NRC-24-0050, Inservice Inspection-Nondestructive Examination (ISI-NDE) Program for the Fourth 10-Year Inspection Interval

Inservice Inspection-Nondestructive Examination (ISI-NDE) Program for the Fourth 10-Year Inspection Interval

ML24225A246
Person / Time
Site:	Fermi
Issue date:	08/12/2024
From:	Frank E DTE Electric Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-24-0050
Download: ML24225A246 (1)

Text

DTE Electric Company 6400 N. Dixie Highway Newport, MI 48166

August 12, 2024 10 CFR 50.55a NRC-24-0050

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 Unit 2 Inservice Inspect ion-Nondestructive Examination (ISI-NDE)

Progr am for the Fourth 10-Year Inspection Interval

In accordance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC),Section XI Rules for Inservice Inspection of Nuclear Power Plant Components, 2013 Edition, Sub-article IWA-1400, "Owners Responsibility," attached for your information is a copy of the Fermi 2 ISI-NDE Program for the Fourth 10-Year Interval. The Fourth 10-Year Interval ISI-NDE Program Plan complies with the requirements of the ASME Section XI 2013 Code Edition. The Fourth 10-Year Interval began on May 2, 2019 and concludes on December 31, 2028.

No new commitments are being made in this submittal.

Should you have any questions or require additional information, pl ease contact me at (734) 586-4772.

Sincerely,

Delegate for Manager - Nuclear Licensing per NANL-23-0007Delegate for Manager - Nuclear Licensing per NANL-23-0007

Eric Frank Manager - Nuclear Licensing

Enclosure:

ISI-NDE Program Plan Rev. 14

cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Enclosure to NRC-24-0050

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

ISI-NDE Program Plan Rev. 14 En clo su re to NRC-2 4-0050 Page 1 of 150 Total Pages  : 150

ISI-NDE Program Rev. 14 Change 0

DTE ELECTRIC COMP ANY ONE ENERGY PLAZA DETROIT, MICHIGAN 48226

INSERVICE INSPECTION-NONDESTRUCTIVE EXAMINATION (ISI-NDE) PROGRAM (PLAN)

FOR FERMI 2 POWER PLANT DOCUMENT NO. ISI-NDE PROGRAM

FERMI 2 NUCLEAR OPERA TIO NS CENTER 6400 N. DIXIE HIGHWAY NEWPORT, MICHIGAN 48166

DATE OF COMMERCIAL OPERATION 1-23-88 Fourth Interval Start May 2, 2019 Projected Completion Date December 31, 2028

Prepared by: Reviewed by: ~ -~ i/1q_L l.Lt J .~~ .;l./1'\\b-~ I Date /Date J.M~el ISI-NDE Program Manager IWE Program Manager

Reviewed by: Reviewed by: /4, I ~:::f2 i rtt~f ¥ J.Jwvw- -i.

J.Wines I Date RVIM Program Manager Supervisor, Engineering Programs

Approved by: Accepted by:

~ 2t-,1,/;,'/ ~ -i 1/2e/..eoz~

§.;;w~ / Dftte' I"~ Wilson / Date .

Manager , Engineering ANII, Hartford Steam Boiler Programs

ARMS - INFORMATION SERVICES

Date approved: Release authorized by: ---- - -2/28 / 202 4

Change numbers incorporated: 0

DSN _IS_I-_ND_E_P_ro_g~ra_m ___ Change 0 Rev 14 Date ---

DTC --- - -----TM PLAN File __ 1_7_1_5._04 __ Recipient

Page 1 of 150 ISINDEProgram Revision14Change0Summary Pagei

ISINDEProgram Revision14Change0Summary LCR-24-003-ISI

1. AddedcreditingstatementsthroughoutPartA,B,andFfortheLicenseRenewal AgingManagementPlansthatarecreditedorimplementedbytheISI-NDE Program.

2. Revisedsection4.22tonotethattheSnubberProgramisindependentoftheISI-NDEProgram.

3. Revisedsection4.24,4.26,and4.28toclarifythatFermiisnotcommittingto RIS-2004-12andRIS-2004-16.

4. RevisedTableA-5.2todeleteRR-A1andRR-A6,addRR-A42,provide additionaldiscussionofRR-A36,andupdatethestatusofRR-A25.

5. AddedNote3atothethirdtableinsection8.1toalignwithBWRVIP-75-A.

6. AddedRACTS20364tosection8.9.

7. Addedsection8.12inaccordancewithCR-2023-32454-A05tocreatesmallbore vibrationinducedfatiguemanagementprogram.

8. RevisedPartFinaccordancewithCR-2023-34803toreducetheIWEbolting population. Boltingconnectionsforcontainmentattachedpiping,suchasrelief valvedischargeflanges,orifices,andrupturediscswereremovedfromtheE8.10 population.

ISINDEProgram Rev.14 Change0 Pageii TABLEOFCONTENTS

SECTION DESCRIPTION PAGE(S) REV.

CoverSheet ProgramApprovalSignaturePage 1 Rev.14 Chg.0

Change RevisionSummary i Rev.14 Summary Chg.0

Tableof DocumentContents ii Rev.14 Contents Chg.0

PartA InserviceInspectionNondestructiveExamination(ISI- 1-62 Rev.14 NDE)Program(Plan)forPiping,Components,and Chg.0 Welded Attachments

PartB InserviceInspectionNondestructiveExamination(ISI- 1-6 Rev.14 NDE)Program(Plan)forComponentSupports Chg.0

PartC SnubberProgram 1-1 Rev.14 Chg.0

PartD InserviceInspectionNondestructiveExamination(ISI- 1-11 Rev.14 NDE)Program(Plan)AdoptedASMECodeCases Chg.0

PartE RiskInformedInserviceInspectionProgram(Plan) 1-8 Rev.14 (ApplicationofASMECodeCaseN-716-1) Chg.0

PartF ASMESectionXIContainmentInserviceInspection 1-37 Rev.14 Program (Plan) Chg.0 ASMESectionXISummaryTables 1-19 Rev.14 Chg.0 IWFSummaryTables 1-3 Rev.14 Chg.0

150Total Pages ISI NDE Program Revision 14 Change 0 Part A Page 1

PART - A

INSERVICE INSPECTION-NONDESTRUCTIVE EXAMINATION (ISI-NDE) PROGRAM (PLAN)

FOR PIPING, COMPONENTS, AND WELDED ATTACHMENTS

ISI NDE Program Revision 14 Change 0 Part A Page 2

1.0 Introduction

1.1 This DTE Electric Company Fermi 2 ASME Section XI, Fourth Ten-Year Interval Program (Plan) Part A of the Inservice Inspection Nondestructive Examination (ISI-NDE) Program (Plan) described herein applies to ASME Class 1, 2 and 3 Components, Welded Attachments, and Augmented Examinations. It was developed and is implemented in accordance with the requirements of Section XI, Inservice Inspection of Nuclear Components, Division 1 of the ASME Boiler and Pressure Vessel Code, 2013 Edition, as modified by the Code of Federal Regulations (CFR) requirements of 10 CFR 50.55a(g)(4)(ii) and various source documents within the Augmented Examinations described in Section 8.0. All references in this document Part A to Section XI the Code, Categories, Item Numbers, etc. refer to the 2013 Edition unless otherwise noted, which is the p

1.2 The ISI-NDE Program is a credited program for License Renewal Aging Management Plan (AMP) B.1.21 ISI Program. In addition, the ISI-NDE Program is credited for, and implements, other AMPs as discussed in Section 8.

1.3 DTE Electric Company will comply with 10 CFR 50.55a(a)(ii)(53) which excludes the use of Examination Category B-F, Item Nos. B5.11 and B5.71, Article IWB-3000

--3110 paragraph (a)(3); and Article IWC--3100

1.4 DTE Electric Company will implement Appendix VIII requirements for performance demonstration of ultrasonic examination systems and personnel as provided by the Utility Performance Demonstration Initiative (PDI Program) administered by the Electric Power Research Institute (EPRI).

1.5 Ultrasonic examinations for the Risk Informed Inservice Inspection (RI-ISI) Program described in Part E of the ISI-NDE Program (Plan) will be performed using PDI qualified procedures and personnel. Where Table 3.4 of Part E identifies a potential degradation mechanism as part of the selection basis, the examination technique and/or examination volume will include the additional requirements of ASME Code Case N-716-1.

ISI NDE Program Revision 14 Change 0 Part A Page 3

2.0 Program Description

2.1 This Part A of the ISI-NDE Program Plan has been developed herein to utilize the Inspection Program requirements of IWA-2431, Tables IWB-2411-1, IWC-2411-1, IWD-2411-1, IWE-2411-1, and IWF-2410-1 for the Fourth Ten-Year Inspection Interval.

2.2 Regulatory Commission (NRC) requesting permission to deviate from either an ASME Section XI requirement, a 10 CFR 50.55a rule, or to use provisions from editions of Section XI, or portions thereof, not approved by the NRC as referenced in 10 CFR 50.55a(b). These Relief Requests are addressed in Section 5.0 of Part A of this program and referenced in the applicable ISI-NDE Program Tables included in Section 7.0 of Part A. If during the course of implementation the need for additional relief is identified, it will be requested at a later date.

2.3 The Fourth Ten-Year Interval will begin on May 2, 2019 and is scheduled to end on December 31, 2028 in accordance with IWA-2430. The fourth interval is planned to include five refueling and inspection outages.

ISI NDE Program Revision 14 Change 0 Part A Page 4

Fermi 2 Fourth Ten-Year Interval Schedule

Interval Periods Start Date To End Start Date To End Date Outages Date RF20 1st March 2020 5/2/19 to 8/28/22 RF21 5/2/19 February 2022(1)

To RF22 12/31/28 2nd March 2024 8/29/22 to 12/25/26(2) RF23 March 2026

3rd RF24 12/26/26 to 12/31/28(3) March 2028

Note 1: Fermi 2 will be going to 24 months cycles after RF21.

Note 2: In accordance with IWA-2430, the second period is increased by 1 year to 4 1/3 years to maintain RF23 in the 2nd Period.

Note 3: In accordance with IWA-2430, the third period is shortened to recoup the 1 year extension to the 2nd Period and 3 month extension to the second Interval.

Following this schedule will result in recouping the full lifetime interval and period extensions allowed by IWA-2430.

2.4 The extent of examinations for ASME Class 1 pipe welds was modified to include weld selections based on a Risk-Informed/Safety-Based (RIS_B) application as described below. During the second interval, Relief Request RR-A30 was submitted to the NRC and approved for use. Relief Request RR-A30 implemented a Risk-Informed Inservice Inspection (RI-ISI) Program based on ASME Section XI Code Case N-578 and EPRI Topical Report No. TR-112657. RR-A30 was updated at the end of the second interval, resubmitted to the NRC, and approved for use during the third interval. During the second period of the third interval, Fermi converted to a RI-ISI Program based on Code Case N-716-1 and EPRI TR-112657. The RI-ISI methodology applies to Class 1, 2, 3 ISI NDE Program Revision 14 Change 0 Part A Page 5

and Non-classed piping and components. Because Code Case N-716-1 is listed as RI-ISI Program did not require the submittal of a Relief Request to the NRC. Code Case N-716-1 will continue to be implemented in the fourth interval. Refer to Section 7.0 which contains the ISI-NDE Summary Tables and includes Examination Category R-A for the RI-ISI Program which is contained in Part E of this ISI-NDE Program (Plan).

2.5 The extent of examination for ASME Class 2 pipe welds was modified for the preservice and First Ten-Year Interval examinations. The selection of individual welds examined on each Class 2 system was based on the stress-based inspection philosophy described in Fermi UFSAR Section 5.2.8.8 along with the prorating methodology described in Section XI (reference ISI Evaluation 99-053). During the Second Ten-Year Interval, Fermi adopted the standard examination criteria specified in ASME Section XI, Table IWC-2500-1, Examination Categories C-F-1 and C-F-2. For the Third Ten-Year Interval, Fermi continued applying the criteria specified in ASME Section XI, Table IWC-2500-1, Examination Categories C-F-1 and C-F-2 into the second period. During the second period of the third interval, Fermi 2 converted to a RI-ISI Program based on Code Case N-716-1 and EPRI TR-112657. The RI-ISI methodology applies to Class 1, 2, 3 and Non-classed piping and components. Because Code Case N-716-1 is listed as RI-ISI Program does not require the submittal of a Relief Request to the NRC. As noted above, Code Case N-716-1 will continue to be implemented in the fourth interval for ASME Class 2 piping welds. Refer to Section 7.0 which contains the ISI-NDE Summary Tables and includes Examination Category R-A for the RI-ISI Program which is contained in Part E of this ISI-NDE Program (Plan).

2.6 The systems or portions of systems subject to the examination requirements of the ISI-NDE Program for Fermi 2 and the associated Class 1, 2 and 3 boundaries are documented on ISI Classification Boundary Drawings. The ISI Classification Boundary Drawings are listed in Section 6.0, Table A-6-5.1.

2.7 Section 6.0, Table A-6-5.2 lists the Fermi 2 Inservice Inspection Isometric Drawings which have been developed for all vessels, piping, pumps, and valves which require volumetric and/or surface examination by this program.

2.8 The system inservice inspection classifications, developed specifically to define the extent to which ASME Section XI requirements will be applied, differ somewhat from the ASME Section III design classifications. Primarily, these differences occur because ISI NDE Program Revision 14 Change 0 Part A Page 6

systems, or portions of systems, were optionally upgraded in design. In addition, ISI classifications are limited to systems important to safety, which contain water, steam, or radioactive materials.

ISI NDE Program Revision 14 Change 0 Part A Page 7

3.0 Exemptions

Certain components (or parts of components) and the associated supports are exempt from the examination requirements of ASME Section XI, Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1, per provisions contained in the Code. This section lists those "Code Allowed Exemptions" as applicable to the Fermi 2 ISI-NDE Program.

3.1 General Exemption (applicable to all Code Classes)

Exemption EX-A0-1 ASME Section XI Code Paragraph: IWA-5110(c)

Piping that penetrates a containment vessel is exempt from the periodic system pressure test when the piping and isolation valves perform a containment function and the balance of the piping system is outside the scope of this Division.

3.2 Class 1 Components exempt from volumetric, surface, VT-1 visual and VT-3 visual examination requirements of IWB-2500 of the Code:

Exemption EX-A1-1 ASME Section XI Code Paragraph: IWB-1220(a)

Components that are connected to the reactor coolant system and part of the reactor coolant pressure boundary, and that are of such a size and shape so that upon postulated rupture the resulting flow of coolant from the reactor coolant system under normal plant operating conditions is within the capacity of makeup systems that are operable from on-site emergency power. The emergency core cooling systems are excluded from the calculation of makeup capacity.

Justification:

The maximum size line break for Fermi that can be made up by the reactor coolant makeup system has been calculated to be 1.44 inches inside diameter for liquid-carrying lines and 2.88 inches inside diameter for steam-carrying lines.

Exemption EX-A1-2 ASME Section XI Code Paragraph: IWB-1220(b)(1) and (2)

(1) Components and piping segments NPS 1 and smaller, except for steam generator tubing.

(2) Components and piping segments which have one inlet and one outlet, both of which are NPS 1 and smaller.

ISI NDE Program Revision 14 Change 0 Part A Page 8

Exemption EX-A1-4 ASME Section XI Code Paragraph: IWB-1220(b)(3)

Components and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 1 pipe.

Exemption EX-A1-4 ASME Section XI Code Paragraph: IWB-1220(c)

Reactor Vessel head connections and associated piping, NPS 2 and smaller, made inaccessible by control rod drive penetrations.

Exemption EX-A1-5 ASME Section XI Code Paragraph: IWB-1220(d)

Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

3.3 Class 2 Components exempt from the volumetric and surface examination requirements of IWC-2500 of the Code:

Exemption EX-A2-1 ASME Section XI Code Paragraph: IWC-1221(a)(1), (a)(2) and (a)(3), IWC-1222(a)(1), (a)(2) and (a)(3)

(1) Component and piping segments NPS 4 and smaller.

(2) Components and piping segments which have one inlet and one outlet, both of which are NPS 4 or smaller.

(3) Components and piping segments which have multiple inlets or multiple outlets, whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 4 pipe.

Exemption EX-A2-2 ASME Section XI Code Paragraph: IWC-1222(c)

Vessels, piping, pumps, valves, other components, and component connections of any size in systems or portions of systems (other than RHR, ECC, and CHR systems) that operate (when the system function is required) at a pressure equal to or less than 275 psig and at a temperature equal to or less than 200ºF.

Exemption EX-A2-3 ASME Section XI Code Paragraph: IWC-1221(d), and IWC-1222(d)

ISI NDE Program Revision 14 Change 0 Part A Page 9

Piping and other components of any size beyond the last shutoff valve in open-ended portions of systems that do not contain water during normal plant operating conditions.

Exemption EX-A2-4 ASME Section XI Code Paragraph: IWC-5230(g) and (h)

For open ended portions of discharge lines beyond the last shutoff valve in non-closed systems, demonstration of an open flow path test shall be performed in lieu of the system hydrostatic test. Test personnel need not be qualified for VT-2 visual examination. Open ended vent and drain lines extending beyond the last shutoff valve and open ended safety or relief valve discharge lines are exempt from hydrostatic testing.

Note: Per IWC-5222(a), the pressure retaining boundary includes only those portions of the system required to operate or support the safety function up to and including the first normally closed valve (including a safety or relief valve) or valve capable of automatic closure when the safety function is required. Per IWC-5222(b), items outside these described safety function boundaries and open ended discharge piping are excluded from the pressure testing and subsequent VT-2 examination requirements. Although these are exclusionss,they are being provided here for information.

3.4 Class 3 Components exempt from the inservice inspection requirements of IWD-2500 of the Code:

Exemption EX-A3-1 ASME Section XI Code Paragraph: IWD-1220(a) through (e)

The following components or parts of components are exempted from the VT-1 visual examination requirements of IWD-2500:

(a) components and piping segments NPS 4 and smaller (b) components and piping segments which have one inlet and one outlet, both of which are NPS 4 or smaller (c) components and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 4 pipe (d) components that operate at a pressure of 275 psig or less and at a temperature of 200°F or less in systems (or portions of systems) whose function is not required in support of reactor residual heat removal, containment heat removal, and emergency core cooling (e) welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

ISI NDE Program Revision 14 Change 0 Part A Page 10

Exemption EX-A3-2 ASME Section XI Code Paragraph: IWD-5222(c)(1), (2), (3) and (4)

(1) items outside the boundaries of IWD-5222(a)

(2) items outside the boundaries of IWD-5222(b)

(3) open-ended discharge piping that is not periodically pressurized to conditions described in IWD-5221 (4) portions of systems that are associated with spray header or are normally submerged in its process fluid such that the external surfaces of the pressure retaining boundary are normally wetted during its pressurized conditions.

Exemption EX-A3-3 ASME Section XI Code Paragraph: IWD-5230(f)

For open ended portions of discharge lines beyond the last shutoff valve in nonclosed systems (e.g., service water systems), confirmation of adequate flow during system operation shall be acceptable in lieu of system hydrostatic test. Test personnel need not be qualified for VT-2 visual examination.

Exemption EX-A3-4 ASME Section XI Code Paragraph: IWD-5230(g)

Open-ended vent and drain lines from components extending beyond the last shutoff valve and open-ended safety or relief valve discharge lines, including safety or relief valve discharge piping which discharges into the containment pressure suppression pool, shall be exempt from hydrostatic testing.

Note:

Per IWD-5222(a), the pressure retaining boundary includes only those portions of the system required to operate or support the safety function up to and including the first normally closed valve (including a safety or relief valve) or valve capable of automatic closure when the safety function is required.

Per IWD-5222(b), the pressure retaining boundary for nonclosed systems includes only those portions of the system required to operate or support the safety function up to and including the first normally closed valve (including a safety or relief valve) or valve capable of automatic closure when the safety function is required. Open-ended discharge piping is included in the pressure retaining boundary, provided it is periodically pressurized to conditions described in IWD-5221.

ISI NDE Program Revision 14 Change 0 Part A Page 11

4.0 Code of Federal Regulations Conditions and Augmented Examination Requirements

The following mandatory and optional Code of Federal Regulations Conditions, and Augmented Examination Requirements are included in 10 CFR 50.55a as published on July 18, 2017 and amended on January 18, 2018. Only those 10 CFR 50.55a Conditions and Augmented Examination Requirements applicable to the 2013 Edition of Section XI Nondestructive Examination requirements for Class 1, 2, and 3 components and their supports are listed. These Conditions and Augmented Examination Requirements were reviewed for inclusion in the ISI-NDE Program Part A, Part B, Part C, Part D, Part E and Part F and are dispositioned as follows (only those applicable to Fermi 2 are included):

4.1 10 CFR 50.55a(b)(2)(ii) - Pressure-Retaining Welds in ASME Code Class 1 Piping (applies to Table IWB-2500 and IWB-2500- 1 and Category B-J)

Fermi 2 will not utilize the option in 10 CFR 50.55a(b)(2)(ii), to examine Class 1 piping per ASME Section XI, 1974 Edition with the Summer 1975 Addenda.

Because Fermi 2 has a N-716-1 RI-ISI Program addressed under the ISI-NDE Program, Part E, for Class 1 piping, this condition is not applicable.

4.2 10 CFR 50.55a(b)(2)(ix) - Examination of Metal Containments and the Liners of Concrete Containments The Fermi 2 design includes a metal containment subject to ASME Section XI, Subsection IWE requirements. Therefore the mandatory conditions in 10 CFR 50.55a(b)(2)(ix) apply to Fermi 2. This condition requires sub-sub paragraphs (A)(2),

(B) and (J) to be implemented when applying the 2013 Edition. Subsection IWE requirements and 10 CFR 50.55a requirements are addressed under the ISI-NDE Program Part F.

4.3 10 CFR 50.55a(b)(2)(x) - Quality Assurance 10 CFR 50.55a(b)(2)(x) does not apply for Fermi 2. The Fermi 2 QA Program is based on 10 CFR 50 Appendix B as described in Conduct Manual MQA10.

4.4 10 CFR 50.55a(b)(2)(xii) - Underwater Welding The requirements for performing underwater welding as stated in 10 CFR 50.55a(b)(2)(xii) are not addressed in the Fermi 2 ISI-NDE Program. Repair/

Replacement activities are addressed in Fermi 2 Engineering Support Conduct Manual MES30.

ISI NDE Program Revision 14 Change 0 Part A Page 12

4.5 10 CFR 50.55a(b)(2)(xiv) - Appendix VIII Personnel Qualification 10 CFR 50.55a(b)(2)(xiv) addresses the requirements for Appendix VIII Qualified Personnel. Fermi 2 will use the annual practice requirements in VII-4240 of Section XI Appendix VII in place of the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training (when deemed appropriate) as discussed in 10 CFR 50.55a(b)(2)(xiv). When utilizing this option, the annual practice requirements will be performed on material or welds that contain cracks, or by analyzing prerecorded data from material or welds that contain cracks.

All training will be completed no earlier than 6 months prior to performing ultrasonic examinations. The implementation of NDE qualification requirements is addressed in Fermi 2 Engineering Support Conduct Manual MES24.

4.6 10 CFR 50.55a(b)(2)(xviii)(A) - Certification of NDE Personnel As required by 10 CFR 50.55a(b)(2)(xviii)(A), Level I and II nondestructive examination personnel at Fermi 2 will be recertified on a 3-year interval in lieu of the 5-year interval specified in IWA-2314(a) and IWA-2314(b) of the 2013 Edition. The certification of nondestructive examination personnel is addressed in Fermi 2 Engineering Support Conduct Manual MES24. The certification of visual examination personnel is addressed in Conduct Manual MES25.

