commitment 7c: Transmittal of Core Plate Hold-Down Bolt Analysis

==References:==
: 1) DTE Electric Company Letter to NRC, Response to the NRC Request for Additional Information for the review of the Fermi 2 License Renewal Application - Sets 27, 28, 29, and 31, NRC-15-0044, dated April 27, 2015 (ML15118A557)
: 2) NRC Letter to EPRI, Final Proprietary Safety Evaluation for BWRVIP-25, Revision 1: BWR Vessel and Internals Project, BWR Core Plate Inspection and Flaw Evaluation Guidelines (CAC NO. MF4887; EPID L-2014-TOP-0008),
dated March 23, 2020 (ML19290G703)
: 3) NRC Letter to DTE Electric Company, FERMI 2 - REVISED RELIEF REQUEST RR-A39 FOR THE FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL (EPID L-2020-LLR-0161), dated October 15, 2021 (ML21253A010)
In accordance with Reference 1, the Fermi 2 Updated Final Safety Analysis Report (UFSAR) was revised to incorporate the updated License Renewal commitments related to Core Plate Hold-Down Bolt examinations required by the Boiling Water Reactor Vessel & Internals project (BWRVIP). In Reference 2, the NRC staff confirmed that Revision 1 of BWRVIP-25 is acceptable for referencing in licensing applications. BWRVIP-25, Revision 1 provides plant-specific criteria that must be met for applicability of a bounding analysis that justifies no core plate hold-down bolt examinations are required.
In Reference 3, the NRC accepted BWRVIP-25 Revision 1-A for use at Fermi.
Option (b) of Fermi 2 License Renewal Commitment 7c requires that for a plant-specific analysis justifying no inspections of core plate hold-down bolts, the analysis will be submitted to the NRC two years prior to the period of extended operation. The Fermi 2 plant-specific analysis is provided in . contains proprietary information as defined by 10 CFR 2.390. As the owners of the proprietary information, GE-Hitachi (GEH) and the Electric Power Research Institute (EPRI) have executed the affidavits in Enclosure 1, which identify that the enclosed proprietary information has been

USNRC NRC-23-0011 Page 2 handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. A non-proprietary version of the documentation in Enclosure 2 is provided in .
No new commitments are made in this letter.
Should you have any questions or require additional information, please contact Mr. Eric Frank, Manager - Nuclear Licensing, at (734) 586-4772.
Sincerely, Peter Dietrich Senior Vice President and Chief Nuclear Officer

==Enclosures:==
: 1) GEH and EPRI Affidavits for 007N5355P
: 2) 007N5355P, Revision 0 - PROPRIETARY
: 3) 007N5355NP, Revision 0 - NON-PROPRIETARY cc:
NRC Project Manager NRC Resident Office Regional Administrator, Region III

Enclosure 1 to NRC-23-0011 Fermi NRC Docket No. 50-341 Operating License No. NPF-43 GEH and EPRI Affidavits for 007N5355P

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Kent E. Halac, state as follows:
(1) I am a Senior Engineer, 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 GEH proprietary report 007N5355P, Fermi 2 Power Plant Core Plate Bolt BWRVIP-25 Appendix I Evaluation, Revision 0, dated January 13, 2023. GEH proprietary information in 007N5355P Revision 1 is identified by a dotted underline inside double square brackets. ((This sentence is an example.{3})). GEH proprietary information in figures and large objects is identified by double square brackets before and after the object. 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. &sect;552(b)(4), and the Trade Secrets Act, 18 U.S.C.
     &sect;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 a license from GEH constitutes a competitive economic advantage over other companies;
: b. Information that, if used by a competitor, would reduce its expenditure of resources or improve its 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.
007N5355P Revision 0                                                           Affidavit Page 1 of 3

GE-Hitachi Nuclear Energy Americas LLC (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 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 for proprietary or confidentiality agreements or both 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.
(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 and/or confidentiality agreements.
(8) The information identified in paragraph (2) 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.
007N5355P Revision 0                                                           Affidavit Page 2 of 3

GE-Hitachi Nuclear Energy Americas LLC 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 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 there 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 is true and correct.
Executed on this 13th day of January 2023.
Kent E. Halac Senior Engineer GE-Hitachi Nuclear Energy Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 kent.halac@ge.com 007N5355P Revision 0                                                          Affidavit Page 3 of 3

