ML050540438

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Comments on Draft Safety Evaluation for BAW-1543(NP), Revision 4, Supplement 5, Supplement to the Master Integrated Reactor Vessel Surveillance Program
ML050540438
Person / Time
Site: Davis Besse, Oconee, Arkansas Nuclear, Crystal River, Crane  Duke Energy icon.png
Issue date: 02/21/2005
From: Crawford H, Holm J
B & W Owners Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BAW-1543(NP), Rev 4, BWOG:05:1867, NRC:05:012, TAC MC1762
Download: ML050540438 (18)


Text

Duke Energy Corporation Entergy Operations, Inc.

Progress Energy. Florida Oconee 1, 2, 3 ANO-1 Crystal River 3 AmerGen Energy Company, LLC The B&W FirstEnergy Nuclear Operating Company Owners Groupl FramatomeANP, Inc. (FANP)

TMI-1 D-B Working Together to Economically Provide Reliable and Safe Electrical Power February 21, 2005 NRC:05:012 BWOG:05:1867 Document Control Desk U.S. Nuclear Regulatory Commission Washington D.C. 20555-0001 Comments on Draft Safety Evaluation for BAW-1543(NP), Revision 4, Supplement 5, "Supplement to the Master Integrated Reactor Vessel Surveillance Program" Ref. 1: Letter, Robert A. Gramm (NRC) to Jerald S. Holm (Framatome ANP), "Draft Safety Evaluation for Babcock and Wilcox Owners Group Topical Report BAW-1543(NP), Revision 4, Supplement 5,

'Supplement to the Master Integrated Reactor Vessel Surveillance Program' (TAC No. MC1762),"

February 3, 2005.

The NRC issued a draft safety evaluation on BAW-1543(NP), Revision 4, Supplement 5, and requested that the B&WOG review for any factual errors or clarity concerns. On behalf of the B&WOG, Framatome ANP has reviewed the draft SER provided in Reference 1.

The SER contains minor errors and clarifications which we recommend correcting. A marked up copy of the pages in the draft SER containing the errors is provided in Attachment A. Attachment B provides a summary table of the minor clarifications.

On behalf of the B&WOG, Framatome appreciates this opportunity to offer clarifying comments.

Sincerely, 4k /l>

Jerald S. Holm, Director Regulatory Affairs tax.

ZIA1 Howard Crawford, Chairman B&W Owners Group Steering Committee enclosures cc:

D.G. Holland Project 693 Reactor Vessel Working Group Framatome ANP, Inc. B&W Owners Group 3315 Old Forest Road Lynchburg, VA 24501 Phone: 434-832-3635 Fax: 434-832-4121 eDDq,5

Documnent Control Desk NRC:05:01 2IBWOG:05:1867 February 21, 2005 Page A-1 Attachment A FEBM- -2 1O:59 P.ewe9 4tDITW STATES NUCLEAR REGULATORY COMMISSION WAsNwgpro.% nr_. "su-mli gAEE s&E vAwArIoN sy THg omE OF uuLAR gEA=R RQES61`10N I

1.0 INMODUC7N 2

By letr dated Deoember 1.2,Z the Babcodc and Wilcox (B&W) Owners Group (B&WOG) 3 Reasew Vesel Working Group submltted, for NRC approval, topical rmport (TR) 4 DAW-1543(NP). Rvislon 4. Supphamard I. 'Supptrnant to the Mlaster Inteatod Rea=tor 5

Vesscl Survelance Progranm." Th. mions c d h ths supplament wore refsuwry duo 6

to a commitment not being met In Supplemont 4, because copsules OC1.D and 0C3-F could 7

not be rwrovedfromn Crystal Rhwr Unit3.

8 20 BACKGROrUND 9

By letr datd Apr 10, 2001, the B&WOG subtd, for sff approvl, rpot BAW1 643, 10 RFvi10on 4, Suppl rnt 4, 'Sutpment to the Master Integrated Reactor VesseI Surveltlarnce 11 Program.' BAW-543. R Wn 4, reported tfe essenti l features of tte master Integrated 12 reactor Vessel u Wanprogram (UIRVP) tar a oporatg W 177-ful assornb~y (FA)

_13 plants and esfnghouse plants twin SW4ablcae ctcr vssels. These reactor 14 vasea Incdud men B&W-deslgne 177-FA plants :and C4es14nl plnts 1s with BWIabrlcated reactor vessels. The pogram was bilt upon the' rated suTrflanoc 16 progran developed by the B&WOG ohe r t r&W 1774A ptants. Al 'rA are of th

_ 17 same basic design concept promumbWd water reactor, operatfng aetSOF and 22S0 psi 18 norminal hlet tenpraure and prsure, anrid th low enri ot fu (approximtely 2% to 4%

19 nddvnnt).

A sou-r 20 The Irradiatn schdAes for the O&WOG MIIRVSP hiclude the plant-spodffo capsules for the 21 B&W-and W64fhous-&abod vassk and Dv supplamanary weld meta suwllnarne 22 capsus and higher fluenoa supplementary weld metal seurve inco capsulez. AD the 23 lracdatlons. wfth the ex-eptVon of Capsule WI and to Westinghousa pant-speclf caupsles, 24 ae perford inth 8&W hot reactm. Crystal RI!n 3 and D sBesse. Capudol W.

_ 25 an Irrafation capsule of te Westhghou

legnr, Iradrated In Surry UnIt Z The 26 Wasstnghouse plant-specfic capules are krradWed h thdr respectiv plnts An updatWd lst 27 of the status of the Weftnghouse and S&W plant-spec&icAnteated survollanoo capsules is 28 p

d dln Attadunent 1.

29 The staff owsted the BWOG~s bash fo the Ineegratod prograrn conapL The criterion as 30 provIded by Appendix H tol 0 CFA Pat 50. Reactor Vel Material Survohlance Program

?

