RBG-47824, License Amendment Request to Correct a Non-Conservative Technical Specification Figure 3.4.11-1 Minimum Temperature Required Vs. RCS Pressure by Replacing with 54 Effective Full Power Years (EFPY) Curves

License Amendment Request to Correct a Non-Conservative Technical Specification Figure 3.4.11-1 Minimum Temperature Required Vs. RCS Pressure by Replacing with 54 Effective Full Power Years (EFPY) Curves

ML18092B187
Person / Time
Site:	River Bend  (NPF-047)
Issue date:	04/02/2018
From:	Maguire W Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18093A374	List: RBG-47824, License Amendment Request to Correct a Non-Conservative Technical Specification Figure 3.4.11-1 Minimum Temperature Required Vs. RCS Pressure by Replacing with 54 Effective Full Power Years (EFPY) Curves
References
RBG-47824 NEDO-33882 Rev. 1
Download: ML18092B187 (80)

Text

Proprietary Information - Withhold From Public Disclosure Under 10 CFR 2.390.

The balance of this letter may be considered non-proprietary upon removal of.

. ~ Entergx Entergy Operat4ons, Inc.

River Bend Station 5485 U.S. Highway 61N St Francisville, LA 70775 RBG-47824 April 2, 2018 U, S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Tel 225*381*4374 William F. Maguire Site Vice President River Bend Station

Subject:

License Amendment Request to Correct a Non-Conservative Technical Specification Figure 3.4.11-1 "Minimum Temperature Required vs. RCS Pressure" by Replacing with 54 Effective Full Power Years (EFPY) Curves River Bend Station - Unit 1 Docket No. 50-458 License No. NPF-47 Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests a license amendment to the Facility Operating License NPF-47 for River Bend Station (River Bend), Unit

1.

River Bend (RBS) has identified that the River Bend (RBS) Technical Specifications (TS) Figure 3.4.11 -1 "Minimum Temperature Required vs. RCS Pressure" for reactor heatup, cooldown, and critical operations as well as for inservice leak tests and hydrostatic tests for the Reactor Coolant System (RCS) is non-conservative. Current plant operations are administratively controlled as described in NRC Administrative Letter (AL) 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety."

The proposed change is to replace the non-conservative curve which is for 34 Effective Full Power Years (EFPY) with a new curve that is 54 EFPYs. The new 54 EFPY limits include new fluence values and material chemistry information.

The Enclosure 1 includes the description of the change, no significant hazards consideration determination, and evaluation for environmental impact. Attachment 1 to the Enclosure provides a copy of the marked-up TS pages and attachment 2 provides a copy of the clean TS Pages. Attachment 3 contains TS Bases (information only). Attachment 4 contains the non-proprietary documentation from GE, GEH Letter NEDO-33882 Rev. 1 "Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full Power Years".

RBG-47824 Page 2 of 3 is proprietary in its entirety, as it contains information that is proprietary to General Electric Hitachi (GEH) and Electric Power Research Institute (EPRI). Attachment 5 and 6 contain the Proprietary Information Affidavits. The purpose of this attachment is to withhold the proprietary information contained in Attachment 7 from public disclosure. The Affidavits signed by GEH and EPRI as the owner of the information, set forth the basis for which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 1 OCFR 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information proprietary to GEH and EPRI be withheld from public disclosure in accordance with 1 OCFR 2.390.

The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that the proposed change involves no significant hazards consideration.

Although this request is neither exigent nor emergency, your prompt review is requested.

Entergy requests prompt review and approval of this LAR to implement the RBS 54 Effective Full Power Years (EFPY) Pressure-Temperature Limits Curves by February 28, 2019, to support Beginning of Cycle 21 (BOC21) startup. Entergy will implement the amendment within 30 days of the NRC approval date.

In accordance with 10 CFR 50.91 (b)(1), Entergy is notifying the State of Louisiana and the State of Texas of this LAR by transmitting a copy of this letter and enclosure to the designated State Official.

This letter does not contain any new commitments.

If you have any questions or require additional information, please contact Mr. Tim Schenk at (225) 381-4177 or tschenk@entergy.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 2, 2018.

WFMI r

EnciOSUre 1: Evaluation Of The Proposed Change - Correct a Non-Conservative Technical Specification Figure : Technical Specification (TS) Pages - Markups : Technical Specification (TS) Pages - Clean : Technical Specification Bases (Bases) - Markups : GEH Letter NEDO-33882 Rev. 1 "Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full Power Years" (Non-Proprietary Information) : GEH Letter NEDC-33882P Affidavit from General Electric Hitachi (GEH) : GEH Letter NEDC-33882P Affidavit from Electric Power Research Institute (EPRI) : PROPRIETARY GEH Letter NEDC-33882P Rev. 1 "Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full Power Years"

RBG-47824 Page 3 of 3 cc:

U.S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.

Arlington, TX 76011 -4511 Ms. Lisa M. Regner, Project Manager U.S. Nuclear Regulatory Commission MS-8-H4 One White Flint North 11555 Rockville Pike Rockville, MD 20852 NRC Senior Resident Inspector PO Box 1050 St. Francisville, LA 70775 Department of Environmental Quality Office of Environmental Compliance Radiological Emergency Planning and Response Section Ji Young Wiley P.O. Box 4312 Baton Rouge, LA 70821 -4312 Public Utility Commission of Texas Attn: PUC Filing Clerk 1701 N. Congress Avenue P. O. Box 13326 Austin, TX 78711-3326 RBF1-18-0012 LAR 2017-09

RBG-47824 Page 1 of 6 ENCLOSURE 1 RBG-47824 Evaluation Of The Proposed Change - Correct a Non-Conservative Technical Specification Figure

1.

SUMMARY

DESCRIPTION............................................................................ 2

2.

DETAILED DESCRiPTION............................................................................. 2 2.1 System Design and Operation................................................................ 2 2.2 Current Technical Specifications Requirements.......................................... 3 2.3 Reason for Proposed Change................................................................. 3 2.4 Description of Proposed Change.............................................................4

3.

TECHNICAL EVALUATION............................................................................4

4.

REGULATORY EVALUATION.........................................................................4 4.1 Applicable Regulatory Requirements/Criteria.............................................4 4.2 No Significant Hazards Consideration Determination Analysis....................... 5 4.3 Conclusion...................................,.....,................................................ 6

5.

ENVIRONMENTAL CONSiDERATION.............................................................. 6

6.

REFERENCES............................................................................................. 6 ATTACHMENTS: : Technical Specification (TS) Page - Markups : Technical Specification (TS) Page - Clean : Technical Specification Bases (Bases) - Markups : GEH Letter NEDO-33882 Rev. 1 "Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full Power Years" (Non-Proprietary Information) : GEH Letter NEDC-33882P Affidavit from General Electric Hitachi (GEH) : GEH Letter NEDC-33882P Affidavit from Electric Power Research Institute (EPRI) : PROPRIETARY GEH Letter NEDC-33882P Rev. 1 "Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full Power Years"

RBG-47824 Page 2 of 6

1.

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests a license amendment to the Facility Operating License NPF-47 for River Bend Station (River Bend), Unit

1. This change concerns non-conservative Technical Specification (TS) Figure 3.4.11-1 "Minimum Temperature Required vs. RCS Pressure".

2. DETAILED DESCRIPTION 2.1 System Design and Operation All components of the Reactor Coolant System (RCS) are designed to withstand effects of cyclic loads due to system pressure and temperature changes. These loads are introduced by startup (heatup) and shutdown (cooldown) operations, power transients, and reactor trips. TS LCO 3.4.11 "RCS PIT Limits" limits the pressure and temperature changes during RCS heatup and cooldown, within the design assumptions and the stress limits for cyclic operation.

TS Figure 3.4.11 -1 contains Pressure-Temperature (PIT) limit curves for heatup and cooldown. The curves provide limits for inservice leak and hydrostatic test, core not critical, and core critical operation.

Each PIT limit curve defines an acceptable region for normal operation. The usual use of the curves is operational guidance during heatup or cooldown maneuvering, when pressure and temperature indications are monitored and compared to the applicable curve to determine that operation is within the allowable region.

TS LCO 3.4.11 establishes operating limits that provide a margin to brittle failure of the reactor vessel and piping of the reactor coolant pressure boundary (RCPB). The vessel is the component most subject to brittle failure.

The PIT limit curves on TS Figure 3.4.11-1 are composite curves established by superimposing limits derived from stress analyses of those portions of the reactor vessel and head that are the most restrictive. At any specific pressure, temperature, and temperature rate of change, one location within the reactor vessel will dictate the most restrictive limit. Across the span of the PIT limit curves, different locations are more restrictive, and, thus, the curves are composites of the most restrictive regions.

The current TS Figure 3.4.11 -1 shows a set of PIT curves for the heat-up and cool-down operating conditions. These curves apply for both the 1/4T (inside surface flaw) and 3/4T (outside surface flaw) locations. When combining pressure and thermal stresses, it is usually necessary to evaluate stresses at the 1/4T location and the 3/4T location. This is because the thermal gradient tensile stress of interest is in the inner wall during cool-down and is in the outer wall during heatup. However, as a conservative simplification, the thermal gradient stress at the 1/4T is assumed to be tensile for both heatup and cooldown.

This results in the approach of applying the maximum tensile stress at the 1/4T location.

This approach is conservative for two reasons: 1) the maximum stress is used regardless of flaw location, and 2) the irradiation effects cause the allowable toughness, K1 c at 1/4T to be

RBG-47824 Page 3 of 6 less than that at 3/4T for a given metal temperature. This approach causes no operational difficulties since the SWR is at steam saturation conditions during normal operation, satisfying the heatuplcooldown curve limits.

The core critical limits include the 10 CFR 50, Appendix G requirement that they be at least 40°F above the heatup curve or the cooldown curve and not lower than the minimum permissible temperature for the inservice leak and hydrostatic testing.

If RBS was to violate the TS LCO 3.4-11 limits, the consequences could be that the RCS had been operated under conditions that could result in brittle failure of the RCPB, possibly leading to a nonisolable leak or loss of coolant accident. In the event these limits are exceeded, an evaluation must be performed to determine the effect on the structural integrity of the RCPS components. The ASME Code,Section XI, Appendix E, provides a recommended method for evaluating an operating event that causes an excursion outside the limits. The PIT limits are not derived from Design Basis Accident (DBA) analyses. They are prescribed during normal operation to avoid encountering pressure, temperature, and temperature rate of change conditions that might cause undetected flaws to propagate and cause nonductile failure of the RCPB, a condition that is unanalyzed. Since the PIT limits are not derived from any DBA, there are no acceptance limits related to the PIT limits.

Rather, the PIT limits are acceptance limits themselves since they preclude operation in an unanalyzed condition.

RCS PIT limits satisfy Criterion 2 of the NRC Policy Statement.

10 CFR 50, Appendix G requires establishing reactor pressure vessel PIT limits to provide adequate margins of safety in accordance with ASME Code,Section III, Appendix G. Shifts in the reference temperature, RT NDT. are periodically established in accordance with ASTM E 185 and 10 CFR 50, Appendix H. Furthermore, USNRC Regulatory Guide (RG) 1.99, Revision 2, "Radiation Embrittlement of Reactor Vessel Materials," provides guidance for calculating shifts in reference temperature (with or without surveillance data available), and the methods given in ASME Section III, Appendix G are to be used in calculating the PIT limit curves.

2.2 Current Technical Specifications Requirements GEH provided the pressure temperature limit curves in the current TS (Figure 3.4.11-1),

which were incorporated into the TS via Amendment 120 received from the NRC on September 14, 2001. These curves analyzed the RPV pressure-temperature limits for operation out to 32 effective full power years (EFPY) using ASME CODE CASE N-640.

2.3 Reason for Proposed Change RBS was notified by GEH via reference 2 that the current pressure temperature limit curves in the TS (Figure 3.4.11-1) were non-conservative.

RBS concluded that curves Sand C found on TS Figure 3.4.11 -1 do not include the bounding limitations due to the reactor vessel discontinuity at the N 12 WLI nozzle. The methodology used for the 2000 pressure temperature limit curves improperly omitted the effects of the N 12 WLI nozzle discontinuity. The 2009 revised methodology included the N 12 WLI nozzle effects and produced the associated more limiting curves. RBS updated

RBG-47824 Page 4 of 6 the STP-050-0700 "RCS Pressurel Temperature Limits Verification" with the curves provided as well as contracted GEH to provide revised pressure temperature limit curves.

Additionally, RBS retroactively verified that plant operations had remained within the bounding curves provided by GEH.

In preparing this license amendment, RBS elected to use the 54-EFPY curves provided by GEH for license renewal. The new neutron fluence data determined for license renewal is a direct input into PIT curves. The PIT curves presented by GEH reflect changes from the 32 EFPY PIT curves. The curves are also based on the most recent surveillance program data and incorporate the methodologies described in the GEH PIT Curve Licensing Topical Report (L TR) NEDC-33178P-A to appropriately address the reactor vessel shell discontinuity at the WLI nozzle. The PIT curves presented by GEH do not account for any instrument uncertainty.

2.4 Description of Proposed Change Replace TS Figure 3.4.11-1 "Minimum Temperature Required vs. RCS Pressure" with the 54-EFPY Pressure Temperature Limit Curves provided in GEH Letter NEDO-33882 Rev. 1 "Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full Power Years" (Non-Proprietary Information). Even though the title of the GEH document contains the wording "Pressure and Temperature Limits Report (PTLR)", RBS in not requesting to remove the curves from the TS.

3 TECHNICAL EVALUATION The technical basis for the proposed revision to TS Figure 3.4.11-1 PIT limit curves provided in the attached GEH Letter NEDO-33882 Rev. 1 "Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full Power Years" (Non-Proprietary Information).

The pressure-temperature (PIT) curves included in the report have been developed to present steam dome pressure versus minimum vessel metal temperature incorporating appropriate non-beltline limits and irradiation embrittlement effects in the beltline. Complete PIT curves were developed for 54 effective full power years (EFPY). The report incorporates a fluence (E > 1 MeV) calculated by GEH using an NRC-approved methodology in accordance with Regulatory Guide 1.190. The calculation utilizes the latest information from the BWRVIP Integrated Surveillance Program that is applicable to River Bend Station (RBS).

