ML13002A008

Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule

ML13002A008
Person / Time
Site:	San Onofre
Issue date:	12/27/2012
From:	St.Onge R Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13002A008 (6)

Text

Richard J.St. Onge J EDISON SOUTHERN CALIFORNIA Director, Nuclear Regulatory Affairs and Emergency Planning An EDISON INTERNATIONAL Company 10 CFR 50, Appendix H, III.B.3 December 27, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Docket Nos. 50-361 and 50-362 Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule San Onofre Nuclear Generating Station (SONGS) Units 2 and 3

References:

1. Materials Reliability Program: Coordinated PWR Reactor Vessel Surveillance Program (CRVSP) Guidelines (MRP-326). EPRI, Palo Alto, CA: 2011.

102287.

Dear Sir or Madam:

Pursuant to 10 CFR 50, Appendix H, III.B.3, Southern California Edison (SCE) is requesting Nuclear Regulatory Commission (NRC) review and approval of the enclosed revision to the surveillance capsule removal schedule for SONGS Units 2 and 3. The proposed reactor vessel surveillance capsule removal schedule was developed to implement recommendations in MRP-326, CoordinatedPressure Water Reactor (PWR) Reactor Vessel Surveillance Program (CRVSP) Guidelinesfor SONGS Units 2 and 3. The Industry program defined in MRP-326 addresses the need for reactor vessel property data at fluences representative of 60 years of operation and beyond.

The requested change to the SONGS Units 2 and 3 reactor vessel surveillance capsule removal schedule satisfies the requirements of 10 CFR 50, Appendix H and ASTM E-185-82, "Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels", dated July 1, 1982.

Approval of this proposed change is requested by December 31, 2014.

This letter and the enclosure contain no new commitments.

If you have any questions or require additional information concerning this subject, please contact Mr. Mark E. Morgan at (949) 368-6745.

Sincerely, P.O. Box 128 San Clemente, CA 92672

Document Control Desk December 27, 2012

Enclosure:

1. Proposed Change to the Reactor Vessel Surveillance Program Capsule Pull Schedule, San Onofre Nuclear Generation Station (SONGS) Units 2 and 3 cc: E.E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, SONGS Units 2, and 3 B. Benney, NRC Project Manager, SONGS Units 2 and 3 G. G. Wamick, NRC Senior Resident Inspector, SONGS Units 2 and 3

Enclosure 1 Proposed Change to the Reactor Vessel Surveillance Program Capsule Pull Schedule San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 10 CFR 50, Appendix H, 1Il.B.3, as Recommended by MRP-326

Enclosure 1 Proposed Change to the Reactor Vessel Surveillance Program Capsule Pull Schedule San Onofre Nuclear Generation Station (SONGS) Units 2 and 3

1.0 Background

Appendix H to 10 CFR Part 50 describes reactor vessel material surveillance program requirements. Paragraph (111)(B)(3) of this Appendix states that a proposed material withdrawal schedule must be submitted with a technical justification per 10 CFR 50.4, and approved prior to implementation.

Industry has developed a Coordinated Pressurized Water Reactor (PWR) Reactor Vessel Surveillance Program (CRVSP), which is documented in MRP-326, CoordinatedPWR Reactor Vessel Surveillance Program (CRVSP) Guidelines. The purpose of the CRVSP is to increase the fluence levels of future surveillance capsules at withdrawal while maintaining compliant with 10 CFR 50 Appendix H and consistent with the guidance of NUREG-1801, Rev. 2, GALL Report. The CRVSP will help generate high fluence PWR surveillance data in support of extended life operations.

The proposed withdrawal schedule satisfies the requirements of American Society for Testing and Materials (ASTM) E 185-73 the version that was current at the time the reactor vessel surveillance program was designed.

Table (1) shows the currently approved withdrawal schedule for San Onofre Nuclear Generating Stations (SONGS) Units 2 and 3 reactor vessel surveillance capsules (Updated Final Safety Analysis Report Table 5.3-12).

2.0 Proposed Revision Table (2) provides the proposed revision to the reactor vessel surveillance capsule withdrawal schedule for SONGS Units 2 and 3. The revised schedule is based on the recommendations for SONGS Units 2 and 3 in MRP-326, and reflects updated fluence information from previously removed surveillance capsules with appropriate adjustment made for fuels loaded in subsequent cycles. As shown below in Section 3.0, the proposed withdrawal schedule satisfies the requirements of ASTM E 185-73, the version that was current at the time the reactor vessels were designed and is consistent with ASTM E 185-82 and the current requirements of Appendix H to 10 CFR Part 50.