Docurment Control Desk NRC.05.012/BWOG.05.1867 February 21, 2005 Page A-2 1 Requirements." were rrst Iherefoze, the ff determind the MPRVSP to be acoepable. By 2

loftrdaledJune 1i. 1,91, 6AW-1 4M RevisionS, was approved by he NRC. The staff noted 3

thnt the dicussions of BAW-1543. Revsibn 4, wer osentially the swrne as those found in 4

BAW-1643, Revision 3, exept for an update of come ot the urs' Whrawal schedules.

5 BAW-1543, RevWson 4, Supplorent 1, contained quanttativo Information which war, In 6

generaiL tuence dopendent ard, theore, subjectto change. This reviion reflected revised 7

flence vaklues for sroe units and revsed some wihdrawal schedules lo corrly with American 8

Society or Testing ard Materials (ASM Stnard E 185-73, Stndard RecoDMMnded 9

Practice for Survellanc Tests for Nuclear Reactor Veoelus.' It was antioated that future 1 0 rsions to BAWl1543 would onty nole the Reviion 4 SupplemenL SAW-1 543. Rvon 4, 11 Supptement 2, refected the revised Blenc values and the revised whdrwal schedules, and, 12 therefore, replaced BAW-1543, Revison 4, Supplement 1.

13 The O&W03 later revised and replaced Supplement 2 of Revision 4 of the sLMect report wih 14 Supplemert 3. In Supplement, the B&WOG deleted Rancho Sao, R.E. Ginur, and Zion 15 Unlts I and 2 from the program. In addmon, Iho B&WOG updated the capsule stats and Xte 16 peak otnsr o f-@nluencee Iorsavelplaznts. InSupplemrt4.hefl&WOG Incorporaed

-_-17 the disposl plan for

, updted the status for vaious capsuls, and 18 (noorporated current noo levels. The O&WOG submrrted Supplement 5 because the last 19 suppktnent uded ac mrle rsgaring Capsuls 014) nd OC3-F; hower, at 20 comtnent could nt be m b thscapsule ecoud not removed from Crysa vr 21 Unft 3.

sroed-b 4a0scurS 2Z 3.0 EVALUATION 23 Appendix H to 10 CFR Part 50 Includes crierda to monitor changes in the fracture toughness 24 prop.itles o ferric ntrla In te reactorveoss bole reglon of fght-vaur nucear power 25 reactors Wkl M

resUt fron sepoure d these materials to neutron Irradiation and the thermal 26 efvironmut. Appendix H to 10 CFR Part 50 endorseG ASTM E 185.73. Apcp~fx H states 27 that fjhe desIgn of the surveiance pmgram and the Atkhdrawal shoduio rnust noat the 28 requirements of the dlhn ot ASTM E 185 that I current on the Isue date of the ASME 29

[American Society of Mechanical Enginwers] Code jBoffar and Pressure Vessel Code) to whkch 30 the eactor vessel was purchasod. Later KW s of ASTM E 185 Nay be used, but including 31 only those editons through 1 982.

32 ASTM E 185-2, "Stantard Practice for Conducting Survollanmo Tos for Ught WaWe Cooled 33 Nuclear Power Reactor Vesses and ASTM E 1 B-6-,

Recommended Practice for 34 SuMvillance Tesk on Stuctural Malerils i ucler Reactorw cow pmoqxus for minooting 35 the relaon-Indced chianges hI the mechanlca properties of tefirlc materials in the bltne of 36 Nght-at cooled nuclear power reactor vesls. Thses practkes Include g~dallrns for 37 designg a ranum srvellance program, seleaing materials, and evaluting test results.

38 The tmff rvakuted the withdrawal schedut for each of the B&W Wnd Weinghouse 39 plant epecHlc Mea~or vssenl surveilance programs, az provided In BAW-1543pNP), Revislon 4, 40 Supplenent 5, and determined that the wtdrawdl schedules were prepared in acrdance wlth 41 ASIM E 15-82 for each of the cublect ts xcpt for Turkey Point Urits 3 and 4. Addifoml 42 detals of the staft assessrnert ere provided below. It should be nated that this evaloUtion vill

Document Control Desk NRC:05:01 2IBWOG:05:1 867 February 21, 2005 Page A-3 I

focus on the staffs review of the B&WOG's revised withdrawal schedules, as provided In 2

BAW-1543 (NP), RevisIon 4, Supplenent 5.

3 As stated pWviously, capsules OC10 and 003-F could not be removed; therefore, cremt lr 4

these two capsules could no longer W taken lor 00oMG Uni 1 and Oonee Unit 3.

5 respectively. The staff indperdontly reviewed the sunvillair capsule withdrawal schedules 6

for Ooonee Unit 1 and Oconee UnIt 3. to nsro that the sPtect ursu' rwviOlance capsule 7

program wvoud atiE compry with the requiremnts of ASTM E 185-22.

8 The staff found that the capsule witdQrwal schedule for Oconee Unit I adoquately met the 9

requIrements of ASTM E 195-92 In tat four capsules have been withdrawn end tested, and 1 0 t

last capsule that was tested, OC1-C, had aibsence of 1 lo2 times the endof-flte fluence.

11 Therore, the st deterrrfid tat t Inaity to wthdrawdtca e OC -D had no

.12 Impact on the ablilty of the Oconra Unit 1 survulllance capsule program to meet the Appendi H 13 requirements.

14 The staff found that the capsule wihdrawal schedule for Oconee Units adequately met the 15 requirsnwrts of ASTM E 185-92. In that three capsuls have boon tested and an additional 16 cap capsule CR3-LG2, wifh contaIns the lWriling bettlfi. material kir Ooonee UnIt 9 (heat 17 number 72442), was tostd and had a fluonce of I to 2 times the end-of-Ifs usnc for Oconee 18 Unit 3. Therefore, the staff detan*ed tiat the inabily to withdrawand4etcapsie OC3-F 19 had no rrpact on the abbity of the Oconee Unk S aurvallanoe capsule program to meet the 20 ApperdKix H requlremnts.