The P-T curves presented in this report reflect changes from the 32 EFPY P-T curves.

These 54 EFPY P-T curves have been generated to incorporate a revised fluence incorporating the methodologies described in the GEH P-T Curve Licensing Topical Report (LTR) NEDC-33178P-A.

4 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria RCS PIT limits satisfy Criterion 2 of the NRC Policy Statement.

RBG-47824 Page 5 of 6 10 CFR 50, Appendix G requires establishing reactor pressure vessel PIT limits to provide adequate margins of safety in accordance with ASME Code,Section III, Appendix G. Shifts in the reference temperature, RT NOT. are periodically established in accordance with ASTM E 185 and 10 CFR 50, Appendix H. Furthermore, USNRC Regulatory Guide (RG) 1.99, Revision 2, "Radiation Embrittlement of Reactor Vessel Materials," provides guidance for calculating shifts in reference temperature (with or without surveillance data available), and the methods given in ASME Section III, Appendix G are to be used in calculating the PIT limit curves.

4.2 No Significant Hazards Consideration Determination Analysis Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests a license amendment to the Facility Operating License NPF-47 for River Bend Station (River Bend),

Unit 1. This change concerns non-conservative Technical Specification (TS) Figure 3.4.11 -1 "Minimum Temperature Required vs. RCS Pressure" for reactor coolant system heatup, cooldown, and critical operations, and for in service leak and hydrostatic tests.

Entergy has evaluated whether a significant hazards consideration is involved with the proposed change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No BASIS: The proposed change to the River Bend reactor coolant system (RCS) pressure/temperature (PIT) limits does not modify the boundary, operating pressure, materials or seismic loading of the reactor coolant system. The proposed change does adjust the PIT limits for neutron irradiation effects to ensure that the Reactor Pressure Vessel (RPV) fracture toughness is consistent with analysis assumptions and NRC regulations. Changing the applicability of the limits to 54 effective full power years (EFPY) will continue to maintain appropriate limits for River Bend during the renewed license term.

The proposed limits are more bounding than the current limits.

Therefore, it is concluded that this change does not significantly increase the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No BASIS: The proposed change to the reactor pressure vessel pressure-temperature limits does not involve any physical changes (installing new equipment or modifying existing equipment). The change does not affect the assumed accident performance of any structure, system or component previously evaluated. These revised limits are in compliance with the brittle fracture requirements of 1 OCFR50 Appendix G. The proposed change does not introduce any new modes of system operation or failure mechanisms.

RBG-47824 Page 6 of 6 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No BASIS: The proposed change, which corrects a non-conservative TS, does not exceed or alter a setpoint, design basis or safety limit. Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Based on the preceding analysis, it is concluded that operation of River Bend in accordance with the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92.

4.3 Conclusions In conclusion, based on the considerations discussed above, (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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5 ENVIRONMENTAL CONSIDERATION The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6 REFERENCES

1. "Licensing Topical Report GE Hitachi Nuclear Energy Methodology for Development of Reactor Pressure Vessel Pressure-Temperature Curves", NEDC-33178P-A, Class III, June 2009.

2. Draft for Utility Review "Impact Assessment for Water Level Instrumentation Nozzle (Penetration) on Pressure-Temperature (PT) Curves Provided to BWROG Members",

file number 0000-0106-1545, September 17, 2009.

3. SA Kleinsmith, "Pressure-Temperature Curves for Entergy Operations Inc. (EOI), Using the KIC Methodology, River Bend", GENE, San Jose, CA, Class III, GE-NE-B13-02094-00-01, Revision 0, January 2001.

RBG-47824 Page 1 of 2 RBG-47824 Technical Specification (TS) Page - Markups

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RCS PIT Limits 3.4.11 INITIAL RTnd\\ VALUES ARE

• 50°F FOR BEL TLiNE 10°F FOR UPPER VESSEL, AND 19'F FOR BOnOM HEAD BEL TLINE CURVES ADJUSTED AS SHOWN:

EFPY SHIFT (OF) 32 152 HEA TUP/COOLDOWN RATE OF COOLANT

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RBG-47824 Page 1 of 2 RBG-47824 Technical Specification (TS) Page - Clean

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RCS PIT Limits 3.4.11 ACCEPTABLE REGION OF OPERATlO IS TO THE RIGHT OF THE APPLICABLE CURVE HEAlUPICOOLDOWN RATE OF COOLANT

.!: 2O°FIHR FOR CURVE A,

~ 100*F/HR FOR CURVES 8&C A, 8, C LlMmNG CURVES A - PRESSURE TEST WITH FUEL THE VESSEL 8 -

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[Without Uncertainty for Instrumentation Error]

RIVER BEND 3.4-32 Amendment No.

RBG-47824 Page 1 of 3 RBG-47824 Technical Specification (TS) Bases Page - Markups (Information only)

BASES RCS PIT Limits B3.4.11 BACKGROUND The operating PIT limit curves will be adjusted, as necessary, based on the (continued) evaluation findings and the recommendations of Reference 5.

RIVER BEND The PIT limit curves are composite curves established by superimposing limits derived from stress analyses of those portions of the reactor vessel and head that are the most restrictive. At any specific pressure, temperature, and temperature rate of change, one location within the reactor vessel will dictate the most restrictive limit. Across the span of the PIT limit curves, different locations are more restrictive, and, thus, the curves are composites of the most restrictive regions.

Figure 3.4.11-1 shows a set of P-T curves for the heat-up and cool-down operating conditions. The P-T curves do not account for any instrument uncertainty. These curves apply for both the 1/4T and 3/4T locations. When combining pressure and thermal stresses, it is usually necessary to evaluate stresses at the 1/4T location (inside surface flaw) and the 3/4T location (outside surface flaw). This is because the thermal gradient tensile stress of interest is in the inner wall during cool-down and is in the outer wall during heatup.

However, as a conservative simplification, the thermal gradient stress at the 1/4T is assumed to be tensile for both heatup and cooldown. This results in the approach of applying the maximum tensile stress at the 1/4T location. This approach is conservative for two reasons: 1) the maximum stress is used regardless of flaw location, and 2) the irradiation effects cause the allowable toughness, K,c at 1/4T to be less than that at 3/4T for a given metal temperature (Reference 9). This approach causes no operational difficulties since the BWR is at steam saturation conditions during normal operation, satisfying the heatuplcooldown curve limits.

The core critical limits include the Reference 1 requirement that they be at least 40°F above the heatup curve or the cooldown curve and not lower than the minimum permissible temperature for the inservice leak and hydrostatic testing.

The consequence of violating the LCO limits is that the RCS has been operated under conditions that can result in brittle failure of the RCPB, possibly leading to a nonisolable leak or loss of coolant accident. In the event these limits are exceeded, an evaluation must be performed to determine the effect on the structural integrity of the RCPB components. The ASME Code,Section XI, Appendix E (Ref. 6), provides a recommended methodology for evaluating an operating event that causes an excursion outside the limits.

( continued)

B 3.4-54 Revision No. 6-4J I

SURVEILLANCE REQUIREMENTS REFERENCES RIVER BEND SR 3.4.11.8 and SR 3.4.11.9 (continued)

Plant specific test data has determined that the bottom head is not subject to temperature stratification with natural circulation at power levels as low as 36% of RTP or with any single loop flow rate when the recirculation pump is on high speed operation. Therefore, SR 3.4.11.8 and SR 3.4.11.9 have been modified by a Note that requires the Surveillance to be met only when THERMAL POWER or loop flow is being increased when the above conditions are not met. The Note for SR 3.4.11.9 further limits the requirement for this Surveillance to exclude comparison of the idle loop temperature if the idle loop is isolated from the RPV since the water in the loop can not be introduced into the remainder of the reactor coolant system.

1.

10 CFR 50, Appendix G.

2.

ASME, Boiler and Pressure Vessel Code,Section III, Appendix G.

3.

ASTM E 185-82, "Standard Practice for Conducting Surveillance Tests For Light-Water Cooled Nuclear Power Reactor Vessels,"

July 1982.

4.

10 CFR 50, Appendix H.

5.

Regulatory Guide 1.99, Revision 2, May 1988.

6.

ASME, Boiler and Pressure Vessel Code,Section XI, Appendix E.

7.

R.G. Carey and B.J. Branlund, "105% Power Uprate Evaluation Report for Entergy Operations Inc. River Bend Station GE Task No.

12.0 Reactor Vessel Fracture Toughness," GE-NE, San Jose, CA, February 1999, (GE-NE-A22-00081 -12).

8.

USAR, Section 15.4.4.

9.

GE NE B13 02094 00 01, Revision 0, Class III January 2001.

"Pressure Temperature Curves for Entergy Operations, Inc. (EOI) using K ~ Methodology River Bend." Deleted 9:-10 GEH Letter NEDC-33882P Rev. 1 "Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full Power Years" B 3.4-63 Revision No. e.44 I

RBG-47824 Page 1 of 55 RBG-47824 GEH Letter NEDO-33882 Rev. 1 "Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full Power Years" (Non-Proprietary Information) 54 pages

(e HITACHI GE Hitachi Nuclear Energy Non-Proprietary lriformation - Class 1 (Public)

Entergy Operations, Inc.

River Bend Station NEDO-33882 Revision 1 November 20 17 Pressure and Temperature Limits Report (PTLR)

Up to 54 Effective Full-Power Years Copyright 2017 GE-Hitachi Nuclear Energy Americas LLC A II Rights Reserved

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

INFORMATION NOTICE This is a non-proprietary version of the document NEDC-33882P Revision I, which has the proprietary information removed.

Portions of the document that have been removed are indicated by an open and closed bracket as shown here ((

n.

IMPORTANT NOTICE REGARDING CONTENTS OF TillS REPORT Please Read Carefully The design, engineering, and other information contained in this document is furnished for the purposes of supporting a License Amendment Request by Entergy for pressure temperature limits in proceedings before the United States (US) Nuclear Regulatory Commission (NRC).

The only undertakings of GEH with respect to information in this document are contained in the contracts between GEH and its customers or participating utilities, and nothing contained in this document shall be construed as changing that contract. The use of this information by anyone for any purpose other than that for which it is intended, is not authorized; and with respect to any unauthorized use, GEH makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document.

II

Revision No.

0 I

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Revision Summary Sections Revised Description Initial issue.

Sections 3.2, 3.7, 3.8, and 5.0 Tables I, 8-6, 8-7, The PTLR has been updated to incorporate the new fluence.

and 8-8 Figure I Appendix 0 111

NEDO-33882 Revision 1 Non-Proprietary Information - Class I (Public)

Table of Contents Abbreviations and Acronyms.......................................................................................................... v 1.0 Purpose................................................................................................................................. 1 2.0 Applicability......................................................................................................................... 1 3.0 Methodology........................................................................................................................ 1 3.1 Chemistry....................................................................................................................... 2 3.2 Fluence........................................................................................................................... 2 3.3 Initial Reference Temperature of Nil-Ductility Transition (RTNDT).............................. 3 3.4 Adjusted Reference Temperature................................................................................... 3 3.5 Surveillance Program..................................................................................................... 4 3.6 Thickness Discontinuities............................................................................................... 5 3.7 Pressure-Temperature Curves........................................................................................ 6 3.8 Reactor Coolant Pressure Boundary (RCPB)................................................................. 9 3.9 Future Changes............................................................................................................... 9 4.0 Operating Limits.................................................................................................................. 9 5.0 Discussion.......................................................................................................................... 10 6.0 References.......................................................................................................................... 11 Appendix A Reactor Vessel Material Surveillance Program..................................................... 18 Appendix B RB RPV P-T Curve Supporting Plant-Specific lnformation............................... 19 Appendix C RB Reactor Pressure Vessel P-T Curve Checklist.............................................. 35 Appendix D Sample P-T Curve Calculations.............................................................................42 Table I Table B-1 Table B-2 Table B-3 Table B-4 Table B-5 Table B-6 Table B-7 Table B-8 Table C-I Figure I Figure B-1 List of Tables RBS Tabulation of Curves - 54 EFPY.................................................................. 13 RBS Initial RTNDT Values for RPV Plate and Flange Materials........................... 21 RBS Initial RTNDT Values for RPV Nozzle Materials........................................ 22 RB Initial RTNDT Values for RPV Weld Materials........................................... 24 RBS Initial RTNDT Values for RPV Appurtenances.............................................. 28 RBS Initial RTNDT Values for RPV Bolting.......................................................... 29 RBS Adjusted Reference Temperatures for Up to 54 EFPY................................. 30 RBS RPV Beltline P-T Curve Input Values for 54 EFPY..................................... 33 RB Definition ofRPV Beltline Region'..............................................................34 RBS Checklist........................................................................................................ 36 List of Figures RB Composite P-T Curves Effective for Up to 54 EFPY [Without Uncertainty for Instrumentation Errors]................................................................ 12 RBS Reactor Pressure Vessel................................................................................ 20 IV

Short Form

%Cu

%Ni 1/4T 3/4T ART ASME BAF BWR BWRVIP CF CFR CMTR CRD EFPY EPR!