BWRVIP 2023-003, Attachment 1 EPf21 STEVE SWILLEY Vice President and Deputy Chief Nuclear Officer Ref. EPRI Docket No. 99902016 January 10, 2023 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:
Fermi 2 Power Plant Core Plate Bolt BWRVIP-25 Appendix I Evaluation GE Hitachi Nuclear Energy 007N5355, Revision OJanuary 2023 To Whom It May Concern:
This is a request under 10 C.F.R. &sect;2.390(a)(4) that the U.S. Nuclear Regulatory Commission ("NRC") withhold from public disclosure the information identified in the enclosed Affidavit consisting of the proprietary information owned by Electric Power Research Institute, Inc. ("EPRI") identified above in the 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 is not 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. In case the NRC rejects this affidavit for protection for any reason, EPRI requests that the NRC contact the EPRI project manager and EPRI Order Center (vvaughn@epri.com) with an offer of an opportunity for EPRI to withdraw this submittal.
If you have any questions about the legal aspects of this request for withholding, please do not hesitate to contact me.
Questions on the content of the Report should be directed to Nathan Palm of EPRI at (724) 288-4043.
Sincerely, Attachment(s)
Together ... Shaping the Future of Energy 1300 West W.T. Harris Boulevard, Charlotte, NC 28262-8550 USA
* 704.595.2630
* Mobile 704.562.8135
* sswilley@epri.com

AFFIDAVIT

==Subject:==
Request for Withholding of the Following Proprietary Information Included In:
Fermi 2 Power Plant Core Plate Bolt BWRVIP-25 Appendix I Evaluation GE Hitachi Nuclear Energy 007N5355, Revision OJanuary 2023 I, Steven Swilley, being duly sworn, depose and state as follows:
I am the Vice President and Deputy Chief Nuclear Officer at Electric Power Research Institute, Inc., whose principal office is located at 3420 Hillview Avenue, Palo Alto, California ("EPRI"), and I have been specifically delegated responsibility for the above-listed Report which 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 C'NRC")
for the withholding of the Proprietary information on behalf of EPRI.
EPRI Proprietary Information is identified in the above referenced report with text inside double brackets.
Examples of such identification is as follows:
((This sentence is an example{El))
Tables containing EPRI Proprietary Information are identified with double brackets before and after the object.
In each case the superscript notation [El refers to this affidavit and all the bases included below, which provide the reasons 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. &sect;2.390(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 is disclosed 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 is strictly limited to individuals and entities who have agreed, in writing, to maintain the confidentiality of the Information. 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 substantial economic resources required of EPRI to develop the Proprietary information.
: c. EPRl's classification of the Proprietary Information as trade secrets is justified 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 &sect;&sect;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."
: d. 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 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 Proprietar1 Information is highly valuable to EPRI.
: e. A public disclosure of the Proprietary Information would be highly likely to cause substantial harm to EPRl's competitive position and the ability of EPRI to license the Proprietary Information both domestically and internationally.
The Proprietary Information and Report 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 the laws of the State of North Carolina.
Executed at 1300 W WT Harris Blvd, Charlotte, NC being the premises and place of business of Electric Power Research Institute, Inc.
Date: _*_5_c_,"'    __\_\~I-~~--()_;i_s      _ _ _ _ __
            /        __,_ .---?*
Steven Swilley

(State of North Carolina)
(County of Mecklenburg)

Enclosure 3 to NRC-23-0011 Fermi NRC Docket No. 50-341 Operating License No. NPF-43 007N5355NP, Revision 0 - NON-PROPRIETARY

e HITACHI                                  GE Hitachi Nuclear Energy 007N5355NP Revision 0 January 2023 Non-Proprietary Information Fermi 2 Power Plant Core Plate Bolt BWRVIP-25 Appendix I Evaluation Copyright 2023 GE-Hitachi Nuclear Energy Americas LLC, All Rights Reserved

INFORMATION NOTICE This is a non-proprietary version of the document 007N5355P Revision 0, 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 are in accordance with the contract between DTE Energy Electric Company and GEH, and nothing contained in this document shall be construed as changing the contract. The use of this information by anyone other than DTE Energy Electric Company or for any purpose other than that for which it is furnished by GEH is not authorized; and with respect to any unauthorized use, GEH makes no representation or warranty, express or implied, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document, or that its use may not infringe privately owned rights.
2

