ML040430101

License Amendment, Changes Updated Safety Analysis Report, in Response to Application Dated 01/30/03 to Modify Basis for Compliance with Requirements of Appendix H to 10 CFR 50, Reactor Vessel Material Surveillance Program Requirements

ML040430101
Person / Time
Site:	Perry
Issue date:	04/15/2004
From:	Sands S NRC/NRR/DLPM/LPD3
To:	Kanda W FirstEnergy Nuclear Operating Co
SANDS S, NRR/DLPM, 415-3154
References
TAC MB7519
Download: ML040430101 (13)

Text

April 15, 2004 Mr. William R. Kanda Vice President - Nuclear, Perry FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P.O. Box 97, A200 10 Center Road Perry, OH 44081

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT 1 - ISSUANCE OF AMENDMENT (TAC NO. MB7519)

Dear Mr. Kanda:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 128 to Facility Operating License No. NPF-58 for the Perry Nuclear Power Plant (PNPP), Unit 1.

This amendment consists of changes to the Updated Safety Analysis Report in response to your application dated January 30, 2003.

FirstEnergy Nuclear Operating Company, (FENOC), the licensee for PNPP, Unit 1, submitted the above request for NRC review and approval of an amendment to modify the basis for their compliance with the requirements of Appendix H to Title 10 Part 50 of the Code of Federal Regulations (Appendix H to 10 CFR Part 50), Reactor Vessel Material Surveillance Program Requirements. In the submittal, FENOC requested that they be approved to implement the Boiling Water Reactor Vessel and Internals Project reactor pressure vessel integrated surveillance program as the basis for demonstrating the compliance of PNPP, Unit 1 with the requirements of Appendix H to 10 CFR Part 50.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Stephen P. Sands, Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosures:

1. Amendment No. 128 to License No. NPF-58

2. Safety Evaluation cc w/encls: See next page

Perry Nuclear Power Plant, Unit 1 cc:

Mary E. OReilly Carol OClaire, Chief, Radiological Branch FirstEnergy Corporation Ohio Emergency Management Agency 76 South Main St. 2855 West Dublin Granville Road Akron, OH 44308 Columbus, OH 43235-7150 Resident Inspectors Office Mayor, Village of Perry U.S. Nuclear Regulatory Commission P.O. Box 100 P.O. Box 331 Perry, OH 44081-0100 Perry, OH 44081-0331 Dennis Clum Regional Administrator, Region III Radiological Assistance Section Supervisor U.S. Nuclear Regulatory Commission Bureau of Radiation Protection 801 Warrenville Road Ohio Department of Health Lisle, IL 60532-4531 P.O. Box 118 Columbus, OH 43266-0118 Sue Hiatt OCRE Interim Representative Zack A. Clayton 8275 Munson DERR Mentor, OH 44060 Ohio Environmental Protection Agency ATTN: Mr. Zack A. Clayton Mr. Vernon K. Higaki P.O. Box 1049 Manager - Regulatory Affairs Columbus, OH 43266-0149 FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Chairman P.O. Box 97, A210 Perry Township Board of Trustees 10 Center Road 3750 Center Road, Box 65 Perry, OH 44081 Perry, OH 44081 Timothy Rausch, Plant Manager Daniel Z. Fisher FirstEnergy Nuclear Operating Company Transportation Department Perry Nuclear Power Plant Public Utilities Commission P.O. Box 97, SB306 180 East Broad Street Perry, OH 44081 Columbus, OH 43215-3793 Mayor, Village of North Perry North Perry Village Hall 4778 Lockwood Road North Perry Village, OH 44081 Donna Owens, Director Ohio Department of Commerce Division of Industrial Compliance Bureau of Operations & Maintenance 6606 Tussing Road P. O. Box 4009 Reynoldsburg, OH 43068-9009

ML040430101 *see previous concurrence OFFICE PM:PD3-2 LA:PD3-2 EMCB:DE SRXB:DSSA OGC SC:PD3-2 NAME SSands PCoates SMCoffin* JUhle* TSmith* AMendiola DATE 04/15/04 04/14/04 03/09/04 03/10/04 03/16/04 04/15/04 FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-440 PERRY NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 128 License No. NPF-58

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the FirstEnergy Nuclear Operating Company (the licensee) dated January 30, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, by Amendment No. 128, the license is amended to revise the Updated Safety Analysis Report (USAR) to reflect incorporation of the Boiling Water Reactor Vessel Internals Project Integrated Surveillance Program into the licensing basis as set forth in the application for amendment dated January 30, 2003. The licensee shall submit to NRC the revised description authorized by this amendment with the next update of the USAR in accordance with 10 CFR 50.71(e).