FW GEH GL ID ISP LPCI LTR n/cm2 N4 N6 NI2 NRC P

P-T PTLR RBS RCPB RCS RFO RG RHR RPV RTNDT RVID SSP T

T-RTNDT NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Abbreviations and Acronyms Description Weight percent Copper Weight percent Nickel v.. Depth into the Vessel Wall from the Inside Diameter

% Depth into the Vessel Wall from the Inside Diameter Adjusted Reference Temperature American Society of Mechan ical Engineers Bottom of Active Fuel Boiling Water Reactor BWR Vessel and Internals Project Chemistry Factor Code of Federal Regulations Certified Material Test Report Control Rod Drive Effective Full Power Years Electric Power Research Institute Feedwater GE Hitachi Nuclear Energy Generic Letter Inside Diameter Integrated Surveillance Program Low Pressure Coolant Injection Licensing Topical Report Neutrons per Square Centimeter (Measure of Fluence)

Feedwater Nozzle RHRlLPCI Nozzle Water Level Instrumentation Nozzle Nuclear Regulatory Commission Pressure Pressure-Temperature Pressure and Temperature Limits Report River Bend Station Reactor Coolant Pressure Boundary Reactor Coolant System Refueling Outage Regulatory Guide Residual Heat Removal Reactor Pressure Vessel Reference Temperature of Nil-Ductility Transition Reactor Vessel Integrity Database Supplemental Surveillance Program Temperature Temperature minus Reference Temperature of Nil-Ductility v

Short Form TAF TS UFSAR WLi WRC NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Description Transition Top of Active Fuel Technical Specification Updated Final Safety Analysis Report Water Level Instrumentation Welding Research Council VI

1.0 Purpose NEDO-33882 Revision I Non-Proprietary Information - Class r (Public)

The purpose of the River Bend Station (RBS) Pressure and Temperature Limits Report (PTLR) is to present operating limits relating to:

I. Reactor Coolant System (RCS) Pressure-Temperature (P-T) limits during heatup, cooldown and hydrostatic/Class I leak testing;

2. RCS heatup and cooldown rates;

3. Reactor Pressure Vessel (RPV) to recirculation loop T requirements during recirculation pump startups;

4. RPV bottom head coolant temperature to RPV coolant temperature £1T requirements during recirculation pump startups;

5. RPV head flange bolt-up temperature limits.

This report has been prepared in accordance with the requirements of Technical Specification (TS) 3.4.11, " Reactor Coolant ystem (RCS) Pressure and Temperature Limits Report (PTLR)".

2.0 Applicability This report is applicable to the RBS RPV for up to 54 Effective Full Power Years (EFPY). The proposed PTLR can be used to update the existing P-T limit curves, which are valid for 32 EFPY.

Rated thermal power for each cycle was used in calculating the EFPY and a sociated fluence.

3.0 Methodology The limits in this report were derived from the NRC-approved methods listed in TS 3.4.11, using the specific revisions listed below:

The neutron fluence was calculated in accordance with General Electric Methodology for Reactor Pressure Ve sel Fast Neutron Flux Evaluations, NEDC-32983P-A, Revision 2, January 2006 (Reference I).

The P-T limits were calculated per GE Hitachi Nuclear Energy Methodology for Development of Reactor Pre 'sure Vessel Pressure-Temperature Curves, NEDC-33 I 78P-A, Revision I, June 2009 (Reference 2).

This PTLR incorporates the following changes to the RB P-T limits:

Initial issuance of the PTLR for RBS Application of Reference 2 for P-T curves Incorporation of new fluence results for 54 EFPY Application of Integrated urveillance Program (ISP) testing and analysis results that are applicable to RBS.

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Changes to the curves, limits, or parameters within this PTLR, based upon new irradiation fluence data of the RPV, surveillance capsule data of the RPV obtained from the ISP, or other plant design assumptions in the Updated Final Safety Analysis Report (UFSAR), can be made pursuant to 10 Code of Federal Regulations (CFR) 50.59, provided the above methodologies are utilized. The revised PTLR shall be submitted to the NRC upon issuance (Reference 2).

3.1 Chemistry The vessel beltline copper and nickel values were obtained from plant-specific vessel purchase order records, Certified Material Test Reports (CMTRs), or are values previously approved by the NRC, and which remain unchanged from previous submittals.

As a result of the new fluence, materials from Shell # I and Shell #3 are required to be evaluated for the P-T curves.

This includes the plates, axial welds, circumferential welds between hells # I and #2 and Shells #2 and #3, the N6 Low Pressure Coolant Injection (LPCl) nozzle, and the N 12 WLI nozzle. The axial welds in Shell # I and Shell #3 are the same heat of material.

The circumferential weld chemistry wa obtained from the CMTRs. The chemistry for the N6 LPCI nozzle forging and the weld connecting the forging to Shell #3 was obtained from the CMTRs. All other chemistries remain unchanged from the previous submittal.

The Chemistry Factors (CFs) for all materials are calculated based upon the requirements of Regulatory Guide (RG) 1.99, Revision 2.

The N 12 Water Level Instrumentation (WLI) nozzle is within the region with fluence exceeding 1.0e 17 n/cm2, and is evaluated for the Adjusted Reference Temperature (ART). This nozzle is fabricated from non-ferritic stainless steel materials and is welded to the RPV using Inconel material. Therefore, the chemistry for the limiting Shell #2 plate is used to evaluate the ART to represent this nozzle forging.

The ISP presents testing and analysis results for the RBS 183 0 surveillance capsule that is applicable to both the plate and weld materials. In addition, the BWR Vessel and Internals Project (BWRVIP) has tested and analyzed Supplemental Surveillance Program (SSP)

Capsules C, F, and H, which are applicable to the RBS weld material. These results have been incorporated into the P-T curves described in this report. Surveillance materials are evaluated using the chemistries obtained from BWRVIP-135 (Reference 3). Be t estimate chemistries for other beltline materials are also obtained from BWRVIP-135 (Reference 3).

3.2 Fluence The peak RPV Inside Diameter (ID) fluence used in the P-T curve evaluation for 54 EFPY is 8.34e 18 n/cm2, which was determined using methods that comply with RG 1.190.

The 1/4T fluence was calculated using methods defined in RG 1.99.

This fluence applies to the Shell #2 plates and associated longitudinal welds. The fluence i also calculated for the Shell #1 plates and associated longitudinal welds, and the girth weld between Shell #1 and Shell #2; the peak 10 surface fluence for these components is 7.68e17 n/cm2 for 54 EFPY.

The fluence applied to the Shell #3 materials including the girth weld between Shell #2 and Shell #3, is 3.43e17 n/cm2. Similarly, the fluence was calculated for the NI2 WLI 2

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public) nozzle and the N6 LPCI nozzle, both of which are in the beltline region; the peak ID surface fluences used for these components are 2.9ge 18 n/cm2 and 2.33e 17 n/cm2, respectively.

3.3 Initial Reference Temperature of Nil-Ductility Transition (RTNDT)

The method for determining the initial RTNDT for all vessel materials is that defined 111 Section 4.1.2 of Reference 2.

Initial RTNDT values for all vessel materials considered 111 developing the P-T curves are presented in the tables in Appendix B.

The N 12 WLI nozzle is evaluated for ART. As the nozzle forging is fabricated from non-ferritic stainless steel, for which fracture toughness evaluations are not required, the material properties from the limiting adjacent shell plate are used.

The initial RTNDT for the Shell # I and Shell #3 materials are obtained from Tables B-1 through B-4 in Appendix B. The initial RTNDT for all other beltline material remain unchanged from those used in the development of the currently licensed 32 EFPY P-T curves for RBS.

Surveillance materials are evaluated using the limiting initial RTNDT of the plant-specific beltline plate or weld material.

3.4 Adjusted Reference Temperature The ART values for 54 EFPY included in Appendix B are developed considering the BWRVIP ISP surveillance data avai lable that is representative of the applicable materials in the RBS RPV beltline (Reference 3). The plate and weld surveillance data used in the ART calculations are obtained from actual RBS RPV test specimens; as these materials are in the beltline region, they are considered in the development of the P-T curves. In addition, the RBS surveillance capsules contribute to the ISP plate and weld results.

The N 12 nozzle ART is determined considering the initial RTNDT of the adjacent plate material together with the fluence at the nozzle elevation.

The ISP plate material, Heat C3054-2, considered Procedure 1 as defined in Appendix I of Reference 2. This procedure wa u ed because the representative surveillance material and plate material in the RB vessel beltline are identical heats, although not the target material defined by the ISP. The ISP plate material is not limiting with respect to the ART.

The ISP weld, Heat 5P6756, evaluated as defined in Procedure I of Appendix I of Reference 2, is the identical heat as the target vessel material as defined in BWRVIP-135. Therefore, this value is considered in the development of the P-T curves. Four (4) data sets of surveillance test results are available for this material; therefore, an adjusted CF is determined and used to calculate the ART. The ISP weld materials are not limiting with respect to the ART; however, the same weld heat, as evaluated without survei llance material considerations, results in a slightly greater ART, as hown in Table B-6.

ART values for 54 EFPY are presented in Table B-6 of Appendix B.

3

NEDO-33882 Revision I Non-Proprietary Information - Class r (Public) 3.5 Surveillance Program As discussed in Appendix A, RBS palticipates in the BWRYIP ISP and is a host plant. One surveillance capsule has already been removed, tested, and analyzed as shown in Reference 3.

The second surveillance capsule is scheduled to be withdrawn from the RBS RPY and tested.

The final of three (3) RBS surveillance capsules has an ISP status designation of "Extended Life Capsule" per Reference 4.

BWRYIP-135 provides the survei llance data considered in determining the chemistry and any fitted or adjusted CFs for the beltline materials.

Excerpt from Reference 3:

Target Ves el Materials and I P Repre entative Material for RBS Target Vessel Materials ISP Representative Materials Weld 5P6756 5P6756 Plate C3 138-2 C3054-2 For RBS, the] P representative plate, Heat C3054-2, is not the vessel target plate. However, this heat occurs in Shell #2 of the beltline in the RBS RPY. The chemistry is ((

)) Cu and ((

)) Ni.

One set of surveillance data is available at this time; therefore, no survei llance-based CF is available. BWRYIP-135 also provides a best estimate chemistry that is used tn the ART evaluation.

The best estimate for plate heat C3054-2 is defined as

((

)) Cu and ((

)) Ni. The CF from RG 1.99 is 51.0°F.

This material was considered in determining the limiting ART for the P-T curves and is not the limiting beltline material for 54 EFPY.

Excerpt from BWRYIP-135:

Best Estimate hemistry of Available Data Sets for Plate Heat C3054-2 Cu (wt%)

Ni (wt%)

P (wt%)

S (wt%)

Si (wt%)

Specimen ID Source 0.08 0.70 0.007 0.01 2 0.26 Baseline plate CMTR 0.09 0.67 0.007 0.020 0.25 Baseline plate CMTR Reference A-II-4

((

))

Average CMTR I 0.075 0.66 0.0069 0.30 B-12 Reference A-II-2

((

))

<-Best Estimate Average Note:

I.

CMTR Data is combined in this case since the two chemical analyses were performed on the same specimen (as indicated by the "check" designation listed on the CMTR indicating a check of the first data set on the same specimen).

4

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

For RBS, the ISP representative weld, Heat 5P6756, is the identical heat as the vessel target weld. This heat was contained in one (I) RBS and three (3) SSP capsules that have been tested and analyzed. It is noted that the maximum scatter in the fitted data falls within the I-sigma value of 28°F from RG 1.99. BWRVIP-1 35 al 0 provides best estimate chemistries that are used in the ART evaluation.

The best estimate chemistry for weld heat 5P6756 is defined as

((

)) Cu and ((

)) Ni.

The limiting vessel chemistry for this material is 0.09% Cu and 0.92% Ni, from plant-specific CMTRs. Using the best estimate chemistry, the CF from RG 1.99 is 108.0°F. The fitted CF is ((

)); as the ISP material is identical to the vessel target material, the ART table evaluates the ISP weld material using an adjusted CF, and is therefore permitted to reduce the margin term as defined in RG 1.99, Position 2.1.

The CF for a weld material that has more than two (2) data points is determined by calculating an adjusted CF in accordance with RG 1.99. The adjusted CF is determined using the following equation:

( Table CFv selChem..)

Adjusted SU1\\"'. CF =

es,.. CFFittedData Table CFswv.Chem.

For RBS, the adjusted CF = ( 108°F / 82°F) * ((

)).

As ((

)) is greater than 108°F, and the survei llance data is credible, ((

)) is used in the ART evaluation.

This material was considered in determining the limiting ART for the P-T curves because it is the identical heat as the target material.

Excerpt from Reference 3:

Best Estimate Chemistry of Available Data ets for Weld Heat 5P6756 Cu (wt%)

Ni (wt%)

P (wt%)

S (wt%)

Si (wt%)

Specimen ID Source 0.06 0.93 0.013 0.015 0.37 TP2-72 0.04 0.92 0.009 TP2-72 Reference 8-11-5

((

))

Average TP2-72 0.067 0.93 0.00659 0.42 W-6 Reference 8-11-2

((

))

<-Best Estimate Average 3.6 Thickness Discontinuities For RBS, there are four (4) thickness discontinuities in the vessel:

I. Bottom Head to upport Skirt

2. Bottom Head to Shell Ring # I

3. Shell Ring # I to Shell Ring #2 5

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

4. Shell Ring #3 to Shell Ring #4 There is also a thickness discontinuity between the top head dollar plate and torus; the P-T limits for the top head are determined considering this discontinuity in order to ensure that the vessel is adequately protected, or "bounded".

An evaluation was performed for the vessel wall thickness transition discontinuities identified above. The P-T curves bound the discontinuities for locations numbered I, 2, and 4 above.

However, this is not the case for the discontinuity located between the lower and lower-intermediate shells (Shell #1 and Shell #2) in the beltline region. Beltline Curve A bounds the discontinuity. However, it was concluded that the discontinuity is not bounded by the beltline Curve B. Rather, the discontinuity bounds Curve B, and requires an adjustment of 8.2°F to ensure that the curve bounds the beltline discontinuity. The same adjustment is applicable and applied to Curve C.

3.7 Pressure-Temperature Curves The RBS plant-specific P-T curves presented in this PTLR are based upon the GEH methodology accepted by the NRC in Reference 2. Selected explanations are presented below and Appendix 0 includes sample calculations demonstrating P-T curve methodology.

The pressure head for the beltline hydrostatic test curve (Curve A) for RBS is 22.5 psig. This is determined using the height of the vessel and the elevation of the Bottom of Active Fuel (BAF).

The full vessel pressure head is 30 pig. This pressure is used in the determination of KI for the bottom head curve as discus ed in Sections 4.3.2.1.1 and 4.3.2.1.2 of the Reference 2 Licensing Topical Report (L TR).

The P-T curves for the non-beltline region were developed for a Boiling Water Reactor (BWR)/6 with a nominal 10 of 251 inches. The analysis is appropriate for RBS because it is a BWRl6 with a nominal lD of 218 inches. The baseline value was adapted to the conditions at RBS using plant-specific RTNDT values for the RPY.

