L-22-253, Submittal of Pressure and Temperature Limits Report, Revision 5

Submittal of Pressure and Temperature Limits Report, Revision 5

ML23010A153
Person / Time
Site:	Davis Besse
Issue date:	01/10/2023
From:	Tony Brown Energy Harbor Nuclear Corp
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-22-253
Download: ML23010A153 (1)

Text

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harbor Terry J. Brown Site Vice President, Davis-Besse Nuclear January 10, 2023 L-22-253 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Energy Harbor Nuclear Corp.

Davis-Besse Nuclear Power Station 5501 N State Route 2 Oak Harbor, 'Ohio 43449 419-321-7676 Submittal of Pressure and Temperature Limits Report, Revision 5 In accordance with Technical Specification 5.6.4, "Reactor Coolant System (RCS)

Pressure and Temperature Limits Report (PTLR)," Energy Harbor Nuclear Corp. hereby submits Revision 5 of the PTLR for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS). Revision 5, which was approved on November 30, 2022, and made effective on December 20, 2022, corrects errors identified in Revision 4 of the report. Minor editorial changes were made in Figure 1 and Section 2.0. Additionally, the table in Figure 2 incorrectly listed pressure data in the temperature data column; however, the associated graph was correct. This item is identified and tracked in the Corrective Action Program.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager - Fleet Licensing, at (330) 696-7208.

Enclosure:

Pressure and Temperature Limits Report for Up to 43.5 Effective Full Power Years, Revision 5 cc:

NRC Region Ill Administrator NRC Resident Inspector NRR Project Manager Utility Radiological Safety Board

Enclosure Pressure and Temperature Limits Report for Up to 43.5 Effective Full Power Years, Revision 5 L-22-253 (12 pages follow)

ENERGY HARBOR NUCLEAR OPERATING COMPANY DA VIS-BESSE UNIT 1 PRESSURE AND TEMPERATURE LIMITS REPORT FOR UP TO 43.5 EFFECTIVE FULL POWER YEARS Revision 5 Prepared by: - ~~

-'))\\;..;__ ______ Date: I I/ 3PllL John R. Marko Reviewed by: ~~

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Michael L. Nelson Date: II nohz.

Brian A. Kan~

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Approved by:

Cl 1---11 ~ate: ;, O Nov ;)._o)J_

Brian A. Kanney

43.5 EFPY PTLR Rev. 5 Page 2 of 12 EnergyHarbor Nuclear Operating Company Davis-Besse Unit 1 Pressure and Temperature Limits Report for up to 43.5 Effective Full Power Years 1.0 Introduction This Pressure and Temperature Limits Report (PTLR) provides the information required by Davis-Besse Nuclear Power Station (DBNPS) Technical Specification 5.6.4 to ensure that the Reactor Coolant System (RCS) pressure boundary is operated in accordance with its design. The limits provided are valid to 43.5 Effective Full Power Years (EFPY).

The PTLR provides the RCS Operating Limits in Section 2.0, which satisfies Technical Specification 5.6.4.a. The Analytical Methods used to develop the limits, including determination of the vessel neutron fluence, are provided in Section 3.0, fulfilling Technical Specification 5.6.4.b. The information and formatting of Section 3 follows the guidance of Attachment 1 to Generic Letter 96-03. The PTLR requirements are provided in Section 4.0 of the report, fulfilling Technical Specification 5.6.4.c.

Revision 0 was the initial issue of the 32 EFPY PTLR after issuance of License Amendment 282, which authorized use of new methodologies.

Revision 1 is re-issuing the 32 EFPY Pressure-Temperature limits to include the limits for the Reactor Vessel Closure Head (RVCH) installed in October 2011 Cycle 17 Mid-cycle Outage. The limits associated with the RVCH obtained from the Midland nuclear power plant have been removed. No methodology changes occurred in this revision.

Revision 2 is re-issuing the 32 EFPY Pressure-Temperature limits to incorporate Revision 4 of ANP-2718, Appendix G Pressure-Temperature Limits for 52 EFPY, Using ASME Code Cases for Davis-Besse Nuclear Power Station (Reference 5.7).

Revision 4 of ANP-2718 combined the Heatup/Cooldown Curves into a single Figure.

This results in the re-numbering of the In-Service Leak and Hydrostatic Tests Figure to Figure 2. No methodology changes occurred in this revision.