-r 21 The staf noted tat added a supplemental capsule, to bo removed and teste to 22 te Point Beach U proump Also, the B&WOG updated th stats of capsules 23 Y and X of Sury Uni 2 and turkeyPint Unai, respectively, lo lndice that they had been 24 tested. The staff found tat these revisions were enhancemnents or updates to the program and 25 ar, Utefore, acceptable to tie staff.

26 27 on May z6, 2004, ia staff reques that the 8&WOG rrnamv or address the relevwe of the 28 statemnt 'The owners of plants that have been granted kce renewar have made no 29 commitment to test or use Irtormatlon from the capsules tat continue to be bradatod under 30 the MIRVSP." becuse future applowant may wish to take credit for hufornMin obtained from 31 the MIRVSP, as opposed to using plant-specific bformatlon In order to meet the require monts 32 of 10 CFR Part 50, Appen H. By tetrdad July 7,2004. te B&WOG indicated that th 33 sttement vMl be removed upon lesuance of the approved version of BAW-1543, RevisIon 4.

34 Supplemrent 5. The staff found ts acmptale.

35 The staff determhied tat the wthdrawal schedules for Oconos UnIt 2, Three Mle Island Unit I 38 (TIlt-i), Crtlal Rhir Unit 3, Arkantas Nuclear One Unft 1, Devis-Busse. Point Beach Un3t 2, 37 urry Unit 1, Turkey Point Unit 4, as provided In Tables VI and YII of BAW-1543(NP), RevIslon 38 4, Supplement 5, CDi not change from Supplement 4 and, therefore, stI coroply wth the 39 requirements of ASTM E 1 8S82, as shied In tt satsrs salety evaluation dated July 31, 2001.

40

However, staff noted that tV onmflon In Toble VIII, of the subject topical report, did not 41 awcuratl Jst fe capsules to be witdmwn and tasted for Oconee Units 1, 2 and 3, and TMI-1.

Document Control Desk NRC:05:012/BWOG:05:1867 February 21, 2005 Page A-4 I

The SWOG Isted capsules for these sujed plants that were n longer going to be withdrawn 2

and tested, I.e., Capsule OCI-D for Oconee Unit 1, Capsule OC2-P for Oconee lUit 2, 3

Capwle OC3-F for Oconee Unit 3, and Capsules F and D for TMI.1.

4 During a conference call thal was hold on Novrmber 23, 200, the staft disssed this Issue S

wh the B&WOG, who indicated that It woutd revise Table Vill of t report to accurately ris the 6

capailes that were going to replace thUm Oh were no kHoger going to be withdrawn and 7

tested. The staff noted that the withdrawal schedule for Oconee Unit 1 already met the B

reiuiremrents of ASTM El B582; owver, the table cUl needed revislon, because the capsules 9

lited worc not correct The B&WOG hxeatad that 04nee Unit 2's luirn material is 1 0 Cor dIn Capsule AS (which was Irradiated in DavIs Besse), which was tested and satftd

-11 th9 h capsule requoremnt of ASTU El 8;-82 for Ocoe Uit 2. For Oeonee Unit3, the

-.-.- 1 2 ritng material Is contained h Carule CM3 LG2. which was taestd and satelled the 4fW9 1 13 capsule roquirement of ASTM El 85-82, for Oconee Unit 3. And for TA-11 the limiting mraterll 14 is contained In Capsule TMAIZ-LOZ which was tested and satfiod theo capsulW 15 requireentd of AST E185-82.

16 By uplernental lottor dated Januawy S. 2005, ea B&WOG revised Table Vill to the 17 BAW-164S(NP), Reviion 4. Supplement S report. The stff found that the revised table 18 accurately Usted tfe Wthdrewal shewdules for COcone Units 1,2. and 3, and TMIM1. As statod 19 above, the staff found that each of these plants me the capsuie withdewal sdiedule 20 requiments of ASTM E

-M82, rv though the oiginut capsu05 wm root Ong to e 21 withdrawn end tested for Oconee Units 2 and 3 and TM1, bocause thee are er capsules in 22 the MIRVSP that contain tho same,niting malerial fw the subject plants hat wil be fthdrawn 23 and sted, and, therefore, will satisfy requirenents of ASTM El 85-82.

24 25 Turkey Point Units 3 and 4 were prepared In accordance with ASTM E 185-66. The Turkey 26 Point Units 3 and 4 roactrvessels were purchased to the SrnrMer 1906 Addenca to the 1965 27 ASME Codo. ASTM E 185-66 was the surveillance capaule gandard hi effect at the time the 28 Turkey Point Units 3 and 4 reactor vessels were purchased. Sice the Turkey Point Units 3 29 and 4 capsule wthcrawal schedules meet the ASTM E l 85 ednicon tha was ourrent at The time 30 the reactor vessels were purchased. the withdrawal schedules meat the requirements of 31 Appordx H to 10 CFR Part 50.

32 It hould Ols be notd fthat, by letter dated Febnrury S. 1985, a sfety evaluation report (SER) 33 was sitmfttod to FRorld Power & Light Comnpan, which Inclcaled that the NRC approved an 34 Integrated aurvillance program for Turkey Point Units 3 and 4. The SER Indicated that tle 35 ody caps tet u

be t

~o k at Tunrey Point a ints 3 a d

4 In a wM l

Wh ASTM E 185 36 reqIrernents, ame tho=e that contain weld mefta specimnn.