The P-T curves for the heatup and cooldown operating conditions at a given EFPY apply for both the 1/4T and 3/4T locations. When combining pressure and thermal stres es, it is usually necessary to evaluate stresses at the 1!4T location (in ide surface flaw) and the 3/4T location (outside surface flaw). This is becau e the thermal gradient tensile stress of interest is in the inner wall during cooldown and the outer wall during heatup.

However, as a conservative simplification, the thermal gradient stress at the 1/4T location is assumed to be tensile for both heatup and cooldown. This results in the approach of applying the maximum tensile stress at the 1/4T location. This approach is conservative because irradiation effects cause the allowable toughness, Klr, at 1/4T to be less than at 3/4T for a given metal temperature. This approach causes no operational difficulties because the BWR is at steam saturation conditions during normal operation, well above the heatup/cooldown temperature curve limits.

For the core not critical curve (Curve B) and the core critical curve (Curve C), the P-T curves specify a coolant heatup and cooldown temperature rate of S 100oP/hr for which the curves are applicable. However, the core not critical and the core critical curves were also developed to 6

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public) bound transients defined on the RPV thermal cycle diagram and the nozzle thermal cycle diagrams.

The P-T limits and corresponding heatup/cooldown rates of either Curve A or Curve B may be applied while achieving or recovering from hydrostatic pressure and leak test conditions. Curve A may be used for the hydrostatic pressure and leak test if a coolant heatup and cooldown rate of :S 20°F/hr is maintained. Otherwise, the limits of Curve B apply when performing the hydrostatic pre sure and leak test.

The P-T curves defined in Section 4.3 of Reference 2 are based upon an RTNDT of 10°F for the bottom head and -16°F for the upper vessel for all curves. The 54 FPY beltline curves are based on an ART of II 0.7°F for the plates and welds, 0.7°F for the N6 LPCI nozzle, and 78.1 OF for the N 12 WLI nozzle. For Curve B, the N 12 nozzle requirements are bounding for lower pressures and the limiting beltline weld requirements are bounding for higher pressures on the beltline limited curves.

For RBS, weld heat 5P6756 is the limiting material for the beltline region for 54 EFPY. Both the N6 LPCT nozzle and the N 12 WLI nozzle are also within the beltline region and are considered in development of the P-T curves. The nozzles are evaluated using the appropriate stresses for each nozzle and shifting the baseline curve by the ART. The baseline pressure test P-T curve is applied to the RB 5P6756 weld curve by shifting the P versus (T-RTNDT) values to reflect the ART value of II 0.7°F (see Appendix B, Table B-6). Similarly, the baseline N6 nozzle and N 12 nozzle curves are shifted by the ART values determined in Appendix B. Using the fluence discussed earlier, the P-T curves are beltline weld limited at all pressures above 620 psig for Curve A. For Curve B, the N 12 nozzle requirements are bounding between 200 and 720 psig; the beltline weld requirements are bounding above 720 psig for Curve B.

In order to ensure that the limiting vessel discontinuity has been considered in the development of the P-T curves, the methods in Sections 4.3.2.1 and 4.3.2.2 of Reference 2 for the non-beltl ine and beltline regions, respectively, are applied.

In order to determine how much to shift the baseline non-beltline P-T curves, an evaluation is performed using Tables 4-4b and 4-5b from Reference 2.

These tables define the required Temperature minus Reference Temperature of Nil-Ductility Transition (T-RTNDT) that is used to adjust the baseline, non-shifted curves. Each component listed in these tables is evaluated using its plant-specific initial RTNDT.

The required temperature is then determined by adding the T-RTNDT to the plant-specific RTNDT, thereby resulting in the required T for the curve. As the upper vessel curve is initially based on the non-shifted Feedwater (FW) nozzle T-RTNDT, all resulting T values are compared to the FW nozzle T. The difference between the maximum T and the FW nozzle T-RTNDT is used to shift the upper vessel curve. The same method is applied for the bottom head Control Rod Drive (CRD) curve. In this manner, it is assured that each curve bounds the maximum discontinuity that is represented.

For the RBS upper vessel curve, the maximum T value for pressure equal to 1563 psig from the method described above is ((

)). The initial required T-RTNDT for the ((

)); this is then adjusted by the RBS-specific maximum FW nozzle discontinuity initial RTNDT of -20°F, resulting in 7

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

((

)). Comparing this to the other components bounded by the upper vessel curve, the limiting value is for the ((

)). The required T-RTNDT for the ((

n, which is added to the limiting ((

)). The resulting T required for the ((

)). As ((

)) is limiting, the RBS upper vessel curve is based on an RTNDT of ((

)). As noted above, this calculation was performed for each component shown in Table 4-4b of Reference 2; only the limiting cases are discussed here.

For the RBS bottom head or CRD hydrotest and core critical curves (Curves A and C, respectively), the maximum T value from the method described above is ((

)). The required T-RTNDT for the ((

));

this is adjusted by the RBS-specific maximum ((

)),

resulting in ((

)). Comparing this to the remaining components represented by the bottom head curve, the required T-RTNDT is ((

)), which is added to the ((

)). The resulting T required for the

((

)). As ((

)), the RBS bottom head (eRD) curve is based on an ((

)). As noted above, this calculation was performed for each component shown in Table 4-Sb of Reference 2; only the limiting case is pre ented here.

Appendix H of Reference 2 contains the details of an analysis performed to determine the baseline requirement (non-shifted) for the ((

)). [n Section H.S of Appendix H, the stre es developed in this finite element analysis demonstrated that the ((

)), resulting in a baseline non-shifted required T-RTNDT of ((

)). Therefore, considering the determination of the required shift from the paragraph above for ((

)), calculations for all components listed in Table 4-Sb of Reference 2 were compared to the CRD T, which is ((

)) (where ((

)) materials). Therefore, the shift for the bottom head

((

)).

The ART of the limiting belt[ine material is used to adjust the belt[ine P-T curves to account for the effects of irradiation. RG 1.99 provides the methods for determining the ART. The RG 1.99 methods for determining the limiting material and adjusting the P-T curves using ART are discussed below.

Appendix J of Reference 2 provides detailed results of an analysis performed for the WLI nozzle that provides the required stresses for the drill hole in the shell plate. These stresses were used to generate a specific curve applicable for the WLI nozzle to ensure that this location is bounded in the P-T curves. The WLI nozzle curve is not bounding for RBS Curve A; as noted above, this 8

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public) nozzle bounds for lower pressures for Curve B.

Sample calculations are provided In Appendix D.

The RBS N 12 WLI nozzle is a partial penetration design similar to that shown in Figure I in Appendix J of Reference 2, fabricated with a non-ferritic stainless steel forging. Therefore, the evaluation is performed, consistent with the statement in Appendix J, by using the material properties and ART of the limiting adjacent shell plate material.

3.8 Reactor Coolant Pres ure Boundary (RCPB)

American Society of Mechanical Engineers (ASM ) Code Section III, NB-2332(b) states:

"Pressure retaining material, other than bolting, with nominal wall thickne s over 2-112 in. for piping (pipe and tubes) and material for pumps, valves, and fittings with any pipe connections of nominal wall thickness greater than 2-1 12 in. shall meet the requirements of NB-233 I. The lowest service temperature shall not be lower than RTNDT + 100°F unles a lower temperature is justified by following methods similar to those contained in Appendix G."

All RBS ferritic RCPB piping has wall thicknesses less than 2.5 inches. The lowest service temperature may be less than 250°F; however, the methods of Appendix G have been followed to ju tify lower temperatures. Therefore, the requirements of NB-2332 have been met, and there are no ferritic RCPB piping components that require consideration in the RPY P-T curves for RBS.

With respect to the concern regarding irradiation effects on RCPB piping, the N6 LPCI and N 12 WLI beltline nozzles were assessed. As shown in Table B-6, the fluence for the LPCI nozzle is greater than 1.0e 17 n/cm2 at the 114T location. In addition, the WLI nozzle exceeds 1.0e 17 n/cm2 at the 1/4T location. The fluence at the outside surface of the RPY at this location also exceeds 1.0e 17 n/cm2. The WLI nozzle forging and the associated piping have a thickness less than 2.5 inches and are fabricated from non-ferritic material. Therefore, this piping meets the conditions identified in ASME NB-2332(b) and does not require evaluation for fracture toughness.

3.9 Future Changes Changes to the curves, limits, or parameters within this PTLR, based upon new irradiation fluence data of the RPY, surveillance capsule data of the RPY, or other plant design assumptions in the UFSAR, can be made pur uant to 10 CFR 50.59, provided the above methodologies are utilized. The revised PTLR shall be submitted to the NRC upon issuance.

4.0 Operating Limits The P-T curves provided in Figure I represent the steam dome pressure versus minimum vessel metal temperature and incorporate the appropriate non-beltline limits and irradiation embrittlement effects in the beltline region.

The operating limits for pressure and temperature are required for three categories of operation:

I.

Curve A: Pressure Test (Hydrostatic Pressure Tests and Leak Tests) 9

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Curve A may be used during pressure tests at times when the coolant temperature heatup or cooldown rate is S 20°F/hr during a hydrotest and when the core is not critical.

2.

Curve B: Non-Nuclear Heatup/Cooldown Curve B must be used whenever Curve A or Curve C do not apply. In other words, thi curve must be followed during times when the coolant heatup or cooldown rate is greater than 20°F/hr during a pressure test and when the core is not critical. Additionally, when performing low-power physics testing, Curve B must be followed.

The heatup and cooldown rate is limited to S I OO°F/hr when using Curve B.

3.

Curve C: Core Critical Operation This curve must be used when the core is critical with the exception as noted in item 2 above, during low-power physics testing activities. The heatup and cooldown rate is limited to S I OO°F/hr when using Curve C.

Complete P-T curve were developed for 54 EFPY. The P-T curves are provided 111 Figure I and a tabulation of the curves is included in Table I.

Other temperature limits applicable to the RPV are:

RPV bottom head coolant temperature to RPV coolant temperature T limit during recirculation pump startup: ~ 100°F.

Recirculation loop coolant temperature in the loop to be started to RPV coolant temperature L1T limit during recirculation pump startup: ~ 50°F.

RPV flange and head flange temperature limit: ~ 68°F.

5.0 Discussion The procedures described in References I and 2 were used in the development of the P-T curves for RBS.

The method for determining the initial RTNDT for all vessel materials is defined in Section 4.1.2 of Reference 2. Initial RTNDT values for al l vessel materials considered are presented in the tables in Appendix B of this report.

The RBS survei llance materials, plate heat C3054-2 and weld heat 5P6756, are considered in this PTLR because the surveillance materials are identical heats to those in the RB vessel. Weld heat 5P6756 is also the target material for the RBS RPV.

The ART of the limiting beltline material is used to adjust the beltline P-T curves to account for irradiation effects. RG 1.99 provides the methods for determining the ART. For many of the RBS materials, the margin term is dependent on the L1RTNDT, consistent with Position 1.1. The final paragraph of this section of the RG states that crt> (standard deviation for L1RTNDT) is 17°F for plates and 28°F for welds, but that crt> need not exceed 0.5*L1RTNDT.

The RBS ART calculation has incorporated the use of 0.5* L1RTNDT for all materials, where applicable.

10

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As shown in Table B-6, the Shell #2 axial weld material, heat 5P6756 (Tandem Wire), has the most limiting ART (110. 7°F).

The initial RTNDT for this material is -50°F.

The baseline pressure test P-T curve is applied to the RBS beltline curve by shifting the P versus (T-RTNDT) values to reflect the ART value of IIO.7°F. Separate curves are prepared to represent the N6 LPCI and N 12 WLI nozzles. While the ARTs for the nozzles are lower than the limiting weld material, stresses at the nozzle are different and can contribute to causing a nozzle curve to be more limiting than the beltline shell curve. This is the case for RBS; the N 12 nozzle is more limiting than the weld and N6 nozzle requirements at lower pressures.

Using the fluence discussed above, the P-T curves are beltline limited for Curves A, B, and C.

Curve A is beltline limited above 620 psig; Curve B is beltline limited above 200 psig. Curve C is beltline limited above 140 psig. In the remaining pressure ranges, 10 CFR 50 Appendix G defines the minimum required temperature.

6.0 References I.

GE Nuclear Energy, "General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluation," NEDC-32983P-A, Revision 2, January 2006.

2.

GE Hitachi Nuclear Energy, "GE Hitachi Nuclear Energy Methodology for Development of Reactor Pressure Vessel Pressure-Temperature Curves,"

N DC-33 I 78P-A, Revision I, June 2009.

3.

BWR Vessel and Internals Project Integrated Surveillance Program (ISP) Data Source Book and Plant Evaluations, B WRVIP-135, Revision 3, EPRJ, Palo Alto, CA, December 2014 (EPRI Proprietary).

4.

BWR Vessel and Internals Project, Updated BWR Integrated Surveillance Program (ISP)

Implementation Plan, BWRVIP-86, Revision I-A, EPRl, Palo Alto, CA: October 2012, 1025144 (EPRl Proprietary).

II

1400 1300 1200 1100

§i 1000 rn

~

C 15 900 J:

Q.

0....

...J 800 w

U)

!3 > 700 0::

0....

u 15 600 0::

Z 500

~

J w

0::

400

J U)

U)

W 0::

Q.