4.7 10 CFR 50.55a(b)(2)(xix) - Substitution of Alternative Methods As required by 10 CFR 50.55a(b)(2)(xix), Fermi 2 will apply the rules in IWA-2240, Alternative Examinations, of Section XI, 1997 Addenda in lieu of the IWA-2240 requirements in Section XI, 2013 Edition for the substitution of alternative examination methods. The provisions of IWA-4520(b)(2) and IWA-4521 of the 2013 Edition allowing the substitution of ultrasonic examination for radiographic examination specified in the Construction Code will not be used.

4.8 10 CFR 50.55a(b)(2)(xx)(B) - System Leakage Tests As required by 10 CFR 50.55a(b)(2)(xx)(B), the NDE provision in IWA-4540(a)(2) of the 2002 Addenda of Section XI will be applied when performing system leakage tests after repair and replacement activities performed by welding or brazing on a pressure retaining boundary using the 2013 Edition of ASME Section XI. This in turn requires that NDE be performed in accordance with the 1992 Edition or later of ASME Section III. Repair/Replacement Activities are addressed in Fermi 2 Engineering Support Conduct Manual MES30.

ISI NDE Program Revision 14 Change 0 Part A Page 13

4.9 10 CFR 50.55a(b)(2)(xxii) - Surface Examination Fermi 2 will not implement the provision in IWA-,

allows the use of an ultrasonic examination method on Class 1 piping welds. The use of this provision is prohibited by 10 CFR 50.55a(b)(2)(xxii). Based on the RIS_B application on Class 1 piping welds and Code Case N-716-1 under the ISI-NDE Program, Part E, Fermi 2 does not need to perform surface examinations on this piping.

4.10 10 CFR 50.55a(b)(2)(xxv) - Mitigation of Defects by Modification Prohibiting the use of IWA-4340 for the mitigation of defects by modification as stated in 10 CFR 50.55a(b)(2)(xxv) is not addressed in the Fermi 2 ISI Program.

Repair/Replacement Activities are addressed in Fermi 2 Engineering Support Conduct Manual MES30.

4.11 10 CFR 50.55a(b)(2)(xxvi) Pressure Testing Class 1, 2 and 3 Mechanical Joints Placing restrictions on the pressure testing of replaced components and appurtenances per IWA-4540(c) as stated in 10 CFR 50.55a(b)(2)(xxvi) is not addressed in the Fermi 2 ISI Program. Repair/Replacement Activities are addressed in Fermi 2 Engineering Support Conduct Manual MES30.

4.12 10 CFR 50.55a(b)(2)(xxvii) - Removal of Insulation 10 CFR 50.55a(b)(2)(xxvii) modifies the requirements of IWA-5241 for insulation removal from 17-4 PH or 410 stainless steel studs or bolts aged at a temperature below 1100°F or those having a Rockwell Method C hardness value above 30, and from A-286 stainless steel studs or bolts preloaded to 100,000 pounds per square inch or higher. These requirements are only applicable for systems that are borated for the purpose of controlling reactivity, and as such are primarily applicable to PWR designs. However, these requirements could apply to the Standby Liquid Control system at Fermi 2. As such, these requirements will be implemented for the Standby Liquid Control system at Fermi 2.

4.13 10 CFR 50.55a(b)(2)(xxviii) Analysis of flaws Fermi 2 will implement the condition identified in 10 CFR 50.55a(b)(2)(xxviii) when implementing Equation (2) in Section XI, Appendix A, A-4300(b)(1).

4.14 10 CFR 50.55a(b)(2)(xxix) Nonmandatory Appendix R Fermi 2 is implementing Code Case N-716-1 for the Risked Informed Program and therefore will not be implementing Nonmandatory Appendix R.

ISI NDE Program Revision 14 Change 0 Part A Page 14

4.15 10 CFR 50.55a(b)(2)(xxxi) Mechanical clamping devices Installation of mechanical clamping devices is not addressed in the Fermi 2 ISI Program. Repair/Replacement Activities are addressed in Fermi 2 Engineering Support Conduct Manual No. MES30.

4.16 10 CFR 50.55a(b)(2)(xxxii) Summary report submittal Fermi 2 will submit inservice inspection summary reports within 90 calendar days of the completion of each refueling outage. Note that Fermi 2 is implementing Code Case N-532-5 as described in the ISI-NDE Program Part D and will use the Forms OAR-1 and NIS-2A.

4.17 10 CFR 50.55a(b)(2)(xxxiii) Risk-Informed allowable pressure When implementing Nonmandatory Appendix G, Fermi 2 will not use Paragraph G.2216 of the 2013 Edition of ASME Section XI.

4.18 10 CFR 50.55a(b)(2)(xxxiv) Nonmandatory Appendix U Nonmandatory Appendix U was the incorporation of two Code Cases, N-513 and 3 piping,-

Degradation in Moderate Energy Class 2 or 3 Vessels and T need to evaluate either moderate energy class 2 or 3 piping or vessels or tanks, implementation of Nonmandatory Appendix U or either Code Case N-513 or N-705 (latest NRC approved version) will be used with all conditions identified.

4.19 10 CFR 50.55a(b)(2)(xxxv) Use of RTT0 in the K1a and K1c equations 10 CFR 50.55a(b)(2)(xxxv) allows the use of T0 if this value is available and apply RTT0 in lieu of RTNDT for applications using K1c equation and the associated K1c curve, but not for applications using the K1a equation and the associated K1a curve.

Fermi 2 will consider this option when utilizing the K1c equation and associated curve.

4.20 10 CFR 50.55a(b)(2)(xxxvi) Fracture toughness of irradiated materials This condition requires NRC approval when implementing Section XI, Appendix A paragraph A-4400 if using T0 and the associated RTT0 in establishing fracture toughness of irradiated materials. Fermi 2 will implement this condition if the use of T0 and the associated RTT0 for irradiated materials.

ISI NDE Program Revision 14 Change 0 Part A Page 15

4.21 10 CFR 50.55a(b)(2)(xxxvii) ASME BPV Code Case N-824 Fermi 2 has not adopted Code Case N-824.

4.22 10 CFR 50.55a(b)(3)(v)(B) - Snubbers: Second Provision Per 10 CFR 50.55a(b)(3)(v)(B) licensees must comply with the provisions for examining and testing snubbers in Subsection ISTD, "Inservice Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Power Plants," ASME OM Code, and make appropriate changes to their technical specifications or licensee-controlled documents. LCR 10-041-TRM was processed to implement ISTD for the 3rd 10-Year Interval. is independent from the ISI-NDE Program.

4.23 10 CFR 50.55a(g)(2)(i) Accessibility requirements for plant with CPs issued between 1971 and 1974 This condition was required for construction and Fermi 2 was required during construction to design for accessibility for Class 1 and 2 components and their supports necessary to perform the required preservice and inservice examinations set forth in ASME Section III or XI. In accordance with 10 CFR 50.55a(g)(4)(ii) successive 120-month intervals shall comply with the requirements of the latest edition and addenda of ASME Code incorporated by reference in paragraph (a) of this section 12 months before the start of the 120-month interval. Fermi 2 is updating to ponsibility, IWA-1400(b), Fermi 2 is required to design and arrangement of system components to include allowances for adequate access and clearances for conduct of examinations and tests. Fermi 2 will implement this requirement.

4.24 10 CFR 50.55a(g)(2)(iii) Accessibility requirements: Meeting later Code requirements This condition provides an option to use later editions/addenda of codes approved by the NRC. The NRC has communicated their position that prior NRC approval is required to use later editions/addenda in RIS-2004-12 and RIS-2004-16. This is not a statement of Commitment to RIS-2004-12 and RIS-2004-16.

4.25 10 CFR 50.55a(g)(3)(i) Preservice examination requirements for plants with CPs issued between 1971 and 1974 This condition was required for construction and Fermi 2 was required during construction to perform the examinations on Class 1 and 2 components and their supports to meet the required preservice examinations set forth in ASME Section III or XI. In accordance with 10 CFR 50.55a(g)(4)(ii), successive 120-month intervals ISI NDE Program Revision 14 Change 0 Part A Page 16

shall comply with the requirements of the latest edition and addenda of ASME Code incorporated by reference in paragraph (a) of this section 12 months before the start of the 120-month interval. Fermi 2 is updating to the 2013 Edition of ASME Section

-1400(h) Fermi 2 is required to perform the examinations and tests. Fermi 2 will implement this requirement.

4.26 10 CFR 50.55a(g)(3)(v) Preservice examination requirements: Meeting later Code requirements This condition provides an option to use later editions/addenda of codes approved by the NRC. The NRC has communicated their position that prior NRC approval is required to use later editions/addenda in RIS-2004-12 and RIS-2004-16. This is not a statement of Commitment to RIS-2004-12 and RIS-2004-16.

4.27 10 CFR 50.55a(g)(4)(ii) - Inservice Inspection Standards Requirements for operating plants Fermi 2 is implementing the requirement to meet the latest edition of Section XI incorporated into 10 CFR 50.55a (see Section 1.1).

4.28 10 CFR 50.55a(g)(4)(v) Applicable ISI Code: Use of subsequent Code editions and addenda This condition allows the use of requirements set forth in subsequent editions/addenda of ASME Section XI that have been NRC approved. The NRC Regulatory Information Summary (RIS) RIS-2004-12 provides guidance for using subsequent editions/addenda. This is not a statement of Commitment to RIS-2004-12.

4.29 10 CFR 50.55a(g)(5)(ii) ISI Program update: Conflicting ISI Code requirements with technical specifications.

The Fermi 2 Technical Specifications and the Technical Requirements Manual were reviewed. The required applicable changes were made.

4.30 10 CFR 50.55a(g)(6)(ii)(B) - Submittal of Containment Inservice Inspection Programs 10 CFR 50.55a(g)(6)(ii)(B) states that licensees do not have to submit their containment inservice inspection programs to the NRC staff for approval. As such, the containment inservice inspection requirements for ASME Section XI Subsection IWE are shown in the ISI-NDE Program (Plan), Part F.

ISI NDE Program Revision 14 Change 0 Part A Page 17

5.0 Relief Requests

Throughout this section submittals to the NRC requesting permission to deviate from either an ASME Section XI requirement, a 10 CFR 50.55a rule, or to use provisions from editions of Section XI not approved by the NRC as referenced in 10 CFR 50.55a(b). However, when communicating with the NRC and in written requests to deviate, the terms as defined below must be used for clarity and to satisfy 10 CFR 50.55a. Submittals to the NRC must clearly identify which of the below rules are being used to request the deviation.

Request for Alternatives When seeking an alternative to the rules contained in 10 CFR 50.55a(b) through (h) the request is submitted under the provision of 10 CFR 50.55a(z). Once approved by the Director, Office of Nuclear Reactor Regulation, the alternative may be incorporated into the ISI program. These types of requests are typically used to request use of Code Cases, Code Editions, or Addenda not yet approved by the NRC. Request for Alternatives must be approved by the NRC prior to their implementation or use. Within the provisions of 10 CFR 50.55a(z) there are two specific methods of submittal:

10 CFR 50.55a(z)(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety.

10 CFR 50.55a(z)(2) Hardship without a compensating increase in quality and safety.

Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Relief Requests Required due to Impracticality or Limited Examinations 10 CFR 50.55(a)(g)(5)(iii) and (iv) allows relief to be requested in instances when a Code requirement is deemed impractical with (iv) being specific to examination requirements that are determined to be impractical. The provisions of these two paragraphs are typically used to address impracticalities like limited examination coverage. Under 10 CFR 50.55(a)(g)(5)(iv), relief requests for impracticality determinations must be submitted for NRC review and approval not later than 12 months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought.

In cases where conformance with an ASME Section XI requirement for inservice inspection is considered impractical, Fermi 2 will notify the NRC and submit information to support the determination, as required by 10 CFR 50.55a(g)(5). The submittal of this information will be referred to as a Request for Relief.

Each Relief Request is written in accordance with the format guidelines provided in Section 5.1. Individual Relief Requests are listed in Section 5.2. As noted in Section 2.2, Program ISI NDE Program Revision 14 Change 0 Part A Page 18

Description, Section 5.2 is subject to change throughout the inspection interval. If examination requirements in this program plan are determined to be impractical during the course of the interval, additional or modified Relief Requests will be submitted in accordance with 10 CFR 50.55a(z) or 10 CFR 50.55a(g)(5)(iii) as applicable.

5.1 Relief Request Format

Relief Requests will be written, to the extent practical, in the formats described in NEI provided below. (Note that the format used in Relief Request RR-A25 is slightly different because it was generated during the second interval and granted through the remaining portion of the initial licensing term.)

5.1.1 ASME Code Component(s) Affected: This section provides a description of, the class, type and the quantity of ASME Code components affected. It ensures that each affected component, weld, etc. is listed, not just referenced generically. For example, it includes the component number, Code Examination Category, Code Item Number, weld identification numbers, etc.

5.1.2 Applicable Code Edition and Addenda: This section provides the Code Edition and Addenda that are applicable to the program interval for the request.

5.1.3 Applicable Code Requirement: This section provides the specific Code requirement (e.g., section, subsection, and paragraph and the text of the Code requirement) from which relief is being requested.

5.1.4 Reason for Request: This section provides a brief description of how the Code requirement applies to the situation and the reason for the request. It describes the hardship or unusual difficulty the Code requirement causes and why there is no compensating increase in level of quality or safety.

5.1.5 Proposed Alternative and Basis for Use: This section describes the proposed alternative to the applicable Code requirement. Sketches may be provided as applicable. This section also provides technical justification as to how the proposed alternative will provide an acceptable level of quality and safety to that of the applicable Code requirement.

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5.1.6 Duration of Proposed Alternative: This section provides the duration of the authorized alternative.

5.1.7 Precedents (Optional): If applicable, this section cites any identified precedents (including plant name, docket number, and approval TAC/CAC number/date) which have similar situations and NRC staff approval. If applicable, this section references Fermi Requests that had been submitted and approved during previous inspection intervals.

5.1.8 References (Optional): This section is necessary only if references beyond the precedents previously cited should be identified.

5.1.9 Processing and Implementation of NRC requests for relief is as follows:

Proposed Alternatives to requirements of ASME Section XI may only be used when authorized by the Director of the Office of Nuclear Reactor Regulation. The applicant shall demonstrate per 10 CFR 50.55a(z) that:

(1) The proposed alternatives would (2) Compliance with the specified requirements of provide an acceptable level of this section would result in hardship or unusual or quality and safety difficulty without a compensating increase in the level of quality and safety.

Furthermore, if the licensee determines that conformance with certain code requirements is impractical for its facility, the licensee shall notify the NRC as specified in10 CFR 50.55a (a)(g)(5)(iii).

Impractical - would require a change in component design to permit the required examination

For Fermi 2, the following process is used for Relief Requests:

1. Prepare the Relief Request in accordance with Section 5 of the ISI-NDE Program Part A in sufficient detail to demonstrate one of the above positions and process in accordance with Fermi 2 procedures.

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2. Initiate a Licensing Change Request (LCR)

3. The Relief Request must be submitted to, reviewed by, and authorized by the Director of the Office of Nuclear Reactor Regulation based on licensee demonstration of the appropriate regulatory provision noted above, prior to its implementation.

4. Upon receipt of the NRC acceptance, complete the LCR and incorporate the Relief Requests into the ISI-NDE Program.

Note: Where Code requirements are determined to be impractical because of component design, geometry, or materials of construction, the Request for Relief shall be submitted for NRC review and approval not later than 12 months after the expiration of the interval in which the requirement was determined to be impractical as specified in 10 CFR 50.55a(g)(5)(iv).

5.2 Relief Request(s)

The Relief Requests submitted for NRC approval with the fourth interval program are listed in Table A-5.2. For historical purposes, Table A-5.2 also includes Relief Requests that were submitted and authorized during the third interval but are not being resubmitted at this time.

TABLE A-5.2 RELIEF REQUESTS

RELIEF REQUEST NUMBER GENERAL DESCRIPTION STATUS RR-A25 Alternative Requirements for Approved for Remainder of License Term Examination of RPV Shell (March 20, 2025) (TAC MA6391),

Circumferential Welds (BWRVIP- resubmitted for the Period of Extended 05), Submitted at the end of first Operation in NRC-23-0028.

interval (NRC Letter 99-0024)

ISI NDE Program Revision 14 Change 0 Part A Page 21

RELIEF REQUEST NUMBER GENERAL DESCRIPTION STATUS RR-A36 Alternative Pressure Testing Submitted for the Third Interval via NRC-Requirements for the RPV Flange 10-0004 and approved via ML102630094.

Leak-Off Piping Submitted for the Fourth Interval via NRC-19-0016 and withdrawn via NRC-19-0029 due to NRC acceptance of Code Case N-805. No longer needed.

RR-A37 Alternative Requirements for the Resubmitted for the Fourth Interval via Examination of RPV Nozzle Inner Letter NRC-19-0016.

Radius Sections and Nozzle-to- Approved via ML19183A472.

Shell Welds RR-A39 Use of Boiling Water Reactor Resubmitted for the Fourth Interval via Vessel Internals Project Letter NRC-19-0016.

(BWRVIP) Guidelines in lieu of Approved via ML19204A253. Updated and ASME Code Requirements. resubmitted via Letter NRC-20-0054.

Reapproved via ML21253A010.

RR-A40 Proposed Alternative to Utilize Resubmitted for the Fourth Interval via Code Case N-513-4 Letter NRC-19-0016.

Approved via ML19143A219.

RR-A41 10 CFR 50.55a(z) Request Use New for the Fourth Interval. Submitted via Rev. 0 of Code Case N-864, Reactor Letter NRC-19-0016.

Threads in Flange Examinations Approved via ML19169A315.

RR-A42 Impracticality During the Third Submitted for the Third Interval via NRC-Ten-Year Inservice Inspection 20-0030 and approved via ML21036A082.

Interval Will be resubmitted following the Fourth Interval

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6.0 Program Support Drawings

6.1 Inservice Inspection Classification Boundary Drawings

The systems or portions of systems subject to the examination requirements of the ISI-NDE Program for Fermi 2 and the associated Class 1, 2 and 3 boundaries are documented on ISI Classification Boundary Drawings. The ISI Classification Boundary Drawings are listed in Table A-6-5.1.

The system Inservice Inspection classifications, developed specifically to define the extent to which Section XI requirements will be applied, differ somewhat from the ASME Section III design classifications. These differences occur because systems, or portions of systems, have been optionally upgraded in design and because ISI classifications are limited to safety related systems which contain water, steam, or radioactive materials. The guidance provided by NUREG 0800, Regulatory Guide 1.26, and 10 CFR 50 were used in establishing these boundaries.

6.2 Inservice Inspection (ISI) Isometric Drawings for Class 1 and 2 Components and their Supports

The ASME Section XI, Class 1 and 2 isometrics referenced in Table A-6-5.2 of this program identify components subject to inservice inspection. Drawings are updated to conform to as-built configuration of plant piping systems following modifications.

ISI NDE Program Revision 14 Change 0 Part A Page 23

TABLE A-6-5.1

FERMI-2 ISI CLASSIFICATION BOUNDARY DRAWINGS

Drawing Title Dwg. No. PIS No's ISI Code Class Associated with Dwg.

ISI Classification Boundary 6M71-5808 Various N/A Drawing Legend & Symbols Nuclear Boiler System 6M721-5808-1 B21 1 6M721-5808-2 1

Main Steam Isolation Valve 6M721-5808-1 B21-06 1 Leakage Control System 2 Main and Reheat Steam 6M721-5808-1 B21 1 Systems 6M721-5822 N11/N30 2 Reactor Recirculation 6M721-5809 B31 1 System/Nuclear Boiler System Control Rod Drive System 6M721-5810-1 C11 2 2

CRD Scram Discharge 6M721-5810-2 C11 2 System Standby Liquid Control 6M721-5811 C41 1 System 2 Traversing Incore Probe 6M721-5812 C51 2 System Residual Heat Removal 6M721-5813-2 E11 1 (RHR) Division I 2 Residual Heat Removal 6M721-5813-1 E11 1 (RHR) Division II 2

RHR Service Water Make 6M721-5813-3 E11 3 Up Decant and Overflow P45 3 Systems R30 3 Core Spray System 6M721-5814 E21 1

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TABLE A-6-5.1 (Cont'd)

FERMI-2 ISI CLASSIFICATION BOUNDARY DRAWINGS

Drawing Title Dwg. No. PIS No's ISI Code Class Associated with Dwg.

High Pressure Coolant 6M721-5815 E41 1 Injection System (HPCI) 2 Reactor Core Isolation 6M721-5816 E51 1 Cooling System (RCIC)

Sump Pump System 6M721-5817 G11 2 Reactor Water Clean-Up 6M721-5818 G33 1 Fuel Pool Cooling and 6M721-5819 G41 2 Clean-Up System Torus Water 6M721-5820 G51 2 Management System Feedwater System 6M721-5821 N21 1 Demineralized Service 6M721-5823 P11 2 Water Risers Sample Line Tie-In And 6M721-5824 P34 1 Return Post Accident 2 Sampling System Emergency Equipment 6M721-5825-1 P44 3 Cooling Water Division I Emergency Equipment 6M721-5825-2 P44 3 Cooling Water Division II Station Air System 6M721-5826-1 P50 2 Stand-by Gas Treatment 6M721-5829-1 T46 2 System Nitrogen Inerting System 6M721-5830-1 T48 2 ISI NDE Program Revision 14 Change 0 Part A Page 25

TABLE A-6-5.1 (Cont'd)

FERMI-2 ISI CLASSIFICATION BOUNDARY DRAWINGS

Drawing Title Dwg. No. PIS No's ISI Code Class Associated with Dwg.

