ML12319A132

FENOC - NRC Pre-Application Meeting License Amendment Request November 15, 2012

ML12319A132
Person / Time
Site:	Beaver Valley
Issue date:	11/15/2012
From:	FirstEnergy Nuclear Operating Co
To:	Peter Bamford Plant Licensing Branch 1
Bamford P
References
TAC ME9582, TAC ME9583
Download: ML12319A132 (16)

Text

FENOC - NRC Pre-Application Meeting License Amendment Request November 15, 2012 Beaver Valley Power Station, Unit No. 1

FENOC Representatives Carmen Mancuso - Acting Director of Engineering Tom Lentz, Manager - Fleet Licensing Carl Battistone, Acting Manager - Technical Services Phil Lashley, Supervisor - Fleet Licensing Wes Williams, Technical Services Engineer Ken McMullen, Licensing Engineer Nathan Palm, Westinghouse Engineer 2

Requested Licensee Action Incorporate Alternate PTS Rule BVPS-1 will reach PTS Rule (10 CFR 50.61) screening criteria before end of license extension (EOLE).

Must submit remedial action plan 3 years before exceeding 10 CFR 50.61 criteria.

Alternate PTS Rule (10 CFR 50.61a) provides updated screening criteria.

Resolution of the vessel PTS screening is a license renewal commitment for BVPS-1.

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Requested Licensee Action Incorporate Alternate PTS Rule Incorporate 10 CFR 50.61a in lieu of 10 CFR 50.61 No changes to current Technical Specifications 10 CFR 50.61a(c) requires License Amendment Application 4

Requested Licensee Action Incorporate Alternate PTS Rule 10 CFR 50.61a requires:

- Each licensee shall have projected values of RTMAX-X for each reactor vessel beltline material for the EOLE fluence of the material

- Each licensee shall perform an examination and an assessment of flaws in the reactor vessel beltline as required by paragraph (e)

- Each licensee shall compare the projected RTMAX-X values for plates, forgings, axial welds, and circumferential welds to the PTS screening criteria in Table 1

- Each licensee shall evaluate the results from plant-specific or integrated surveillance program if the surveillance data satisfy the criteria in 10 CFR 50.61a(f) 5

Requested Licensee Action Incorporate Alternate PTS Rule Safety Evaluation Report Related to the License Renewal of BVPS-1 and BVPS-2 (NUREG-1929):

The limiting beltline material at Unit 1 is Lower Shell Plate B6903-1 (Heat No. C6317-1). The RT PTS value for this material at the end of the period of extended operation is 275.7F, which exceeds the 270F PTS screening limit for plates. The 270F screening limit for this material will be reached at a fluence level of 4.961 x 1019n/cm2 (E > 1.0 MeV). This fluence level will be reached in the year 2033 (43.87 EFPYs).

The 10 CFR 50.61 PTS numbers will be updated over time based on operating history 6

Requested Licensee Action Incorporate Alternate PTS Rule NUREG-1929(continued):

Commitment - Prior to exceeding the PTS screening criteria for BVPS Unit 1, FENOC [the applicant] will select a [neutron] flux reduction measure to manage PTS in accordance with the requirements of 10 CFR 50.61. A flux reduction plan will be submitted for NRC review and approval at least 1 year prior to implementation of the flux reduction measure.

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Requested Licensee Action Incorporate Alternate PTS Rule Technical Basis for Revision of the Pressurized Thermal Shock (PTS) Screening Limit in the PTS Rule (10 CFR 50.61), NUREG-1806:

Acknowledges the limitations of the input used in the 1980s resulted in significant conservatisms Revised approach:

- Utilized realistic input values and models

- Focused on an explicit treatment of uncertainties Revision of the PTS screening limits was proposed in NUREG-1874, Recommended Screening Limits for Pressurized Thermal Shock (PTS) 8

Requested Licensee Action Incorporate Alternate PTS Rule Proposed amendment has been reviewed against Generic Design Criteria (GDC),

NUREG-0800 Standard Review Plan (SRP), Regulatory Guides, and Branch Technical Position (BTP) documents to determine whether applicable regulations, requirements, and guidance will continue to be met; specifically:

GDC 1, Quality Standards and Records GDC 31, Fracture prevention of the reactor coolant pressure boundary GDC 32, Inspection of the reactor coolant pressure boundary Regulatory Guide 1.190, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence Regulatory Guide 1.99, Radiation Embrittement of Reactor Vessel Materials (Not applicable to 10 CFR 50.61(a))

SRP Section 5.3.2, Pressure-Temperature Limits, Upper-Shelf Energy, and Pressurized Thermal Shock and SRP Section 5.3.3, Reactor Vessel Integrity (Not applicable to 10 CFR 50.61(a))

10 CFR 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements BTP 5-3, Fracture Toughness Requirements (Not applicable to 10 CFR 50.61(a))

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Evaluation RTMAX-X values for BVPS-1 are below the 10 CFR 50.61a Table 1 screening criteria at EOLE Results of last ASME Section XI Appendix VIII qualified inspection satisfy the requirements of paragraph (e)

Mean and outlier deviation tests ((f)(6)(i) and (f)(6) (iii))

are not satisfied by the base metal surveillance capsule results for lower shell plate B6903-1

- Adjustment made to RTMAX-X values to account for deviation (to be discussed later in the presentation)

RTMAX-X values calculated realizing that BVPS-1 was fabricated by multiple vendors 10

RTMAX-X Criteria Alternate PTS Rule Limiting Vessel Components Criteria Axial Welds 269°F Circumferential Welds 312°F Plates 356°F Axial Welds & Plates 538°F 11

Evaluation of BVPS-1 ISI Data Three 10-Year inservice inspections have been performed for the BVPS-1 RV welds The most recent inservice inspection was performed to ASME Section XI, Appendix VIII, 1989 Edition with no Addenda, as modified by 10 CFR 50.55a(b)(2)(xiv, xv and xvi)

Based on the inservice inspection data, the requirements of 10 CFR 50.61a(e) are met.

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Evaluation of Surveillance Capsule Data All BVPS-1 and applicable sister plant surveillance capsule data (SCD) evaluated All three tests (mean, slope, outlier) satisfied for all materials with exception of mean and outlier tests for lower shell plate B6903-1 Adjustment made to RTMAX-X values to account for lower shell plate B6903-1 not satisfying mean and outlier deviation tests

- Calculated the adjustment temperature needed to satisfy the mean or outlier statistical tests

- Added the adjustment temperature to all the predicted SCD values, which reduced the residual values by the same amount, and showed that all three statistical tests are now satisfied

- Added the adjustment temperature to the predicted values of T30 and RTMAX-X for the lower shell plate B6903-1

- Approach is consistent with MRP-334, Materials Reliability Program: Proposed Resolutions to the Analytical Challenges of Alternate PTS Rule (10 CFR 50.61a)

Implementation 13

Calculation of RTMAX-X with Different Vessel Fabricators BVPS-1 RV was fabricated by Babcock and Wilcox (B&W) and Combustion Engineering (CE)

- Procurement and testing of plates was performed by B&W

- Welding and machining was performed by CE Equation 7 in 10 CFR 50.61a differentiates between CE and non-CE plate Since BVPS-1 plate was procured and tested by B&W, RTMAX-X values calculated based on non-CE plate 14

Requested Licensee Action Incorporate Alternate PTS Rule Preliminary results of the review:

Consistent with 10 CFR 50.61a No significant hazards No change to the site Environmental Plan No impact on the environment 15

ncorporate Alternate PTS Rule Next Steps:

Submittal planned for March 2013 Normal NRC review period 16