300 200 100 0

NEDO-33882 Revision 1 Non-Proprietary Information - Class I (Public)

Curve A Curve B Curve C BOTTOM HEA D I j I

(CURVE A )

f

"'/

BOTTOM i

HEAD (CURVE B)

I

~

Ii

~, I i

, I 1

J J

~

)

,, V I J

I i /

I I BOTTOM HEAD

/

6S' F J

J 312 pslGI V

'( /

../

~

CURVE C FLANGE REGION 6S' F o

25 50 75 100 125 150 175 200 225 250 275 300 MINIMUM REACTOR VESSEL METAL TEMPERATURE (OF)

ACCEPTABLE REGION OF OPERA llON IS TO THE RIGHT OF THE APPLICABLE CURVE HEA TUP/COOLDOWN RATE OF COOLANT

~ 20°F/HR FOR CURVE A,

~ 100°F/HR FOR CURVES B&C A, B, C LlMIllNG CURVES A - PRESSURE TEST WITH FUEL IN THE VESSEL B - NON-NUCLEAR HEA TUP/COOLDOWN CORE NOT CRITICAL C - NUCLEAR HEA TUP/COOLDOWN CORE CRill CAL Figure 1 RBS Composite P-T Curves Effective for Up to 54 EFPY

[Without Uncertainty for Instrumentation Errors]

12

NEDO-33882 Revision 1 Non-Proprietary Information - Class I (Public)

Table 1 RBS Tabulation of Curves - 54 EFPY Required Metal Temperature with Required Coolant Temperature Rate at I OO°F/hr for Curves B and C and 20°F/hr for Curve A Bottom Upper RPV and Bottom Upper RPV Limiting Pressure Head BeItline at Head and Beltline (psi g)

Curve A 54 EFPY Curve B at 54 EFPY 54 EFPY (OF)

Curve A (OF)

(OF)

Curve B (OF)

Curve C (OF) 0 68.0 68.0 68.0 68.0 68.0 10 68.0 68.0 68.0 68.0 68.0 20 68.0 68.0 68.0 68.0 68.0 30 68.0 68.0 68.0 68.0 68.0 40 68.0 68.0 68.0 68.0 68.0 50 68.0 68.0 68.0 68.0 68.0 60 68.0 68.0 68.0 68.0 68.0 70 68.0 68.0 68.0 68.0 68.0 80 68.0 68.0 68.0 68.0 68.0 90 68.0 68.0 68.0 68.0 68.0 100 68.0 68.0 68.0 68.0 68.0 110 68.0 68.0 68.0 68.0 68.0 120 68.0 68.0 68.0 68.0 68.0 130 68.0 68.0 68.0 68.0 68.0 140 68.0 68.0 68.0 68.0 68.0 150 68.0 68.0 68.0 68.0 71.0 160 68.0 68.0 68.0 68.0 75.3 170 68.0 68.0 68.0 68.0 86.5 180 68.0 68.0 68.0 68.0 95.6 190 68.0 68.0 68.0 68.0 103.0 200 68.0 68.0 68.0 69.1 109.1 2 10 68.0 68.0 68.0 74.5 114.5 220 68.0 68.0 68.0 79.4 119.4 230 68.0 68.0 68.0 83.9 123.9 240 68.0 68.0 68.0 87.9 127.9 250 68.0 68.0 68.0 91.4 13 1.4 260 68.0 68.0 68.0 94.8 134.8 270 68.0 68.0 68.0 97.9 137.9 280 68.0 68.0 68.0 100.8 140.8 13

Pressure (psig) 290 300 3 10 3 12.5 3 12.5 320 330 340 350 360 370 380 390 400 410 420 430 440 450 460 470 480 490 500 5 10 520 530 540 550 560 570 580 NEDO-33882 Revision 1 Non-Proprietary Information - Class I (Public)

Bottom Upper RPV and Bottom Upper RPV Head Beltline at Head and Beltline Curve A S4 EFPY Curve B at S4 EFPY (OF)

Curve A (OF)

(OF)

Curve B (OF) 68.0 68.0 68.0 103.5 68.0 68.0 68.0 106.0 68.0 68.0 68.0 108.3 68.0 68.0 68.0 108.9 68.0 80.0 68.0 110.0 68.0 80.0 68.0 11 0.6 68.0 80.0 68.0 11 2.7 68.0 80.0 68.0 114.8 68.0 80.0 68.0 116.7 68.0 80.0 68.0 118.5 68.0 80.0 68.0 120.3 68.0 80.0 68.0 122.0 68.0 80.0 68.0 123.6 68.0 80.0 68.0 125.2 68.0 80.0 68.0 126.7 68.0 80.0 68.0 128. 1 68.0 80.0 68.0 129.6 68.0 80.0 68.0 130.9 68.0 80.0 68.0 132.2 68.0 80.0 68.0 133.5 68.0 80.0 68.0 134.7 68.0 80.0 68.0 135.9 68.0 80.0 68.0 137.1 68.0 80.0 68.0 138.2 68.0 80.0 68.0 139.3 68.0 80.0 68.0 140.4 68.0 80.0 68.0 141.4 68.0 80.0 68.0 142.5 68.0 80.0 68.0 143.4 68.0 80.0 68.0 144.4 68.0 80.0 68.0 145.4 68.0 80.0 68.0 146.3 14 Limiting S4 EFPY Curve C (oF) 143.5 146.0 148.3 148.9 152.2 152.2 152.7 154.8 156.7 158.5 160.3 162.0 163.6 165.2 166.7 168. 1 169.6 170.9 172.2 173.5 174.7 175.9 177.1 178.2 179.3 180.4 181.4 182.5 183.4 184.4 185.4 186.3

Pre ure (psi g) 590 600 610 620 630 640 650 660 670 680 690 700 710 720 730 740 750 760 770 780 790 800 810 820 830 840 850 860 870 880 890 900 NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Bottom Upper RPV and Bottom Upper RPV Head Beltline at Head and Beltline Curve A 54 EFPY Curve B at 54 EFPY (OF)

Curve A (OF)

(OF)

Curve B (OF) 68.0 80.0 68.0 147.2 68.0 80.0 68.0 148.0 68.0 80.0 68.0 148.4 68.0 80.0 68.0 148.8 68.0 80.9 68.0 149.2 68.0 83.7 68.0 149.5 68.0 86.4 68.0 149.9 68.0 88.9 68.0 150.3 68.0 91.3 68.0 150.7 68.0 93.6 68.7 15 1.0 68.0 95.8 69.9 151.4 68.0 97.8 71.0 151.8 68.0 99.9 72.2 152.1 68.0 101.8 73.3 152.5 68.0 103.7 74.4 153.3 68.0 105.4 75.5 154.4 68.0 107.2 76.6 155.4 68.0 108.9 77.6 156.4 68.0 110.5 78.6 157.4 68.0 11 2.0 79.6 158.4 68.0 11 3.6 80.6 159.3 68.0 11 5.0 81.5 160.3 68.0 116.5 82.5 161.2 68.0 117.9 83.4 162. 1 68.0 119.2 84.3 163.0 68.0 120.5 85.2 163.8 68.0 12 1.8 86.0 164.7 68.0 123. 1 86.9 165.5 68.0 124.3 87.7 166.3 68.0 125.5 88.6 167.2 68.0 126.7 89.4 168.0 68.0 127.8 90.2 168.7 15 Limiting 54 EFPY Curve C (OF) 187.2 188.0 188.4 188.8 189.2 189.5 189.9 190.3 190.7 191.0 191.4 191.8 192.1 192.5 193.3 194.4 195.4 196.4 197.4 198.4 199.3 200.3 201.2 202.1 203.0 203.8 204.7 205.5 206.3 207.2 208.0 208.7

Pressure (psig) 910 920 930 940 950 960 970 9S0 990 1000 1010 1020 1030 1035 1040 1050 1055 1060 1070 10SO 1090 II 00 1105 1110 11 20 11 30 11 40 11 50 1160 1170 II SO 1190 NEDO-33882 Revision 1 Non-Proprietary Information - Class I (Public)

Bottom Upper RPV and Bottom Upper RPV Head Beltline at Head and Beltline Curve A 54 EFPY Curve B at 54 EFPY (OF)

Curve A eF)

(°F)

Curve B (°F) 68.0 128.9 91.0 169.5 68.0 130.0 91.7 170.3 68.0 131.1 92.5 171.0 6S.0 132. 1 93.3 171.S 6S.0 133. 1 94.0 172.5 68.0 134.2 94.7 173.2 6S.0 135. 1 95.5 173.9 6S.0 136.1 96.2 174.6 6S.0 137.0 96.9 175.3 6S.0 13S.0 97.6 176.0 6S.0 13S.9 9S.2 176.7 6S.0 139.S 98.9 177.3 6S.0 140.7 99.6 178.0 6S.0 141.1 99.9 17S.3 6S.0 141.5 100.2 17S.6 6S.0 142.4 100.9 179.3 6S.0 142.S 10 1.2 179.6 6S.0 143.2 10 I.S 179.9 6S.0 144.0 102. 1 ISO.5 6S.0 144.S 102.S ISI.I 6S.6 145.6 103.4 ISI.7 69.2 146.4 104.0 IS2.3 69.6 146.S 104.3 IS2.6 69.9 147.2 104.6 IS2.9 70.6 147.9 105.2 IS3.5 71.2 14S.7 105.S IS4. 1 71.9 149.4 106.3 IS4.7 72.5 150.2 106.9 IS5.2 73.1 150.9 107.5 IS5.8 73.S 151.6 10S.0 IS6.3 74.4 152.3 108.6 IS6.9 75.0 153.0 109.1 IS7.4 16 Limiting 54 EFPY Curve C (oF) 209.5 210.3 211.0 21 1.S 212.5 2 13.2 2 13.9 2 14.6 2 15.3 216.0 216.7 217.3 2 1S.0 2 1S.3 21S.6 219.3 219.6 2 19.9 220.5 22 1.1 22 1.7 222.3 222.6 222.9 223.5 224. 1 224.7 225.2 225.8 226.3 226.9 227.4

Pressure (psig) 1200 12 10 1220 1230 1240 1250 1260 1270 1280 1290 1300 13 10 1320 1330 1340 1350 1360 1370 1380 1390 1400 NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Bottom Upper RPV and Bottom Upper RPV Head Beltline at Head and Beltline Curve A S4 EFPY Curve B at S4 EFPY (OF) urve A (OF)

(OF)

Curve B (OF) 75.6 153.6 109.7 188.0 76.2 154.3 110.2 188.5 76.8 155.0 110.8 189.0 77.3 155.6 111.3 189.5 77.9 156.3 111.8 190.0 78.5 156.9 11 2.3 190.5 79.0 157.5 11 2.8 191.0 79.6 158. 1 11 3.3 191.5 80.1 158.7 11 3.8 192.0 80.7 159.3 11 4.3 192.5 81.2 159.9 11 4.8 193.0 81.7 160.5 115.3 193.5 82.3 161.1 11 5.8 194.0 82.8 161.7 116.2 194.4 83.3 162.3 116.7 194.9 83.8 162.8 117.2 195.4 84.3 163.4 117.6 195.8 84.8 163.9 118.1 196.3 85.3 164.5 118.5 196.7 85.8 165.0 119.0 197.2 86.3 165.5 119.4 197.6 17 Limiting S4 EFPY Curve C (OF) 228.0 228.5 229.0 229.5 230.0 230.5 23 1.0 23 1.5 232.0 232.5 233.0 233.5 234.0 234.4 234.9 235.4 235.8 236.3 236.7 237.2 237.6

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Appendix A Reactor Vessel Material Surveillance Program In accordance with 10 CFR 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements, the first surveillance capsule was removed from the RBS reactor vessel during Refueling Outage (RFO) 7 and tested and analyzed.

RBS is participating in the BWRVIP ISP and is a representative host plant. The RBS material surveillance program is admini tered by EPRI in accordance with the BWRVIP I P, and EPR!

will determine the removal schedule for the RBS surveillance capsules. The I P combines the United States BWR surveillance programs into a single integrated program. This program uses similar heats of materials in the surveillance programs of BWRs to represent the limiting materials in other vessels. It also adds data from the BWR SSP. One RBS capsule has been removed, tested, and analyzed, and one capsule is scheduled to be withdrawn from the RBS vessel; the final surveillance capsule is clas ified a "Extended Life Capsule".

18

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Appendix B RBS RPV P-T Curve Supporting Plant-Specific Information 19

TOPO ACT1VEFUEL (TAF)

BOno 0 ACTIVE FUel (BAF)

NEDO-33882 Revision I Non-Proprietary Information - Class r (Public)

TORUS TOPHEAO TOP tEA.O FlANG S

LlFlANGE SHELl.

SHELL SHELl 112 SHeU, t1 BOTTOM HEAD

'---- SUPPORT SI<JRT Note: The WLI nozzle centerline is at 358" elevation, at the Top of Active Fuel (TAF).

Figure B-1 RBS Reactor Pressure Vessel 20

Table B-1 Component PLATES & FORGI NGS:

Top Head & Flange Top Head Dollar 36-2 Top Head Radial Plates 36 1 through 36-1-3 36-1-4 through 36-1-6 Top Head Flange HF-I Shell Courses & Shell Flange Shell Flange SF-I Upper Shell Plates 24-1-1 24-1-2 24-1-3 Upper Intermediate Plates 23-1-1 23-1-2 23-1-3 Lower-Intermediate Plates 22 1 22-1 -2 22-1-3 Lower Shell Plates 21 1 2 1-1-2 Bottom I-lead Bottom Ilead Center Plate 12-1 Bollom Head Side Plates 12-2-1 12-2-2 ote:

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

RBS Initial RTNDT Values for RPV Plate and Flange Materials Heat or !-Ieat /

Test Temp Charpy Energy III (TsoT-60)

Drop Weight Flux / Lot (OF,)

(ft-Ib)

(OF)

NOT (OF)

B6669-1 40 5 1 56 58

-20

-40 B6813-1 50 53 5 1 5 1

- 10

-40 B68 13-2 50 52 57 6 1

-1 0

-40 51-2882 20 99 98 78

-40

-40 5 1-2882 40 65 83 83

-20

-40 A 14 17-1 40 70 62 66

-20

-30 A 14 15-1 10 71 53 68

-50

-60 A 1494-2 20 55 63 50

-40

-40 C2904-2 70 80 53 54 10

-30 C300 1-2 20 50 58 62

-40

-40 C2929-2 10 58 55 56

-50

-50 C3054-1 40 53 53 62

-20

-40 C3054-2 70 51 64 62 10

-40 C3138-2 60 66 50 51 0

-20 C2904-1 70 51 50 5 1 10

-20 C2879-1 70 52 5 1 50 10 0

B6552-1 60 51 60 50 0

0 A 14 15-2 70 52 52 50 10

-30 A 14 17-2 50 70 50 60

- 10

-30 I: Minimum charpy values are provided for all materials.