Hydrogen Recombiner 6M721-5830-2 T48 2 System Primary Containment 6M721-5831 T50 2 Monitoring System Primary Containment 6M721-5856 T49 2 Pneumatic Supply System Reactor Building Closed 6M721-5916 P42 2 Cooling Water System

ISI NDE Program Revision 14 Change 0 Part A Page 26

TABLE A-6-5.2 FERMI-2 ISI ISOMETRIC DRAWINGS

Class 1

Drawing Description

6M721-2000-5 Index for Inservice Inspection Isometrics 6M721-2001-5 Legends and Symbols for Inservice Inspection Isometrics 6M721-2192-5 RCIC Steam Line in Drywell 6M721-2297-5 HPCI Steam Line in Drywell 6M721-2298-5 RHR Return Line Div. 1 (North) 6M721-2299-5 RHR From Recirculation Pump Suction 6M721-2327-5 RHR Return Line Div. 2 (South) 6M721-3052-5 Core Spray Piping Div. 1 (North) 6M721-3053-5 Core Spray Piping Div. 2 (South) 6M721-3096-5 Reactor Water Clean-Up Suction From the RPV Bottom Head Drain 6M721-3536-5 Reactor Feedwater Piping (North) 6M721-3537-5 Reactor Feedwater Piping (South) 6M721-5351-5 Reactor Water Clean-Up Suction From the Recirculation Loops 6M721-5352-5 Main Steam Loop A 6M721-5353-5 Main Steam Loop B 6M721-5354-5 Main Steam Loop C 6M721-5355-5 Main Steam Loop D 6M721-5356-5 Reactor Recirculation Loop A Ring Header 6M721-5357-5 Reactor Recirculation Loop A Pump Suction and Discharge 6M721-5358-5 Reactor Recirculation Loop B Ring Header 6M721-5359-5 Reactor Recirculation Loop B Pump Suction and Discharge 6M721-5360-5 Reactor Vessel No. 1 6M721-5361-5 Reactor Vessel No. 2 6M721-5362-5 Reactor Vessel No. 3 6M721-5363-5 Reactor Vessel No. 4 6M721-5364-5 Reactor Vessel No. 5 6M721-5365-5 Reactor Recirculation Pump

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TABLE A-6-5.2

Class 2

Drawing Description

6M721-2095-5 Combustible Gas Control Return Header to Torus (Div. 1) 6M721-2097-5 Combustible Gas Control Return Header to Torus (Div. 2) 6M721-2979-5 Standby Liquid Control Explosive Valves and Line to Drywell Pen. X-42 6M721-3035-5 RHR Head Spray From Return Header to Drywell Penetration 6M721-3144-5 North Core Spray Pump Discharge to RPV 6M721-3145-5 North Core Spray Min. Low-Flow By-Pass & Test Line 6M721-3146-5 RHR Return (North) From RHRHX to Drywell Pen. No. X-13B 6M721-3147-5 Core Spray Pump (South) Discharge to RPV Penetration 6M721-3148-5 Core Spray Pump (North) Suction From Suppression Chamber 6M721-3149-5 Core Spray Pump (South) Suction From Suppression Chamber 6M721-3150-5 South Core Spray Min Low-Flow By-Pass & Test Line 6M721-3151-5 RHR Return (South) From RHR HX to Drywell Pen. No. X-13A 6M721-3153-5 South RHR Pump Suction From Suppression Chamber 6M721-3154-5 North RHR Pump Suction From Suppression Chamber 6M721-3157-5 RHR Pump Discharge North 6M721-3158-5 RHR Pump (N & S) Discharge to Heat Exchanger 6M721-3159-5 RHR Containment Spray (North) From Header to RPV 6M721-3160-5 RHR Test Line & Suppression Chamber Spray Header (North) 6M721-3161-5 6M721-3162-5 HPCI Turbine Exhaust 6M721-3163-5 HPCI Booster Pump Suction From Suppression Chamber & Condensate Storage Header 6M721-3164-5 RHR Containment Spray (South) From Return Hdr. To Drywell Pen.

6M721-3167-5 HPCI Pump Discharge to South Reactor Feedwater Header 6M721-3169-5 HPCI From Pump Discharge to Condensate Storage System 6M721-3172-5 HPCI Steam Supply From RPV to HPCI Turbine Stop Valve 6M721-3177-5 RHR Pump Discharge (South)

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TABLE A-6-5.2

Drawing Description

6M721-3184-5 RHR Service Water Supply & Return to HX 6M721-3258-5 Main Steam From Drywell to Turbine Manifold 6M721-3259-5 6M721-3361-5 Standby Liquid Control Pump Suction 6M721-3519-5 RHR Head Spray 6M721-3669-5 RHR Supply Header to FPC System 6M721-4611-5 Relief Line From RHR HX (South) 6M721-4612-5 Relief Line From RHR HX (North) 6M721-5370-5 RHR Div. 2 Heat Exchanger B 6M721-5371-5 RHR Div. 1 Heat Exchanger A 6M721-5372-5 6M721-5373-5 HPCI Booster to HPCI Main Pump 6M721-5374-5 Standby Liquid Control Pump Discharge & Test Tank Line 6M721-5375-5

ISI NDE Program Revision 14 Change 0 Part A Page 29

7.0 ISI-NDE Program Plan Summary Tables

The following provides a summary of the application of ASME Code,Section XI, 2013 Edition for the Fermi 2 ISI Fourth Inspection Interval. The application and distribution of examinations for this interval is based upon the requirements as defined by Articles IWB-2411, IWC-2411, and IWD-2411 of Section XI.

The results of this application are summarized by ASME Category and Item Number and are contained in Enclosure 1. Only those ASME Item Numbers that are relevant to Fermi 2 are contained in the enclosure. Enclosure 1 also identifies the number of components selected originally for examination during the fourth inspection interval and provides a schedule by period, for the applicable required examinations to be performed. This schedule will be adhered to as much as practical, recognizing that maintenance or other activities may result in unanticipated opportunities for other inspections. Adjustments may be made to this initial period schedule as long as the Section XI minimum/maximum percentage examination requirements for each period are met. Scheduling and tracking of exam completion for the required inspections and tests will be done using IDDEAL software.

7.1 ASME Section XI Code Category Summary Tables in Enclosure 1 The Class 1, 2, and 3 components requiring examination per ASME Section XI are shown in Enclosure 1 which provides the following information:

Examination Category

This column lists the examination category as identified in ASME Section XI, Tables IWB-2500-l, IWC-2500-1 and IWD-2500-1.

Item Number

This column lists the Code Item No. as identified in ASME Section XI, Tables IWB-2500-l, IWC-2500-1 and IWD-2500-1.

Description

This column lists a description of the components examined as identified in ASME Section XI, Tables IWB-2500-l, IWC-2500-1 and IWD-2500-1.

Examination Method

ISI NDE Program Revision 14 Change 0 Part A Page 30

This column provides the required or alternative examination method to be used for examination

Number of Components in Item No.

This column lists the total population of components potentially subject to examination.

Required to be Examined during Interval

The number of components required to be examined during the inspection interval.

Those Item Numbers that are not applicable at Fermi 2 such as for components that are only found in Pressurized Water Reactors are not included.

Examination Percentage Required

The column lists the percentage of each Item Number required to be examined per ASME Section XI, Tables IWB-2500-1, IWC-2500-1 and IWD-2500-1.

Number Scheduled During the Interval This column lists the number of components that are scheduled during the interval.

mined During

Number to be Examined in First, Second and Third Period columns These three columns provide the number of components scheduled each inspection period with the cumulated percentage at the bottom of each column to show compliance with Tables IWB-2411-1, IWC-2411-1, and IWD-2411-1 if applicable.

7.1.1 EXAMINATION CATEGORY B-A PRESSURE RETAINING WELDS IN REACTOR VESSEL Reactor Vessel examinations are scheduled on the reactor pressure vessel to meet the alternative requirements of Request for Alternative RR-A25 Alternative Requirements for Examination of RPV Shell Circumferential Welds (BWRVIP-05),

submitted at the end of first interval (NRC Letter 99-0024) to use the provisions of BWRVIP-05 for the Reactor Pressure Vessel Circumferential Shell Welds during the remaining term of operation (until March 20, 2025). This alternative is based on the Boiling Water Reactor Vessel Internals Project (BWRVIP) report BWRVIP-05 ISI NDE Program Revision 14 Change 0 Part A Page 31

alternative provision is summarized below:

The examination requirements of ASME Section XI, Table IWB-2500-1, Examination Category B-A, Item No. B1.12, for the RPV longitudinal shell welds will be performed as required to the extent possible. The examination requirements for Item No. B1.11, RPV circumferential shell welds will be limited to the segment of the weld that intersects with the longitudinal weld.

The examination requirements of Item Nos. B1.21 and B1.22 for the Reactor Vessel Head Circumferential and Meridional Welds will be performed as required (Note that deferral is permitted), however the welds are scheduled throughout the interval meeting the required percentages. There is one B1.21 weld (5-306) and seven B1.22 welds (2-306A through G) that are inaccessible due to the control rod drives and therefore not scheduled (reference RR-A1).

Examinations will be completed in accordance with Appendix VIII.

This meets the Examination Category B-A examination requirements in the 2013 Edition as modified by Request for Alternative RR-A25.

7.1.2 EXAMINATION CATEGORY B-B PRESSURE RETAINING WELDS IN VESSELS OTHER THAN REACTOR VESSELS This Category is not applicable to Fermi Unit 2.

7.1.3 EXAMINATION CATEGORY B-D FULL PENETRATION WELDED NOZZLES IN VESSELS Reactor Vessel Nozzles are scheduled and examined in accordance with Code Case N-Radius and Nozzle-to--A37. This permits the examination to be performed on a minimum of 25% of nozzle inner radii and nozzle-to-shell welds, including at least one nozzle from each system and nominal pipe size. Excluded from the implementation of Code Case N-702 are the BWR feedwater and control rod drive return nozzles. Below is the number of nozzles that are scheduled for each system and nominal pipe size nozzles:

Identification Description Size Total Minimum Number Inches Number Number to be Examined N1 Recirculation Outlet 28 2 1 N2 Recirculation Inlet 12 10 3 N3 Main Steam Outlet 26 4 1 N5 Core Spray 10 2 1 ISI NDE Program Revision 14 Change 0 Part A Page 32

Identification Description Size Total Minimum Number Inches Number Number to be Examined N6 Spare Nozzles 2 1 N7 Closure Head Vent 1 1 N8 Jet Pump 2 1 Instrumentation

In addition, all six feedwater nozzles and the one control rod drive return nozzle are scheduled for examination.

Item Nos. B3.110, B3.130, B3.150, and B3.160 are not applicable to Fermi Unit 2.

Examinations will be completed in accordance with Appendix VIII.

This meets the Examination Category B-D examination requirements in the 2013 Edition as modified by Request for Alternative RR-A37.

7.1.4 EXAMINATION CATEGORY B-F PRESSURE RETAINING DISSIMILAR METAL WELDS IN VESSEL NOZZLES

This category addresses Nozzle-to-Safe End Welds and Piping Welds. Fermi Unit 2 has developed a Risk-Informed Program implementing Code Case N-716-1. All Examination Category B-F welds have been re-categorized as R-A welds in accordance with N-716-1. Therefore, no examinations will be performed per Examination Category B-F.

7.1.5 EXAMINATION CATEGORY B-G-1 PRESSURE RETAINING BOLTING

The Reactor Vessel Studs, Nuts, Washers, and Bushings are scheduled. The RPV Threads in Flange Stud Holes is not required to be examined with the implementation of Code Case N-864 via Request for Alternative RR-A41. For the volumetric examination of the Pump Studs, one of two sets of recirculation pump studs is selected for examination. For the visual examination of the recirculation pump bolting and flange surface, one of the recirculation pumps will be examined, only if disassembled.

ISI NDE Program Revision 14 Change 0 Part A Page 33

This meets the Examination Category B-G-1 examination requirements in the 2013 Edition as modified by Request for Alternative RR-A41.

7.1.6 EXAMINATION CATEGORY B-G-2 PRESSURE RETAINING BOLTING

This category includes the RPV, piping, pump, and valve bolting. Examinations will be conducted as required in Table IWB-2500-1 of ASME Section XI. The bolting will only be examined if the associated connections are disassembled.

For components other than piping, bolting examination will be required only when the component is examined under Examination Category B-A, B-L-2, or B-M-2.

This meets the Examination Category B-G-2 examination requirements in the 2013 Edition.

7.1.7 EXAMINATION CATEGORY B-J PRESSURE RETAINING WELDS IN PIPING

This category addresses piping welds. Fermi 2 has developed a Risk-Informed Program implementing Code Case N-716-1. All Examination Category B-J welds have been re-categorized as R-A welds in accordance with N-716-1. Therefore, no examination will be performed per Examination Category B-J.

7.1.8 EXAMINATION CATEGORY B-K WELDED ATTACHMENTS FOR VESSELS, PIPING, PUMPS, AND VALVES

Examination Category B-K requires examination of Welded Attachments. For vessel welded attachments, Note 4 allows for single vessels, only one welded attachment shall be selected for examination. The welded attachment selected shall be an attachment under continuous load or intermittent load if one under continuous load does not exist. Fermi 2 has nine welded attachments on the reactor vessel, eight on each vessel stabilizer and one vessel skirt. The vessel skirt welded attachment has been selected for examination as it is under continuous load.

For piping and pumps, a sample of 10% of the welded attachments associated with the component supports selected for examination under IWF-2510 shall be selected for examination. Fermi 2 has no valve welded attachments.

This meets the Examination Category B-K examination requirements in the 2013 Edition.

ISI NDE Program Revision 14 Change 0 Part A Page 34

7.1.9 EXAMINATION CATEGORY B-L-2 PUMP CASINGS

This category requires a visual VT-3 examination on pump internal surfaces when disassembled. The recirculation pumps are the only Class 1 pumps.

B-L-2 requires examination of one pump in each pump group performing similar functions in the system. However, this examination is only required when a pump is disassembled for maintenance or repair. This examination will be selected and schedule when one of the recirculation pumps is disassembled for maintenance or repair.

This meets the Examination Category B-L-2 examination requirements in the 2013 Edition.

7.1.10 EXAMINATION CATEGORY B-M-2 VALVE BODIES

This category involves the examination of valve bodies greater than NPS 4. There are sixty valves at Fermi 2 within this examination category. The valves are placed into nineteen groups. B-M-2 examinations are limited to at least one valve within each group of valves that are of the same size, constructural design, and manufacturing method and that perform similar functions in the system. However, the visual VT-3 examination is only required when a valve is disassembled for maintenance or repair. This examination will be selected and scheduled when a valve is disassembled for maintenance or repair, unless the examination requirement has already been met for its valve group over the course of the interval.

This meets the Examination Category B-M-2 examination requirements in the 2013 Edition.

7.1.11 EXAMINATION CATEGORIES B-N-1 INTERIOR OR REACTOR VESSEL AND B-N-2 WELDED CORE SUPPORT STRUCTURES AND INTERIOR ATTACHMENTS TO REACTOR VESSELS

This category addresses the reactor vessel internal surfaces and the welded attachments within and beyond the beltline region. Fermi 2 has submitted a Request for Alternative RR-A39 to implement the Boiling Water Reactor Vessel Internals Project requirements in lieu of those contained in this category. Therefore, there are no examinations performed under Examination Categories B-N-1 or B-N-2. These ISI NDE Program Revision 14 Change 0 Part A Page 35

examinations will be documented under the Reactor Vessel Internals Management Program (Conduct Manual MES47).

7.1.12 EXAMINATION CATEGORY B-O PRESSURE RETAINING WELDS IN CONTROL ROD DRIVE AND INSTRUMENT NOZZLE HOUSINGS

This category requires examination of 10% of the peripheral control rod drives.

Fermi 2 has 40 peripheral control rod drives each with two welds. These are the Tube-to-Flange and the Tube-to-Tube welds. Therefore, 4 control rod drives (total of eight welds) are selected for examination. The examination requirement is either a volumetric or surface examination. Fermi 2 has elected to perform the surface examination.

This meets the Examination Category B-O examination requirements in the 2013 Edition.

7.1.13 EXAMINATION CATEGORY C-A PRESSURE RETAINING WELDS IN PRESSURE VESSELS

This category addresses examination of the pressure retaining welds in the RHR Heat Exchangers. Fermi 2 has implemented Code Case N-716-1 which determined that the RHR Heat Exchangers are Low Safety Significant (LSS) and therefore no examinations are required.

7.1.14 EXAMINATION CATEGORY C-B PRESSURE RETAINING NOZZLE WELDS IN VESSELS

This category addresses examination of the nozzle welds in the RHR Heat Exchanges. Fermi 2 has implemented Code Case N-716-1 which determined that the RHR Heat Exchangers are Low Safety Significant (LSS) and therefore no examinations are required.

7.1.15 EXAMINATION CATEGORY C-C WELDED ATTACHMENTS FOR VESSELS, PIPING, PUMPS, AND VALVES

This category addresses examination of the welded attachments on vessels, piping, pumps, and valves.

ISI NDE Program Revision 14 Change 0 Part A Page 36

Item C3.10 - Fermi 2 has two Residual Heat Removal Heat Exchangers with several attachments each. There are two welds per welded attachment (one weld on each side). Note 6 of Table IWC-2500-1 states for multiple vessels of similar design, function, and service, only one welded attachment of only one of the multiple vessels shall be selected for examination. Therefore, two welds (for one welded attachment) are selected for examination.

Item C3.20 - For piping, a sample of 10% of the welded attachments associated with the component supports selected for examination under IWF-2510 shall selected for examination. Fermi 2 has no Class 2 pump or valve welded attachments.

7.1.16 EXAMINATION CATEGORY C-F-2 PRESSURE RETAINING WELDS IN CARBON OR LOW ALLOY STEEL PIPING

This category addresses piping welds. Fermi Unit 2 has developed a Risk-Informed Program implementing Code Case N-716-1. All Examination Category C-F-2 welds have been re-categorized as R-A welds in accordance with N-716-1. Therefore, no examinations will be performed per Examination Category C-F-2.

7.1.17 EXAMINATION CATEGORY D-A WELDED ATTACHMENTS FOR VESSELS, PIPING, PUMPS, AND VALVES

This category addresses welded attachments on vessels, piping, pumps, and valves.

Item D1.10 Fermi 2 has twelve Emergency Diesel Generator Heat Exchangers that use Diesel Generator Service Water as cooling water, with multiple welded attachments each. Only one welded attachment is required to be selected and examined for each similar vessel. Therefore one welded attachment on one Air Cooler, one Jacket Cooler and one Oil Cooler will be examined.

Item D1.20 Fermi 2 has a total of 90 piping welded attachments with 10% or 9 being selected for examination.

Item D1.30 Fermi 2 has four Emergency Diesel Generator Service Water Pumps with one welded attachment each, two Emergency Equipment Service Water Pumps with one welded attachment each, and four Residual Heat Removal Service Water Pumps with one welded attachment each. Therefore one welded attachment will be examined.

ISI NDE Program Revision 14 Change 0 Part A Page 37

7.1.18 EXAMINATION CATEGORY R-A

The implementation of the Risked-Informed ISI Program utilizing ASME Code Case N-716-1 has been substituted for Class 1 and 2 piping welds (Examination Categories B-F, B-J, C-F-1, and C-F-2).

Refer to Part E of this Program Plan, Table 1, for details on the number of R-A welds and how the Examination Category R-A examination requirements are met.

ISI NDE Program Revision 14 Change 0 Part A Page 38

7.2 List of Abbreviations: The following abbreviations are used:

Plant Identification System (PIS) - Codes for Plant Systems

B11 - PIS Number for the Reactor Pressure Vessel B21 - PIS Number for the Nuclear Boiler System B31 - PIS Number for the Reactor Recirculation System C11 - PIS Number for the Control Rod Drive System C41 - PIS Number for the Standby Liquid Control System C51 - PIS Number for the Neutron Monitoring System E11 - PIS Number for the Residual Heat Removal System E21 - PIS Number for the Core Spray System E41 - PIS Number for the High Pressure Coolant Injection System E51 - PIS Number for the Reactor Core Isolation Cooling System G11 - PIS Number for the Rad Waste System G33 - PIS Number for the Reactor Water Cleanup System G41 - PIS Number for the Fuel Pool Cooling System G51 - PIS Number for the Torus Water Management System N20 - PIS Number for the Condensate System N21 - PIS Number for the Feedwater System P11 - PIS Number for the Condensate Storage and Transfer N11 - PIS Numbers for the Main Steam System N30 - PIS Numbers for the Turbine Generator System P34 - PIS Number for the Post Accident Sampling System P42 - PIS Number for the Reactor Building Closed Cooling Water System P44 - PIS Number for the Emergency Equipment Cooling Water System P45 - PIS Number for the Emergency Equipment Service Water System P50 - PIS Number for the Compressed Air System R30 - PIS Number for the Emergency Diesel Generator and Service Water System T23 - PIS Number for the Containment System T46 - PIS Number for the Standby Gas Treatment System T48 - PIS Number for the Combustible Gas Control System (T4804)

T49 - PIS Number for the Primary Containment Pneumatic Supply System T50 - PIS Number for the Primary Containment Monitoring System T71 - PIS Number for Instrumentation

ISI NDE Program Revision 14 Change 0 Part A Page 39

Acronyms Used to Identify Plant Systems

CGC - Combustible Gas Control CRD - Control Rod Drive CS - Core Spray FPC - Fuel Pool Cleanup HPCI - High Pressure Coolant Injection RCIC - Reactor Core Isolation Cooling RHR - Residual Heat Removal RRC - Reactor Recirculation RWCU - Reactor Water Cleanup SDV - Scram Discharge Volume SLC - Standby Liquid Control

Non-Destructive Examination Method Abbreviations

MT - Magnetic Particle Examination PT - Liquid Penetrant Examination UT - Ultrasonic Examination VT - Visual Examination VT-1 - Visual Examination per IWA-2211 VT-2 - Visual Examination per IWA-2212 VT-3 - Visual Examination per IWA-2213 UT Mech. - UT Mechanized UT Mech./Man. - UT Mechanized or Manual

ISI NDE Program Revision 14 Change 0 Part A Page 40

RI-ISI Degradation Mechanisms

CC - Crevice Corrosion FAC - Flow Accelerated Corrosion IGSCC - Intergranular Stress Corrosion Cracking TASCS - Thermal Stratification, Cycling, Striping TT - Thermal Transient

Plant Component and Weld Terminology Abbreviations

CRDH - Control Rod Drive Housing EXPJT - Pipe Expansion Joint FBC - Flange Bolted Connection FW - Field Weld HX - Heat Exchanger HXS - Heat Exchanger Shell IBR - Inner Bore Region (Nozzle)

IRS - Inner Radius Section (Nozzle)

IIH - Incore Instrumentation Housing LD - Longitudinal Downstream (Seam Weld)

LU - Longitudinal Upstream (Seam Weld)

PAD - Integral Attachment Weld Directly onto the Pressure Boundary of the Pipe PSFW - Piping Support Field Weld PS - Primary Steam (Nuclear Steam Supply System)

RD - Recirculation Discharge RS - Recirculation Suction SDV - Scram Discharge Volume SW - Shop Weld TRUNION - Hanger Support Welded Directly onto the Pressure Boundary of the Pipe VBB - Valve Body and Bonnet Housing

ISI NDE Program Revision 14 Change 0 Part A Page 41

Generic Miscellaneous Abbreviations

BWR - Boiling Water Reactor BWRVIP - Boiling Water Reactor Vessel Internals Project DWG - Drawing DW - Drywell EF2 - Enrico Fermi 2 in. - Inches LRA - License Renewal Application N/A - Not Applicable NUREG - Nuclear Regulatory Report PWR - Pressurized Water Reactor RR - Relief Request RB - Reactor Building TB - Turbine Building RPV - Reactor Pressure Vessel CRC - Corrosion Resistant Cladding

Component Support Abbreviations

A - Anchor C - Constant Support G - Guide R - Rigid Support SP - Spring Hanger

ISI NDE Program Revision 14 Change 0 Part A Page 42

Outage Codes

XX C or S

Refuel Outage Sequential Number Completed Exam or Scheduled Exam

EXAMPLE: 19C - Nineteenth Refueling Outage, Completed Exam 20S - Twentieth Refueling Outage, Scheduled Exam

NOTE: Modifications to the above Codes by inclusion of an ,

P for (Partial Inspection), or an L for (Limited Examination) will be utilized as necessary. Generally, the extent of the examination completed or limitations of the examination will be noted in the adjacent remarks column for each component.

Description of Building Floor Abbreviations:

DW Primary Containment (Drywell)

RBB Reactor Building Basement/Sub-basement RB1 Reactor Building First Floor RB2 Reactor Building Second Floor RB3 Reactor Building Third Floor TB1 Turbine Building First Floor TB2 Turbine Building Second Floor TB3 Turbine Building Third Floor

ISI NDE Program Revision 14 Change 0 Part A Page 43

8.0 Augmented Examination Requirements

Augmented Examinations are not ASME Section XI requirements, but are 1) additional examination areas or 2) increased inspection frequencies or a combination of both. Augmented Examinations can be requested by the NRC, required by License Renewal Application (LRA) commitments, recommended in General Electric (GE) Service Information Letters (SILs),

recommended by the Boiling Water Reactor Vessel Internals Program (BWRVIP), or added by Fermi 2 management direction. Below is a summary of those examinations performed by Fermi 2 that are not specifically addressed by ASME Section XI, or the examinations that will be performed in addition to the requirements of the Code on a routine basis during the Fourth ISI Interval and the Third CISI Interval. Changes to the augmented examinations shall be in accordance with the 10 CFR 50.59 process where required.