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No.

are hereby incorporated into this license. The FirstEnergy Nuclear Operating Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Anthony J. Mendiola, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

1. Amendment No. 128 to NPF-58

2. Safety Analysis Date of Issuance: April 15, 2004

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 128 TO FACILITY OPERATING LICENSE NO. NPF-58 FIRSTENERGY NUCLEAR OPERATING COMPANY PERRY NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-440

1.0 INTRODUCTION

By letter dated January 30, 2003 [1], FirstEnergy Nuclear Operating Company, (FENOC), the licensee for Perry Nuclear Power Plant (PNPP), Unit 1, submitted a request for Nuclear Regulatory Commission (NRC) review and approval of a license amendment to modify the basis for their compliance with the requirements of Appendix H to Title 10 Part 50 of the Code of Federal Regulations (Appendix H to 10 CFR Part 50), Reactor Vessel Material Surveillance Program Requirements. In their license amendment submittal, FENOC requested that they be approved to implement the Boiling Water Reactor Vessel and Internals Project (BWRVIP) reactor pressure vessel (RPV) integrated surveillance program (ISP) as the basis for demonstrating the compliance of PNPP, Unit 1, with the requirements of Appendix H to 10 CFR Part 50.

The BWRVIP RPV ISP was submitted for NRC staff review and approval in topical reports BWRVIP-78, BWR Vessel and Internals Project, BWR Integrated Surveillance Program Plan, and BWRVIP-86, BWR Vessel and Internals Project, BWR Integrated Surveillance Program Implementation Plan [2, 3]. Additional information necessary to establish the technical basis for, and proposed implementation of, the BWRVIP ISP was provided in letters from the BWRVIP to the NRC dated December 15, 2000, and May 30, 2001 [4, 5]. The NRC staff approved the proposed BWRVIP ISP in a safety evaluation (SE) which was provided to the BWRVIP by letter dated February 1, 2002 [6]. However, the NRC staffs SE required that plant-specific information be provided by BWR licensees who wish to implement the BWRVIP ISP for their facilities. FENOCs January 30, 2003, submittal addressed the plant-specific information required in the NRC staffs February 1, 2002, BWRVIP ISP SE.

2.0 REGULATORY EVALUATION

Nuclear power plant licensees are required by Appendix H to 10 CFR Part 50 to implement RPV surveillance programs to monitor changes in the fracture toughness properties of ferritic materials in the reactor vessel beltline region...which result from exposure of these materials to neutron irradiation and the thermal environment. Two specific alternatives are provided with regard to the design of a facilitys RPV surveillance program which may be used to address the requirements of Appendix H to 10 CFR Part 50.

The first alternative is the implementation of a plant-specific RPV surveillance program consistent with the requirements of American Society for Testing and Materials (ASTM)

Standard Practice E-185, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels. In the design of a plant-specific RPV surveillance

program, a licensee may use the edition of ASTM Standard Practice E 185 which was current on the issue date of the American Society of Mechanical Engineers Code to which the reactor vessel was purchased, or later editions through the 1982 edition.

The second alternative provided in Appendix H to 10 CFR Part 50 is the implementation of an ISP. An ISP is defined in Appendix H to 10 CFR Part 50 as occurring when, the representative materials chosen for surveillance for a reactor are irradiated in one or more other reactors that have similar design and operating features. Five specific criteria are stated in Section III.C.1 of Appendix H to 10 CFR Part 50 which must be met to support approval of an ISP:

a. The reactor in which the materials will be irradiated and the reactor for which the materials are being irradiated must have sufficiently similar design and operating features to permit accurate comparisons of the predicted amount of radiation damage.

b. Each reactor must have an adequate dosimetry program.

c. There must be adequate arrangement for data sharing between plants.

d. There must be a contingency plan to assure that the surveillance program for each reactor will not be jeopardized by operation at reduced power level or by an extended outage of another reactor from which data are expected.

e. There must be substantial advantages to be gained, such as reduced power outages or reduced personnel exposure to radiation, as a direct result of not requiring surveillance capsules in all reactors in the set.