Revision 3 removes the restriction of exceeding the operating limit date of April 22, 2017 which was included in earlier revisions. This change is the result of the Nuclear Regulatory Commission issuing a renewed operating license to Davis-Besse which extends the period of operation to midnight April 22, 2037, which made 32 EFPY limiting. This change also corrects an administrative error that existed in the previous revision where Figure 2 was combined with Figure 1 and the original Figure 3 was designated as Figure 2, however Figure 3 was still referred to in the body of the document.

Revision 4 is the initial issue of the 43.5 EFPY PTLR. CR-2019-03982, Reactor Vessel 52 EFPY Projected Neutron Fluence (Exposure) Higher Than Previous Projections (Reference 5.17), identified that due to the reactor vessel (RV) fast neutron fluence accumulating faster than previously predicted, the RV would reach the analyzed fluence

43.5 EFPY PTLR Rev. 5 Page 3 of 12 sometime prior to 52 Effective Full Power Years (EFPY) of operation. Document 32-9300671-000, Davis-Besse Reactor Vessel Embrittlement Fluence Reconciliation Through 60 Years (Reference 5.16) and CR 2020-07840 Revised Vessel P-T Curves Limited to 43 EFPY (Reference 5.18), has determined that the most limiting part of the RV will reach the analyzed fluence at approximately 43.5 EFPY. Data is based on fluence projections of Fuel Cycles 18 and 19. No methodology changes occurred in this revision.

Revision 5 is re-issuing the 43.5 EFPY Pressure and Temperature Limits Report to remove two data points in Figure 1 (Heatup Limit) at 226 °F and to incorporate the correct temperature data table in Figure 2. Consistent use of units was incorporated into Section 2.0 RCS Pressure and Temperature Limits". No methodology changes occurred in this revision.

Revisions to the PTLR are to be submitted to the NRC after issuance.

2.0 RCS Pressure and Temperature Limits

a.

The Reactor Coolant System (except the pressurizer) temperature and pressure shall be limited in accordance with the limit lines and ramp rates shown on Figures 1, 2, 3 and 4 (Reference 5.7) during heatup, cooldown, criticality, and in-service leak and hydrostatic (ISLH) testing with:

1.

A maximum heatup of 50 °F in any one hour period, and

2.

A maximum cooldown of 100 °F in any one hour period with a cold leg temperature of > 270 °F and a maximum cooldown of 50 °F in any one hour period with a cold leg temperature of < 270 °F.

b.

During periods of low temperature operation (Tavg <280 °F), Technical Specification 3.4.12 (Reference 5.3) provides additional requirements for RCS pressure and temperature limits. Those limits are maintained in the Technical Specifications because they are not determined using methods generically approved by the NRC.

43.5 EFPY PTLR Rev. 5 Page 4 of 12 Figure 1: Reactor Coolant System Pressure-Temperature Heatup and Criticality Limits

43.5 EFPY PTLR Rev. 5 Page 5 of 12 Figure 2: Reactor Coolant System Pressure-Temperature Cooldown Limits

43.5 EFPY PTLR Rev. 5 Page 6 of 12 Figure 3: Reactor Coolant System Pressure-Temperature Heatup Limits for In-Service Leak and Hydrostatic Tests

43.5 EFPY PTLR Rev. 5 Page 7 of 12 Figure 4: Reactor Coolant System Pressure-Temperature Cooldown Limits for In-Service Leak and Hydrostatic Tests

43.5 EFPY PTLR Rev. 5 Page 8 of 12 3.0 Analytical Methods 3.1 The limits provided in Section 2 and Figures 1, 2, 3, and 4 are valid until the Reactor Vessel has accumulated 43.5 Effective Full Power Years (EFPY) of fast (E> 1 MeV) neutron fluence (Reference 5.16).

3.2 The neutron fluence is calculated (Reference 5.7) consistent with Regulatory Guide 1.190 using the NRC-approved methodology described in BAW-2241P-A (Reference 5.5). Table 1 provides the neutron fluence values used in the adjusted reference temperature calculations. The listed fluence values are based on 52 EFPY of operation.

3.3 The Davis-Besse Reactor Vessel Material Surveillance Program complies with the requirements of Appendix H to 10 CFR 50 and is described in BAW-1543A (Reference 5.6). This information was approved by the NRC in the SER of Amendment 199 (Reference 5.1). The specimen capsule withdrawal schedule is contained within the supplements of the topical report. All plant specific specimen capsules have been withdrawn from the reactor vessel. The ART values were not calculated using surveillance data (Reference 5.14) since it was determined to be non-credible.