The existing Inservice Inspection Program is credited as a License Renewal Aging Management Program (B.1.21). The following related programs are credited by ISI inspections, but do not specify additional mandatory examinations.

B.1.6 BWR Feedwater Nozzles B.1.7 BWR Penetrations B.1.8 BWR Stress Corrosion Cracking B.1.9 BWR Vessel ID Attachment Welds B.1.10 BWR Vessel Internals B.1.22 IWF Inspection Program B.1.37 Reactor Head Closure Studs

requirements for opportunistic visual examinations of BWR Penetrations inside the reactor vessel when maintenance activities make the area accessible. The lower plenum housing and penetration are not accessible during maintenance activities associated with a normal refueling outage and there are no scheduled maintenance activities that will provide access to the lower plenum. BWRVIP-47-A, (BWR Vessel and Internals Project, BWR Lower Plenum Inspection and Flaw Evaluation Guidelines), Section 3.2.5 guidelines for the inspections are followed in the event that the lower plenum housing and penetration area becomes accessible during other maintenance activities. BWR Vessel Internals Program procedures were revised to perform opportunistic inspections of the differential pressure and standby liquid control line inside the reactor vessel when the line becomes accessible.

ISI NDE Program Revision 14 Change 0 Part A Page 44

8.1 License Renewal AMP B.1.8 BWR Stress Corrosion Cracking, Examination of Austenitic Stainless Steel and Dissimilar Metal Welds Susceptible to Intergranular Stress Corrosion Cracking (IGSCC) (Generic Letter (GL) 88-01, NUREG-0313, Revision 2, and BWRVIP Source Document: GL 88-01,

88-01 dated February 1992. EPRI Topical Report TR-1012621 (BWRVIP Basis for Revisions to Generic Letter 88-

Associated Documents: NUREG-0313 Rev. 2, Processing Guidelines for BWR Coolant Pressure Boundary Pip 84-

-61 (EPRI TR-112

Letter EF2--

Background:

These documents discuss the examination requirements for Intergranular Stress Corrosion Cracking (IGSCC) in BWR Austenitic Stainless Steel Piping. References to Generic Letter (GL) 88-01 within the ISI Program refer to the comprehensive commitments to all of these

-75 and BWRVIP-75-A revised inspection schedules were based on consideration of inspection results and service experience gained by the industry since issuance of GL 88-01 and USNRC NUREG-0313, and includes additional knowledge regarding the benefits of improved BWR water chemistry.

Since the issuance of GL 88-01, the BWR Vessels and Internals Project (BWRVIP) have been created. This BWR owners group has worked on the mitigation of IGSCC for BWR reactor vessel internal components. As part of their activities, EPRI Topical Report TR-Vessel and Internals Project, Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules (BWRVIP--1012621, o Generic Letter 88-01 Inspection Schedules (BWRVIP Among other issues, this document proposed alternative inspection schedules for IGSCC susceptible welds. Two different inspection schedules were presented; one for plants on Normal Water Chemistry (NWC) and one for plants on effective Hydrogen Water Chemistry (HWC).

Fermi 2 implements both HWC and Noble Metal Chemical Addition (NMCA).

ISI NDE Program Revision 14 Change 0 Part A Page 45

After review of BWRVIP-75 and BWRVIP-75-s approving the documents with minor changes Vessel and Internals Project, Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules (BWRVIP-75)PRI TR-113932 (TAC No.

Approval Letter for BWRVIP Revisions to Generic Letter 88-ed March 16, 2006).

Based upon USNRC endorsement of BWRVIP-75-A, the Fermi 2 GL 88-01 (IGSCC) inspection schedule was updated to the requirements of BWRVIP-75-A except for Category A welds. (See Risked-Informed Inservice Inspection discussion below).

RI-ISI guidelines have been invoked for Fermi 2 in this ISI-NDE Program Plan. Under these guidelines, ISI Class 1 and 2 piping are inspected in accordance with Code Case N-716-1 which is approved by the USNRC in Regulatory Guide (RG) 1.147 Revision 18. The inspection population for N-716-1 credits some welds inspected as part of the BWRVIP-75-A population, however, the inspection percentages of both guidance documents are independently met.

Purpose:

Austenitic stainless steel and dissimilar metal circumferential welds in piping four inches or larger in nominal pipe diameter which contain reactor coolant at temperature above 200°F during power operation shall be examined in accordance with the requirements of BWRVIP-75-A. Sample expansion of Categories B, C, D, or E weldments shall be in accordance with BWRVIP-75-A. Generic Letter 88-01 was issued by the NRC in 1988 to seek information regarding implementation of the new staff positions covering the industry issues with IGSCC. The staff positions were developed to cover the following subjects:

1. Materials

2. Processes

3. Water Chemistry1

4. Weld Overlay Reinforcement

5. Partial Replacement

6. Stress Improvement of Cracked Weldments

7. Clamping Devices

8. Crack Characterization and Repair Criteria

9. Inspection Methods and Personnel1

10. Inspection Schedules1

11. Sample Expansion1

12. Leak Detection

1 With the implementation of BWRVIP-75A these commitments are superseded by the guidance in BWRVIP-75A.

ISI NDE Program Revision 14 Change 0 Part A Page 46

13. Reports Requirements

remedial actions are taken, BWR plants may not be in conformance with their current design and

This augmented examination implements the NRC Positions related to inspection of austenitic stainless steel piping in boiling water reactor environment which are susceptible to IGSCC.

Because of improved water chemistry that significantly reduced the propensity for initiation and growth of IGSCC, plus improved examination procedures/techniques for the detection and sizing of IGSCC, new inspection criteria was subsequently developed and incorporated in BWRVIP-75-A.

In addition during the construction phase, Fermi 2 performed the following countermeasures:

COUNTERMEASURE NUMBER OF WELDS Induction Heat Stress Improvement (IHSI) 791 Corrosion Resistant Cladding 201

Mechanical Stress Improvement Process (MSIP) 27 Solution Heat Treatment 38

Total 164 120 welds received both Induction Stress Improvement and Corrosion Resistant Cladding.

The following Inspection Categories were established based on the GL 88-01/NUREG-0313 requirements.

Category A Weldments with no known cracks that are made from materials that are considered resistant to IGSCC due to their metallurgical properties. Welds joining cast pump and valve bodies to resistant materials are also considered to be Category A unless the weld material is considered susceptible. Fermi has thirty-eight (38) welds that are Category A.

Category B - Weldments made from material that is considered susceptible to IGSCC, but the propensity for IGSCC was mitigated by stress improvement prior to two cycles of operation. NOTE: Fermi 2 has one hundred six (106) welds that have corrosion resistant cladding on the inside diameter of the piping. These welds would normally be considered IGSCC Category A welds per the requirements of BWRVIP-75A/Generic Letter 88-01.

However, the cladding was only applied to the fabricated spool pieces and not the base material on the other side of the field welds. As a conservative measure, Fermi 2 has made the decision to categorize these welds as IGSCC Category B welds.

ISI NDE Program Revision 14 Change 0 Part A Page 47

Category C - Weldments made from material that is considered susceptible to IGSCC, but the propensity for IGSCC was mitigated by stress improvement after more than two cycles of operation. Fermi 2 has no welds in this Category.

Category D - Weldments made from material that is considered susceptible to IGSCC where there is no mitigation by stress improvement. Fermi 2 has welds designated as IGSCC Category D* welds. These welds are non-Code Class ANSI B31.1 piping welds which are being examined as an Owner Elected examination. (Reference Part A, Section 8.6 for additional information on these examinations.)

Category E - Weldments with cracks that have been overlaid with IGSCC-resistant material. Additionally, weldments with cracking that are mitigated by an effective stress improvement process may be considered Category E. Fermi 2 has no welds in this Category.

Category F Weldments with cracking that have not been mitigated by an effective stress improvement process. Fermi 2 has no welds in this Category.

Category G Weldments made from material that is considered susceptible to IGSCC that have not been examined. Fermi 2 has no welds in this Category.

Scope: The scope of this augmented program includes RCPB piping, welds and components, of four inches and larger nominal pipe size, made of stainless steel and nickel alloy. The following table provides the scope for each Category described in GL 88-01 and BWRVIP-75-A for Fermi 2.

IGSCC Category Total Number of Welds A 39 B 106 C 0 D 0 D* 24 E 0

Method: Ultrasonic

Industry Code or Standards: ASME Section XI

ISI NDE Program Revision 14 Change 0 Part A Page 48

Frequency: Fermi 2 implements the revised inspection schedules for NWC in BWRVIP-75A.

Cat. Weld Description Existing Inspection Proposed Inspection Frequency Frequency of (Note 1, 2, 3(b))

GL 88-01 NWC HWC A Resistant 25% every 10 years at B-F = 25% every 10 years 10% every 10 years Materials least 12% in 1st 6 years B-J = 25% every 10 years (Note 3(a))

B Non-Resistant 50% every 10 years at 25% every 10 years (Notes 10% every 10 years Materials Stress least 25% in 1st 6 years 4 and 5) (Notes 4 and 5)

Improved within 1st 2 years of Operation C Non-Resistant All within 2 cycles of 25% every 10 years (Note 10% every 10 years Materials Stress SI, then all within 10 5) (Note 5)

Improved after 2 years at least 50%

years of Operation within 1st 6 years D Non-Resistant Every 2 refueling cycles 100% every 6 years 100% every 10 years, Materials, No at least 50% in 1st 6 Stress years Improvement E Cracked Every 2 refueling cycles 25% every 10 years, at 10% every 10 years Reinforced by least 12.5% in 1st 6 years Weld Overlay E Cracked Every 2 refueling cycles 100% every 6 years 100% every 10 years, Mitigated by at least 50% in 1st 6 Stress years (Note 6)

Improvement F Cracked Every refueling cycle Every Refueling Outage Every Refueling Inadequate or No Outage repair G Non-Resistant, Next Outage Next Outage Next Outage Not Inspected ISI NDE Program Revision 14 Change 0 Part A Page 49

Cat. Weld Description Existing Inspection Proposed Inspection Frequency Frequency of (Note 1, 2, 3(b))

GL 88-01 NWC HWC

1. For the examination sample percentages that are less than required by ASME Section XI for Category A welds, Fermi 2 will be implementing Code Case N-716-1 which is an approved alternative and therefore no additional alternative is required.

2. When examination sample is less than 100%, approximately 50% of the sample is required to be inspected during the first 6 years of the interval.

3. a. Category B-J welds can be inspected with a scope of 10 percent every 10 years when a second mitigator is applied. The acceptable second mitigator is heat sink welding (HSW), mechanical stress improvement (MSIP), induction heating stress improvement (IHSI), solution annealing or hydrogen water chemistry (HWC).

b. During the selection of locations for inspection, consideration should be given regarding locations where IGSCC could be accelerated by crevice corrosion or thermal fatigue. In addition, locations having attributes that would promote IGSCC should have higher priority for inspection. The attributes that may be considered include: high carbon or low ferrite content, crevice or stagnant flow condition, evidence of weld repair, surface cold work, and high fit-up, residual and operating stresses.

4. If qualified IGSCC examinations have not been conducted, the inspection frequency for Category B welds will be 25 percent of the population every 6 years under NWC conditions, or 25 percent every 10 years under HWC conditions.

5. The licensee must ensure that an effective stress improvement was achieved. Additionally, there must have been either:

(a) a preservice (post-stress improvement) and inservice examination with a qualified procedure with no cracking identified or (b) for welds that were stress-improved prior to publication of BWRVIP-75-A but did not receive a preservice examination, at least one examination performed with a qualified procedure after more than two operating cycles and no cracking detected.

6. If a flawed weld is stress improved and becomes Category E, a preservice examination must be performed followed by two successive inservice examinations using qualified procedures, to be performed every second refueling outage (i.e., a repeat inspection after two cycles and another inspection after two more cycles).

Sample Expansion If cracking is detected in any Category B weld as part of a sample examination, an additional sample of approximately the same number of welds from the category will be examined. The sample should be similar in distribution (size, system, etc.) to the original sample unless there is a ISI NDE Program Revision 14 Change 0 Part A Page 50

technical basis for selecting a different sample. If cracking is detected in any welds in the expanded sample, all remaining welds in that Category are to be examined.

Category D* welds are examined on a sample basis and if cracking is detected, the remaining Category D welds are to be examined. However, if technically justified, the sample expansion may be limited to the piping system in which cracking was initially detected.

Acceptance Criteria or Standard: ASME Section XI, IWB-3640 (IWB-3514 does not apply to austenitic stainless steels and associated welds in BWR environments which are subject to stress corrosion cracking).

Regulatory Basis: GL 88-01 and the NRC Safety Evaluation for BWRVIP-75-A. The Fermi 2 Updated Cracking Program.

Responsible Organization: Program Engineering is responsible for the development and implementation of the augmented inspection program. Design Engineering is responsible for evaluating conditions of degradation for acceptance or corrective action.

8.2 License Renewal AMP B.1.6 BWR Feedwater Nozzles, Feedwater Nozzle Examinations In Accordance With U.S. NRC NUREG 0619 and NUREG-1801

Background:

-NE-523-A71-0594-

approved by USNRC final SER dated M (BWROG) Report GE-NE-523-A71-

1998; and USNRC NUREG-er Nozzle and Control Rod Drive Return Line Nozzle Cracking,-

These documents discuss the initial and current examination requirements for BWR Feedwater Nozzle Cracking. The alternate approach was developed and submitted to the USNRC by the BWROG. The USNRC accepted these alternate requirements in a final SER dated March 10, 2000.

This program augments the examinations specified in the ASME Code,Section XI, with the recommendations and schedule of General Electric NE-523-A71-0594 and NUREG 0619 to

nozzles are not clad and include the improved sparger design.

Enclosure to NRC-24-0050 Page 54 of 150 ISI NDE Program Revision 14 Change 0 Part A Page 51

Source Document: The augmented examination requirements for the feedwater nozzles and spargers are contained in NUREG-0619 and BWR Owners Group (BWROG) Licensing Topical Report GE-NE-523-A71-0594, Revision 1, August 1999, Table 6-1.

Associated Documents: UFSAR, Section B.1.6, "BWR Feedwater Nozzle Program," General Electric document GE-NE-523-A71-0594-A, Revision 1, May 2000, "Alternate BWR Feedwater Nozzle Inspection Requirements," and the NRC Final Safety Evaluation ofBWR Owner's Group Alternate Boiling Water Reactor (BWR) Feedwater Nozzle Inspection, NUREG-1801, Section XI.MS "BWR Feedwater Nozzle."

Purpose:

NUREG-0619 was issued by the NRC in November 1980, and described a cracking phenomenon ofBWR RPV Feedwater (FW) nozzle and CRD nozzle inside radius sections. As a result of enhanced technology and more sophisticated techniques for stress and fracture mechanics analysis, the examination of the FW Nozzle Blend Radius is now performed in accordance with NRC approved guidance of GE-NE-523-A 71-0594-A Rev. I. This program uses inspection activities to monitor the effects of nozzle cracking due to cycle loading.

Scope: The scope of this augmented examination program section includes UT of all six of the FW nozzle bores and inside radius sections as depicted in Figure 1 and VT-3 visual examinations for the FW spargers.

A

The volumetric UT examination region begins at the inside radius-to-vessel intersection point (A). The examination region ends at the point on the inner diameter (JD) corresponding to the point on the outer diameter (OD) where the taper on the nozzle thickness starts at (B).

Figure 1 ISI NDE Program Revision 14 Change 0 Part A Page 52

Method: Volumetric UT examination will be performed on the FW nozzle inside radius sections and VT-3 visual examinations will be performed on the FW spargers as specified in the Reactor Vessel Internal Management Program.

Industry Code or Standards: ASME Section XI

Frequency: FW Nozzle Zones 1, 2, and 3 are examined once every 10 years. Additionally the Feedwater Spargers which are internal to the reactor pressure vessel are visually examined in accordance with the Reactor Vessel Management Program nominally every fourth refueling outage.

Acceptance Criteria or Standard: ASME Section XI, IWB-3000 and the supplemental guidance provided in GE-NE-523-A71-0594-A, Rev. 1.

Regulatory Basis: The AMP in Fermi 2 Updated Final Safety Analysis Report (UFSAR),

feedwater nozzles.

Responsible Organization: Program Engineering is responsible for the development and implementation of the augmented inspection program. Design Engineering is responsible for evaluating conditions of degradation for acceptance or corrective action.

8.3 Core Delta P/SLC Nozzle

Background:

This program incorporates the inspection and evaluation recommendations of BWRVIP Evaluation Guidelines.

Source Document: BWRVIP Inspection and Flaw Evaluation Guidelines.

Associated Documents: GE Service Information Letter (SIL) No. 571 -

Purpose:

Manage the effects of cracking of the Core Delta P/SLC Nozzle.

Scope: Core Delta P/SLC Nozzle 5-315, inspection boundary to include all stainless steel material accessible for ultrasonic examination.

ISI NDE Program Revision 14 Change 0 Part A Page 53

Method: Volumetric Examination (UT)

Industry Code or Standards: ASME Section XI

Frequency: Once every ten-year interval

Acceptance Criteria or Standard: No cracks

Regulatory Basis: None

Responsible Organization: Program Engineering is responsible for the development and implementation of the augmented inspection program. Design Engineering is responsible for evaluating conditions of degradation for acceptance or corrective action.

8.4 License Renewal AMP B.1.34

Background:

The One-Time Inspection of Small-Bore Piping Program is a new program that is derived from the program described in NUREG--Time Inspection of ASME Code Class 1 Small-Bore Piping Program.

Section XI (2013 Edition) requirements and is applicable to ASME Code Class 1 piping and components with a nominal pipe size diameter greater than or equal to 1 inch NPS and less than 4 inches NPS. These exams are in Class 1 systems that have not experienced cracking. Fermi 2 has not experienced cracking of Class 1 small-bore piping due to stress corrosion, cyclical (including thermal, mechanical, and vibration fatigue) loading, or thermal stratification and thermal turbulence. The program can also be used for systems that have experienced Small-bore pipe cracking but have implemented design changes to effectively mitigate cracking.

This program provides a one-time volumetric or opportunistic destructive inspection (socket welds only) of ASME Class 1 piping butt weld locations and socket weld locations that are susceptible to cracking.

This program includes a sampling approach. Sample selection is based on susceptibility to stress corrosion, cyclic loading (including thermal, mechanical, and vibration fatigue), thermal stratification and thermal turbulence, and failure history. Since Fermi 2 will not have more than 30 years of operation at time of submitting the license renewal application, the inspections include 10% of the weld population or a maximum of 25 welds of each weld type (e.g., full penetration and socket weld).

ISI NDE Program Revision 14 Change 0 Part A Page 54

The program includes measures to verify that degradation is not occurring, thereby either confirming that there is no need to manage aging-related degradation or validating the effectiveness of any existing program for the period of extended operation. If evidence of cracking is revealed by this one-time inspection, it will be entered into the Corrective Action Program to determine extent of condition and a follow-up periodic inspection will be managed by a plant-specific program. Flaws or indications are evaluated in accordance with the ASME Code.

Source Document: NUREG-One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program.

Associated Documents: -Time Inspection Small-Bore

Purpose:

Monitoring of small bore piping welds to ensure that degradation is not occurring.

Scope: A one-time inspection of 10% or 25 welds of each type of Class 1 weld. (full penetration and/or socket weld). Scope includes pipes, fittings, branch connections and welds (full and partial penetration).

Method: Volumetric

Industry Code or Standards: ASME Section XI

Frequency: This is a one-time inspection.

Acceptance Criteria or Standard: IWB-3514

Regulatory Basis: NUREG-1801, Section X1.M35; UFSAR Appendix B, B.1.34, -Time Inspection Small-

Responsible Organization: Program Engineering is responsible for the development and implementation of the augmented inspection program. Design Engineering is responsible for evaluating conditions of degradation for acceptance or corrective action.

8.5 License Renewal AMP B.1.37

ISI NDE Program Revision 14 Change 0 Part A Page 55

Background:

Regulatory onal examination requirements for vessel closure studs to ensure that there is no cracking of the bolts.

Source Document Vessel Closure Studs.

Associated Documents: UFSAR,

Purpose:

Based on the above requirements, an augmented inspection program is implemented for the sixty-eight (68) Reactor Vessel Closure studs, nuts and washers.

Scope: Reactor Vessel Closure studs that are removed during refueling outages will be examined.

Method: Surface

Industry Code or Standards: ASME Section XI

Frequency: Each inspection interval

Acceptance Criteria or Standard: ASME Section XI & ASME Section III, NB-2545 or NB-2546 Regulatory Basis: UFSAR 5.4.1 and Reg. Guide 1.65, Position 4; UFSAR Appendix B, B.1.37,

Responsible Organization: Program Engineering is responsible for the development and implementation of the augmented inspection program. Design Engineering is responsible for evaluating conditions of degradation for acceptance or corrective action.

8.6 -Classed BWR

Background:

In accordance with Letter No. NRC-92-0090, Fermi 2 requested removal of the feedwater and condensate system welds from the ISI-NDE Program (Plan). In the review of the Fermi 2 License Renewal Application, the NRC noted that the feedwater and condensate systems included 24 Category D welds in accordance with GL 88-01 (i.e., welds with materials nonresistant to IGSCC with no stress improvement process). By letter dated December 4, 2014, ISI NDE Program Revision 14 Change 0 Part A Page 56

the NRC requested clarification whether the feedwater and condensate systems included GL 88-01 Category D welds. Fermi 2 responded in a letter dated January 5, 2015 that the subject welds were proposed to be removed, however the NRC did not agree with that position and stated

from the Fermi 2 ISI-staff de

Source Document: Fermi 2 Letter to the NRC, NRC-92-0090, NUREG-Evaluation Report Related to License Renewal of Fermi 2.

Associated Documents: NUREG-

Purpose:

Verify structural integrity of IGSCC Category D welds.

Scope

Method: Ultrasonic

Industry Code or Standards: N/A

Frequency: Ten percent of the feedwater and condensate systems Category D welds are inspected each refueling outage, unless 100% of the welds have already been inspected in the Inservice Inspection Interval.

Acceptance Criteria or Standard: Generic Letter 88-01

Regulatory Basis: NUREG-Fermi 2.

Responsible Organization: Program Engineering is responsible for the development and implementation of the augmented inspection program. Design Engineering is responsible for evaluating conditions of degradation for acceptance or corrective action.

8.7

Background:

The industry experienced instances of recirculation pump hydrostatic bearing baffle plate cracking. The pumps in question were manufactured by Byron Jackson and a ISI NDE Program Revision 14 Change 0 Part A Page 57

licensee of Byron Jackson. Therefore, in accordance with GE Rapid Information Communication Service Information Letter (RICSIL) #038, Fermi 2 will perform a visual examination on the hydrostatic bearing baffle plate in the reactor recirculation pumps when disassembled.

Source Documentange Failure

Associated Documents: Deviation Event Report (DER) 89-

Purpose:

To confirm that the baffle plates have not cracked.

Scope: Each reactor recirculation pump has one set of baffle plates.

Method: Visual Examination.

Industry Code or Standards: RICSIL #038

Frequency: When Disassembled.

Acceptance Criteria or Standard: No Cracks

Regulatory Basis: None

Responsible Organization: Program Engineering is responsible for the inspection of the recirculation pump bearing flange. The results of the pump examination should be sent to GE for consideration in characterizing the cracking mechanism.