007N5355NP Revision 0 Non-Proprieta1y Infonnation REVISION 

==SUMMARY==

Revision Revision Summary 0     Initial Release 3

007N5355NP Revision 0 Non-Proprietary Information TABLE OF CONTENTS

==1.0  INTRODUCTION==
 .............................................................................................................................. 5 2.0  BWRVIP-25 APPENDIX I METHODOLOGY FOR CORE PLATE BOLTS ................................. 6 3.0  FERMI 2 CORE PLATE BOLT EVALUATION.............................................................................. 7 3.1   Fermi 2 Core Plate Design and Load Combination ................................................................. 7 3.2   SC 11-05 Considerations ......................................................................................................... 7 3.3   Fermi 2 Core Plate Vertical Loads ........................................................................................... 7 3.4   Fermi 2 Core Plate Horizontal Load and Required Number of Core Plate Bolts .................... 8

==4.0  CONCLUSION==
S ................................................................................................................................ 9 5.0  ACRONYMS ................................................................................................................................... 10

==6.0  REFERENCES==
 ................................................................................................................................. 11 LIST OF TABLES Table 1 Fermi 2 Vertical Loads vs. Those Analyzed in BWRVIP-25 Appendix I Table 8-3 ........7 4

007N5355NP Revision 0 Non-Proprietary Information

==1.0     INTRODUCTION==

Fermi 2 core plate bolts are evaluated for eliminating or reducing the inspection requirements using the methodology in the BWRVIP-25 Appendix I (Reference 1). The current licensed operating conditions analyzed in the Thermal Power Optimization Safety Analysis Report (Reference 2) are applied with GNF3 fuel and 24 month fuel cycle in the evaluation. The fluence for 60 years of plant life is considered in the analysis. Consistent with GNF3 RPV internals evaluations, Safety Communication (SC) 11-07 (Reference 3) is not considered for the core plate bolt evaluation.
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007N5355NP Revision 0 Non-Proprietary Information 2.0     BWRVIP-25 APPENDIX I METHODOLOGY FOR CORE PLATE BOLTS The analysis in BWRVIP-25 Appendix I (Reference 1) was based on the Service Level D (Faulted condition) loading and allowable limits because of the dominating effect of horizontal SSE (a Faulted condition seismic load) on the displacement and ASME Code stress limits. In BWRVIP-25 Appendix I analysis for each category of core plate/bolt design, several horizontal loads were evaluated to determine the corresponding required number of bolts with fixed vertical loads, which are intended to be bounding. These fixed vertical loads are listed in Table 8-3 of BWRVIP-25 Appendix I. In order to apply the results in BWRVIP-25 Appendix I to a specific plant, the plant specific vertical loads and accumulated neutron fluence need to be bounded by those in Table 8-3. Otherwise, the BWRVIP-25 Appendix I results should not be used and additional plant-specific analysis for the core plate bolts should be considered. In addition, the conditions of SC 11-05 (Reference 5) are met.
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007N5355NP Revision 0 Non-Proprietary Information 3.0      FERMI 2 CORE PLATE BOLT EVALUATION 3.1      Fermi 2 Core Plate Design and Load Combination Fermi 2 is a BWR/4 Mark I containment plant. Fermi 2 core plate design is classified as Category 1 with 34 core plate bolts as listed in BWRVIP-25 Appendix I (Reference 1). Fermi 2 is one of the Mark I Exception plants (Reference 4) which is not a New Loads or Old Loads plant. The applicable dynamic loads for the core plate include Annulus Pressurization (AP) and Fuel Lift in addition to the seismic. The limiting load combination for Fermi 2 core plate in Service Level D is (Table 13-5 of Reference 4) as follows.
((                                             ))
The ((                         )) are vertical loads. SSE has both vertical and horizontal components.
AP is a horizontal load. Thermal stresses of core plate are insignificant because there are no thermal gradients on the core plate. Furthermore, it is not required to include the thermal stress in Faulted condition for the ASME code evaluation. Therefore, thermal stresses are not included in BWRVIP-25 Appendix I and design basis calculations in Faulted condition.
3.2      SC 11-05 Considerations BWRVIP-25 Appendix I set the acceptable core plate horizontal displacement limit to ((
)) inch with the considerations of conditions identified in SC 11-05 (Reference 5). This displacement limit accounts for additional control-blade-to-fuel-channel friction due to the possibility of existing channel bow, monitored by SC 11-05. For Fermi 2, one of the plants that SC 11-05 is applicable, the conditions of SC 11-05 are met for the core plate bolt evaluation because SC 11-05 has been considered in the displacement limit and the channel bow is monitored.
3.3      Fermi 2 Core Plate Vertical Loads The vertical loads are summarized in the following table. Fermi 2 specific vertical loads are found to be within the analyzed conditions of BWRVIP-25 Appendix I. The Fermi 2 fluence in the table is the maximum value at the top of the core plate bolts among all azimuthal locations. The Fermi 2 fluence and core plate bolt torque also meet the analyzed limits. Therefore, the Preload Final Multiplier of ((          )) in Table 6-1 of BWRVIP-25 Appendix I applies to Fermi 2.
Table 1 Fermi 2 Vertical Loads vs. Those Analyzed in BWRVIP-25 Appendix I Table 8-3 Combined Vertical             Core Plate DP         Core Plate Bolt Fluence*
Plant              Load (kips)                     (psid)              Torque (n/cm2)
(With Fuel Lift)            (With Fuel Lift)           (ft-lbf)
BWRVIP-25                    ((                                                                           ))
Fermi 2                       ((                                                                            ))
(*) Fermi 2 peak fluence for 60 years of plant life (52 Effective Full Power Year) is with GNF3 fuel and 24 month fuel cycle. The methodology of fluence calculation is documented in the New Fuel Introduction (NFI) Report.
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007N5355NP Revision 0 Non-Proprietary Information 3.4      Fermi 2 Core Plate Horizontal Load and Required Number of Core Plate Bolts The combined horizontal load on Fermi 2 core plate is ((                )) kips. Per the Table 9-2 of BWRVIP-25 Appendix I, ((            )) bolts are needed if the horizontal load is ((     )) kips. The load of 455 kips is the minimum combined horizontal load analyzed in BWRVIP-25 Appendix I for category 1 core plate plants with FLL in their design bases. With ((                    )) kips of horizontal load for Fermi 2 core plate, the number of core plate bolts needed are less than ((       ))
out of the total of 34 bolts. However, the exact number of bolts needed cannot be determined because interpolation or extrapolation of the results is not allowed as stated in Section 9 of BWRVIP-25 Appendix I (Reference 1). There is considerable margin in terms of number of core plate bolts needed versus available number of bolts for the horizontal load of ((              )) kips.
Following the Figure 9-9 Applicability Flow Chart in BWRVIP-25 Appendix I, this evaluation justifies no additional inspections of core plate bolts for Fermi 2.
8