3.4 Low Temperature Overpressure Protection (LTOP) limits are addressed in Section 2.b, above, and Technical Specification 3.4.12 (Reference 5.3).

Reference 5.7 discusses the methods used to determine the temperature at which LTOP must be active. The pressure limit was determined using ASME Section XI, Appendix G, as modified by the alternative rules provided in ASME Code Case N-588 and ASME Code Case N-640 (Reference 5.9).

3.5 Table 1 provides the Adjusted Reference Temperature (ART) for each reactor vessel beltline material. The ART values were calculated in accordance with Regulatory Guide 1.99, Revision 2. For welds in the reactor beltline region, the initial RTNDT values used (in part) to determine ART were calculated using an alternate methodology described in the NRC-approved BAW-2308, Revisions 1-A and 2-A (Reference 5.10). The NRC required licensees to obtain an exemption from 10 CFR 50.61 and 10 CFR 50, Appendix G to use the alternate initial RTNDT values provided in BAW-2308 Revisions 1-A and 2-A. The required exemption was granted by the NRC in Reference 5.15. The NRC confirmed the limits and conditions for using the methodology were satisfied in the SER of Amendment 282 (Reference 5.8).

3.6 The Pressure-Temperature (P/T) limits of Section 2 and Figures 1, 2, 3, and 4 (with applicability as stated in 3.1) were generated consistent with the requirements of 10 CFR 50 Appendix G and Regulatory Guide 1.99, Revision 2, using the methods described in BAW-10046A (Reference 5.4) and ASME Section XI, Appendix G (Reference 5.9), as modified by the alternative rules provided in ASME Code Case N-588 and ASME Code Case N-640.

43.5 EFPY PTLR Rev. 5 Page 9 of 12 3.6.1 The NRC has reviewed the methods described in BAW-10046A (Reference 5.4) and approved the topical report by issuance of a Safety Evaluation Report (SER) dated April 30, 1986. Section 1.2 of BAW-10046A states that it is applicable to all current B&W nuclear steam systems.

3.6.2 ASME Code Cases N-640 and N-588 have been incorporated into ASME Section XI, Appendix G, 2003 Addenda, which are the edition and addenda codified in 10 CFR 50.55a (effective May 27, 2008) and thus may be used per NRC Regulatory Issue Summary (RIS) 2004-04. Specific approval for application at DBNPS is included in Ref. 5.8.

3.7 The minimum temperature requirements of 10 CFR 50, Appendix G are included on Figures 1, 2, 3 and 4. Figures 3 and 4 provide the In-Service Leak and Hydrostatic (ISLH) Test Limits. These limits were calculated in accordance with the requirements of 10 CFR 50, Appendix G and ASME Code Section XI, Appendix G, 1995 Edition, with Addenda through 1996 and ASME Code Cases N-588 and N-640.

3.8 Davis-Besse has removed more than two surveillance capsules. The capsule test results have been evaluated and found to be non-credible (Reference 5.14).

Consequently, ART calculations are not based on the surveillance data. The Measured RTNDT - Predicted RTNDT data scatter was less than 2, so the Regulatory Guide 1.99, Rev. 2 Chemistry Table values used in the ART calculations are conservative.

4.0 PTLR Requirements 4.1 The PTLR has been prepared in accordance with the requirements of Technical Specification 5.6.4 (see Reference 5.11 for plant implementation). The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto. Davis-Besse will continue to meet the requirements of 10 CFR 50, Appendix G, and any changes to the Davis-Besse P/T limits will be generated in accordance with the NRC approved methodologies described in TS 5.6.4.

43.5 EFPY PTLR Rev. 5 Page 10 of 12 Table1: Davis-Besse Nuclear Power Station Reactor Vessel Beltline Region Data (Applicable as noted in Section 3.1)

Reactor Vessel Location Material Identification Wetted Inner Surface Fluence, n/cm² (E > 1.0 MeV) Current Licensing Basis (CLB) @52 EFPY (Ref. 5.16)

Projected EFPY to Reach CLB Fluence (Ref. 5.16)

ART

@ 1/4 T (F)

@52 EFPY (Note 1)

ART

@ 3/4 T (F)

@52 EFPY (Note 1)

Limiting Matl?