8.8

Background:

In March 1984, the suction splitters of a recirculation pump were penetrant tested (PT) and cracks were found in the area of the heat affected zone (HAZ) of the splitter welds.

Therefore, in accordance with GE Service Information Letter (SIL) #415, Fermi 2 will perform a surface examination (Liquid Penetrant) on the suction splitters in the reactor recirculation pumps when disassembled.

Source Document

ISI NDE Program Revision 14 Change 0 Part A Page 58

Associated Documents: Deviation Event Report (DER) 88-

--19:

Byron Jackson Tech. Note 8609

Purpose:

To ensure that Recirculation Pump Suction Splitters are not cracked.

Scope: Each recirculation pump has one set of Suction Splitters.

Method: Surface Examination [If cracks are found, a UT of the splitter adjacent to the weld will be performed to determine the depth of the crack(s) and if subsurface cracks are present].

Industry Code or Standards: No cracking

Frequency: When Disassembled.

Acceptance Criteria or Standard: ASME Section XI, IWB-3516

Regulatory Basis: None

Responsible Organization: Program Engineering is responsible for the inspection of the suction splitters. Design Engineering is responsible for evaluating conditions of degradation for acceptance or corrective action using SIL 415 for guidance.

8.9 License Renewal AMP B.1.5

Background:

This is an existing program that is being credited to the aging management during the period of extended operations. The BWR Control Rod Drive (CRD) Return Line Nozzle Program is an existing program that is compared to the program described in NUREG-1801,

the CRD return line nozzle using preventive, mitigative, and inservice inspection activities, in accordance with Fermi 2 commitments to implement the recommendations in NUREG-0619, and ASME Code.

Section XI, Subsection IWB, Table IWB 2500-1. Examinations that can detect the presence of cracking are performed to assure detection of cracks before the loss of intended function of the CRD return line nozzle. Cracking found during inservice inspection is evaluated in accordance with ASME Code Section XI requirements. The Fermi 2 CRD return line nozzle was capped during construction prior to plant operation.

ISI NDE Program Revision 14 Change 0 Part A Page 59

Per Telecon with DTE on 2-5-2013 - The CRDRL Nozzle N9 cap and cap-to-nozzle weld are currently being volumetrically inspected every 10 years. The CRDRL Nozzle Program will continue to inspect the N9 cap and cap-to-nozzle weld once before the period of extended operation (PEO) and once every 10 years thereafter.

This program provides monitoring of the N9 nozzle for cracking through station ISI procedures based on ASME Section XI requirements. Fermi 2 has capped the N9 nozzle to mitigate fatigue cracking. The N9 nozzle-to-cap weld is also volumetrically examined.

Source Document

Associated Documents: NUREG-Generic Letter 88-,

RACTS 20364.

Purpose:

Perform ultrasonic examinations to verify the structural integrity of the CRD Return Line nozzle and cap.

Scope: CRD Return line nozzle to cap weld, CRD Return line nozzle-to-vessel welds, and the CRD Return line nozzle blend radius and adjacent vessel wall.

Method: Ultrasonic Examination

RACTS 20364 The commitment was made in Appendix A.4 of the Fermi 2 License Renewal Application (LRA). The required action is that the BWR CRD return line nozzle program be enhanced prior to 09/20/2024 or the end of the last refueling outage prior to March 20, 2025, whichever is later.

The enhancements are to: (a.) Revise BWR CRD return line nozzle program procedures as necessary to ensure that ultrasonic test (UT) examinations will be used to detect applicable aging effects.

Industry Code or Standards: ASME Section XI

Frequency: Once every 10-years.

Acceptance Criteria or Standard: ASME Section XI

Regulatory Basis

ISI NDE Program Revision 14 Change 0 Part A Page 60

Responsible Organization: Program Engineering is responsible for the development and implementation of the CRDRL inspection. Design Engineering is responsible for evaluating conditions of degradation for acceptance or corrective action.

8.10

Background:

In accordance with a commitment made in Letter No. EF2-53.873 (DSN-EF1-53873), Fermi 2 will perform surface examinations on Class 2 standby liquid control piping (SLC) that is considered exempt per ASME Section XI, IWC-1220.

Source Document: Letter EF2-53.873, dated NRC Staff positions are enclosed [Position MTEB-3 (ISI-Head Spray/SLCS)].

Associated Documents: N/A

Purpose

Scope: SLC piping exempt per IWC-1220, there are a total of 136 welds. Of those 136 welds, 16 are selected for examination or 11.7%.

Method: Surface Examination

Industry Code or Standards: ASME Section XI

Frequency: Once every 10 years

Acceptance Criteria or Standard: IWC-3514

Regulatory Basis: Letter EF2-53.873

Responsible Organization: Program Engineering is responsible for the development and implementation of the inspection of the SLC welds. Design Engineering is responsible for evaluating conditions of degradation for acceptance or corrective action.

8.11 License Renewal AMP B.1.12

Background:

The Containment Inservice Inspection (CISI) IWE Program implements the requirements of 10 CFR 50.55a. The regulations in 10 CFR 50.55a impose the inservice ISI NDE Program Revision 14 Change 0 Part A Page 61

inspection (ISI) requirements of the ASME Boiler and Pressure Vessel (B&PV) Code,Section XI, Subsection IWE, for steel containments (Class MC).

Associated Documents: UFSAR Appendix B, B.1.12

Scope: Drywell, Torus, and Vent System

The Containment IWE Aging Management Program (B.1.12) adds the following augmented inspections:

1) 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.

2) Determine drywell shell thickness in the sand cushion area before the period of extended operation and once in each ten 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.

Method: Visual and Ultrasonic Testing

Industry Code or Standards: ASME Section XI

Frequency: Once per ten-year interval.

Acceptance Criteria or Standard: IWE-3000

Regulatory Basis: UFSAR Appendix B, B.1.12

Responsible Organization: Program Engineering is responsible for the development and implementation of the augmented inspection program. Design Engineering is responsible for evaluating conditions of degradation for acceptance or corrective action.

8.12 Vibration Induced Fatigue of Small-Bore Piping

Background:

Root Cause Evaluation CR-2023-32454 documented fatigue failure of the branch connection weld at CT-B31L018, which resulted in increasing drywell unidentified leakage, and a unit shutdown. A Corrective Action from this Root Cause was to update the Inservice ISI NDE Program Revision 14 Change 0 Part A Page 62

Inspection Aging Management Plan to implement inspections of vibration induced fatigue susceptible locations.

Source Document: CR-2023-32454

Purpose:

Ensure cracking of piping susceptible to vibration induced fatigue is identified prior to through wall failure.

Scope: Determined by Design Engineering based on susceptibility

Method: Surface Examination

Industry Code or Standards: ASME Section XI

Frequency: Determined by Design Engineering based on susceptibility

Acceptance Criteria or Standard: IWB-3514

Regulatory Basis: MES83 requires the revision to License Renewal Aging Management Programs (AMPs), or creation of a new AMP, when evaluation reveals age-related degradation that may not be adequately managed.

Responsible Organization: Program Engineering is responsible for implementation of the inspections. Design Engineering is responsible determining the scope and frequency of the inspections.

ISI-NDE Program Rev. 14 Change 0 Part B Page 1

PART - B

INSERVICE INSPECTION-NONDESTRUCTIVE EXAMINATION (ISI-NDE) PROGRAM (PLAN)

FOR COMPONENT SUPPORTS

ISI-NDE Program Rev. 14 Change 0 Part B Page 2

1.0 Introduction

This DTE Electric Company Fermi 2 ASME Section XI, Fourth Ten Year Interval Program (Plan) Part B of the Inservice Inspection-Nondestructive Examination (ISI-NDE) Program (Plan) described herein applies to Component Supports of ASME Class 1, 2, and 3 components. It was developed and is implemented in accordance with the requirements of Section XI, Inservice Inspection of Nuclear Components, Division 1 of the ASME Boiler and Pressure Vessel Code, 2013 Edition, as modified by the Code of Federal Regulations (CFR) requirements of 10 CFR 50.55a(g)(4)(ii). All references in this document Part B to Section XI which includes Code Category F-A Supports and their Item Numbers refer to the 2013 Edition unless otherwise noted, which interval. The results of this application are summarized by Item Number and are contained in Enclosure 2. Enclosure 2 also identifies the number of components selected originally for examination during the fourth inspection interval and provides a schedule by period, for the applicable required examinations to be performed. This schedule will be adhered to as much as practical, recognizing that maintenance or other activities may result in unanticipated opportunities for other inspections. Adjustments may be made to this initial period schedule as long as the Section XI minimum/maximum percentage examination requirements for each period are met. Scheduling and tracking of exam completion for the required inspections and tests will be done using IDDEAL software.

Part B of the ISI-NDE Program is credited for the performance of Inservice Inspection IWF Aging Management Program (AMP) activities required by License Renewal (UFSAR Section B.1.22).

2.0 Program Description

Visual examination requirements in accordance with ASME Section XI, Subsection IWF for all component supports, except snubbers, are addressed in this section. The Inservice Inspection and Testing Program (Plan) for snubbers can be found in the Snubber Program Plan as referenced in Part C.

All component supports to be examined will receive a VT-3 visual examination to determine the general mechanical and structural condition of the component support. Component supports with moving parts (other than pin connections) will also receive a VT-3 visual examination to determine conditions relating to the functional adequacy of the component support.

For the examination of snubbers the examination shall only include the attachments to the pressure retaining boundary and the building structure. As shown in Figure IWF-1300-1(f) of the 2013 Edition of ASME Section XI, the pin-to-pin dimension (including the snubber) is excluded from Section XI examination.

2.1 Supports To Be Examined ISI-NDE Program Rev. 14 Change 0 Part B Page 3

In accordance with ASME Section XI, those component supports selected for examination shall be the supports of those components that are required to be examined under IWB, IWC, IWD, and IWE.

Component supports determined not to have integrity for intended service are defined as unacceptable for continued service.

Component supports subject to examination are listed in the Tables found in Section 5.0, Part B of this document.

3.0 Exemptions

Certain component supports are exempt from the examination requirements of ASME Section XI, Table IWF-2500-1 per provisions contained in the Code. This section lists those Code Allowed Exemptions as applicable to the Fermi 2 Component Support Inservice Inspection Program.

Exemption EX-B1-1 ASME Section XI Code Paragraph: IWF-1230 Supports exempt from the examination requirements of this section are those connected to piping and other items exempted from volumetric, surface, or VT-1 or VT-3 visual examinations by IWB-1220, IWC-1220, IWD-1220, and IWE-1220. In addition, portions of supports that are inaccessible by being encased in concrete, buried underground or encapsulated by guard pipe are also exempt from the examination requirements of IWF-1230.

The Inservice Inspection Classification Boundary Drawings list in Part A, Section 6.0 provides coded system functional drawings identifying all piping and components exempt from examination.

4.0 Relief Requests

No Relief Requests are included in Part B of this program for the fourth interval. If requests for relief become necessary they will be processed as described in Part A, Section 5.0.

5.0 IWF Code Category Summary Tables in Enclosure 2

5.1 ASME Section XI Inservice Inspection and Examination Code Category Summary Table The Class 1, 2, and 3 component supports requiring examination per Section XI are shown in Enclosure 2. The table provides the following information:

Examination Category

ISI-NDE Program Rev. 14 Change 0 Part B Page 4

This column lists the examination category as identified in ASME Section XI, Table IWF-2500-l.

Item Number

This column lists the Code Item No. as identified in ASME Section XI, Table IWF-2500-l.

Description of Component Supports Examined

This column lists a description of the component supports examined as identified in ASME Section XI, Table IWF-2500-l.

Examination Method(s)

The column lists the examination method(s) required by ASME Section XI, Table IWF-2500-1.

Number of Components in Item No.

This column lists the total population of component supports potentially subject to examination. The number of component supports actually examined during the inspection interval will be based upon the Code requirements for the subject Code Item Number.

Required to be Examined during Interval

The number of component supports required to be examined during the inspection interval.

Examination Percentage Required

The column lists the percentage of each Item Number required to be examined per ASME Section XI, Table IWF-2500-1.

Number to be examined in Interval

This column lists the number of component supports that are scheduled during the g requirements.

Number to be examined in 1st, 2nd, and 3rd Period columns

ISI-NDE Program Rev. 14 Change 0 Part B Page 5

These three columns provide the number of components scheduled each inspection period with the cumulated percentage at the bottom of each column to show compliance with Tables IWF-2410-1 if applicable.

5.2 List of Abbreviations For definitions of abbreviations used in the following tables, refer to Part A, Section 7.2.

5.3 EXAMINATION CATEGORY F-A SUPPORTS

Examination Category F-A of ASME Section XI requires 25% of Class 1 Piping Supports, 15% of Class 2 Piping Supports, and 10% of Class 3 Piping Supports to be examined during the inspection interval. For multiple components other than piping, within a system of similar design, function, and service, the supports of only one of the multiple components are required to be examined. The supports have been separated by type as defined in Note (1) to Examination Category F-A. This type has been added to the Item Number to clearly identify each support type. Twenty-five percent (25%) of the Class 1 supports have been selected and are prorated by type and system. Fifteen percent (15%) of the Class 2 supports have been selected and are prorated by type and system. Ten percent (10%) of the Class 3 supports have been selected and are prorated by type and system.

Support Types:

Class 1 Piping Supports:

F1.10A Anchor F1.10B Guide F1.10C Thermal Movement F1.10R Rigid F1.10S Snubber

Class 2 Piping Supports:

F1.20A Anchor F1.20B Guide F1.20C Thermal Movement F1.20R Rigid F1.20S Snubber

Class 3 Piping Supports:

F1.30A Anchor F1.30B Guide F1.30C Thermal Movement F1.30R Rigid F1.30S Snubber

Class 1, 2, and 3 Component Supports F1.40

ISI-NDE Program Rev. 14 Change 0 Part B Page 6

There are 106 total component supports which are categorized into groups of multiple components based on size, similar design, system, function, and service. One of the component supports within each group is selected for examination, resulting in 62 of the total 106 component supports being selected or 51%.

ISINDEProgram Revision14 Change0 PartCPage1

PART-C

THESNUBBERPROGRAMHASBEENRELOCATEDTOASEPARATEDOCUMENT-DOCUMENTSERIALNUMBERSNUBBERPROGRAM ISINDEProgram Revision14 Change0 PartDPage1

PART-D ADOPTEDASMECODECASES

INSERVICEINSPECTION-NONDESTRUCTIVE EXAMINATION(ISI-NDE)PROGRAM(PLAN)

ISINDEProgram Revision14 Change0 PartDPage2

1.0 Introduction ThisDTEElectricCompanyFermi2ASMESectionXI,FourthTen-YearIntervalProgram (Plan)PartDoftheInserviceInspection-NondestructiveExamination(ISI-NDE)ProgramPlan describedhereincontainsalistingofASMESectionXICodeCasesthatareapprovedforuseat andhavebeenadoptedbyFermi2forthefourthinterval.

D.1 AdoptionofCodeCases

ASMESectionXICodeCasesadoptedforISIandrelatedNDEactivitiesfortheISIIntervalare listedinTablesD.2-1,D.3-1,andD.4-1. TheuseofCode Casesis inaccordancewithASME Section XI, IWA-2440, 10 CFR 50.55a, and Regulatory Guide 1.147. As permitted by ASME SectionXIandRegulatoryGuide1.147or10CFR50.55a,ASMESectionXICodeCasesmaybe adoptedandusedasdescribedbelow:

AdoptionofCodeCasesListedforGenericUseinRegulatoryGuide1.147 CodeCasesthatarelistedforgenericuseinthelatestrevisionofRegulatoryGuide1.147maybe includedintheISIprogramprovidedanyadditionalconditionsspecifiedintheRegulatoryGuide arealsoincorporated. TableD.2-1identifiestheCodeCasesapprovedforgenericuseandadopted fortheinterval.

AdoptionofCodeCasesNotApprovedinRegulatoryGuide1.147 CertainCodeCasesthathavebeenapprovedbytheASMEBoardofNuclearCodesandStandards may not have been reviewed and approved by the NRC Staff for generic use and listed in RegulatoryGuide1.147. UseofsuchCodeCasesmayberequestedintheformofaRequestfor Alternative in accordance with 10 CFR 50.55a(z). Once approved, these Requests for Alternatives will be available for use until such time that the Code Cases are adopted into RegulatoryGuide1.147,atwhichtimecompliancewiththeprovisionscontainedintheRegulatory Guidearerequired.

Table D.3-1 identifies those Code Cases that have been requested through a Request for Alternative. For convenience to the user of this ISI Program Section, the appropriate internal correspondencenumberisprovidedtoassistinretrievaloftherequestfromDocumentControl.

All other Requests for Alternatives and Requests for Relief (those not associated with NRC approvalofCodeCases)areaddressedinPartA.

AdoptionofCodeCasesMandatedby10CFR50.55a Code Cases required by rule in 10 CFR 50.55a are incorporated into the ISI Program and implemented at the specified schedule. Code Cases currently required by 10 CFR 50.55a are identifiedinTableD.4-1.

UseofAnnulledCodeCases AspermittedbyRegulatoryGuide1.147,CodeCasesthathavebeenadoptedforuseinthecurrent inspectionintervalthataresubsequentlyannulledbyASMEmaybeusedfortheremainderofthe interval.

ISINDEProgram Revision14 Change0 PartDPage3

CodeCaseRevisions Initial adoption of a Code Case requires use of the latest revision of that Code Case listed in RegulatoryGuide1.147. However,ifanadoptedCodeCaseislaterrevisedandapprovedbythe NRC,theneithertheearlierorlaterrevisionmaybeusedaspermittedbyRegulatoryGuide1.147.

An exception to this provision would be the inclusion of any conditions on the later revision necessarytoenhancesafety.Inthissituation,theconditionsimposedonthelaterrevisionmustbe incorporatedintotheprogram.

AdoptionofCodeCasesIssuedSubsequenttoFilingtheInserviceInspectionPlan CodeCasesissued byASMEsubsequentto filing1 the Inservice InspectionPlanwiththeNRC maybeincorporatedwithintheISIPlan. AnysubsequentCodeCasesshallbeincorporatedinto theprogramandidentifiedineitherTableD.2-1orD.3-1,asapplicable,priortotheiruse.

NonInserviceInspectionCodeCases OnlyCodeCasesapplicabletoISIandrelatedNDErequirementsandFlawEvaluationsforClass 1,2,and3componentsandtheirsupportsareincludedinTableD.2-1,D.3-1andD.4-1.

CodeCasesNotApprovedforGenericUsebytheNRC CodeCasesthathavebeenapprovedbytheASMEBoardofNuclearCodesandStandardsmaynot beapprovedbytheNRCStaffforgenericuse. TheseCodeCasesarelistedinRegulatoryGuide 1.193, ASME Code Cases Not Approved for Use. However, the NRC may approve their use in specificcases.CodeCaseslistedinRegulatoryGuide1.193willnotbeusedatFermiwithoutan approvedRequestforAlternativeinaccordancewith10CFR50.55a(z).

D.2 RegulatoryGuide1.147,Revision18ApprovedCodeCases

TableD.2-1-CodeCasesAdoptedfromRegulatoryGuide1.147 CodeCase Title NRCConditions Number N-532-5 Repair/ReplacementActivityDocumentation None RequirementsandInserviceInspection SummaryReportPreparationandSubmission

1TheNRCnolongerrequiresfilingorsubmittaloftheISIProgramPlan.

ISINDEProgram Revision14 Change0 PartDPage4

TableD.2-1-CodeCasesAdoptedfromRegulatoryGuide1.147 CodeCase Title NRCConditions Number N-561-2 AlternativeRequirementsforWallThickness 1) Paragraph5(b):for RestorationofClass2andHighEnergyClass repairsperformedona 3CarbonSteelPiping wetsurface,theoverlay isonlyacceptableuntil thenextrefuelingoutage

2) Paragraph7(c):ifthe causeofthedegradation hasnotbeendetermined, therepairisonly acceptableuntilthenext refuelingoutage

3) Theareawheretheweld overlayistobeapplied mustbeexaminedusing ultrasonicmethodsto demonstratethatno crack-likedefectsexist

4) Pipingwithwall thicknesslessthanthe diameteroftheelectrode shallbedepressurized beforewelding ISINDEProgram Revision14 Change0 PartDPage5

TableD.2-1-CodeCasesAdoptedfromRegulatoryGuide1.147 CodeCase Title NRCConditions Number N-562-1 AlternativeRequirementsforWallThickness 1) Paragraph5(b):for RestorationofClass3ModerateEnergy repairsperformedona CarbonSteelPiping wetsurface,theoverlay isonlyacceptableuntil thenextrefuelingoutage

2) Paragraph7(c):ifthe causeofthedegradation hasnotbeendetermined, therepairisonly acceptableuntilthenext refuelingoutage

3) Theareawheretheweld overlayistobeapplied mustbeexaminedusing ultrasonicmethodsto demonstratethatno crack-likedefectsexist

4) Pipingwithwall thicknesslessthanthe diameteroftheelectrode shallbedepressurized beforewelding N-606-1 SimilarandDissimilarMetalWeldingUsing Priortowelding,an AmbientTemperatureMachineGTAW examinationorverification TemperBeadTechniqueforBWRCRD mustbeperformedtoensure Housing/StubTubeRepairs properpreparationofthe basemetal,andthatthe surfaceisproperly contouredsothatan acceptableweldcanbe produced. Thisverification istoberequiredinthe weldingprocedures.

N-613-2 UltrasonicExaminationofPenetrationNozzles None inVessels,ExaminationCategoryB-D, ReactorNozzle-to-VesselWeldsandNozzle InsideRadiusSection,Figs.IWB-2500-7(a),

(b),(c),and(d).

ISINDEProgram Revision14 Change0 PartDPage6

TableD.2-1-CodeCasesAdoptedfromRegulatoryGuide1.147 CodeCase Title NRCConditions Number N-638-6 SimilarandDissimilarMetalWeldingUsing Demonstrationforultrasonic AmbientTemperatureMachineGTAW examinationoftherepaired TemperBeadTechnique volumeisrequiredusing representativesamples whichcontainconstruction typeflaws.

N-639 AlternativeCalibrationBlockMaterial Chemicalrangesofthe calibrationblockmayvary fromthematerials specificationif(1)itis withinthechemicalrangeof thecomponentspecification tobeinspected,and(2)the phaseandgrainshapeare maintainedinthesame rangesproducedbythe thermalprocessrequiredby thematerialspecification.

N-651 FerriticandDissimilarMetalWeldingUsing None SMAWTemperBeadTechniqueWithout RemovingtheWeldBeadCrownoftheFirst Layer ISINDEProgram Revision14 Change0 PartDPage7

TableD.2-1-CodeCasesAdoptedfromRegulatoryGuide1.147 CodeCase Title NRCConditions Number N-661-2 AlternativeRequirementsforWallThickness 1. Paragraph4(b): for RestorationofClasses2and3CarbonSteel repairsperformedona PipingforRawWaterService wetsurface,theoverlayis onlyacceptableuntilthe nextrefuelingoutage

2. Paragraph7(c): ifthe causeofthedegradation hasnotbeendetermined, therepairisonly acceptableuntilthenext refuelingoutage

3. Theareawheretheweld overlayistobeapplied mustbeexaminedusing ultrasonicmethodsto demonstratethatno crack-likedefectsexist

4. Pipingwithwall thicknesslessthanthe diameteroftheelectrode shallbedepressurized beforewelding N-666-1 WeldOverlayofClass1,2,and3Socket Asurfaceexamination WeldedConnections (magneticorliquid penetrant)mustbe performedafterinstallation oftheweldoverlayonClass 1and2pipingsocketwelds.