As noted in Section 1.0 of this SE, the NRC staff approved the proposed BWRVIP ISP in a SE which was issued to the BWRVIP by letter dated February 1, 2002 [6]. All of the criteria cited above for approval of the ISP were addressed either completely or partially in Reference 6. For those criteria which could not be fully addressed in Reference 6, plant-specific information would be required from licensees who wished to implement the BWRVIP for their facilities. As stated in Reference 6:

[L]icensees who wish to participate in the BWR ISP must provide, for NRC staff review and approval, information which defines how they will determine RPV and/or surveillance capsule fluences based on the dosimetry data which will be available for their facilities. This information must be submitted concurrently with each licensees submittal to replace their existing plant-specific surveillance program with the BWR ISP as part of their facilitys licensing basis. The information submitted must be sufficient for the staff to determine that:

(1) RPV and surveillance capsule fluences will be established as based on the use of an NRC-approved fluence methodology that will provide acceptable results based on the available dosimetry data, (2) if one methodology is used to determine the neutron fluence values for a licensees RPV and one or more different methodologies are used to establish the neutron fluence values for the ISP surveillance capsules

which represent that RPV in the ISP, the results of these differing methodologies are compatible (i.e., within acceptable levels of uncertainty for each calculation).

This plant-specific information was required by the NRC staff to ensure that criterion III.C.1.b of Appendix H to 10 CFR Part 50 for an ISP could be met by each facility, and to confirm that data which would be shared as part of the BWRVIP ISP could be effectively utilized by each licensee for the monitoring of RPV embrittlement for their facility.

3.0 TECHNICAL EVALUATION

In their letter dated January 30, 2003, FENOC submitted information for PNPP, Unit 1, which addressed the information requested in the NRC staffs February 1, 2002, BWRVIP ISP SE [6].

FENOC submitted a revised Table 1.8-1 of the PNPP, Unit 1 updated safety analysis report (USAR) by Reference 1, which stated:

Regulatory Guide 1.190 - (Revision 0 - 4/01) Calculation and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence. Neutron fluence methodologies used by PNPP will conform to this guide.

In addition, FENOC submitted a revised Section 5.3.1.6.2 of the PNPP, Unit 1 USAR by Reference 1, which stated:

A neutron fluence calculation methodology which has been approved by the NRC staff and conforms with U.S. Nuclear Regulatory Commission Regulatory Guide 1.190, Calculation and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence, will be used for the determination of neutron fluence values for the PNPP.

FENOC also provided a comment in Reference 1 regarding the completion of their updated RPV fluence analysis for the PNPP, Unit 1 RPV:

With respect to the specific fluence methodology, PNPP has used the NRC-approved General Electric NEDC 32983P-A, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations, to calculate the most recent fluence values.

This calculation was performed to support a revision to the PNPP RPV pressure/temperature limit curves which was submitted to the NRC for review and approval by letter dated June 4, 2002 (PY-CEI/NRR-2627L).

The NRC staff has concluded that the above comment, in addition to the inclusion of these revised sections in the PNPP, Unit 1, USAR, is sufficient to address both items (1) and (2) from Reference 6. Regarding item (1), the licensees use of a methodology for determining the PNPP, Unit 1, RPV neutron fluence values which is consistent with the attributes of Regulatory Guide (RG) 1.190 and has been approved by the NRC staff will provide acceptable results based upon the available dosimetry data. Regarding item (2), RPV surveillance capsules tested under the BWRVIP ISP will have their fluences determined by the use of a methodology which is consistent with the attributes of RG 1.190 and has been approved by the NRC staff.

The NRC staff has concluded that any two (or more) different fluence methodologies will provide compatible (as defined in Reference 6) results provided that the best estimate fluence values are within each others uncertainty bounds.