37 4.0 CONCU§10N 38 39 Based on te stafs reviw d the B&WOG IARVSP, thestall found that the revised witrawal 40 ucedules, as khdced In Report BAW.1543(NP), neision 4, Supploment S, are acceptabta 41 for the B&W-desisd 1 77-FA plants OMd the Westinghouse-designed plants wFth B&W-42 fabricated reactorvessels. The proposed withdr sched es satlsfy the ASTM E 165-82 43 Standard for a& plants particlpating in the B&WOG MIRVSP except forTurkey Point Units 3 and 44

4. Turkey Point Units 3 and 4 saily the ASTM E 185-66 Stadard. Since ths edlton o the

Document Control Desk NRC:05:012/BWOG:05:1867 February 21, 2005 Page A-5 I

standeid was current at the aima the reactor vessels were purchased, the Turkey Point Units 3 2

and 4 survelse cap sue wi*dwal sceidules Utley the requiremnts of Appendlb H to 3

10 CFR Pat 50. A.ItI should be noted tat the NnC previously approved an integrated 4

survellaice program for Turkey Point Unft 3 and 4.

5 The staf onclud*d that ft proposod %ididrawal schedule of 8AW-1543(NP), PWViSIon 4, B

Supplement 5, comply with Appwdtk H to 10 CFR Part So. Thereform, the staff approves the 7

revfted widrawal schaedue for each d the plants hcbded in te O&WOG MIRVSP.

8 5.0 BREERENCES 9

t.

BAWl 543, Revisin 4, Supphement 4. "Supplemert to the Mter Integrated Reactor 10 VesWd Sumrvillance ProgranApril 2001.

11

2.

NRCC ler to A. Mendida, from K. WIchrmm, NRC, 'Safety Evaltutlon ot BAW-1 543, 12 Master Inrtgrated Feactor Voseel &aIIarva Program. Plevision 4. Supplement 4,'

13 July 31. 2001.

14

3.

Code of Federal Reguistims TaM&e 10, Pat 50, Appendix H1,

  • Raador Vessel Material 15 Survoillanc Program Requirements!

16

4.

American Sockey for Tvs&Q and Malsrials, 'Recommandod Prace r WSuvellance 17 Tests on uc M eaal aI Nude Rear ASTM E 18-8.

18

5.

Amenan Socie for Testing ad Matrls, 'RecTnod aPrate for Survedlan 19 Tests for Nuclear ReactorVands,' ASTM E 185.70.

20 S.

Amrican Sociery for TesUng and Mat s, Standard Practica for ConducIng 21 Surveillance Tests for Ught Water Cooled Nudeat Power Reaowor Vessts, 22 ASTM E 18!2.

23

7.

NUREt3-151 1. S pplefrn 2, 'Reactor Pressure Vessel Status RportA October2000.

t Docuinent Control Desk February 21, 2005 1

2 3

4 S

7 r

a8 NRC:05:01 2/BWOG:05:1 867 Page A-6 STATUS OF WESTINGHOUSE PLWT-SPECIFIC SURVEILLANCE CAPSULES 9

10 11 12 13 14 15 NOES:

1. TO BE WITHDRAWN AND STORED
2. TO BE WITDRAWN AND TESTED 3, WITHDRAWN AND STORED A. WILL REMAIN FOR LIFE EXTENSION
5. DOSIMtETRY During ftreurkey Point licame renewal revdew. the appliarnt statad that the szandty COpsuloS can be used to gather data on fluenee. spectrmr, temporaturc, and neutron tfujx durki me Iloense renewal period.

AttachmW I

I Documnent Control Desk February 21, 2005

  • 1 2

3_

4 NRC:05:01 2/BWOG:05:1 867 Page A-7 STATUS OF BABCOCK AND WILDOX PLANT-SPECIFIC (INTEGRATED)

SURVEILLANCE CAPSULES a

7 a

10 11 12 13 14 15 NOTES:

i.

Capsti conlans onl bms meta spcnense, or wold data alroady exrcts at the expactt~eIVOW capuIB Wernoim or data is wavabk at tlugnme greitW the the wpodo4~reoolvd ftpsule flue ncms so wRI be disposed of in~ accodaInc uw tha March 17,2000, leetter from D-L Hoewel to the USN1M Docu~ment Control Desk.

2.

W~drawn and Stored is 17 8.lifditd In0 eamee-a

Document Control Desk February 21, 2005 NRC:05:012/BWOG:05:1867 Page B-1 Attachment B

SUMMARY

TABLE OF PROPOSED CHANGES PAGE NO.

LINE(S) NO.

PROPOSED CHANGE AND REASON 1

13 Add participating" prior to the words 'Westinghouse plants." Not all Westinghouse plants having B&W-fabricated reactor vessels participated in the program.

1 14 Change "nine" to "six." As of April 10, 2001, the submittal date of Supplement 4 of BAW-1543, Revision 4, there were six Westinghouse-designed plants with B&W-fabricated reactor vessels participating in the program.

1 16 Change "16" to "13" for accuracy (see above comments).

1 17 Add "about" prior to "5500F" for accuracy.

1 25 Change "is being" to "was" for accuracy.

2 17 Change uarchive specimens" to "stored capsules" for clarification.

3 11 Delete "and test." OC1-D was a standby capsule with no commitment for testing.

3 18 Delete "and test." OC3-F was a standby capsule with no commitment for testing.

3 21 Change "the B&WOG" to "NMC" for accuracy.

4 11, 12, 14 Change "fourth" to "fifth" for accuracy.

7 5, 6 Under the fifth column entitled "Notes," omit note 3 for consistency. None of the other capsule irradiation locations are noted.

7 6

Under the second column entitled "Capsule ID," omit Capsule ID "F." This capsule was unable to be removed and is still in the reactor.

7 7

Under the second column entitled "Capsule ID," Omit Capsule ID 'A," or substitute with "WI."

7 17 Omit note 3 for consistency.

Duke Energy Corporation Entergy Operations, Inc.