21 RTNoT (OF)

-20

- 10

-1 0

-40

-20

-20

-50

-40 10

-40

-50

-20 10 0

10 10 0

10

-10

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Table B-2 RBS Initial RTNDT Values for RPV Nozzle Materials Test Component Hcat or Heat I Temp C harpy Energy ill (TSOT-60)

Flu x I Lot (ft-Ib)

(OF)

(OF)

Nozzles:

N I Recirculation Outlet Nozzle (Shell I) 510A-1 Q2Q69W 40 98 108 85

-20 510A-2 Q2Q69W 30 55 88 70

-30 N2 Recirculation Inlet Nozzle (Shell I) 5 11 A-1 Q2QL3W 30 III 76 87

-30 511A-2 Q2QL3W 30 79 100 103

-30 511A-3 Q2QL3W 40 91 97 80

-20 5 11 A-4 Q2QL3W 30 88 82 64

-30 511A-5 Q2QL3W 40 82 96 66

-20 51 1A-6 Q2QL3W 30 108 105 90

-30 511A-7 Q2QL3W 30 102 86 78

-30 511A-8 Q2QL3W 30 85 99 97

-30 51 1A-9 Q2QL3W 40 74 70 74

-20 511A-10 Q2QL3W 30 82 89 86

-30 N3 Steam Outlet Nozzle (Shell 4) 1028-1 Q2QL5W 40 125 128 102

-20 1028-2 Q2QL5W 40 100 104 126

-20 1028-3 Q2Q68W 40 102 92 III

-20 1028-4 Q2QL5W 40 100 104 126

-20 N4 Feedwater Nozzle (Shell 3)

FN4-0-1 103 B-1 Q2QL3W 40 123 115 97

-20 FN4-0-2 R519A-I Q2QL3W 40 128 11 4 95

-20 FN4-0-3 103B-3 Q2QL3W 40 66 74 102

-20 FN4-0-4 R519A-2 Q2QL3W 30 118 106 63

-30 N5 Core Spray Nozzle (Shell 3)

FN5 1 1048-1 Q2QL2W 40 99 98 11 4

-20 FN5-0-2 104B-2 Q2QL2W 30 9 1 108 96

-30 N6 RHRlLPCI Nozzle (Shell 3)

FN6 1 13C-I Q2QL4W 30 51 64 50

-30 FN6-0-2 13C-2 Q2QL4W 40 85 65 72

-20 FN6-0-3 13C-3 Q2QL4W 40 58 55 65

-20 N7 Spray Nozzle (Top Head)

FN7-1 178F Q2QL4W 40 51 64 68

-20 44-1-1 Flange C3687-2 40 61 53 61

-20 N8 Spare Nozzle (Top Head )

FN8-1 179F Q2QL4W 40 51 64 68

-20 44-1-2 Flange C3687-2 40 61 53 6 1

-20 N9 Jet Pump Instrument Nozzle (Shell I)

FN9-0-1 5 12A-I Q2Q68W 20 76 85 69

-40 FN9-0-2512A-2 Q2Q68W 40 64 86 64

-20 N 10 CRD HYD Return Nozzle (Shell 3)

N IO-020B Q2QL4W 30 71 53 57

-30 N II Core 6P Nozzle (Bottom Head)

FNII-O NX692 1-140 14 22 Drop Weight RTNDT NOT (OF)

(OF)

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-20

-50

-20

-20

-20

-50

-20

-20

-20

-20

-20

-20

-20

NEDO-33882 Revision 1 Non-Proprietary Information - Class I (Public)

Test Component Heat or Heat /

Temp Charpy Energy III Flu x / Lot (OF)

(ft-Ib)

NI2 Instrument Nozzle (Shell 2)

FN 12-0-1 through FN 12-0-4 62039-11 560 N 13 Instrument Nozzles (Shell 3)

FN 13-0-1 through FN 13-0-4 62039-11 560 N 14 Instrument Nozzles (Shell 4)

FN I4 1 652 154-11 720 FN 14-0-2 through FN 14-0-4 62039-11 560 N 15 Drain Nozzle (Bottom Head)

FN 15-08679 719282 30 180 209 239 N 16 Vibration Instrument Nozzle (Shell 4)

FN 16-1 21 B Q2QL4W 40 70 77 82 53-2 Flange C3687-2 40 61 53 61 N 17 Seal Leak Detector Nozzle (Shell Flange)

STD25-0 461 NX4745 N 18 Core 6 P and Liquid Control Nozzle (Bottom Head)

FN 18-0 NX692 1-1401 4 Notc:

I. Minimum eharpy values are provided for all materials.

23 Drop (TsOT-60)

Weight RT DT (OF)

DT (OF)

(OF)

-30

-30

-30

-20

-20

-20

-20

-50

-20

Table B-3 Component WELDS:

Girt" Welds Top Head Torus to Dollar Plate All A 1-1 AI-I All AH Top Head Flange to Torus AG AG AG AG AG Shell Flange to Upper Shell AE AE Upper Shell to Upper Intermediate Shell AD AD NEDO-33882 Revision I Non-Proprietary Information - Class 1 (Public)

RBS Initial RTNDT Values for RPV Weld Materials Test Charpy Energy III I-Ieat or Heat / Flux / Lot Temp (OF)

(ft-Ib) 402P3162 1-1 426B27A~

-1 0 60 54 68 629865 A42 1 A27AD

-10 69 70 88 40lP2871 11430B27AF

-20 75 76 107 07R458 S403B27AG 0

59 61 70 412L47 11 A423B27AH 0

72 83 95 402P31621-142 1B27AE

-10 60 54 68 492L4871 A422B27AF 10 56 58 61 07R458 S403 B27AG 0

59 61 70 412L4711 A423B27AI-I 0

72 83 95 40 I P287 1 H430B27AF

-20 75 76 107 5P6756 Linde 124 Lot 0342 (S) 0 51 55 68 5P6756 Linde 124 Lot 0342 (T) 10 64 72 80 5P7397 Linde 124 Lot 0156 (S) 10 55 64 67 51'7397 Linde 124 Lot 0156 (T) 20 50 51 55 Upper Intermediate Shell to Lower Intermediate Shell AC 51'6771 Linde 124 Lot 0342 (S) 30 78 53 68 AC 5P677 I Linde 124 Lot 0342 (T) 40 77 81 83 Lower Intermediate Shell to Lower Shell AB 4P72 16 Linde 124 Lot 075 1 (S) 10 60 60 64 AB 4P721 6 Linde 124 Lot 075 1 (T)

-20 62 73 84 AB 4P7465 Linde 124 Lot 075 1 (S) 0 63 57 68 AB 4P7465 Linde 124 Lot 075 1 (T) 0 79 83 74 Lower Shell to Bottom Head AA 3P4966 Linde 124 Lot 0342 AA 5P5657 Linde 124 Lot 0342 (S) 10 53 54 55 AA 5P5657 Linde 124 Lot 0342 (T) 10 57 58 59 Support Skirt to Bottom Head Weld Buildup 5P5657 Linde 124 Lot 093 1 (S) 0 51 55 68 Weld Buildup 5P5657 Linde 124 Lot 0931 (T) 0 51 57 55 CG Knuckle 5P6756 Linde 124 Lot 0342 (S) 0 55 66 63 CG Knuckle 5P6756 Linde 124 Lot 0342 (T) 10 64 72 80 CW Skirt Knuckle to Weld Buildup 51'677 1 Linde 124 Lot 0342 (S) 30 78 53 68 CW Skirt Knuckle to Weld Buildup 5P677 1 Linde 124 Lot 0342 (T) 40 77 81 83 24 Drop (TsoT-60)

Weight RTNDT (OF)

DT (oF)

(OF)

-70

-70

-70

-70

-90

-70

-80

-70

-70

-60

-60

-60

-60

-90

-60

-70

-70

-70

-50

-80

-50

-60

-60

-60

-60

-90

-60

-80

-70

-70

-60

-60

-60

-50

-50

-50

-50

-50

-50

-40

-40

-40

-30

-30

-30

-20

-20

-20

-50

-60

-50

-80

-80

-80

-60

-70

-60

-60

-60

-60

-50

-40

-40

-50

-60

-50

-60

-60

-60

-60

-80

-60

-60

-60

-60

-50

-50

-50

-30

-30

-30

-20

-20

-20

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Test ChHrpy Energy IIJ Component Heat or Heat / Flux / Lot Temp (OF)

(ft-Ib)

Vertical Weldl' Welds within Lower Shell Ring BA, BB 5 PS657 Linde 124 Lot 093 I (S) 0 51 55 68 BA, BB 5P5657 Linde 124 Lot 093 1 (T) 0 51 57 55 Welds within Lower Intermediate Shell Ring BE BF, BG 5P6756 Linde 124 Lot 0342 (S) 0 55 66 63 BE, BF, BG 5P6756 Linde 124 Lot 0342 (T) 10 64 72 80 BG 492L487 1 A421B27AF 10 56 58 61 Welds within Upper Intermediate Shell Ring BJ, BK, BM 5P5657 Lindc 124 Lot 0931 (S) 0 51 55 68 BJ BK, BM 5P5657 Linde 124 Lot 093 1 (T) 0 51 57 55 Welds within Upper Shell Ring BP, BR, BS 5PS657 Linde 124 Lot 093 1 (S) 0 51 55 68 BP, BR, BS 5P5657 Linde 124 Lot 093 1 (T) 0 51 57 55 Bottom I-lead OG, OH 5 P5657 Linde 124 Lot 093 1 (S) 0 51 55 68 OG OH 5P5657 Linde 124 Lot 093 1 (T) 0 51 57 55 Top I-lead Upper Torus Meridional Welds OJ OK OM ON OP DR 492L487 1 A421B27AE 0

50 51 57 OJ OK, OM, DN, DP, DR 492L487 1 A421 B27 AF 10 56 58 6 1 DJ DN DP, DR 04T93 I A423B27AG 0

65 69 72 DJ 629865 A42 1 A27 AD

-10 69 70 88 Shroud Support to Lower Shell AT 4448 Shroud Support to BOllom Head 4156 Nozzle Weftls N I Recirculation Outlet KA 0° 5P6771 Linde 124 Lot 0342 (S) 30 78 53 68 KA 0° 5P677 1 Linde 124 Lot 0342 (T) 40 77 81 83 KA 0°, 180° 3P4955 Linde 124 Lot 0342 (S) 40 51 52 56 KA 0° 180° 3P4955 Linde 124 Lot 0342 (T) 30 60 65 52 N2 Recirculation Inlet KA 30°, 60°, 90°, 120°, 150°,2 10°, 240°, 270°, 330° 5P6756 Linde 124 Lot 0342 (S) 10 54 58 69 KA 30°, 60°, 90°, 120°, 150°, 210°, 240° 270°, 330° 5P6756 Linde 124 Lot 0342 (T) 10 64 72 80 KA 300° 3P4955 Linde 124 Lot 0342 (S) 40 51 52 56 KA 300° 3 P4955 Linde 124 Lot 0342 (T) 30 60 65 52 N3 Steam Oullet KA 72°, 252° 3P4955 Linde 124 Lot 0342 (S) 40 51 52 56 KA 72° 252° 3P4955 Linde 124 Lot 0342 (T) 30 60 65 52 KA 72° 5P6756 Linde 124 Lot 0342 (S) 10 54 58 69 KA 72° 5P6756 Linde 124 Lot 0342 (1')

10 64 72 80 KA 106°, 288° 5P677 I Linde 124 Lot 0342 (S) 30 78 53 68 KA 106°, 288° 5P677 I Linde 124 Lot 0342 (1')

40 77 81 83 N4 Feedwater Nozzle KA 4so, 31So 5P6756 Linde 124 Lot 0342 (S) 10 54 58 69 KA 45°, 31So 5P6756 Linde 124 Lot 0342 (T) 10 64 72 80 KA 45°, 135°, 225°, 315° 3P4955 Linde 124 Lot 0342 (S) 40 51 52 56 25 Orop (T~oT-60)

Weight RTNoT (OF)

NOT (OF)

(OF)

-60

-60

-60

-60

-80

-60

-60

-60

-60

-50

-50

-50

-50

-80

-50

-60

-60

-60

-60

-80

-60

-60

-60

-60

-60

-80

-60

-60

-60

-60

-60

-80

-60

-60

-90

-60

-50

-80

-50

-60

-90

-60

-70

-90

-70

-30

-20

-20

-20

-30

-20

-20

-40

-20

-30

-20

-20

-50

-60

-50

-50

-50

-50

-20

-40

-20

-30

-20

-20

-20

-40

-20

-30

-20

-20

-50

-60

-50

-50

-50

-50

-30

-30

-30

-20

-20

-20

-50

-60

-50

-50

-50

-50

-20

-40

-20

Component KA 45°, 135°, 225°, 315° KA 275° KA 275° N5 Core Spray Nozzle KA 90° 270° KA 90° 270° N6 LPCI Nozzle KA 45°, 135°, 225° KA 45°, 135°, 225° N7 Top Head Spray Nozzle KAO° KAO° KA O° KA 0° N8 Top Head Spare Nozzle KA 90° KA 90° KA 90° N9 Jet Pump Instrumentation Nozzle KA 105° 285° KA 105° 285° KA 105°, 285° N I 0 CRD HYD Return Nozzle KA 180° N II Core I'1P Nozzle KA N 12, N 13, N 14 Instrument Nozzles KA N 15 Drain Nozzle KA N 16 Vibration Instrumentation Nozzle KA 190° N 17 Seal Leak Detection Nozzle KA N 18 Core I'1P Nozzle KA NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Test Charpy Energy (II Heat or Heat / Flux / Lot Temp (OF)

(ft-Ib) 3P4955 Linde 124 Lot 0342 (T) 30 60 65 52 5P5657 Linde 124 Lot 0342 (S) 10 53 54 55 5 P5657 Linde 124 Lot 0342 (T) 10 57 58 59 5P6756 Linde 124 Lot 0342 10 54 58 69 5P6756 Linde 124 Lot 0342 10 64 72 80 5P6771 Linde 124 Lot 0342 (S) 30 78 53 68 5P677 1 Linde 124 Lot 0342 (T) 40 77 81 83 40 lP287 1 H430B27AF