Fabricationdefects,if detected,mustbe dispositionedusingthe surfaceexamination acceptancecriteriaofthe ConstructionCodeidentified intheRepair/Replacement Plan N-716-1 AlternativePipingClassificationand None ExaminationRequirements ISINDEProgram Revision14 Change0 PartDPage8

TableD.2-1-CodeCasesAdoptedfromRegulatoryGuide1.147 CodeCase Title NRCConditions Number N-730-1 RollExpansionofClass1ControlRodDrive None BottomHeadPenetrationsinBWRs

N-733 MitigationofFlawsinNPS2andSmaller None NozzlesandNozzlePartialPenetrationWelds inVesselsandPipingbyUseofaMechanical ConnectionModification N-735 SuccessiveInspectionsofClass1and2Piping None Welds

N-747 ReactorVesselHead-to-FlangeWeld None

N-749 AlternativeAcceptanceCriteriaforFlawsin Inlieuoftheuppershelftransition FerriticSteelComponents temperature,Tc,asdefinedinthe OperatingintheUpperShelfTemperature CodeCase,thefollowingshallbe Range used:

Tc=154.8°F+0.82xRTNDT(in U.Scustomaryunits).

Tc=82.8°C+0.82xRTNDT(in theInternationalSystemofUnits).

Tcisthetemperatureabovewhich theelasticplasticfracture mechanics(EPFM)methodmust beapplied.Additionally,theNRC definestemperatureTc1below whichthelinearelasticfracture mechanics(LEFM)methodmust beapplied:

Tc1=95.36°F+0.703xRTNDT(in U.Scustomaryunits).

Tc1=47.7°C+0.703xRTNDT(in internationalsystemofunits).

BetweenTc1andTc,althoughthe fracturemodeisintransitionfrom LEFMtoEPFM,usersshould considerwhetheritisappropriate toapplytheEPFMmethod.

Alternatively,thelicenseemay useadifferentTcvalueifit canbejustifiedbyplant-specific Charpycurves.

ISINDEProgram Revision14 Change0 PartDPage9

TableD.2-1-CodeCasesAdoptedfromRegulatoryGuide1.147 CodeCase Title NRCConditions Number N-751 PressureTestingofContainmentPenetration Whena10CFR50, Piping AppendixJ,TypeCtestis performedasanalternative totherequirementsofIWA-4540(IWA-4700inthe 1989editionthroughthe 1995edition)duringrepair andreplacementactivities, nondestructiveexamination mustbeperformedin accordancewithIWA-4504(a)(2)ofthe2002 AddendaofSectionXI N-769-2 RollExpansionofClass1In-CoreHousing None BottomHeadPenetrationsInBWRs

N-771 AlternativeRequirementsforAdditional None ExaminationofClass2and3Items

N-786-1 AlternativeRequirementsforSleeve None ReinforcementofClass2and3Moderate-EnergyCarbonSteelPiping N-789 AlternativeRequirementsforPad Areascontainingpressure ReinforcementofClass2and3Moderate- padsshallbevisually EnergyCarbonSteelPipingforRawWater observedatleastonceper Service monthtomonitorfor evidenceofleakage. Ifthe areascontainingpressure padsarenotaccessiblefor directobservation,then monitoringwillbe accomplishedbyvisual assessmentofsurrounding areasorgroundsurface areasabovepressurepadson buriedpiping,ormonitoring ofleakagecollection systems,ifavailable.

ISINDEProgram Revision14 Change0 PartDPage10

TableD.2-1-CodeCasesAdoptedfromRegulatoryGuide1.147 CodeCase Title NRCConditions Number N-795 AlternativeRequirementsforBWRClass1 1) Theuseofnuclearheat SystemLeakageTestPressureFollowing toconducttheBWR Repair/ReplacementActivities Class1systemleakage testisprohibited(i.e.,the reactormustbeinanon-criticalstate),except duringrefuelingoutages inwhichtheASME SectionXICategoryB-P pressuretesthasalready beenperformed,oratthe endofamid-cycle maintenanceoutages fourteen(14)daysorless duration.

2) Thetestcondition holdingtime,after pressurizationtotest conditions,andbefore thevisualexaminations commence,shallbe1 hourfornon-insulated components.

N-798 AlternativePressureTestingRequirementsfor None Class1PipingBetweentheFirstandSecond Vent,Drain,andTestIsolationDevices N-800 AlternativePressureTestingRequirementsfor None Class1PipingBetweentheFirstandSecond InjectionValves N-805 AlternativetoClass1ExtendedBoundaryEnd None ofIntervalorClass2SystemLeakageTesting oftheReactorVesselHeadFlangeO-Ring Leak-DetectionSystem ISINDEProgram Revision14 Change0 PartDPage11 D.3 CodeCasesAdoptedViaReliefRequests

ThefollowingASMECodeCasesarenotcontainedinRegulatoryGuide1.147,Revision18,[4.4]

andrequirearequestforalternativepriortoimplementation. RefertoSection3.0ofthisplanfor theapplicablerequests.

TableD.3-1-CodeCasesAdoptedViaReliefRequests CodeCase Title Requestfor Number AlternativeNo.

RR-A40(NRC-19-0016)

N-513-4 AlternativeEvaluationCriteriaforTemporaryAcceptanceofFlawsinModerateEnergyClass2or3PipingSafetyEvaluationDSN:

190613 RR-A37(NRC-19-0016)

N-702 AlternativeRequirementsforBoilingWaterReactor(BWR)NozzleInnerRadiusandNozzle-to-ShellWeldsSafetyEvaluationDSN:

190819 RR-A41(NRC-19-0016)

N-864 ReactorVesselThreadsinFlangeExaminations SafetyEvaluationDSN:

190626

D.4 CodeCasesrequiredby10CFR50.55a

ThefollowingASMECodeCasesarenotcontainedinRegulatoryGuide1.147,Revision18,[4.4],

butaremandatedin10CFR50.55a.

TableD.4-1-CodeCasesRequiredby10CFR50.55a CodeCase Title Notes Number NONE ISINDEProgram Revision14 Change0 PartEPage1

PART-E

RISK-INFORMEDINSERVICEINSPECTIONPROGRAM(PLAN)

(ApplicationofASMECodeCaseN-716-1)

ISINDEProgram Revision14 Change0 PartEPage2

RI-ISILIVINGPROGRAMEVALUATION

Introduction

TheobjectiveoftheRI-ISIprogramistoprovideanalternativemethodforselectingand categorizingpipingandcomponentsintoHSSandLSSgroupsforthepurposeofdevelopinga RI-ISIprogramasanalternativetotheASMESectionXIrequirementforExamination CategoriesB-F,B-J,C-A,C-B,C-F-1,andC-F-2. Fermi2usesCodeCaseN-716-1.TheNRC hasapprovedthiscodecaseinRegulatoryGuide1.147. ThecodecasewasplacedinTable1of theRegulatoryGuideandapprovedwithnoconditions.

Purpose

TheRI-ISIprogramoutlinesanacceptablealternativeapproachtotheexistingSectionXI requirementsforthescopeandfrequencyofpipingexamination.

HistoricalInformation

IntheSecondTen-YearIntervalatFermi2,aRisk-InformedInserviceInspection(RI-ISI)

ProgramprocesswasimplementedfortheselectionofClass1pipingweldsforexaminationas analternativetoASMESectionXICoderequirements. TheFermi2RI-ISIProgramforthe examinationofClass1pipingweldswasdevelopedinaccordancewiththerisk-informed processbasedonEPRITR-112657,RevisionB-A,withidentifieddifferences,andwith additionalguidancetakenfromASMECodeCaseN-578. Thiswasaccomplishedusing references1through10.

OnApril30,2001,Fermi2submittedISIReliefRequestRR-A30totheNRC,requestingrelief fromtheASMESectionXICodeexaminationrequirementsofClass1weld(Examination CategoriesB-FandB-J)inserviceinspectionsbyimplementingaRI-ISIProgram. Relief RequestRR-A30wasapprovedbytheNRCinNRCLetterNRC-01-038datedSeptember10, 2001. RR-A30wassubsequentlyupdatedattheendoftheSecondTen-YearIntervaland resubmittedfortheThirdTenYearInterval.

IntheSecondPeriodoftheThirdTen-YearInterval,theRI-ISIProgramasdescribedaboveand implementedperaCodeCaseN-578-1Risk-InformedRequirementsforClass1,2,and3 PipingMethodB,SectionXI,Division1,forClass1pipingonly,wasconvertedtoaCodeCase N-716-1,RI-ISIProgramfortheremainderoftheThirdInterval. TheapplicationofCodeCase N-716-1includedClass1,2,3andNon-Classedpipingandcomponents. TheASMESectionXI CodeofRecordfortheThirdIntervalwasthe2001Editionthroughthe2003Addenda. This wasdocumentedinReferences11through16.

Scope

CodeCaseN-716-1providesalternativerequirementstoIWB-2420,IWB-2430,TableIWB-2500-1ExaminationCategoryB-FandB-J,IWC-2420,IWC-2430,andTableIWC-2500-1 (excludingExaminationCategoriesC-CandC-H),forinserviceinspectionofClass1piping ISINDEProgram Revision14 Change0 PartEPage3

weldsorClass2components,IWB-2200andIWC-2200forpreserviceinspectionofClass1 pipingweldsorClass2components,orasadditionalrequirementsforClass3ornon-class components. ThefollowingsummarizestheASMESectionXIscopeincludedintheN-716-1 evaluations:

Table1:N-716-1EvaluationScope Class1Welds (1) Class2Welds (2) AllPipingWelds (3)

Total Selected Total Selected Total Selected 586 59 1042 0 1628 59

ThesystemsassessedintheRI-ISIProgramarelistedbelow. Thepipingandinstrumentation diagramsandadditionalplantinformation,includingtheexistingplantISIProgramwereusedto definethepipingsystemboundaries. PerCodeCaseN-716-1requirements,weldsareassigned safety-significancecategories,whicharethenusedtodeterminetheexaminationtreatment requirements(assigningtotheappropriateItemNumber).

CodeCaseN-716-1SafetySignificanceDetermination N-716-1SafetySignificanceDetermination Safety System(1) Code Weld Significance Class Count RCPB SDC PWR BER CDF>1E-06 High Low SG/FW LERF>1E-07 RPV 1 8 X X

NBS/MS 1 113 X X

RCR 1 121 X X

CRD 2 34 X

1 75 X X X RHR 2 480 X

1 45 X X CS 2 196 X

1 14 X X HPCI 2 149 X

RCIC 1 16 X X

RWCU 1 74 X X

FPC 2 9 X

FW 1 120 X X

MS 2 74 X

CGC 2 100 X ISINDEProgram Revision14 Change0 PartEPage4

Note:

Systemsareasfollows:

RPV(B11)-ReactorPressureVessel NBS/MS(B21)-NuclearBoilerSystem(includingClass1portionsofMainSteam)

RCR(B31)-ReactorCoolantRecirculation CRD(C11)-ControlRodDrives RHR(E11)-ResidualHeatRemoval CS(E21)-CoreSpray HPCI(E41)-HighPressureCoolantInjection RCIC(E51)-ReactorCoreIsolationCooling RWCU(G33)-ReactorWaterCleanup FPC(G41)-FuelPoolCooling FW(N21)-Feedwater MS(N30)-MainSteam CGC(T48)-CombustibleGasControl

Thefollowingtablesummarizesthefailurepotentialassessmentbysystemforeachdegradation mechanismthatwasidentifiedaspotentiallyoperative.

FailurePotentialAssessmentSummary System(1) ThermalFatigue StressCorrosionCracking LocalizedCorrosion FlowSensitive TASCS TT IGSCC TGSCC ECSCC PWSCC MIC PIT CC E-C FAC RPV X NBS/MS RCR X CRD (2)

RHR (2) X CS(2) X HPCI(2)

RCIC RWCU X FPC (2)

FW X MS (2)

CGC (2)

Notes:

1. Systemsaredescribedabove.

2. Adegradationmechanismassessmentwasnotperformedonlowsafetysignificantpipingsegments.

ThisincludestheCRD,FPC,MS,andCGCsystemsintheirentirety,andClass2portionsoftheRHR, CS,andHPCIsystems.

ISINDEProgram Revision14 Change0 PartEPage5

Frequency

TheinspectionperiodsandinspectionintervalaredefinedinPartA. Thepipingsegmentsand inspectionstrategy(i.e.,frequency,numberofexaminations,andexaminationmethods)are definedinPartAandEnclosure1.

DuringtheFourth10-YearISIInterval,Fermi2willimplement100%oftheinspectionlocations selectedforexaminationperCodeCaseN-716-1. ThisevaluationwasdocumentedinReference

17. ExaminationsshallbeperformedsuchthattheperiodpercentagerequirementsofASME SectionXIaremet. AllCategoryC-AandC-BweldsareconsideredLSSanddonotrequire examination.

PeriodicUpdates

Aspartoftheimplementationofthiscodecase,inaccordancewithSection7ofN-716-1,For the2007EditionthroughthelatestEditionandAddenda,examinationselectionsmadein accordancewiththisCaseshallbereevaluatedonthebasisofinspectionperiodsthatcoincide withtheinspectionprogramrequirementsofIWA-2431. Fortheinspectionprogram,thethird periodreevaluationwillserveasthesubsequentinspectionintervalreevaluation.

Theperformanceofeachinspectionperiodreevaluation(PTEventPE99)maybeacceleratedor delayed by as much as one year. Each reevaluation shall consider the cumulative effects of previous reevaluations. The reevaluation shall determine if any changes to the HSS/LSS categorizationorexaminationselectionsneedtobemadebyevaluationofthefollowing:

(a)Plantdesignchanges(e.g.,physical:newpipingorequipmentinstallation;programmatic:

poweruprating/18to24monthfuelcycle;andprocedural;operatingprocedurechanges).

(b) Changes in postulated conditions or assumptions (e.g., check valve seat leakage greater thanpreviouslyassumed).

(c)Examinationresults(e.g.,discoveryofleakageorflaws).

(d) Failures in HSS or LSS components (e.g., plant-specific or industry occurrences of through-wallorthrough-weldleakage,failureduetoanewdegradationmechanism,ora non-postulatedmechanism).

(e) PRA updates that would increase the scope (e.g., new initiating events, new system functions,moredetailedmodelused,andinitiatingeventanddatachanges).

(f) Theimpactof(a)through(e)onthechange-in-riskevaluation.

CorrectiveActionProgram

AnycorrectiveactionrequiredastheresultofRI-ISIexaminationsshallbehandledin accordancewithFermiCorrectiveActionProgram.

ISINDEProgram Revision14 Change0 PartEPage6

InserviceInspectionRequirements

Theexaminationsshallbecompletedduringeach10-yearinspectionintervalwiththefollowing exceptions:

a) Ifduringtheinspectioninterval,areevaluationusingtheRI-ISIprocessisconductedand scheduleditemsarenolongerrequiredtobeexamined,theseitemsmaybeeliminated.

b) Ifduringtheinspectioninterval,areevaluationusingtheRI-ISIprocessisconductedand itemsarerequiredtobeaddedtotheexaminationprogram,thoseitemsshallbeaddedin accordancewithIWB-2412(b)orIWC-2412(b).

LSScomponentsareexemptfromvolumetric,surface,andVT-1andVT-3VisualExamination requirementsofSectionXI. HSSvessels,pumps,valves,andpressure-retainingboltingshallbe selectedandexaminedinaccordancewithSectionXI.TenpercentoftheHSSpipingweldsshall beselectedforexamination. TheexistingplantIGSCC(GenericLetter88-01,CategoriesB throughG)inspectionprogrammaybecreditedtowardthe10%requirement,providedthe requirementsofN-716-1aremet. Theexistingplantflowacceleratedcorrosionprogramand localizedcorrosionprogram,excludingcrevicecorrosion,maynotbecreditedtowardthe10%

requirement. TheselectionofHSScomponentsforexaminationisbasedonSection4ofCode CaseN-716-1.

PreserviceInspections

For plants implementing N-716-1 after initial startup, the preservice inspection requirements applyonlytoHSScomponentsaffectedbyarepair/replacementactivity.

a) Vessels, pumps, valves, and pressure-retaining bolting require preservice inspection at least once prior to initial service. The examination volumes, areas, techniques, and proceduresshallbeinaccordancewiththeapplicablerequirementsofSectionXI.

b) Piping weld examinations, with the exception of VT-2 visual examinations listed in N-716-1Table1,shallbeperformedinaccordancewiththerequirementsdefinedinN716 Table1atleastoncepriortoinitialservice. Examinationsshallincludeallpipingwelds, with the exception of VT-2 visual examinations listed in N-716-1Table 1, classified as HSSinaccordancewithN-716-1.

SuccessiveExaminations

SuccessiveexaminationsshallbeinaccordancewithSection6ofCodeCaseN-716-1.

AdditionalExaminations

AdditionalexaminationsshallbeinaccordancewithSection6ofCodeCaseN-716-1.

ISINDEProgram Revision14 Change0 PartEPage7

ExaminationCoverage

CodeCaseN-716-1providesadditionalrequirementsforexaminationcoveragewithintheNotes to Table 1. If none of these Notes apply to a specific examination listed in Table 1, then examinationcoveragewillbeinaccordancewithASMESectionXI.

REFERENCES/DOCUMENTATION

1) EPRITopicalReportTR-112657,RevisedRisk-InformedInserviceInspection EvaluationProcedure,Rev.B-A

2) ASMEBoilerandPressureVesselCodeSectionXI,1989Edition

3) ASMEBoilerandPressureVesselCodeSectionXI,2001Editionthrough2003 Addenda

4) ASMECodeCaseN-716-1,AlternativeClassificationandExamination Requirements,Division1

5) RegulatoryGuide1.174,AnApproachforUsingProbabilisticRiskAssessmentin Risk-InformedDecisionsonPlant-SpecificChangestotheLicensingBasis

6) RegulatoryGuide1.178,AnApproachforPlant-SpecificRisk-Informed DecisionmakingInserviceInspectionofPiping

7) RegulatoryGuide1.147,InserviceInspectionCodeCaseAcceptability,ASME SectionXI,Division1,Rev.17

8) RegulatoryGuide1.200,"AnApproachforDeterminingtheTechnicalAdequacyof ProbabilisticRiskAssessmentResultsforRisk-InformedActivities,"Rev.1

9) NEI05-04,"ProcessforPerformingFollow-onPRAPeerReviewsUsingtheASME PRAStandard,"January2005

10)ASMEWhitePaper92-01-01,EvaluationofInserviceInspectionRequirementsfor Class1,CategoryB-JPressureRetainingWelds,Rev.1

11)ProjectDocumentNo.FERM-003-001,Risk-Informed/SafetyBasedInservice InspectionSafetySignificanceDeterminationfortheFermi2EnergyCenter,Rev.1

12)ProjectDocumentNo.FERM-003-002,Risk-Informed/SafetyBasedInservice InspectionDegradationMechanismEvaluationfortheFermi2EnergyCenter,Rev.1

13)ProjectDocumentNo.FERM-003-003,Risk-Informed/SafetyBasedInservice InspectionRiskRankingfortheFermi2EnergyCenter,Rev.0 ISINDEProgram Revision14 Change0 PartEPage8

14)ProjectDocumentNo.FERM-003-004,Risk-Informed/SafetyBasedInservice InspectionRiskImpactAnalysisfortheFermi2EnergyCenter,Rev.1

15)ProjectDocumentNo.FERM-003-005,Risk-Informed/Safety-BasedInservice InspectionTemplatefortheFermi2EnergyCenter,Rev.0

16)ProjectMemorandum No.MEMO-003-001,Risk-Informed/SafetyBasedInservice InspectionElementSelectionfortheFermi2EnergyCenter,Rev.0

17)ReportFermi-4701211913EnricoFermiNuclearGeneratingStationUnit2Revision 1CodeCaseN-716-1ApplicationIntervalUpdate ISI NDE Program Revision 14 Change 0 Part F Page 1

PART F

ASME SECTION XI CONTAINMENT INSERVICE INSPECTION PROGRAM (PLAN)

ISI NDE Program Revision 14 Change 0 Part F Page 2

1.0 INTRODUCTION

1.1. Purpose

This DTE Electric Company Fermi 2 ASME Section XI, IWE Third Ten-Year Interval Containment Inservice Inspection (CISI) Program Plan constitutes an administrative technical document that is Part F of the overall Fermi 2 Inservice Inspection-Nondestructive Examination (ISI-NDE) Program (Plan) (which is in its Fourth Ten-Year Interval). It was developed and is implemented in accordance with the requirements of ASME Section XI, Subsection IWE, 2013 Edition, as mandated and modified by the Code of Federal Regulations (CFR) requirements contained in 10 CFR 50.55a.

This CISI Program Plan is utilized to obtain data through the application of NDE based on the requirements of ASME Section XI Code for Class MC Components or Code Class MC equivalent components to determine the acceptance of these components for continued service and the generic nature of defects found, if any.

This CISI Program Plan reflects built-in limitations of the original plant design, geometry, construction, component materials, and state-of-art NDE techniques. It specifies the number of components to be examined, the examination methods to be used and provides schedule tables from which specific items are scheduled for NDE by the Fermi 2 Performance Engineering / Inservice Inspection Department.

Tquestsmay be used interchangeably as applicable for any Request for Relief or any Request for Alternative referring to submittals to the NRC requesting permission to deviate from either an ASME Section XI requirement, a 10 CFR 50.55a rule, or to use provisions from editions of Section XI, or portions thereof, not approved by the NRC as referenced in 10 CFR 50.55a(b). These requirements for Relief Requests and a listing of those requests that apply to this CISI Program Plan are referenced in Appendix F4.4.

The CISI Program Plan is credited for the performance of Containment Inservice Inspection IWE Aging Management Program (AMP) activities required by License Renewal (UFSAR Section B.1.12).

1.2. Scope (Applicability):

This Program Plan serves as the ISI / NDE plan and schedule for the implementation of the third interval examinations of Class MC components in accordance with IWE-2411, Inspection Program, and the requirements of 10 CFR 50.55a, for Fermi 2.

The ASME Section XI Code Classification Drawings and the CISI Drawings listed in Section 2 identify the components and systems to be examined. These drawings are prepared and maintained by Fermi 2 Plant Support Engineering and are issued and controlled through the Fermi 2 Records Management System.

The provisions of 10 CFR 50.55a relative to the examination of Class CC components (ASME Section XI Subsection IWL) are not applicable to Fermi 2, since Fermi 2 does not ISI NDE Program Revision 14 Change 0 Part F Page 3

have any ASME Code Class CC equivalent components.

1.3. Frequency

Examinations will be performed in accordance with the examination schedule per Table IWE-2500-1 and 10 CFR 50.55a as implemented by this CISI Program Plan.

1.4. Codes of Record and Code Cases:

The Code of Record for the examination of Class MC components and related requirements for Fermi 2 is the 2013 Edition of the ASME Boiler and Pressure Vessel Code (the Code),Section XI, Division I in accordance with 10 CFR 50.55a(b)(2), 10 CFR 50.55a(b)(2)(vi), 10 CFR 50.55a(g)(4) and the conditions specified in 10 CFR 50.55a(b)(2)(ix) and 10 CFR 50.55a(g)(6)(ii)(B).

Unless otherwise noted, all references within this CISI Program Plan to the Code, or a given section, subsection, or paragraph of the Code, are intended to mean the 2013 Edition.