Progress Energy, Florida Oconee 1, 2, 3 ANO-1 Crystal River 3 AmnerGen Energy Company, LLC rho B&W FirstEnergy Nuclear Operating Company Owners, Group Framatome ANP, Inc. (FANP)

TMI-1 D-B Working Together to Economically Provide Reliable and Safe Electrical Power February 21, 2005 NRC:05:012 BWOG:05: 1867 Document Control Desk U.S. Nuclear Regulatory Commission Washington D.C. 20555-0001 Comments on Draft Safety Evaluation for BAW-1543(NP), Revision 4, Supplement 5, "Supplement to the Master Integrated Reactor Vessel Surveillance Program" Ref. 1: Letter, Robert A. Gramm (NRC) to Jerald S. Holm (Framatome ANP), "Draft Safety Evaluation for Babcock and Wilcox Owners Group Topical Report BAW-1543(NP), Revision 4, Supplement 5,

'Supplement to the Master Integrated Reactor Vessel Surveillance Program' (TAC No. MC1762),"

February 3, 2005.

The NRC issued a draft safety evaluation on BAW-1543(NP), Revision 4, Supplement 5, and requested that the B&WOG review for any factual errors or clarity concerns. On behalf of the B&WOG, Framatome ANP has reviewed the draft SER provided in Reference 1.

The SER contains minor errors and clarifications which we recommend correcting. A marked up copy of the pages in the draft SER containing the errors is provided in Attachment A. Attachment B provides a summary table of the minor clarifications.

On behalf of the B&WOG, Framatome appreciates this opportunity to offer clarifying comments.

Sincerely, 4ki/41>

Jerald S. Holm, Director Regulatory Affairs Howard Crawford, Chairman B&W Owners Group Steering Committee enclosures cc:

D.G. Holland Project 693 Reactor Vessel Working Group Framatome ANP, Inc. B&W Owners Group 3315 Old Forest Road Lynchburg, VA 24501 Phone: 434-832-3635 Fax: 434-832-4121

Docdment Control Desk NRC:05:012/BWOG:05:1867 February 21. 2005 Page A-i Attachment A FED-3-5 18Z59 PP93/'09 UN'TED STATES NUCLEAR REGULATORY COMMISSION WASI-,tO D..

054001 pRAFr SAFEr EVAWUATION BY THE OFMiE OF NUCLEAR REACTOR REGQU6IQAFN MASTER INTEtOR&

N uACTOR VESSE SURELAC

_O =

=

I 1.0 INTRODUCTIN 2

By lettr dated Dooenmbe 19. 2003 the Babcdc ard Wilcox (B&W) Owners Group (B&WOG) 3 Reactor Vessel Warking Gmrup abnhd, for NRC approval, topkal report (TR) 4 BAW-1543(NP), Re slon 4, Susipleno 6,

'Supptant to the Maer Integrated Reao 5

Ve Surveilano Program. The rsons ntainedin thi supplement wore neessmry due 6

toa conifnt not being metr In Supplomo 4, because cepetes OC1.0 and O

C3-F could 7

not be re&oved from Cy91 River Unf 3.

8 2.0 ~BAQKGR 9

By llater dated Apr{ 0, 2001, the &WOG subtd. for stff approWi prtE AW

51643, 10 Reviion 4. Suppt nt 4, 'SuppIrnwl to the Master Integrated Reactr Vessel Survelitance 11 Pra.m BAAW-543.Re' on 4, repofed ths assential features of tFe mastr Intbated 12 reactor vessel u Waneprogmm (UIRVSP) ford operating B&W 177uel assmnnbl (FA)

-_-13 plants mnd esn use pants lwing B&W4&abr teoesr vossals. The.

reactr 14 v

s Indcluda S*n &W-dosigned 17?- FA plnts and 4 Wkesing u

pbnts 15 wfth B&W4abricated nmctr vw,*Afo. The program ws built upon the raled surVfillanxc 1

6 progran deloped by the B&WOG for m S&W 177-FA plants. Al t se.

r ame of te

_-. 17 same baic design oonoept pressurized water rewor, operating aV0 F and 2250 pf 18 nomina Irdt terpore and presure, and wih l oenrhntf (pprxmt* 2% t 4%

19 jjddivt).

A Sour 20 The Irradiation sdcehilas for the d&WOG MIRVSP hchido de pt npaspedflo capaues for the 21 O&W. and Wi4tfhous&da*u msselu and fth supplmarntaMry weld metul smillance 22 cmpsuls and Ngoer nluc SuppLenmt Wed metal surianoe capsuleS. ALD the 23 Irradiatfons. with the excepon of Capsule WI and Oe Wstinghouss plard-specift capsules, 24 are peformod in the B&W host reactos, Crystal Rlnqsit 3 and Dav-Bosse. Capsule WI.

_ 25 an Irnadiafon capsule of tie Westsnghouse-deilgn, kidaiatd In Surry Unit 2. The 26 Wastinghouse plaanspeec capsules are Ira4ted h thir respocM prns. An updatnd Est 27 of the status ol the Westirnhouse and B&W plant-spacticiintegrated sarvolanoo capsules is 28 providd ln Attachl 1.

29 The MS evaluated the BMW s basis for the htgmted prgfram conept. Than crierion as 30 provided by Appendix H to10 CFR Padt 50. ¶Reacbr Vessl Material Sumvoance Program

Document Control Desk NRC:05:012/BWOG:05:1867 February 21, 2005 Page A-2 1 Requirmntsn were met; 11fore, te Staff determined fth MIRVSP to be acceptable, By 2

kttardated June 11. 1a1, 6AW-1543. Revion S. was approved by he NRC. The staff noted 3

tuat the dic cussons of BAW-1543. Resion 4, wr essentially the same as those found in 4

BAW1 5.43, Revision a, excW for an update of some of the units9 wvirawaJ schedula2.