(Yes/No)

RTPTS (F)

(Note 2)

Nozzle Belt Forging ADB 203 2.20E+18 47.4 67.1 58.7 No 82.0 Nozzle Belt to Upper Shell Weld (ID 9%)

WF-232 2.17E+18 45.9 Note 3 Note 3 No 120.5 Nozzle Belt to Upper Shell Weld (OD 91%)

WF-233 2.17E+18 45.9 98.3 66.2 No Note 4 Upper Shell Forging AKJ 233 1.64E+19 51.4 71.4 56.9 No 79.2 Upper Shell to Lower Shell Weld WF-182-1 1.64E+19 51.4 150.9 101.2 Yes 181.1 Lower Shell Forging BCC 241 1.64E+19 51.4 89.5 78.4 No 95.5 Note 1: Reported ART values (Ref. 5.7) are based on Regulatory Guide 1.99, Revision 2.

Note 2: Values from Ref. 5.16, which are based on the location specific clad to vessel interface fluence at 52 EFPY.

Note 3: This weld material does not extend out to the 1/4T or 3/4T location.

Note 4: This weld material is not present at the clad to vessel interface, so RTPTS does not apply to it.

Note 5: BWW 279/BWW 249 (Inlet Nozzle Forgings (at Lower Nozzle Belt to Inlet Nozzle Forging weld)) and WF-232/WF-233 (Lower Nozzle Belt to Inlet Nozzle Forging Welds) are projected to reach the CLB fluence at 43.5 EFPY (Ref. 5.16).

43.5 EFPY PTLR Rev. 5 Page 11 of 12 5.0 References 5.1 Safety Evaluation by the NRC Office of Nuclear Reactor Regulation Related to Amendment No. 199 to Facility Operating License No. NPF-3 Davis-Besse Nuclear Power Station, Unit No. 1, attached to correspondence dated July 20, 1995.

5.2 Technical Specification 5.6.4, Revision 339, Reactor Coolant System (RCS)

PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR).

5.3 Technical Specification 3.4.12, Revision 339, Low Temperature Overpressure Protection.

5.4 BAW-10046A, Revision 2 Methods of Compliance with Fracture Toughness and Operational Requirements of 10 CFR 50 Appendix G.

5.5 BAW-2241P-A, Fluence and Uncertainty Methodologies, dated April 1999.

5.6 BAW-1543A, Master Integrated Reactor Vessel Material Surveillance Program.

5.7 ANP-2718, Revision 7, Appendix G Pressure-Temperature Limits for 52 EFPY for Davis-Besse Nuclear Power Station FirstEnergy Nuclear Operating Company, dated April 2019.

5.8 Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 282 to Facility Operating License No. NPF-3, FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station, Unit No. 1, (FENOC Ltr. R11-030), dated 01/28/2011.

5.9 ASME Code Section XI, Appendix G, as modified by the alternate rules provided in ASME Code Case N-640 and ASME Code Case N-588. ASME Code Cases N-640 and N-588 have subsequently been incorporated into ASME Section XI, Appendix G, 2003 Addenda, which are the edition and addenda codified in 10 CFR 50.55a (effective May 27, 2008).

5.10 BAW-2308, Revision 1-A and Revision 2-A, Initial RTNDT of Linde 80 Weld Materials, dated August 2005 (1-A) and March 2008 (2-A).

5.11 Calculation C-NSA-064.02-037, Revision 3, Davis-Besse 43.5 EFPY Pressure-Temperature Limits, dated 7/7/2021.

5.12 Not used 5.13 Not used 5.14 AREVA Document 32-9031157-000, Davis-Besse Revised ART Values at 52 EFPY, dated 9/20/2006.

5.15 NRC Letter to FirstEnergy Nuclear Operating Company, Davis-Besse Nuclear Power Station, Unit 1-Exemption from the Requirements of 10 CFR Part 50.61 and 10 CFR Part 50, Appendix G, (FENOC Ltr. R10-298) dated December 14, 2010.

5.16 AREVA Document 32-9300671-000, Davis-Besse Reactor Vessel Embrittlement Fluence Reconciliation Through 60 Years, dated 12/10/2019.

5.17 CR 2019-03982 Reactor Vessel 52 EFPY Projected Neutron Fluence (Exposure)

Higher than Previous Projection, dated 4/30/2019.

43.5 EFPY PTLR Rev. 5 Page 12 of 12 5.18 CR 2020-07840 Revised Vessel P-T Curves Limited to 43 EFPY, dated 10/9/2020