Qualification / Certification of NDE personnel shall be in accordance with IWA-2300 of ASME Section XI as implemented by MES24 (Nondestructive Examination) and MES25 (Visual Examination). NDE required by Subsection IWE shall be conducted by personnel qualified and certified to a written practice based on ANSI/ASNT CP-189 to the current Section XI Code of record for Subsection IWB, IWC, etc., which is the 2013 Edition. All VT certified personnel will be trained on the requirements of IWE.

Code Cases may be used as allowed by USNRC Regulatory Guide 1.147. Code Cases adopted by DTE Electric Company are incorporated in Part D of the overall Fermi 2 ISI-NDE Program Plan. Code Cases not approved in Regulatory Guide 1.147 may be used if approved by NRC in a Relief Request (i.e., Request for Alternative) in accordance with 10 CFR 50.55a(z) (See Appendix F4.4).

1.5. 10 CFR 50.55a Limitations and Modifications The following 10 CFR 50.55a limitations and modifications apply to this Fermi 2 Containment Inservice Inspection (CISI) Program Plan:

10 CFR 50.55a(b)(2)(ix),Section XI condition: Metal containment examinations.

Licensees applying Subsection IWE, 2007 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, must satisfy the requirements of paragraphs (b)(2)(ix)(A)(2), (b)(2)(ix)(B), (b)(2)(ix)(J) and (K) of this section.

(b)(2)(ix)(A)(2) For each inaccessible area identified for evaluation, the applicant or licensee must provide the following in the ISI Summary Report as required by IWA6000:

(A)(2)(i) A description of the type and estimated extent of degradation, and the conditions that led to the degradation; (A)(2)(ii) An evaluation of each area, and the result of the evaluation, and; (A)(2)(iii) A description of necessary corrective actions.

(b)(2)(ix)(B) Metal containment examinations: Second provision. When performing remotely the visual examinations required by Subsection IWE, the maximum direct ISI NDE Program Revision 14 Change 0 Part F Page 4

examination distance specified in Table IWA22111 may be extended and the minimum illumination requirements specified in Table IWA 22111 may be decreased provided that the conditions or indications for which the visual examination is performed can be detected at the chosen distance and illumination.

(b)(2)(ix)(J) Metal containment examinations: Tenth provision. In general, a repair/replacement activity such as replacing a large containment penetration, cutting a large construction opening in the containment pressure boundary to replace steam generators, reactor vessel heads, pressurizers, or other major equipment; or other similar modification is considered a major containment modification. When applying IWE5000 to Class MC pressure-retaining components, any major containment modification or repair/replacement must be followed by a Type A test to provide assurance of both containment structural integrity and leak-tight integrity prior to returning to service, in accordance with 10 CFR part 50, Appendix J, Option A or Option B on which the applicant's or licensee's Containment Leak-Rate Testing Program is based. When applying IWE5000, if a Type A, B, or C Test is performed, the test pressure and acceptance standard for the test must be in accordance with 10 CFR part 50, Appendix J.

(b)(2)(ix)(K) Metal Containment examinations: Eleventh provision. A general visual examination of containment leak chase channel moisture barriers must be performed once each interval, in accordance with the completion percentages in Table IWE-2411-1 of the 2017 Edition. Examination shall include the moisture barrier materials (caulking, gaskets, coatings, etc.) that prevent water from accessing the embedded containment liner within the leak chase channel system. Caps of stub tubes extending to or above the concrete floor interface may be inspected, provided the configuration of the cap functions as a moisture barrier as described previously. Leak chase channel system closures need not be disassembled for performance of examinations if the moisture barrier material is clearly visible without disassembly, or coatings are intact. The closures are acceptable if no damage or degradation exists that would allow intrusion of moisture against inaccessible surfaces of the metal containment shell or liner within the leak chase channel system.

Examinations that identify flaws or relevant conditions shall be extended in accordance with paragraph IWE-2430 of the 2017 Edition. Fermi 2 does not have an embedded leak-chase channel system (e.g., containment basemat metallic shell and liner plate seam welds of pressurized water reactors which are embedded in 3- to 4-feet (0.9- to 1.2-meter) thick concrete floor during construction and are typically covered by a leak-chase channel system that incorporates pressurizing test connections). Although Fermi 2 does have a moisture barrier which is a concrete-to-metal interface moisture barrier examined per the ASME Class MC Examinations Schedule (reference Part F Appendix F4.2), it does not have an embedded leak-chase channel moisture barrier, therefore, (b)(2)(ix)(K) does not apply.

Although not specifically referenced in 10 CFR 50.55a(b)(2)(ix) and 10 CFR 50.55a(g)(4),

10 CFR approval of their containment inservice inspection programs which were developed to satisfy the requirements of Subsection IWE and Subsection IWL with specified conditions. The program elements and required documentation must be maintained on site

ISI NDE Program Revision 14 Change 0 Part F Page 5

1.6. Exemptions Certain components (or parts of components) and the associated supports are exempt from the examination requirements of ASME Section XI, Table IWE-2500-1 per provisions contained in the Code. This section lists those "Code Allowed Exemptions" as applicable to this CISI Program Plan.

Exemption EX-F1-1 ASME Section XI Code Paragraph: IWE-1220(a) through (d)

The following components (or parts of components) are exempted from the examination requirements of IWE-2500:

(a) vessels, parts, and appurtenances outside the boundaries of the containment system as defined in the Design Specification (b) embedded or inaccessible portions of containment vessels, parts, and appurtenances that met the requirements of the original Construction Code (c) portions of containment vessels, parts, and appurtenances that become embedded or inaccessible as a result of vessel repair/replacement activities if the conditions of IWE-1232(a) and (b) and IWE-5220 are met (d) piping, pumps, and valves that are part of the containment system, or which penetrate or are attached to containment vessel. These components shall be examined in accordance with the requirements of IWB or IWC, as appropriate to the classification defined by the Design Specification.

ISI NDE Program Revision 14 Change 0 Part F Page 6

2.0 REFERENCES

2.1. ISI Drawings:

2.1.1. ASME Section XI Code Classification Drawings:

ISI Drawing System Description Number No.

6M721-5808 N/A Legend and Symbols 6M721-5808-1 B21 Nuclear Boiler 6M721-5808-2 B21 Nuclear Boiler 6M721-5809 B31 Nuclear Boiler Reactor Recirculation 6M721-5810-1 C11 Control Rod Drive 6M721-5810-2 C11 CRD Scram Discharge Volume 6M721-5811 C41 Standby Liquid Control 6M721-5812 C51 Traversing In-Core Probe 6M721-5813-1 E11-1 Residual Heat Removal Division II 6M721-5813-2 E11-2 Residual Heat Removal Division I 6M721-5814 E21 Core Spray 6M721-5815 E41 High Pressure Coolant Injection 6M721-5816 E51 Reactor Core Isolation Cooling 6M721-5817 G11 Sump Pump System 6M721-5818 G33 Reactor Water Clean Up 6M721-5820 G51 Torus Water Management 6M721-5821 N21 Feedwater 6M721-5823 P11 Demineralized Service Water Risers 6M721-5824 P34 Post Accident Sampling 6M721-5825-1 P44-1 Closed & Emergency Equipment Cooling Water 6M721-5825-2 P44-2 Closed & Emergency Equipment Cooling Water 6M721-5826-1 P50 Station Air 6M721-5829 T46 Stand By Gas Treatment 6M721-5830-1 T48 Nitrogen Inerting 6M721-5830-2 T48 Hydrogen Recombiner 6M721-5831 T50 Primary Containment Monitoring 6M721-5856 T49 Primary Containment Pneumatic Supply

ISI NDE Program Revision 14 Change 0 Part F Page 7

2.1.2. IWE Inspection Drawings:

ISI Drawing Description Number 6C721-2304 Primary Containment Penetration Drywell 6C721-2305 Containment Vessel 6C721-2971 IWE Containment Inspection Drywell Reference Drawing 6C721-2972 IWE Containment Inspection Suppression Chamber Ref.

Dwg.

2.1.3. Chicago Bridge & Iron - ISI Drawings / Sketches / Marked Up Prints:

CBI Drawing No. Title CBI Drawing No. Title

/ DTE Energy No. / DTE Energy No.

C-2701 General Plan C-2700 / Anchor Bolt Plan B2-50 P1 Rev. 3 Paint Detail 002 Rev. 8 / Shell Stretch out B2-105 3 Rev. 2 / Penetration Schedule 4 Rev. 2 / Penetration Schedule B2-191 Orientation Above Equator B2-192 Orientation Below Equator 5 Rev. 2 / Penetration Schedule 6 Rev. 6 / S.C. Penetration B2-193 Orientation in Drywell B2-154 Schedule and Orientation Cylinder 9 Rev. 0 / Drywell Basic Curve 11 Rev. 0 / Drywell Cylindrical Shell B2-61 B2-79 12 Rev. 0 / Bracing for 33-B 13 Rev. 3 /

B2-222 B2-51 14 Rev. 5 / Details of Drywell Top Head 15 Rev. 4 / Drywell Vent Insert B2-104 and Lifting Lugs B2-52 Assembly 16 Rev. 3 / Drywell Vent Jet Deflector 17 Rev. 3 / Nameplate Assy.

B2-59 B2-185 18 Rev. 4 / Top Flange Plates 19 Rev. 5 / Top Flange Plates B2-63 B2-64 20 Rev. 0 / Top Flange Plates 21 Rev. 1 / Top Flange Plates B2-65 B2-66 22 Rev. 6 / Top Flange Plates 23 Rev. 4 / Drywell Erection Skirt B2-67 B2-75 24 Rev. 6 / CRD Removal Hatch 25 Rev. 3 / Upper Beam Seats B2-201 Penetration X-6 B2-94 25-A Rev. 1 Modification for Upper 26 Rev. 1 / Lower Beam Seats Beam Seats B2-95 27 Rev. 2 / Beam Seat Orientation 28 Rev. 5 / Male Stabilizer B2-96 B2-163 Assemblies 29 Rev. 4 / 30 Rev. 2 / Bracing for (33-A)

B2-164 B2-220 ISI NDE Program Revision 14 Change 0 Part F Page 8

CBI Drawing No. Title CBI Drawing No. Title

/ DTE Energy No. / DTE Energy No.

31 Rev. 4 / Drywell Spray Headers 32 Rev. 3/B2-167 Drywell Spray Headers B2-166 33 Rev. 4 / Drywell Spray Headers and 34 Rev. 1 / Drywell Weld Pads B2-168 Support Plates B2-103 35 Rev. 5 / Drywell Control Rod Insert 36 Rev. 1 / Drywell Control Rod B2-100 B2-101 Insert Detail 37 Rev. 1 / Shield Wall Sleeves for CRD 38 Rev. 1 / ,

B2-194 Penetrations B2-122 Penetration 39 Rev. 8 / Drywell Penetration Details 40 Rev. 6 / Single Electrical B2-107 B2-108 Penetrations 41 Rev. 6 / Single Electrical Penetrations 42 Rev. 5 / Drywell Penetrations B2-109 B2-98 (X-102A, X-104A, X-106A) 43 Rev. 5 / Electrical Drywell 44 Rev. 6 / Drywell Penetrations B2-99 Penetrations B2-110 (X-100F, X-103B, X-106B) 45 Rev. 7 / Drywell Penetrations 46 Rev. 5 / Drywell Penetrations B2-119 B2-128 (X-13A, X-45) 47 Rev. 5 / Drywell Penetrations (X-20, 48 Rev. 5 / Drywell Penetrations B2-120 X-21, & X-22) B2-123 (X-12, X-13B)

49 Rev. 5 / Drywell Penetrations (X-18, 50 Rev. 3 / Drywell Penetrations B2-129 X-23, X-24, X-34A&B, X- B2-130 (X-43, X-44, X-31A&B, 33A&B) X-51, X-53) 51 Rev. 5 / Drywell Penetrations (X-19 52 Rev. 9 / Drywell Penetrations B2-131 & X-32B) B2-132 (X-14, X-15, X-16A, X-16B, X-17, X-36, & X-42) 53 Rev. 6 / Drywell Penetrations 54 Rev. 9 / Drywell Penetrations B2-133 B2-162 (X-41, X-39A, X-39B) 55 Rev. 3 / Drywell Penetrations (X- 56 Rev. 4 / Drywell Penetrations B2-150 28A, X-28C, X-28E, X-28F, B2-151 (X-47, X-48, X-29A, &

X-28G) X-29B) 57 Rev. 3 / Drywell Penetrations 58 Rev. 1 / Drywell Penetrations B2-152 (X-40C, X-40D, X-28B&D, B2-153 (X-40 A&B, X-46A, X-X-52, X-46B) 49, X-50) 59 Rev. 7 / -0 I.D. Equip. Door 60 Rev. 2 /

B2-160 B2-161 61 Rev. 1 / Drywell Penetrations 62 Rev. 2 / Drywell Penetrations B2-155 (X-30A&B, X-32A) B2-199 (X-35A thru G) 63 Rev. 2 / -0 Dia. Equip. Door 64 Rev. 8 / -0 I.D. Equip. Door B2-217 Handling Device B2-214 ISI NDE Program Revision 14 Change 0 Part F Page 9

CBI Drawing No. Title CBI Drawing No. Title

/ DTE Energy No. / DTE Energy No.

65 Rev. 3 / Equipment Door Details 66 Rev. 2 / -0 Dia. Equip. Door B2-215 B2-218 Handling Device 67 Rev. 4 / Drywell Penetration X-105A 68 Rev. 4 / Penetration Sleeve Dims.

B2-219 B2-253 & End Prep. Details 69 Rev. 0 / Drywell Shear Bars & Uplift 70 Rev. 3 / Suppression Chamber B2-254 Straps B2-261 Thermocouple Pads 71 Rev. 2 / Thermocouple Pads 72 Rev. 3 / Bottom Head Repair B2-262 Drywell & Refueling Skirt B2-260 Plate 73 Rev. 6 / 74 Rev. 0 / Drywell Cylindrical B2-265 Electrical Penets. B2-280 Penets. (X-54A&B & X-55A&B) 75 Rev. 0 / Drywell Weld Pads 76 Rev. 1 / Radiation Shielding for B2-282 B2-283 Electrical Penetrations 77 Rev. 3 / Drywell Duct Hanger Weld 78 Rev. 2 / Drywell Duct Hanger B2-286 Pads Above Knuckle B2-287 Weld Pads in Sphere 79 Rev. 1 / 80 Rev. 0 / Shield Wall Sleeve B2-292 B2-293 Penetrations 100 Rev. 2 / - 150 Rev. 4 / Lock Structural B2-169 -5uM?ijfee?cIfZb B2-170 Personnel Lock 151 Rev. 2 / - 

B2-171   -/uM?ijfee?cIfZb 153 Rev. 4 / -- 154 Rev. 1 / --

B2-173 Structural Details B2-174 Lock Interior Door Details 155 Rev. 1 / -- 156 Rev. 2 / Personnel Lock Misc.

B2-175 Exterior Door Details B2-176 Details 157 Rev. 1 / -- 158 Rev. 1 / Personnel Lock Interior B2-177 B2-198 Door Tie-Down For Lock Pressure Test

159 Rev. 0 / Valve & Latching Limit  -

B2-178 Switch Locations L.H. Door  -



162 Rev. 2 / Air Lock Nameplate 164 Rev. 0 / Interior Door B2-180 Assembly B2-284 Modification Personnel Lock 165 Rev. 1 / Field Installation of Purge 202 Rev. 2 / Suppression Chamber B2-289 Penetrations in Personnel B2-53 Support Girder & Vent Lock Header Support 200 Rev. 0 / Suppression Chamber Gen. 201 Rev. 1 / Suppression Chamber C-2702/B2-68 Arrange C-2703/B2-62 Shell 203 Rev. 2 / Suppression Chamber 204 Rev. 1 Suppression Chamber B2-54 Support Girder & Header C-2704/B2-55 Columns ISI NDE Program Revision 14 Change 0 Part F Page 10

CBI Drawing No. Title CBI Drawing No. Title

/ DTE Energy No. / DTE Energy No.

205 Rev. 3 / Suppression Chamber 206 Rev. 7 /

C-2705/B2-56 Columns B2-97 Bellows for Vent Lines 207 Rev. 5 / Earthquake Ties 208 Rev. 6 / Suppression Chamber B2-60 B2-80 Internal Spray Header Assembly 209 Rev. 3 / Suppression Chamber Vent 210 Rev. 1 / Vent Header Intersection B2-57 Header & Downcomers B2-76 Assemblies 211 Rev. 1 / Vent Header Intersection 212 Rev. 2 / Suppression Vent Line B2-77 B2-69 213 Rev. 5/ Vent Line Assembly 214 Rev. 2 / Suppression Chamber B2-111 B2-149 Monorail 215 Rev. 1 / Vent Line Relief Line Insert 216 Rev. 1 / Penetration Weld Details B2-134 Assemblies B2-296 for Field 217 2 / S.C. Platform Support Sys. 218 Rev. 1 /

B2-187 B2-188 C 219 Rev. 1 / S.C. Platform Sys. 220 Rev. 2 / S.C. Platform Handrails B2-189 B2-190 221 Rev. 3 / Supp. Chamber Penets (X- 222 Rev. 1 / Access B2-156 200A&B) B2-157 Hatch 223 Rev. 1 / Suppression Chamber 224 Rev. 5 / Suppression Chamber B2-121 Penetrations (X-210A&B, & B2-124 Penets (X-204A-H&J-M, X-227A&B) X-206A-D, X-209A-D, X-229, X-205A-D, & X-213A&B) 225 Rev. 3 / Suppression Chamber 226 Rev. 2 / Suppression Chamber B2-158 Penetrations (X-212 & X- B2-125 Penets. (X-214, X-215, 220) X-216A&B, X-217, X-218, X-219) 227 Rev. 3 / Suppression Chamber Penets 228 Rev. 3 / Strainers B2-159 (X-224A&B, X-226, X- B2-165 223A-D, & X-225) 229 Rev. 3 / Relief Blowdown Pipes 230 Rev. 1 / Supp. Chamber Penets.

B2-135 B2-136 (X-222, X-228A-D, & X-221) 231 Rev. 1 / Suppression Chamber 232 Rev. 1 / Suppression Chamber B2-181 External Platform B2-182 External Platform Handrail & Weld Pads 233 Rev. 1 / Suppression Chamber 234 Rev. 1 / Ladder Access B2-183 External Platform Ladders B2-264 Manway to Interior Platform Suppression Chamber 235 Rev. 1 / Anchorage for Single 236 Rev. 1 / Details for Anchorage for B2-312 Blowdown Line B2-313 Single Blowdown Line 237 Rev. 1 / Anchorage for Double 238 Rev. 1 / Detail for Anchorage for B2-314 Blowdown Line B2-315 Double Blowdown Line ISI NDE Program Revision 14 Change 0 Part F Page 11

CBI Drawing No. Title CBI Drawing No. Title

/ DTE Energy No. / DTE Energy No.

239 Rev. 1 / Relief Blowdown Pipes @ 240 Rev. 1 / Relief Blowdown Pipes B2-316 AZ 67-- B2-317 @ AZ 157-337-241 Rev. 1 / Elbow Assembles for 242 Rev. 1 / Jet Deflector Reinforcing B2-318 Blowdown Lines B2-323 Pads 243 Rev. 1 / Relief Blowdown Pipes and 244 Rev. 1 / Relief Blowdown Pipes B2-324 Vent Line Insert Assemblies B2-325 @ AZ. 22 292 245 Rev. 1 / Anchorage for Single 246 Rev. 0 / Details for Anchorage for B2-326 Blowdown Line B2-327 Single Blowdown Line

2.2. Reference Documents:

2.2.1. ASME Boiler and Pressure Vessel Code,Section XI, Division 1, 2013 Edition.

2.2.2. ASME Section XI Code Cases as discussed in Section 1.4.

2.2.3. United States Federal Register, Volume 82, Number 136, Nuclear Regulatory Commission, Final Rule, 10 CFR Part 50, published July 18, 2017, effective August 17, 2017.

2.2.4. United States Federal Register Volume 83, Number 12, Nuclear Regulatory Commission, Final Rule, 10 CFR Part 50, published January 18, 2018, effective January 18, 2018.

2.2.5. United States Federal Register Volume 83, Number 11, Nuclear Regulatory Commission, Final Rule, 10 CFR Part 50, published January 17, 2018, effective February 17, 2018.

2.2.6. Root Cause Evaluation Report: CARD 20-Condition of the

3.0 DEFINITIONS

3.1. Abnormal Degradation:

A condition that has (1) exceeded the Acceptance Criteria defined in the inspection /

examination procedure, (2) affects the structural integrity and/or leak tightness of the containment vessel, and (3) has been determined by engineering evaluation to be abnormal.

3.2. Accessible Areas:

The definitions of accessible areas (and conversely inaccessible areas), as implemented in this CISI Program Plan, are dependent upon the type of examination being performed.

ISI NDE Program Revision 14 Change 0 Part F Page 12

During the conduct of the general visual examination (IWE-3510) of the containment system, accessible areas are those surface areas that can be readily seen by direct line of sight from available viewing angles from floors, platforms, walkways, ladders or other permanent vantage points, as discussed in IWE-2310(c). The establishment of the line of sight may include measures such as laying on the floor or platforms as necessary to see around or under permanent plant structures, equipment and components; and may include the use of remote visual examination aids such as a set of binoculars or long focus lens cameras.

3.3. Augmented Examination: All examinations which are not required by ASME Section XI, except as identified in 3.3.1 & 3.3.2 below:

3.3.1. Fabrication and installation NDE performed in accordance with Design Specification or Construction Code requirements are not augmented NDE.

3.3.2. Leak rate testing required by 10 CFR 50, Appendix J, is not augmented NDE.

3.4. Augmented CISI (IWE) Examinations: Augmented examinations performed on Containment System; components, and structures subject to accelerated degradation and aging which are required by ASME Section XI, as a result of the requirements shown in Table IWE-2500-1 for items in Category E-C (See Paragraphs IWE-1240 and IWE-3520).

3.5. Coating Inspection Program: Detroit Edison committed to the NRC on the containment structure as accepted in NUREG-0798 (SSER No. 5) and in accordance with NRC Generic Letter 98-04. Fermi 2 has committed to visually inspect segments of the containment pressure boundary during refuel outages to determine onset of corrosion, blistering or peeling, and coating discoloration of the drywell and torus. The extent of theses inspections will be commensurate with the number of affected areas found.

Suspect areas will be cleaned, surface prepared, and new coatings will be applied. A detail of containment coating is included in Appendix F4.6.

3.6. Components

Denotes items such as vessels, pumps, valves and piping systems.

3.7. Component Supports: A metal support designed to transmit loads from a component to the load carrying building or foundation structure. Component supports include piping supports and encompass those structural elements relied upon to either support the weight or provide structural stability to components.

3.8. Containment Inservice Inspection (CISI): Examinations of containment structures and components as required by ASME Section XI and 10 CFR 50.55a during the service lifetime of Fermi 2.

3.9. Engineering Evaluation: An evaluation of indications that exceed allowable acceptance standards to determine if the margin required by the Design Specification and Construction Code are maintained.

3.10. Evaluation: The process of determining the significance of examination and test results, ISI NDE Program Revision 14 Change 0 Part F Page 13

including the comparison of examination or test results with applicable acceptance criteria or previous results.

3.11. Examination: Denotes the performance of all visual observations and nondestructive examination by personnel qualified / certified in accordance with ANSI/ASNT CP-189.

3.12. Examination Category: A grouping of items to be examined or tested.

3.13. Examination Plan: A schedule of CISI examinations required to be performed during a particular period of time.

3.14. General Corrosion: An approximately uniform wastage of a surface of a component, through chemical or electrochemical action, free of deep pits or cracks.