S BAW-1543, Revin 4, Supplement 1, contained quantitative Information which was, In 6

general flene dependent and, therefore, subject to change. This reviion reflctd revsed 7

fluence vaks for some units and revd sorne Wthdrawal schedules l vorrny with American 8

Society lbr Testing and Matarial; (ASTM) Standard E 185-73, Standard Recommended 9

Pract9 for Survellance Tests for Nuclar Reactor Vaessls.' It was anticipated that future 10 revdons to BAW-1543 would orly Invole the RAvision 4 Supplement BAW-1 543, Aev~ison 4, 11 Supplement 2, reflected the rovised lluence values mnd the revised withdrawal schedules, and, 12 therefore. replaced BAW-1543, RevWision 4, Supplemont 1.

13 The S6&WOO Iter revised and replaced Suppnerit 2 of RemisIon 4 of the BLMc report With 14 Supplement 3. In Supplement 3, the B&WOG deleted Rancho Soco, R.E. Ginna, and Zron 15 Units I ard 2 from the progrm In oddffon the B&WOG updated the capsule statws and the 16 peakt end-of-oknse fentes for several plants. In Supplement 4. the B&WOG hcorporated

-hI-17 the spossal plan for e,

updated the status for varous capsuies, and 18 a oorporated current levels. The S&WOG submtetd Supplemern 5 because the last 19 supplemnt bdec a comrnrnl:e regaring Capsules OC1 -D and OC3+; however, that 20 cmrnitnet could n A be rnot booam these capsules could not be renmved from Crystal River 21 Unh 3.

-Srozeb c#Gscui&S 22 3.0 EALUATION 23 Appendix H to 1 O CFR PaSrt5 nh crterls to rsot changes freth ftCture t

lughness 24 propertes f fertc nerals ln the recorvessel bdtlne reglon of figt-watr nucearpower 25 roactors wtl rest from exosure of these Mateials to urn Irradation and Me thermal 26 emrtonmmt. Appendlix H to 10 CFR Part 50 endorses AS1M E 185.73. Appndx H states 27 that 1qhe design of the undleanco progran and t vAthdrawol s=hWdule nuet moat the 28 reqment o lhe don of ASTM E 1e5 that Is current on the su date of O ASME 29

[American Society 01 Mechanical Engineers] Code Bolar and Pressure Vessel Code) to whIch 30 the reactorvessel was purchasod. Lateroditos of ASTM E 185 may be used, but inlucding 31 only hose editions through 1982."

32 ASTM E I BS2 "Standard Practice for Conducting Survoiinco Taft for Ught Water Cooled 33 Nuclear Power Reactor Vessele and ASTM E I 8566, dRecommendod Prtactk for 34 Sutysflanu Tests on Strucu MaterM in huclr RmseiatW covr prooe~ss for monoring 35 tMne mnatlon-nduced changes in the m earica properties of lutec materials in the beMine or 36 Fght-watr cooled nuclear power reactor vessels. These pruatices include uidexlnes for 37 dwsgning a minimurnm suneilance program, seloctiNg materials, and evaluating test resut.

38 The slaff vritad the vvthdrwal schedult for each of the B&W and Westnghouse 39 plantrepeclc oaCLor vesse1 survelihnca programs, a provied In BAW-1543(NP), Revson 4, 40 Supplenent 5. and deterrined that the wtfdtawal scheduls were prepared in accordance with 41 ASTM E 1B5 82 for each of the f

W ect unit weept for TuKoy PoW Units 3 and 4. Adiorml 42 deoles of the stftz assessment ae provided below. It Should be noted that this evaluation wI

Doclment Control Desk NRC:05:012/BWOG:05:1867 February 21, 2005 Page A-3 I

focw on the stairs review of the B&WOGs revised wrthdrawi schadeds, aS provided In 2

BAW-1543 (NP), Revion 4. Supplement 5.

3 As stated peviously, capsules OC140 and O03-F could not be remod; hthrefore, credt for 4

thest two capsules could no longer be taken for Ocore Unat and Oconee UIt 3, 5

respectNly. The staff indopendorg1y reiewed the suiejillnce capsule vWthdrawi schedules 6

for Oconee Unit 1 and Oconee Unit 3. to nswroe that th sukect unih' survallance capsue 7

program would stil conply with the requIretnents of ASTM E 185-92.

8 The statf found that the capsule withdrawal schedule for Oconee Unit I adequately mIt the 9

requrements of AST71 E 15-2, In tat four capsu&es have ben withdrawn and tested. and 10 the last capsule that was testad, OC1-C, had a fluenc of 1 to2 times the end-of.Ule fluence.

11 Therefore. the staff deterrrnied Whet dth Inabilityto whdraw capsule 0010 D had no

.12 Impact on the ability of th Ocorwe UnIt 1 surveillance capsda program to rneet the Appendbi H 13 roquLrernentb.

14 Th. stiff found that the capsule wfthdrawal schedul for Oconee Unit 3 adequately met the 15 roquiremans of ASTM E 18s 2, In that three capsules have boen tested and an addtionat 16 capsule, capsule C3 LG2, whvit contains the limiting be tino material kfr Oconee Unit 9 (heat 17 numbor72442), was tested and had a flumoe of 1 to 2 tnies the end-d-oie ftuonc for Oconee 18 UnIt 3. Therefore, fte saff detemfined tat the inabily to wkhrawc4estoapmti OC3-F

-19 had no Irnpact on the abay of the Oconee Unk 3 survatianoe capsule program to meet the 20 Appendix H requirements 21 The staff noted 4t added a supplemntal capsile. to be removed and tested, to 22 tie Point Beach U 2 wurveanoc proum Also, tho B&WOG updated th& status of capsules 23 Y and X of Surty Uni 2 and Turkey Point Unit 3, respecvely, to indpcat, that they had been 24 tested. The staff found that these rev rlo were enharnenents or updates lo the program and 25 ar, therefore, acceptable to the taff.