007N5355NP Revision 0 Non-Proprietary Information

==4.0   CONCLUSION==
S Fermi 2 core plate design is category 1 with 34 core plate bolts as analyzed in BWRVIP-25 Appendix I with FLL considered in the design basis.
* The loads and conditions for Fermi 2 core plate with licensed/analyzed operating conditions, including GNF3 fuel and 24 month fuel cycle, are bounded by those analyzed in BWRVIP-25 Appendix I.
* Therefore, the results of BWRVIP-25 Appendix I can be applied to Fermi 2 core plate bolts.
* The number of core plate bolts needed for Fermi 2 are less than ((        )) out of total of 34 bolts.
* Following the Figure 9-9 Applicability Flow Chart in BWRVIP-25 Appendix I, this evaluation justifies no additional inspections of core plate bolts for Fermi 2.
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007N5355NP Revision 0 Non-Proprietary Information 5.0   ACRONYMS Acronym       Explanation AP           Faulted P AP            Annulus Pressurization ASME          American Society of Mechanical Engineers BWRVIP        Boiling Water Reactor Vessel and Internals Project P            Delta Pressure EPRI          Electric Power Research Institute FLL           Fuel Lift Load kips          Kilo pounds NL            Normal load (such as Dead Weight)
RPV           Reactor Pressure Vessel SC            Safety Communication SSE           Safe Shutdown Earthquake THF           Thermal Load at Faulted Condition 10

007N5355NP Revision 0 Non-Proprietary Information

==6.0    REFERENCES==
: 1. BWRVIP-25, Revision 1-A: BWR Vessel and Internals Project, BWR Core Plate Inspection and Flaw Evaluation Guidelines, EPRI, September 2020.
: 2. NEDC-33578P, Safety Analysis Report for Fermi Generating Station Unit-2 Thermal Power Optimization, January 2013.
: 3. SC 11-07 Rev.0, Impact of Inertial Loading and Potential New Load Combination fromRecirculation Suction Line Break Acoustic Loads, June 2013.
: 4. BWRVIP-303, Revision 0: BWR Vessel and Internals Project, Load Definitions and Combinations for Use in BWR Internals Repair/Replacement and Flaw Evaluations, EPRI, January 2019.
: 5. SC 11-05 Revision 2, Failure to Include Seismic Input in Channel-Control Blade Interference Customer Guidance, December 2013.
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