-20 75 76 107 640892 J424B27AE 0

55 62 62 07R458 S403 B27AG 0

59 61 70 412L47 11 A423B27 AH 0

72 83 95 40 lP287 111430B27AF

-20 75 76 107 640892 J424B27AE 0

55 62 62 07R458 S403B27AG 0

59 6 1 70 40lP287 1 H430B27AF

-20 75 76 107 07R458 S403B27AG 0

59 6 1 70 412L4711 A423B27A J-l 0

72 83 95 05T776 LJI4A27AH

-10 69 72 81 A25 13T382V & 4448 4158 5P6756 no lot

-20 94 97 105 412L47 11 A423B27AH 0

72 83 95 A25 13T382V A25 13T382V 26 Drop (TsoT-60)

Weight RTNDT (OF)

NDT(OF)

(OF)

-30

-20

-20

-50

-40

-40

-50

-60

-50

-50

-60

-50

-50

-50

-50

-30

-30

-30

-20

-20

-20

-80

-70

-70

-60

-70

-60

-60

-60

-60

-60

-90

-60

-80

-70

-70

-60

-70

-60

-60

-60

-60

-80

-70

-70

-60

-60

-60

-60

-90

-60

-70

-70

-70

-80

-60

-60

-60

-90

-60

Component App"rtemll/ce Welds Thermocouple Pads 32-1 and 32-2 N4 135*, 3 J50 Shell 4 Top Head Flange Shell Flange, Top Head Flange Top Head Lifting Lugs EJ EJ EJ Guide Rod Bracket 0*, 180° Steam Dryer Support Bracket EC 34°, 90°, 146°, 214° 270° 326° Steam Dryer Hold Down Brackets to Top Head Core Spray Bracket 25° 155° 205° 33SO Core Spray Pad Buildup 2So, IS5°, 20So, 335° Jet Pump Riser Support Pads Refueling Bellows Bar to Shell Flange RA RA RA RA Feedwater Sparger Bracket SO, 8So 95° 175°, 185° 265°, 275°,355° Note:

NEDO-33882 Revision 1 Non-Proprietary Information - Class I (Public)

Test Charpy Energy III Heat or Heat I Flux I Lot Temp (oF)

(ft-Ib) 422K8511 G3 13A27 AD

-20 65 74 127 629865 A42 1A27AD

-10 69 70 88 629865 A42 1 A27 AD

-1 0 69 70 88 422K8511 G3 13A27AD

-20 65 74 127 629865 A421 A27 AD

-10 69 70 88 401 P287 I H430B27AF

-20 75 76 107 640892 J424B27AE

-20 75 76 107 90496C 90496C 422K851 1 G3 13A27AD

-20 65 74 127 629865 A42 1 A27AD

-10 69 70 88 492L4871 A42 1 B27AE 0

50 51 57 492L4871 A421B27AF

-30 56 58 6 1 90496C 53679 1 A2341T 422K8511 G3 13A27 AD

-20 65 74 127 492L487 1 A42 1 B27 AE 0

50 51 57 492L487I A421B27AF

-30 56 58 61 627069 C3 12A27 AG 0

72 64 78 90496C I: Minimum charpy values are provided for all materials.

27 Drop (TsoT-60)

Weight RT OT (OF)

OT(OF)

(oF)

-80

-80

-80

-70

-90

-70

-70

-90

-70

-80

-80

-80

-70

-90

-70

-80

-70

-70

-80

-70

-70

-80

-80

-80

-70

-90

-70

-60

-90

-60

-90

-80

-80

-80

-80

-80

-60

-90

-60

-90

-80

-80

-60

-60

-60

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Table B-4 RBS Initial RTNDT Values for RPV Appurtenances Test harpy Energy III Heat or Heat I Flux (To()T-60)

Component Temp I Lot (OF)

(fI-lb)

(OF)

Miscellaneous Appurtenances:

Support Skirt Forging and Extension (Bottom Head) 9-1-1 and 10-1-1 A 1966-3 30 52 50 55

-30 9-1-2 and 10-1-2 A 1966-4 60 53 56 50 0

Support Skirt Base Plate (Bottom Head) 10-2-1 through 10-2-3 R04 13-1 60 55 59 60 0

10-2-4 through 10-2-6 R04 14-1 70 53 56 53 10 Jet Pump Riser Support Pads (Shell 2) 642CDA Shroud Support Legs (Bottom Head) 19 1 through 19-2-3 2NX7222-I-COI5 14 19-2-4; 19-2-7; 19-2-8; 19-2-9 2NX7472-I-PI 869 19-2-5; 19-2-6; 19-2-10; 19-2-11 ; 19 12 I NX7378-I-P2347 Shroud Support Ring (Bottom Head) 19-1-1 3NX738 1-I-COI040 19-1-2 3NX738 1-I-COI040 Shroud Support Stubs (Bottom Head) 17-1 NX60 15-1 Shroud Support (Bottom I-lead) 18-1-1 through 18-1 -3 2NX7349-1 18-1-4 18-2, 18-3 INX7349-1 Guide Rod Brackets STO 17-0-1 and STO 17-0-2 120867-333 Steam Dryer Support Brackets (Shell 4)

STO 18-0-1 through S TO 18-0-6 633345-333 Steam Dryer Hold Down Brackets (Top Head Flange)

BOH-O-I through BOH-0-6 B68 13-1 50 53 51 51

-10 Core Spray Brackets (Shell 3)

ST022-0-1 through ST022-0-8 120867-533 Refueling Bellows Skirt 26 1 through 26-2-3 DO 170- 19AB 100 68 77 73 40 Refueling Bellows Bar 26-1-I through 26-1-6 R0503-1 70 59 62 67 10 29-1-1 through 29-1-6 A2457-8B 80 56 60 54 20 Refueling Bellows Base Plate 26 1 through 26-3-6 B789 1-1 40 57 58 59

-20 Feedwater Sparger Brackets (Shell 3)

STD20 1 through STD20-0-8 633345-333 Thermocouple Pads 32-1, 32-2 (Shell Flange Bottom I-lead N4 FW Nozzle)

C3427-13A 50 54 62 52

-10 Lifting Lugs (Top Head) 64-1 B6669-1 70 52 50 51 10 Note:

I. Minimum charpy values are provided for all materials 28 Drop RTNOT Weight DT (OF)

(OF)

-30

-30

-30 0

-20 0

-20 10

-40

-10 40 0

10

-20 20

-30

-20

-30

-10

-40 10

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Table B-5 RBS Initial RT DT Values for RPV Bolting Test Charpy Energy III Component Heat Temp (OF)

(ft-Ib)

STUDS:

A-I through A-8 63182 10 50 51 51 B-1 through 8-3 0-4 through D-8 E-I through E-5 F-I through F-8 G-I through G-4 H-I through H-7 8-4 through 8-8 84299 10 49 50 49 C-I through C-8 0-1 through D-3 E-6 through E-8 G-5 through G-8 H-8 NUTS:

A-I through A-8 83706 10 50 51 54 B-1 through 8-8 C-I through C-8 D-I through D-8 E-I through E-8 F-I through F-8 G-l through G-8 H-l through H-8 WASHERS:

A-I through A-8 83706 10 50 51 54 8-1 through 8-8 C-I through C-8 0-1 through D-8 E-I through E-8 F-I through F-8 G-I through G-8 H-I through H-8 Note:

I. Minimum charpy values are provided for al l materials.

29 LST (OF) 10 10 10 10

Table B-6 Thickness in inches = 5.41 Thickness in inches = 5.41 Thickness in inches = 5.813 Thickness in inches = 5.41 Thickness in inches = 5.41 Component Heat Plant-Specific Chemistries:

Plates:

C2904-2 Shell #3 C3001-2 C2929-2 C3054-1 Shell #2 C3054-2 C3138-2 C2904-1 Shell #1 C2879-1 Axial Welds:

Shell #3 BJ, BK, BM 5P5657/Linde 124/093 1 (S)[4]

Shell #3 BJ, BK, BM _.1 5P5657/Linde 124/093 1 (T)[4]

NEDO-33882 Revision I Non-Proprietary lnformation - Class I (Public)

RBS Adjusted Reference Temperatures for Up to 54 EFPY Shell #3 and Axial Welds, Circumferential Weld AC Shell #2 and Axial Welds 54 EFPY Peak 1.0. fluence = 3.43E+ 17 n/cm2 54 EFPY Peak 114 T fluence = 2.48E + 17 n/cm2 54 EFPY Peak 1.0. fluence = 8.34E+ 18 n/cm2 54 EFPY Peak 114 T fluence = 6.03E+ 18 n/cm2 Shell #1 and Axial Welds, Circumferential Weld AB

%Cu

0. 11 0.04 0.12 0.09 0.09 0.08

0. 11 0.12 0.07 0.04 54 EFPY Peak 1.0. fluence = 7.68E+ 17 n/cm2 54 EFPY Peak 1/4 T fluence = 5.42E+ 17 n/cm2 N12 Water Level Instrumentation Nozzle

%Ni 0.65 0.66 0.64 0.70 0.70 0.63 0.65 0.61 0.71 0.89 54 EFPY Peak 1.0. fluence = 2.99E+ 18 n/cm2 54 EFPY Peak 114 T fluence = 2.16E+ 18 n/cm 2 N6 RHRlLPCl Nozzle CF Adjusted CF 75 26 84 58 58 51 75 83 95 54 30 54 EFPY Peak 1.0. fluence = 2.33E+ 17 nlcm2 54 EFPY Peak 114 T fluence = 1.68E+ 17 n/cm2 Initial 1/4T S4 RTNDT Fluence EFPY Margin aRTNDT a J a A OF OF n/cm2 OF 10 2.48E+ 17 14.7 0

7.3 14.7

-40 2.48E+ 17 5.1 0

2.5 5.1

-50 2.48E+ 17 16.4 0

8.2 16.4

-20 6.03E+ 18 49.8 0

170 34.0 10 6.03E+ 18 49.8 0

17.0 34.0 0

6.03E+ 18 43.8 0

17.0 34.0 10 5.42E+ 17 22.8 0

11.4 22.8 10 5.42E+17 25.4 0

12.7 25.4

-60 2.48E+17 18.6 0

9.3 18.6

-60 2.48E+ 17 10.6 0

5.3 10.6 S4 54 EFPY EFPY Shift ART OF OF 29.3 39.3 10.2

-29.8 32.8

-17.2 83.8 63.8 83.8 93.8 77.8 77.8 45.7 55.7 50.9 60.9 37.3

-22.7 21.2

-38.8

Component Heat Shell #2 BE, BF, BG 5P6756/Linde 124/0342 (S)[4]

Shell #2 BE, BF, BG 5P6756/Linde 124/0342 (T)[4]

Shell # I BA, BB 5P5657/Linde 124/0931 (S)[4]

Shell # I BA, BB 5P5657/Linde 124/0931 (T)[4]

Circumferential Welds:

Shell #2 to Shell #3: AC 5P677I1Linde 124/0342 (S)[4]

Shell #2 to Shell #3 : AC 5P677llLinde 124/0342 (T)[4]

Shell #1 to Shell #2: AB 4P7216/Linde 124/0751 (S)[4]

Shell #1 to Shell #2: AB 4P7216/Linde 124/0751 (T)[4]

Shell #1 to Shell #2: AB 4P7465/Linde 124/0751 (S)[4]

Shell #1 to Shell #2: AB 4P7465/Linde 124/0751 (T)[4]

Nozzles:

N6 Forging Q2QL4W N6 Weld 5P677I/Linde 124/0342 (S)[4]

N6 Weld 5P677I1Linde 124/0342 (T)[4]

NI2 Forging [I]

C3054-2 NI2 Weld [I]

Inconel 182 Best Estimate Chemistries from BWRVIP-135:

Shell #2 C3054-2 Shell #3 BJ, BK, BM 5P5657/Linde 124/0931 (S)[4]

Shell #3 BJ, BK, BM 5P5657/Linde 124/0931 (T)[ 4]

Shell #2 BE, BF, BG 5P6756/Linde 124/0342 (S)[4]

Shell #2 BE, BF, BG 5P6756ILinde 124/0342 (T)[ 4]

Shell #2 to Shell #3 : AC 5P677llLinde 124/0342 (S)[4]

Shell #2 to Shell #3: AC 5P677llLinde 124/0342 (T)[4]

Shell # I BA, BB 5P5657/Linde 124/093 1 (S)[4]

Shell # 1 BA, BB 5P5657/Linde 124/0931 (T)[4]

Shell #1 to Shell #2: AB 4P7216/Linde 124/075 1 (S)[4]

Shell # I to Shell #2: AB 4P7216/Linde 124/0751 (T)[4]

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Initial 1/4 T

% C u

% Ni CF Adjusted RTNDT Fluence CF of nlem' 0.08 0.93 108

-60 6.03E+ 18 0.09 0.92 122

-50 6.03E+18 0.07 0.71 95

-60 5.42E+17 0.04 0.89 54

-60 5.42E+17 0.03 0.88 41

-30 2.48E+17 0.04 0.95 54

-20 2.48E+ 17 0.06 0.85 82

-50 5.42E+17 0.04 0.83 54

-80 5.42E+17 0.02 0.82 27

-60 5.42E+ 17 0.02 0.80 27

-60 5.42E+ 17 0.10 0.86 67

-20 1.68E+ 17 0.03 0.88 41

-30 1.68E+17 0.04 0.95 54

-20 1.68E+17 0.09 0.70 58 10 2.16E+18

((

51 10 6.03E+18 46

-60 2.48E+ 17 46

-60 2.48E+ 17 108

-60 6.03E+18 108

-50 6.03E+18 46

-30 2.48E+17 46

-20 2.48E+ 17 46

-60 5.42E+17 46

-60 5.42E+17 51

-50 5.42E+ 17 51

-80 5.42E+17 31 54 54 54 EFPY Margin EFPY EFPY

.1.RTNDT 0 1 0 "

of Shift ART of of of 92.7 0

28.0 56.0 148.7 88.7 104.7 0

28.0 56.0 160.7 110.7 29.0 0

14.5 29.0 58.1

-1.9 16.5 0

8.3 16.5 330

-27.0 8.0 0

4.0 8.0 16.1

-13.9 10.6 0

5.3 10.6 21.2 1.2 25.1 0

12.5 25.1 50.1 0.1 16.5 0

8.3 16.5 33.0

-47.0 8.3 0

4.1 8.3 16.5

-43.5 8.3 0

4.1 8.3 16.5

-43.5 10.3 0

5.2 10.3 20.7 0.7 6.3 0

3.2 6.3 12.7

-17.3 8.3 0

4.2 8.3 16.7

-33 34.1 0

17.0 34.0 68.1 78.1 43.8 0

17.0 34.0 77.8 87.8 9.1 0

4.5 9.1 18.1

-41.9 9.1 0

4.5 9.1 18.1

-41.9 92.7 0

28.0 56.0 148.7 88.7 92.7 0

28.0 56.0 148.7 98.7 9.1 0

4.5 9.1 18.1

-11.9 9.1 0

4.5 9.1 18.1

-1.9 14.1 0

7.1 14.1 28.2

-31.8 14.1 0

7.1 14.1 28.2

-3 1.8 15.7 0

7.9 15.7 31.4

- 18.6 15.7 0

7.9 15.7 31.4

-48.6

Component Heat Shell # I to Shell #2: AB 4P7465/Linde 124/0751 (S)[4]