26 27 CM May 2M 2004, the ff requeStd at the SWOG rwnmove or address the rleivance of te 28 statement 'The owners of plants that have been granted llcans, renewal have made no 29 commitments to tast or use Irgormatlon from the capsules that continue to be Irradiated under 30 the MIRVSP.' because fture appicants may wish to take credit for Infornmaon obtained from 31 the MIRVSP. as opposed lo using plant-specilic ktformnson in order to mSet the requirements 32 of 10 CFR Part 50, Appendix H. By letter dated Juty 7,2004, te S&WOG IndicatDd that the 33 statement wAi be removed upon Issuance of the approved version of BAW-1543, Revision 4.

34 Supplement 5. The st found tis0 aecptable.

35 The staff detemined tht t whdrawal sohodults for Oconos Unit 2, Three Mile Island Unit I 38 (7MI-1). Crystal River Unit 3, Arkarss NuduI One UnIt 1, Davis-Sesso. Pohit Beach Unit 2, 37 Surry Unit 1, Turkey Point Unit 4, as provided hn Tblea VI and VII of 8AW-1 543NP), Revision 38

4. Supplement 5, did not change fzom Supplement 4 and, therefore, stIl comply vwth the 39 requirements of ASTM E 185-82,3a stated In fe stafrs safety evaluation dated Juy 1, 2001.

40 However, toh staff noted that he ldommtion In Table ViIi. of the subject topical report, did not 41 acuratel st the capsules to be WIwdrawn ard tesed for Oconee UnIts 1, 2 and 3, and TMI-1.

Docdment Control Desk NRC:05:012/BWOG:05:1 867 February 21, 2005 Page A-4 I

The EMWOG lsted capsules for these Mtgd Plants that MM no loner going to be withdrawn 2

and tbst, Le., Capsule OCt-D for Ocnee Unit 1. Capsule OC2-F lor Oconee Unit 2, 3

Capsule O0F for Oconee U 3, and Capsulos F andD for TM-11.

4 Durrig a conference call that was hold on November 23, 2004. the staff diszussed this Issue S

with the B&WOG, vf indicAte that it would revise Thblo Vill of the report to ac:urate* yst the 6

capwles that were going to replac those 0th were no bnger going to be withdrawn and 7

tested. The staff noted that thc withdrawal schedule for Ocon.. Unit 1 already met the B

reqUrements of ASTM El S82; bowever, the table sc needed revsion, becae the capsules 9

listed were not correct. The B&WOG Ineatd that C0onee Unt 2s limiting material Is 10 c

d I

bIn Capeule AS (which was iated in Davls Besse). wtich was ts and satsfted 11 the capsule requirement of ASTML E185-62 for 0conae Unit 2. For Oconos Unh 3, the P-1 2 Whoitng material Is conftned h Capsule CR3.62. "which was tese d saitfled the 4e*th f, 13 capsulo requirement of ASTM El B-2, for Oaonee Unll 3. And for Tm-1 the Wirnwng rnatarale 14 is contained In Capsule TMIZ-LQZ Whdch war tested and safifd theo, capsule 15 requirement of ASTM El 85-82.

16 By wupplemtal Wor dated Janualy S. 2005, the B&WOG resed Table VI10 to the 17 SAW-I543(NP), RevWorn 4,S Suppkm tS report. The staff found that the revised table 1 8 acauratei Usted the YWihdrAwal schdules for Oconee Urits 1, Z and 3, and TMI-1. As statod 19 above, the staff found that sach of these plants nwt the capsule wthdrwal schedule 20 requinoments of ASTM El 8582. even tuh the ordnat capsules were not XOing to be 21 withdrawn and tested for Oconee Units 2 end 3 and TW1-1, bmcause thee ar other capsules in 22 the MIRVSP that contain te samr Siniing marteri fw th, subject plants that WI be withdrawn 23 and tested, and. therefore, wil satisfy the requirements of ASTM El 85-62.

24 25 TUrkay Poant Units 3 and 4 were prepared In accordane with ASTh E 185a-6 Tho Turkey 26 PoWnt (nht 3 and 4 rencovessels were purchased lo the Surnmer 1988 Addenda tothe 1905 27 ASME CodO. ASTM E 185-66 was the surveillance capsule standard in effoct at the tine the 28 Turkey Point Units and 4 reactur sels were purchased. Since the Turkey Point Units 3 29 and 4 capsule witthdawal schedules inet the ASTM E 185 edtion mat was ourrent at the time 30 the reactor vessels were purhased. th withdmrwa schedules meet the requirements of 31 Appondix H to 10 CFR Part:5o.

32 It should Alo be noted that, by fetter dated Febnrry 8. 1 985 asafet evaluation report (SEB) 33 was stubrm d to Flride Power & Light Company, which Indicaled that the NRC approved an 34 Integrated surveilance program for Turkey Point Units 3 and 4. The SER Indicated that the 35 ONiy cPSeS to be testd al TUrk6y Pohtl WAS 3 and 4 In a e stWh AST$A E 185 36 re rments, are those that cnta weld metal spocimens.

37 4.0 CONCLU§ION 38 39 Based on the 3taef review d the B&WOG MIRVSP, the staff ound that the revised wfthdrawat 40 schedules, as kicated In Report BAW.1543(NP), flevision 4, Supplement 5, are acceptable 41 for the S&W-designed 177-FA plants an the Wastinghouse-deslgud piants wfth B&W-42 fabricated reactorvessels. Te proposed withrewal schecles stify Ole ASTM E 185-52 43 Standard for al plants particlpatn In the B&WOG MIRVSP except forTurkey Point Urits 3 and 44

4. Tlurkey Point Units S and 4 satisly ft ASTM E 185-66 Standard. Sirce this don cd tha

Docuiment Control Desk NRC:05:012/BWOG:05:1867 February 21, 2005 Page A-5 I

dandard was current et the time the reactor veels were purchased, the Turkey Point Units 3 2

and 4 sunlance capsule wlhdruwa ehedulas sty the requiments of Apperdbc H to 3

10 CFR Pad 50. Also, it should be noted that tie NRC previously approved in irnegr;ied 4

surveilance program for Turkey Point Urns 3 and 4.