3.15. Inaccessible Surface Areas: This term applies to surface areas that are embedded or otherwise obstructed from direct visual examination. Inaccessible Surface Areas are discussed in IWE-1232. Examples of surface areas that are considered inaccessible are listed below:

a) Surface areas that are permanently embedded in concrete.

b) Surface areas covered by insulation that is permanently sealed by design to prevent the intrusion of moisture.

c) Surface areas sealed by a moisture barrier that is designed to prevent intrusion of moisture.

d) Access, for the examination personnel and equipment to conduct the direct visual examination of the surface area, is permanently obstructed.

e) Access to the surface areas would require removal of existing plant equipment or structure and the original design did NOT provide sufficient space for the removal and storage of the equipment or structure.

f) Access to the surface areas would require removal of existing plant equipment or structure and the original design did NOT provide a permanently installed handling machinery (e.g., hoists) to facilitate removal, disassembly, and storage.

3.16. Inservice Inspection (ISI): Methods and actions for assuring the structural and pressure-retaining integrity of safety-related nuclear power plant components in accordance with the rules of ASME Section XI.

3.17. Inspection Interval: Normally it is the 10 years following placement of the power unit into initial commercial service and each subsequent 10 years thereafter. In accordance with 10 CFR 50, the inspection interval is 10 years following the date selected to begin the interval.

3.18. Inspection Period: A duration of time within an inspection interval, approximately 40 months long, (i.e., 1st Period, 0-3 years; 2nd Period, 4-7 years; 3rd Period, 8-10 years).

ISI NDE Program Revision 14 Change 0 Part F Page 14

Inspection periods are applicable to IWE requirements.

3.19. : The Containment Inservice Inspection Program Conduct Manual is implemented to obtain data utilizing NDE performed on ASME Section XI Code Class MC equivalent components to determine acceptance of components for continued service and the generic nature of defects found, if any.

3.20. Nondestructive Examination (NDE): An examination by the visual, surface, or volumetric method.

3.21. Normal Operation Conditions: Normal plant operation conditions include reactor startup, operation at power, hot standby, and reactor cool down to cold shutdown conditions. Test conditions are excluded.

3.22. Notification of Indication (NOI): A form used in conjunction with a CARD to report any discrepant conditions found during the performance of ASME Section XI NDE. This form shall be used together with a CARD for CISI examinations.

3.23. Preservice Inspection (PSI): Examinations of containment structures and components as required by ASME Section XI to be completed prior to initial plant startup, or inspections required by ASME Section XI if a component is replaced, added, repaired, or altered during the service lifetime of a power plant.

3.24. Relevant Condition: A condition observed during a visual examination that requires supplemental examination, corrective measure, correction by repair/replacement activities, or analytical evaluation.

4.0 APPENDICES

F4.1. ASME Class MC Components Subject To Examination

F4.2. ASME Class MC Examination Schedule

F4.3. ASME Class MC Classification Basis

F4.4. Requests For Relief

F4.5. Augmented Examinations

F4.6. Containment Coatings

ISI NDE Program Revision 14 Change 0 Part F Page 15

APPENDIX F4.1 ASME CLASS MC COMPONENTS SUBJECT TO EXAMINATION

The ASME Code Class MC components to be examined during the inspection interval are outlined below. Class MC components are identified on the ASME Code Classification drawings of 2.1.

Appendix F4.3 documents the basis for the classification of these components. The examinations apply to surface areas, including welds and base metal.

1.1 Examination Category E-A, Containment Surfaces A. Accessible surface areas General Visual (E-A, E1.11)

The examination boundary includes the steel containment vessel (drywell and torus) including reinforcing structures (stiffening rings, manhole frames, and reinforcement around openings) and their attachment welds. Penetration nozzles (and reinforcement) and associated bellows assembly are also included, as applicable. Surface areas that are submerged or insulated are not included in the examination boundary.

Examination shall include the attachment welds between structural attachments and the pressure retaining boundary or reinforcing structure, except for nonstructural and temporary attachments as defined in NE-4435. Examination shall include the weld metal and base metal for 1/2 inch and beyond the edge of the weld.

Examination shall include surfaces of containment structural and pressure boundary welds, including longitudinal welds (Category A), circumferential welds (Category B), flange welds (Category C), and nozzle-to shell welds (Category D) as defined in NE-3351 for Class MC; and surfaces of Flued Head and Bellows Seal Circumferential Welds joined to the penetration.

The examination shall also include pressure-retaining bolted connections, including bolts, studs, nuts, bushings, washers, and threads in base material and flange ligaments between fastener holes. Bolted connections need not be disassembled for performance of examinations, and bolting may remain in place under tension.

Examination shall include all accessible interior and exterior surfaces of Class MC components, parts, and appurtenances. The examination must be performed once each period per Table IWE-2500-1, Category E-A.

Examinations are performed in accordance with Fermi 2 procedures MES46 and ISI NDE Program Revision 14 Change 0 Part F Page 16

B. Wetted Surfaces of Submerged areas Visual, VT-3 (E-A, E1.12)

The examination boundary is the same as that described in Section 1.1A, except that the examination is limited to portions of primary containment surface areas which are wetted or submerged. The examination may be performed at any time during the interval, provided successive examinations are performed no less frequently than every third period.

C. Vent System accessible surface areas Visual, VT-3 (E-A, E1.20 and E-C, E4.11)

The examination boundary includes the vent piping between the drywell and torus including the flow channeling devices in the torus (e.g., 80 downcomers).

Examination shall include all accessible interior and exterior surfaces. When the Vent System is categorized as E-A, E1.20, the examination may be performed at any time during the interval, provided successive examinations are performed no less frequently than every third period. However, in RF20, the Vent System (i.e.,

the interior lower region of the Torus Vent Header and the downcomers #5, #9,

1. 29, #38, #40, #79, and #80) have been re-categorized as Examination Category E-C based on IWE-1241- Examination Surface Areas. The containment surface areas in the Torus Vent Header (e.g., interior vent header lower region intersection assemblies and ck in the interior main runs) and in the lower interior region of the specific downcomers, are subjected to standing water, repeated wetting and drying, and/or mechanical damage, that has resulted in loss of protective coatings. In the torus vent header this has led to substantial corrosion and pitting (i.e., in the vent header interior), as identified in RF20.

Weld repairs to restore thickness at local thinned areas were required during RF20. Therefore, examination of 100% of surface areas identified by IWE-1241 for augmented examination, are required to be examined during each inspection period.

The interior of the torus vent header, specifically the interior vent header clock, and the interior lower region of the specific downcomers, have been reclassified as requiring augmented examinations in RF21. The exterior of the torus vent header and the interior of the torus vent lines, and the exterior and the interior of the remaining downcomers all remain Examination Category, E-A, E1.20.

D. Moisture Barriers - General Visual (E-A, E1.30)

Examination shall include moisture barrier materials intended to prevent intrusion of moisture against inaccessible areas of the pressure retaining metal containment shell or liner at concrete-to-metal interfaces and at metal-to-metal interfaces which are not seal-welded. Containment moisture barrier materials include caulking, flashing, and other sealants used for this application.

ISI NDE Program Revision 14 Change 0 Part F Page 17

E. Visual Examination of Coatings Preservice and inservice visual examination of coatings shall be performed in accordance with IWE-2600(a).

1.3 Examination Category E-C, Containment Surfaces Requiring Augmented Examination

A. Visible Surfaces Visual, VT-1 (E-C, E4.11)

Per IWE-2500(b)(1), surface areas requiring augmented examination that are accessible for visual examination shall be visually examined using a VT-1 visual examination method using the following IWE-1241 criteria:

1. Interior and exterior containment surface areas that are subject to accelerated corrosion with minimal or no corrosion allowance or areas where the absence or repeated loss of protective coatings has resulted in substantial corrosion and pitting. Typical locations of such areas are those exposed to standing water, repeated wetting and drying, persistent leakage, and those with geometries that permit water accumulation, condensation, and microbiological attack. Such areas may include penetration sleeves, surfaces wetted during refueling, concrete-to-steel shell or liner surfaces, embedment zones, leak chase channels, drain areas, or sump liners.

Based on the degraded conditions identified in the interior lower region of the Torus Vent Header in RF20 (e.g., interior vent line intersection assemblies and interior main runs ), such as, failing/missing coating and corrosion of the metal structure (e.g., general corrosion and pitting), and meeting the criteria in IWE-1241, the interior Torus Vent Header lower region has been reclassified as Examination Category (E-C),

examination method is a VT-1, with contingent supplemental UT (Ultrasonic Testing) and physical measurements (e.g., pit depth) as required, per IWE-3200.

In addition, based on the degraded coating conditions (e.g., peeling coating, mechanical damage of coating, and spot corrosion) that was identified in the interior lower region of the downcomers (i.e, #5, #9, #29, #38, #40, #79, and

1. 80) in RF20, the remediation for removing degraded coatings that was performed, and the UT data measurements being above the minimum wall thickness for spot corrosion, the interior of these specific downcomers have been reclassified as Examination Category (E-require augmented examinations in RF22.

ISI NDE Program Revision 14 Change 0 Part F Page 18

2. Interior and exterior containment surface areas that are subject to excessive wear from abrasion or erosion that causes a loss of protective coatings, deformation, or material loss. Typical locations of such areas are those subject to substantial traffic, sliding pads or supports, pins or clevises, shear lugs, seismic restraints, surfaces exposed to water jets, and areas that experience wear from frequent vibrations.

3. Interior and exterior containment surface areas identified in accordance with IWE-2420(b).

B. Surface Area Grid, Minimum Wall Thickness Location - Volumetric (E-C, E4.12)

Surface areas subject to Category E-C, Item No. E4.12 are those that are not accessible for visual examination from the side requiring augmented examination per IWE-2500(b)(2), (3), and (4). The IWE-1241 criteria noted in Section 1.3.A. are also applicable to these areas.

Refer to MES46 and Appendix F4.2 of this Program Plan for the areas identified for augmented examination in accordance with IWE-1240 and IWE-2500.

1.4 Examination Category E-G, Pressure Retaining Bolting (E-G, E8.10)

All pressure retaining bolting shall be examined using the VT-1 visual examination method. Examination shall include bolts, studs, nuts, bushings, washers, and thread in base material and flange ligaments between fastener holes.

The examination may be performed with the connections assembled and bolting in place under tension, provided the connection is not disassembled during the interval.

If the bolted connection is disassembled for any reason during the interval, the examination shall be performed with the connection disassembled.

ISI NDE Program Revision 14 Change 0 Part F Page 23

APPENDIX F4.3 ASME CLASS MC CLASSIFICATION BASIS

1.0 Purpose

The purpose of this appendix is to document the basis for classification of the components subject to examination and components exempted from examination in accordance with the requirements of ASME Subsection IWE.

10CFR50.55a was revised effective September 9, 1996 to incorporate by reference Class MC, metal containment, and Class CC, concrete containment, components. Class CC is not applicable for Fermi 2, as there are no pressure retaining concrete structures or components within the Fermi 2 containment design. The Class MC boundaries include the Steel Containment Vessel (SCV), which is comprised of the drywell, pressure suppression chamber or torus, and associated vent piping, including vertical and circumferential structural stiffeners; penetrations, reinforcement structure, the portion of the SCV embedded in the drywell concrete floor slab, and attachment welds between structural attachments and the SCV pressure retaining boundary or reinforcing structure.

ASME Section XI, 2013 Edition, IWE-1220(d), requires piping, pumps, and valves that are part of the containment system, or penetrate containment, to be examined in accordance with the rules of IWB (Class 1) or IWC (Class 2), as appropriate to the classification defined by the Design Specification. Piping contained within spare penetrations is considered within the Class MC boundary.

For RF-07 a set of marked-up drawings (prints) was used to identify components and systems to be examined. Following RF-07, a set of CISI drawings was prepared for CISI Program purposes. The Class MC boundaries will be highlighted on the set of CISI prints.

A list of drawings is included in Section 2.

2.0 Class MC Equivalent Components and Examination Boundaries:

As defined in IWE-1210, the examination requirements of Subsection IWE apply to Class MC pressure retaining components and their integral attachments. This section provides the basis for defining the examination boundaries of those components subject to examination. Note that some components or portions of components may be declared inaccessible in later sections or not examined in accordance with submitted Requests for Relief as documented in Appendix 4.4. The ISI drawings referenced in Section 2.1.1 provide the specific component boundaries subject to examination as based on this appendix. The examination requirements for these components are detailed in Appendix F4.1.

The following components, as described in MES46, comprise the Class MC boundaries.

A. Drywell and associated penetrations are shown on drawing 6C721-2971. The Class MC boundary includes the SCV and associated reinforcing structures (stiffening rings, manhole frames, and reinforcement around openings) and attachment welds between structural attachments and the SCV pressure retaining boundary or ISI NDE Program Revision 14 Change 0 Part F Page 24

reinforcing structure. The drywell head, equipment hatches, and personnel airlock are part of the Class MC boundary. Typical examples of Code Class boundaries between penetrations and process piping are shown in this Appendix. Penetration nozzles /

sleeves (and reinforcement), associated bellows assemblies, and flued head to sleeve (or bellows) welds are part of the Class MC boundary. Spare penetrations and any piping penetrating a spare penetration are part of the Class MC boundary. For electrical penetrations, the header plates which form the pressure retaining boundary and the seal weld to the penetration sleeve are Class MC. Flanges and bolting associated with penetrations are Class MC. In accordance with IWE-pumps, and valves that are part of the containment system, or which penetrate or are attached to the containment ves of IWE-examined in accordance with the requirements of IWB or are not inspected as Class MC, but Class 2 instead.

Process piping and welds between process piping and flued heads or penetration flanges are not Class MC.

B. Vent System, drawing 6C721-2972 Section A-A and CBI-213 (B2-111). The Class MC boundary includes the vent pipes extending from the drywell to the torus including the bellows assemblies, the connecting circular vent header in the torus airspace, and the 80 downcomer pipes connected to the vent header and extending into the pool. The Class MC boundary includes associated reinforcing structures (stiffening rings, manhole frames, and reinforcement around openings) and attachment welds between structural attachments and the vent system pressure retaining boundary or reinforcing structure.

The MSIV discharge pipes, which run inside the vent header pipes, are not Class MC.

The drywell to torus vacuum breaker valves are not Class MC.

C. Pressure Suppression Chamber (torus), drawing 6C721-2972. The Class MC boundary includes the SCV and associated reinforcing structures (stiffening rings, manhole frames, and reinforcement around openings) and attachment welds between structural attachments and the torus pressure retaining boundary or reinforcing structure; structural attachments which perform a pressure retaining function; and welds between non-structural attachments and the SCV. The two access hatches and associated bolting are Class MC. The Class MC boundary extends one-half inch down each ring girder support from its attachment weld to the SCV, and one-half inch out from the attachment weld of each torus snubber support.

ISI NDE Program Revision 14 Change 0 Part F Page 25

3.0

References:

The information provided in this Appendix was derived from the following sources.

A. Fermi 2 UFSAR Chapter 3.0 B. Fermi 2 Design Specification 3071-009 Design Criteria for the Primary Containment System C. Fermi 2 Design Specification 3071-516 for Primary and Secondary Containment Penetrations, Primary Containment Penetration Assemblies.

CONTAINMENT BOUNDARY FIGURES

The following figures show the IWE containment boundary for the various types of containment penetrations in Fermi 2. Note that in accordance with ASME Section XI, 2013 Edition, Table IWE-2500-1, Examination Category E-A, Footnote 1, general visual examinations shall include all accessible interior and exterior surfaces of Class MC components, parts and appurtenances.

This applies to all the figures.

= IWE Boundary Containment Shell Cover Plate

Biological Shield Nozzle Bellows Flued Head

Process Pipe

PRIMARY CONTAINMENT SYSTEM PROCESS LINE FLEXIBLE PENETRATION FIGURE F4.3-1 Enclosure to NRC-24-0050 Page 117 of 150 ISi NOE Program Revision 14 Change 0 Part F Page 26

- = IWE Boundary Process Pipe

~'.. --- *.. , ........ *

/ , 'Bio

/ ~ **-

Containment Shell

PRIMARY CONTAINMENT SYSTEM PROCESS LINE PENETRATION FIGURE F4.3-2 Enclosure to NRC-24-0050 Page 118 of 150 ISI N DE Program Revision 14 Change 0 Part F Page 27

_ / .. CONT AIN ME T

,_ = IWE B omdary . . SHELL

PROCESS PI PE BJOL GICAL SHIELD

- _- I I

IS LATf N V LVE

PR IM ARY CONTAINMENT SYSTEM N N- RCP B PROCESS LINE PENE T RATI N FIGURE F4.3-3

= IWE Boundary Pipe Sleeve Concentric Seal Rin s

-7

Flange

TYPICAL PRIMARY CONTAINMENT SYSTEM ELECTRICAL PENETRATION FIGURE F4.3-4 ISI NDE Program Revision 14 Change 0 Part F Page 28

= IWE Boundary Steel Containment

Seal Hatch Frame

Exterior Door

Detail A Interior Door

PRIMARY CONTAINMENT Detail A

PERSONNEL HATCH FIGURE F4.3-5

ISI NDE Program Revision 14 Change 0 Part F Page 29

Containment Shell = IWE Boundary

Hatch Cover Hatch Sleeve

PRIMARY CONTAINMENT EQUIPMENT HATCH FIGURE F4.3-6

Enclosure to NRC-24-0050 Page 121 of 150 ISI NDE Program Revision 14 Change 0 Part F Page 30

Process Pipe - = IWE Boundary

Cap

Containment Shell

TYPICAL SPARE PENETRATION FIGURE F4.3-7 Enclosure to NRC-24-0050 Page 122 of 150

!SI NDE Program Revision 14 Change 0 Part F Page 31

= IWE Boundary Process Pipe Reducer

Containment Shell

PENETRATION X-15 AND X-44 FIGURE F4.3-8 Enclosure to NRC-24-0050 Page 123 of 150 ISI NDE Program Revision 14 Change 0 Part F Page 32

= IWE Boundary Process Pipe Cap

Cap

FlatWOL

Containment Shell

PENETRATION X-45 FIGURE F4.3-9 ISI NDE Program Revision 14 Change 0 Part F Page 33

APPENDIX F4.4 RELIEF REQUESTS

There are no Relief Requests for this CISI Program Plan at this time. If Relief Requests are needed during the Third Ten-Year Interval they will be added to Part A, in Section 5.0.

ISI NDE Program Revision 14 Change 0 Part F Page 34 APPENDIX F4.5 AUGMENTED EXAMINATIONS

IWE-1241 provides the selection criteria for those areas requiring augmented

that are subject to accelerated corrosion with no or minimal allowance or areas where the absence or repeated loss of protective coatings has resulted in substantial corrosion and pitting.

Fermi 2 has re-categorized the interior lower region of the Torus Vent Header (e.g.,

as an Examination Category E-C, Containment Surfaces Requiring Augmented Examination, which is in accordance with IWE-1241, Examination Surface Areas. Based on the issues identified in RF20, the Vent System (lower interior Torus Vent Header) was re-categorized as Examination Category E-C. The lower interior areas of the Torus Vent Header were identified as being subjected to standing water, and repeated wetting and drying, which resulted in loss of protective coatings, that has led to substantial corrosion and pitting, as identified in RF20. Weld repairs to restore thickness at local thinned areas were required during RF20. Therefore, examination of 100% of surface areas identified by IWE-1241 for augmented examination, are required to be examined during each inspection period.

During RF21, augmented examinations were completed on the interior lower region of the Torus Vent Header. Based on these examinations, additional areas for repair were identified. The Torus Vent Header was repaired and recoated in RF21. Per IWE-2411

able Examination Category and Item Number for the added item shall be performed during each of the second and third

-2420(b) states that when examination results detect flaws, areas of degradation, or conditions that require an engineering evaluation the conditions shall be reexamined during the next inspection period. IWE-2420(d) states

degradation remain essentially unchanged for the next inspection period, these areas no longer required augmented examination in accordance with Table IWE-2500-1 (E-Therefore, although augmented examinations were completed in RF21, these are also required in the second and third inspection period of the 3rd 10-Year Interval for IWE, until areas of degradation remained unchanged.

In addition, based on the degraded coating conditions (e.g., peeling coating, mechanical damage of coating, and spot corrosion) that was identified in the interior lower region of the downcomers (i.e., #5, #9, #29, #38, #40, #79, and #80) in RF20, and the remediation for removing degraded coatings that was performed, and the UT data measurements being above the minimum wall thickness for spot corrosion, the interior of these specific downcomers have been reclassified as Examination Category (E-C),

conservatism, and will require augmented examinations in RF22. During RF21, limited ISI NDE Program Revision 14 Change 0 Part F Page 35 augmented examinations were completed on the downcomers previously identified above, due to inaccessibility and inability to get the VT-1 distance requirements at the location due to the waterline. Additionally, during RF21 loose coatings were removed at these locations. Per IWE-

Examination Category and Item Number for the added item shall be performed during each of t-2420(b) states

inspection period. IWE-reveal that the flaws or areas of degradation remain essentially unchanged for the next inspection period, these areas no longer required augmented examination in accordance with Table IWE-2500-1 (E-were completed in RF21, these are also required in the second and third inspection period of the 3rd 10-Year Interval for IWE, until areas of degradation remained unchanged.

Additionally, for Inspection the IWE program requires that the drywell shell thickness in the sand cushion region be determined before the period of extended operation and once in each ten year interval during the period of extended operations. Therefore, NDE were performed in RF20 (2020) and in RF18 (2017). All measured thicknesses specified on CB&I Drawing C-2701 (General Plan). UT readings started at 120°

Two readings were taken The

elevation between 120° Azimuth and 195° Azimuth, and the minimum measured reading This is not currently classified as an area subject to augmented examinations.

Historically since RF-01, Fermi 2 has monitored the blister condition on specific immersed areas of the Torus. Those areas were chosen based on their relatively high number of indications when compared to the rest of the immersed area. During each inspection time frame, every other refuel, the size, population density and condition of the blisters are monitored. A significant growth or number of blisters could indicate impending general coating failure. From RF-04 to RF-19 an increase in the total number blisters was noted in each evaluation area, however there has been no significant change in the blister size.

boundary invert in a continuous band paralleling either side of the mitigation beam and approximately up twelve (12) f mechanical damage exhibiting corrosion on the pressure boundary immersion area are repaired. In RF19, a total collective surface area of approximately nine hundred thirty-four square inches (934 in2). An a total surface area of this repair is two-thousand-three-hundred-four square inches (2,304 ISI NDE Program Revision 14 Change 0 Part F Page 36 in2). Then in RF20, the coating of the interior wetted region of the Torus was removed and recoated, as well as, the exterior of the downcomers. The interior wetted region of the Torus is not currently classified as an area subject to accelerated corrosion, thus does not require augmented examinations. This is due to the UT data that was collected during RF20, which documented no significant corrosion or wall loss of the interior wetted region of the Torus. Additionally, as discussed above, this area has been recoated. Fermi 2 performs examinations of the interior surface of the torus in the wetted and vapor region in accordance with ASME Section XI, Table IWE-2500-1 (E-A) Examination Category E-A, Containment Surfaces.

ISI NDE Program Revision 14 Change 0 Part F Page 37 APPENDIX F4.6 CONTAINMENT COATINGS

Design Specifications:

1. 3071-359: Design Specification for Field Painting Level 1 Steel and Concrete Coating Inside Drywell

2. 3071-360: Interior Protective Coating Suppression Chamber - Reactor Building ISINDEProgram Revision14 Change0 Enclosure1Page1

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