3.0 Justification The SONGS Units 2 and 3 reactor vessel was designed to the 1971 Edition through the summer 1971 Addenda of the American Society of Mechanical Engineers Code. American Society for Testing and Materials E 185-73 was the current standard when the surveillance program was designed. As stated in the SONGS Units 2 and 3 Updated Final Safety Analysis Report section 5.3.1.6, the reactor vessel surveillance program meets the requirements of ASTM E 185 and 10CFR50 Appendix H.

The guidance provided in ASTM E 185-82 is consistent with, but more specific than, the guidance provided in earlier editions, including ASTM E 185-73 to which the SONGS Units 2 and 3 reactor vessel surveillance program is required to conform. Therefore, compliance with Page 1 of 3

Enclosure 1 Proposed Change to the Reactor Vessel Surveillance Program Capsule Pull Schedule San Onofre Nuclear Generation Station (SONGS) Units 2 and 3 the ASTM E185-82 withdrawal schedule guidance ensures compliance with ASTM E 185-73 withdrawal schedule guidance. ASTM E 185-82 provides a withdrawal schedule in terms of years of operation but also provides the option to develop a schedule tied to target fluences accumulated in the vessel. As in the case of the currently approved withdrawal schedule, the proposed withdrawal schedule follows the guidance that ties the withdrawal schedule to vessel fluence targets.

This request proposes to revise the reactor vessel surveillance capsule withdrawal schedule from approximately 24 Effective Full Power Years (EFPY) of operation to the refueling outage most closely approaching 26.5 EFPY. Additional explanation of the basis for proposed changes to the SONGS Units 2 and 3 surveillance capsule schedule is provided in MRP-326.

The capsules located at the 83 degree azimuthal locations meet the requirements of ASTM E 185-82 to withdraw the third capsule at a time when the accumulated neutron fluence on the capsule corresponds to the approximate end of life peak fluence at the reactor vessel %T location. As noted on Table (2), SCE plans to withdraw the 83-degree capsules at approximately 26.5 EFPY which approximately corresponds to the cycle-1 9 refueling outages of both Units. SONGS Units 2 and 3 are currently in extended outages to implement replacement steam generator repairs. It is not possible to accurately forecast the date at which target neutron fluences will be achieved. This proposed change meets the requirements of Appendix H to 10 CFR Part 50.

Three (3) additional standby reactor vessel material surveillance capsules located at the 104, 284 and 277 degree azimuthal locations remain available for monitoring material properties during a period of extended operation beyond the current license expiration.

Page 2 of 3

Enclosure 1 Proposed Change to the Reactor Vessel Surveillance Program Capsule Pull Schedule San Onofre Nuclear Generation Station (SONGS) Units 2 and 3 Table 1 Current SONGS Units 2 and 3 Reactor Vessel Surveillance Program Capsule Removal Schedule Capsule Azimuthal SONGS Unit-2 SONGS Unit-3 Number Location Removal Neutron Removal Time Neutron (degrees) Time (EFPY) Fluence (EFPY) Fluence (x 1019 n/cm2) (x 1019 n/cm 2 )

1 83 24 3.8 x 1019 24 3.8 x 1019 2 97 2.85 5.07 x 1O'8 4.33 8.0 x 101l 3 104 Standby Standby 4 284 Standby -- Standby --

5 263 13.3 2.2 x 1019 14.92 2.47 x 1019 6 277 Standby Standby --

Table 2 Proposed SONGS Units 2 and 3 Reactor Vessel Surveillance Program Capsule Removal Schedule Capsule Azimuthal SONGS Unit-2 SONGS Unit-3 Number Location Removal Neutron Removal Time Neutron (degrees) Time (EFPY) Fluence (EFPY) Fluence (x 1019 (x 1019 n/cm 2) n/cm 2) 1 83 26.5 (a) 4.37 x 101 9 26.5 (a) 4.19 x 101 9 (a)

(a) 2 97 2.85 5.07 x 101" 4.33 8.0 x 1018 3 104 Standby Standby --

4 284 Standby -- Standby --

5 263 13.3 2.2 x 10' 9 14.92 2.47 x 10' 9 6 277 Standby Standby (a) Proposed revision to capsule removal schedule based on MRP-326 Page 3 of 3