5 The staff concluded tht te proposed withdrawal schedue of BAW-1543(NP). Reftsyon 4, a

Supplenmnt 5, comply with AppJrdbe H to 10 CFR Part So. Therefors, the s"l apprves the 7

revtsed withdrawal scheduiA for each of the plsnts ineh ed in the B&WOG MIRVSP.

5.0 eEEER 9

1 BAW-1 $43, RevPsio 4. Supplentrf 4,'Supplenent to the Mastor Integrated Reactor 10 VesWe Surveillance Programb Apr11 2001.

11

2.

NRC letter to A. Mendila, from K. Wldwin. NRC, "Safety Evaluation of SAW-1543, 12 Mastof Irnagruted Reactor VoesslSurvallane. Program. Revision 4. Supplemernt4.

13 July31.2001.

14

3.

Code of Federal Regublaiors. TM&le 10, Part 50, Appendix H. *Reactor Vessel Material 15 Survoilanoa Program Requirements."

16

4.

American Socity forTpst and Materlals, 'Recomnwndod Practice for Survelance 17 Tests on Structal Materals In Nuclear Reactora, ASIM E 185-66.

18

5.

American Soclet for Testig and Mabriai, 'Recornmnondod Practice for Survelance 19 Tests for Ntuclear ReactorViesols," ASTM E 185-70.

20

6.

American Society for Testing and Mats,;us, "Standard Pruace for CorAcnid-g 21 Surveillance Tests for Ught Water Cooled Nucear Power Reacto Vesas,"

22 ASTM E 15B-82.

23

7.

NUREG-1511, Supplmen 2, 'Reactor Pressure Vessel Status Report, October2000.

Docdment Control Desk Document Control Desk February 21, 2005 1

NRC:05:012/BWOG:05:1867 Page A-6 STATUS OF WESTINGHOUSE PLANT-SPECIFIC SURVEILLANCE CAPSULES 2

PLANT CAPSULE TARGET STATUS NOTES to FLIJENCE 3

POINT BEACH 1 N

45Ets STANDBY I

P REIOVED 3

RATU TESTED 4

PONT BEAW 2 N

6.0E19 STANDBY 1

P REMOVED 9

R,S,TV TESTED W

SUPPL CAPSULE 2

S SURRY 1 S

3IsE19 srTANOBY 4

U

&OE19 STAND1Y 4

W TESTED 5

Y 4.3E19 STANDBY 4

Z 2E19 STANDBY 1

TVX TESTED 6

SURRY2 VX.Y TESTED S

TEESTED 5

T 3.8E19 STANDBY I

U 3.6E19 STANDBY 1

W TESTED 5

z 3&4E19 STANDBY 4

7 TURKEY POINT 3 SSTV.X TES ED U,w.,Z STANDBY 8

TURKEY POINT 4 S5T TESTED X

STAND1 Y U,V,W.Y.Z aBSfi _

STANDBY 9

10 11 12 13 14 I5 NOTES:

1. TO BE WIMHDRAWN AND STORED 2.TO BEWnHDRAWNANDTESTED S. WITIDRAWN AND STORED A. WILL REMAIN FOR UFE EXTENSION S. DOSMETRY During the Turkey Point lense renmwa review. the apU1cWn stated that the starofty capsules can be used to Dafthr data on fluence. spectrum, temperaturo, and neufron flux durkng thie Ilooeea rwnwAd period.-

Attaolvnt I

Document Control Desk February 21, 2005 2

NRC:05:012/BWOG:05:1867 Page A-7 STATUS OF BABCOCK AND WILCOX PLANT-SPECIFIC (INTEGRATEED)

SURVEILLNC CAPSULES 3

4 5

6 8

9 10 11 NOTES:

12 13 14 15 16

1.

CapsLAe cwtins only base met specens, or weld data atready exmcdt at the expcted'rae capaule fhenn or rdata is avaiabe at fluence;s gr then the vpectd&reclved capsule fuences so vM be fsiposed of In accodanwe with ths March 17, 2000, Letter from D.L. Howl to the USNRM Document Control Dsk.

2.

Witdrawn and Stored 17

3.

Irr A

tc In Dz 13 a

Document Control Desk February 21, 2005 NRC:05:01 2/BWOG:05:1 867 Page B-1 Attachment B

SUMMARY

TABLE OF PROPOSED CHANGES PAGE NO.

LINE(S) NO.

PROPOSED CHANGE AND REASON 1

13 Add uparticipating" prior to the words 'Westinghouse plants." Not all Westinghouse plants having B&W-fabricated reactor vessels participated in the program.

1 14 Change "nine" to "six." As of April 10, 2001, the submittal date of Supplement 4 of BAW-1 543, Revision 4, there were six Westinghouse-designed plants with B&W-fabricated reactor vessels participating in the program.

1 16 Change "16" to "13" for accuracy (see above comments).

1 17 Add "about" prior to "5500F" for accuracy.

1 25 Change "is being" to "was' for accuracy.

2 17 Change "archive specimens" to "stored capsules" for clarification.

3 11 Delete "and test." OC1-D was a standby capsule with no commitment for testing.

3 18 Delete "and test." OC3-F was a standby capsule with no commitment for testing.

3 21 Change "the B&WOG" to "NMC" for accuracy.

4 11, 12, 14 Change "fourth" to "fifth" for accuracy.

7 5, 6 Under the fifth column entitled "Notes," omit note 3 for consistency. None of the other capsule irradiation locations are noted.

7 6

Under the second column entitled "Capsule ID," omit Capsule ID "F." This capsule was unable to be removed and is still in the reactor.

7 7

Under the second column entitled "Capsule ID," Omit Capsule ID 'A," or substitute with "W1."

7 17 Omit note 3 for consistency.