Inasmuch as this action was submitted as a license amendment, consistent with the NRC staffs understanding of the decision given in Commission Memorandum and Order CLI-96-13, FENOC provided a revised Section 5.3.1.6.1 of the PNPP, Unit 1 USAR by Reference 1 which documented the licensees incorporation of the BWRVIP ISP into the PNPP, Unit 1, licensing basis:

The program for implementation of the scheduling, withdrawal, and testing of the material surveillance specimens is governed and controlled by the Boiling Water Reactor Vessel and Internals Project (BWRVIP) BWRVIP-78, BWR Vessel and Internals Project, BWR Integrated Surveillance Program Plan (Reference 7);

BWRVIP- 86, BWR Vessel and Internals Project, BWR Integrated Surveillance Program Implementation Plan (Reference 8); NRC letter dated December 15, 2000, Request for Additional Information Regarding BWRVIP-78" (Reference 9); NRC letter dated May 30, 2001, Project No. 704 - BWRVIP Response to Second NRC Request for Additional Information on the BWR Integrated Surveillance Program (Reference 10);

and the NRC Safety Evaluation (Reference 11) which approved BWRVIP-78 and BWRVIP-86. The BWRVIP Integrated Surveillance Program (ISP) complies with the requirements of 10 CFR 50, Appendix H.

In addition, FENOC provided, in Section 5.3.1.6.1 of the PNPP USAR, the revised withdrawal schedule for PNPP, Unit 1, in accordance with the NRC staff approved BWRVIP-86. The NRC staff has concluded that the information provided in the revised PNPP, Unit 1, USAR is adequate to document the licensees intent to appropriately implement the BWRVIP ISP as the method for demonstrating the compliance of PNPP, Unit 1, with the requirements Appendix H to 10 CFR Part 50.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Ohio State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

S The amendment changes the requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding (69 FR 696). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

S The NRC staff has concluded that the information provided by FENOC was sufficient to conclude that the BWRVIP ISP, as approved in Reference 6, can be implemented for PNPP, Unit 1, as the basis for demonstrating the facilitys continued compliance with the requirements of Appendix H to 10 CFR Part 50. As part of the implementation and documentation of the

licensees intent to utilize the BWRVIP ISP for this purpose, the licensee shall modify the PNPP, Unit 1, USAR as noted in Section 3.0 of this SE and as stated in their January 30, 2003, submittal.

The staff has concluded, based on the considerations above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

[1] W. R. Kanda (FENOC) to U.S. NRC Document Control Desk, License Amendment Request Pursuant to 10 CFR 50.90: Revision to Perry Nuclear Power Plant Reactor Pressure Vessel Material Surveillance Program, January 30, 2003 (ML030380338).

[2] C. Terry (BWRVIP) to U.S. NRC Document Control Desk, Project No. 704 - BWR Vessel and Internals Project, BWR Integrated Surveillance Program Plan (BWRVIP-78), December 22, 1999.

[3] C. Terry (BWRVIP) to U.S NRC Document Control Desk, Project No. 704 -

BWRVIP-86: BWR Vessel and Internals Project, BWR Integrated Surveillance Program Implementation Plan, EPRI Technical Report 1000888, December 22, 2000 (ML003780862).

[4] C. Terry (BWRVIP) to U.S. NRC Document Control Desk, PROJECT NO. 704 - 5 BWRVIP Response to NRC Request for Additional Information Regarding BWRVIP-78, December 15, 2000 (ML003778478).

[5] C. Terry (BWRVIP) to U.S. NRC Document Control Desk, PROJECT NO. 704 -

BWRVIP Response to Second NRC Request for Additional Information on the BWR Integrated Surveillance Program, May 30, 2001 (ML011560296).

[6] W. H. Bateman (USNRC) to C. Terry, Safety Evaluation Regarding EPRI Proprietary Reports BWR Vessel and Internals Project, BWR Integrated Surveillance Program Plan (BWRVIP-78) and BWRVIP-86: BWR Vessel and Internals Project, BWR Integrated Surveillance Program Implementation Plan, February 1, 2002 (ML020380691).

Principal Contributor: John Honcharik, NRR Date: April 15, 2004