Shell #1 to Shell #2: AB 4P7465/Linde 124/0751 (T)[ 4]

Integrated Surveillance Program from BWRVIP-135:

Plate [2]

C3054-2 Weld [3]

5P6756/Linde 124/0342 (S)[4]

Weld [3]

5P6756/Linde 124/0342 (T)[4]

Notes:

NEDO-33882 Revision L Non-Proprietary Information - Class I (Public)

Initial 1/4 T

%Cu

%Ni CF Adj usted RT~'DT Fluence CF of nlem' 27

-60 5.42E+ 17 27

-60 5.42E+ 17 51 10 6.03E+ 18

((

-60 6.03E+ 18 II II

-50 6.03E+ 18 54 54 54 EFPY Margin EFPY EFPY t.RTNDT cr, crd of Shift ART of of of 8.3 0

4.1 8.3 16.5

-43.5 8.3 0

4.1 8.3 16.5

-43.5 43.8 0

17.0 34.0 77.8 87.8 132.1 0

14.0 28.0 160.1 100.1 132.1 0

14.0 28.0 160.1 11 0.1 I.

The N 12 WLI nozzle occurs in the beltline region. Because the forging is fabricated from stainless steel, the ART is calculated using the plate heats where the nozzles occur. The weld connecting the forging to the vessel shell is Inconel 182 material and is not required to be evaluated.

2.

The ISP plate material is not the vessel target material, but does occur within the beltline region (Lower-Intermediate Shell). Therefore, this material is considered in determining the limiting ART. Only one set of surveillance data is currently available; therefore, upon testing of a second ISP capsule, the CF can be reviewed.

3.

The ISP weld material is the vessel target material and occurs within the beltline region. Therefore, this material is considered in determining the limiting ART. The adjusted CF is determined to be the [RG 1.99 CF(vessel material)IRG 1.99 CF(surveiliance material)] x CF(fitted). For this material, the adjusted CF = [I08°F/82°F] x ((

)). The surveillance data is credible; therefore (J6 is reduced as permitted by RG 1.99.

4.

S = Single Wire; T = Tandem Wire 32

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Table B-7 RBS RPV Beltline P-T Curve Input Values for 54 EFPY Adjusted RTNDT = Initial RTNDT + Shift (Based on ART values in Table B-6)

Plate/Weld A = -50 + 160.7 = 110.7°F N6 Nozzle A = -20 + 20.7 = 0.7°F N I2 Nozzle A = 10 + 68. 1 = 78.1 0 F Vessel Height H = 831.75 inches Bottom of Active Fuel Height B = 208.56 inches Vessel Radius (to base metal)

R = 110.19 inches Minimum Vessel Thickness (without clad) t = 5.4 1 inches 33

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Table B-8 RBS Definition of RPV Beltline Region I Component Shell # 2 - Top of Active Fuel Shell # 2 - Bottom of Active Fuel Shell # 2 - Top of Extended Beltline Region (54 EFPY)

Shell # I - Bottom of Extended Beltline Region (54 EFPY)

Centerline of Residual Heat Removal (RHR)lLPCI Nozzle N6 in Shell # 3 Bottom ofRHR/LPCI Nozzle N6 in Shell #3 Centerline of Recirculation Outlet Nozzle N I in Shell # I Top of Recirculation Outlet Nozzle N I in Shell # I Centerline of Recirculation Inlet Nozzle N2 in hell # I Top of Recirculation Inlet Nozzle N2 in Shell # I Centerline of2" WLl Nozzle N I2 in Shell # 2 Circumferential Weld AB (Shell #1 to Shell #2)

Circumferential Weld AC (Shell #2 to Shell #3)

Note:

Elevation (inches from RPV"O")

358.56 208.56

> 378.2 190.1 398.3 383.2 166.5 187.3 171.5 187.0 358.0 202.0 378.5 I. The beltline region is defined as any location where the peak neutron fluence is expected to exceed or equal 1.0e 17 n/cm2.

Based on the above, it is concl uded that none of the RBS reactor vessel plates, nozzles, or welds, other than those included in the ART table, are in the beltline region.

34

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Appendix C RBS Reactor Pressure Vessel P-T Curve Checklist 35

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Table C-\\ provides a checklist that defines pertinent points of interest regarding the methods and information used in developing the RBS PTLR. This table demon trates that all important parameters have been addressed in accordance with Reference 2 and includes comments, resolutions, and clarifications as necessary.

Table C-l RBS Checklist Parameter Completed Comments/Resolutions/Clarifications Initial RT 01' Initial RTNDT has been determined for all

~

The N 12 WLI nozzle forging was vessel materials including plates, flanges, fabricated from stainless steel.

forgings, studs, nuts, bolts, welds.

Therefore, the material properties for the Include explanation (including limiting adjacent shell plate material are methods/sources) of any exceptions, considered.

resolution of discrepant data The N6 LPCI nozzle forging and weld (e.g., deviation from originally reported material properties were obtained from values).

plant-specific purchase records.

Heat 492L487I was previously included in the beltline weld material evaluation.

Review of the plant-specific purchase records determined that this heat was only used for seam patches. Therefore, this material was not included in this evaluation. The e materials were not previously considered to be limiting and would not be limiting if included in this evaluation.

Materials in Shell #3, including plates, axial weld, N6 nozzle forging, and the circumferential weld between Shell #2 and hell #3 have been added to the beltline region based upon the new nuence. The values used for these materials are shown in Tables 8-1 through 8-5.

Materials in Shell # I, including plates, axial welds, and the circumferential weld between Shell # I and Shell #2 have been added to the beltline region based upon the new fluence. The values 36

NEDO-33882 Revision I Non-Proprietary Information - Class 1 (Public)

Parameter Completed Comments/Resolutions/Clarifications lIsed for these materials are shown in Tables 8-1 through 8-5.

All other information remains unchanged from previous submittals.

Appendix 8 contains tables of all Initial

[g]

RTNDT values.

Has any non-plant-specific initial RTNDT

[g]

All Initial RTNDT values used in the information (e.g., ISP, comparison to other ART calculations are plant-specific.

plant) been used?

If deviation from the P-T curve L TR

[g]

No deviations from the P-T curve L TR (Reference 2) process occurred, sufficient (Reference 2) process were applied.

supporting information has been included (e.g., Charpy V -Notch data used to determine an Initial RTNDT).

All previou Iy published Initial RTNDT

[g]

RVID was reviewed for the beltline values from sources such as the Generic materials; the weld material initial Letter (GL) 88-0 I, Reactor Vessel Integrity RTNDT values agree. RVlD reports Database (RVID), and UF AR have been different values for the plate materials; reviewed.

the values used in this evaluation are consistent with the plant-specific purcha e records.

37

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Parameter Completed Comments/Resolutions/Clarifications Adjusted Reference Temperature Sigma I (<iI, standard deviation for Initial

[Z]

Plant-specific Initial RTNDT values were RTNDT) is OaF unless the RT DT was obtained from CMTRs in all cases.

obtained from a source other than CMTRs.

If <iI is not equal to OaF, reference/basis has been provided.

Sigma /j. <<M, standard deviation for

[Z]

/j.RTNDT) is determined per RG 1.99, Revision 2.

Chemistry has been determined for all I:8J The N 12 WLI nozzle is fabricated from vessel beltline materials including plates, non-ferritic stainless steel materials.

forgings (if applicable), and welds.

Therefore, the chemistry for the limiting Include explanation (including adjacent shell plate material is methods/sources) of any exceptions, considered.

resolution of discrepant data Heat 5P6756, Linde 124, Lot 0342 (e.g., deviation from originally reported chemistries were obtained from plant-values).

specific purchase records, and vary slightly from those previously reported.

This change has increa ed the CF for the tandem wire material, which is the limiting material for the beltline region.

All other chemistry values were obtained from plant-specific purcha e records.

Be t estimate chemistries obtained from BWRVIP-135 are used in addition to the plant-specific chemistries.

No deviations from previously reported values except as noted above.

38

N 00-33882 Revision I Non-Proprietary Information - Class I (Public)

Parameter Completed Comments/Resolutions/Clarifications Non-plant-specific chemistry information

[gJ Best estimate chemistries obtained from (e.g., I SP, comparison to other plant) used BWRVIP-135 are used in addition to the has been adequately defined and described.

plant-specific chemistries.

Survei llance chemistries obtained from BWRVIP-135 are lIsed in addition to the plant-specific chemistries.

For any deviation from the P-T curve L TR

[gJ No deviations from the P-T curve L TR (Reference 2) process, sufficient (Reference 2) process.

information has been included.

All previously published chemi try values

[gJ RVID was reviewed. Heat 5P6756, from sources such as the GL 88-01, RVID, Linde 124, Lot 0342 chemistrie were and UFSAR have been reviewed.

obtained from plant-specific purchase records, and vary slightly from those previously reported.

This change has increased the CF for the tandem wire material, which is the limiting material for the beltline region.

The fluence used for determination of ART

[gJ One ( I) NRC-approved fl uence and any extended beltline region was methodology (Reference I) was used for obtained using an NRC-approved the entire plant license.

methodology.

The fluence calculation provides an axial

[gJ distribution to allow determination of the vessel elevations that experience fluence of 1.0e 17 n/cm2 both above and below active fuel.

The fluence calculation provides an axial

[gJ distribution to allow determination of the t1uence for intermediate locations such as the beltline girth weld (if applicable) or for any nozzles within the beltline region.

All materials within the elevation range

~

where the vessel experiences a fluence

> 1.0e 17 n/cm2 have been included in the 39

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Parameter Completed Comments/Resolutions/Clarifications ART calculation. All initial RTNDT and chemistry information is ava ilable or explained.

40

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Parameter Completed Comments/Resolutions/Clarifications Discontinuities The discontinuity comparison has been rg]

There are no deviations.

performed as described in Section 4.3.2.1 of the P-T curve L TR (Reference 2). Any deviations have been explained.

Discontinuities requiring additional rg]

All di continuities are bounded by either components (such as nozzles) to be the upper vessel, bottom head, or considered part of the beltline have been beltline curve; those bounded by the adequately described. It is clear which upper vessel and/or bottom head are in curve is used to bound each discontinuity.

accordance with Tables 4-4b and 4-5b of Reference 2.

Appendix G of the P-T curve L TR rg]

The thickness discontinuity evaluation (Reference 2) describes the process for demonstrates that Curve B and Curve C considering a thickness discontinuity, both require an additional adjustment of beltline and non-beltline. If there is a 8.2°F that has been applied; therefore, discontinuity in the vessel that requires the P-T curves bound the discontinuitie.

such an evaluation, the evaluation was performed. The affected curve was adjusted to bound the discontinuity, if required.

Appendix H of the P-T curve L TR rg]

(Reference 2) defines the basis for the CRD penetration curve discontinuity and the appropriate transient application. The plant-specific evaluation bounds the requirements of Appendix H.

Appendix J of the P-T curve L TR rg]

(Reference 2) defines the basi for the WLI nozzle curve discontinuity and the appropriate transient application. The plant-specific evaluation bounds the requirements of Appendix 1.

41

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Appendix D Sample P-T Curve Calculations 42

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Beltline NI2 Water Level Instrumentation Nozzle Pressure Test (Curve A) for 54 EFPY KI for the discontinuity is determined considering the KI obtained from Table 7 of Appendix J of Reference 2 (for hydrotest). For 1070 psig, this KI is scaled by pressure as follows:

((

))

T-RTNDT is calculated in the following manner:

((

))

The ART is added to T-RTNDT to obtain the required T:

((

))

This temperature is not obvious from the P-T curve as it is bounded by the beltline axial weld requirements.

Core Not Critical (Curve B) for 54 EFPY KI for the discontinuity is determined considering the KI obtained from Table 5 of Appendix J of Reference 2.

KI(prcSsure)

KI(thcrmal)

((

((

))

))

The transient used for the WLI nozzle, defined in Appendix J, is used in determination of KI.

The total KI is therefore:

((

))

T-RTNDT is calculated in the following manner:

((

))

The ART is added to T-RTNDT to obtain the required T:

((

))

This temperature is not obvious from the P-T curve as it is bounded by the beltline axial weld requirements.

Correction Factor The total stress for the WLI nozzle exceeds the yield stress; therefore, the correction factor, R, is calculated to consider the nonlinear effects in the plastic region. This calculation is performed in accordance with the following equation, based on the assumptions and recommendation of Welding Research Council (WRC) Bulletin 175, as shown in Equation 4-7 of Reference 2.

R

[crys - crpm + ((crtotal-crys)/30)]/( crtotal - crpm) 43

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Applied to the WLI nozzle:

((

))

44

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

Beltline Calculations Excluding Nozzles Pressure Test (Curve A) at 1,070 psig for 54 EFPY The limiting beltline material is the bounding component for Curve A; therefore, a sample calculation for this material, not including the WLl nozzle is provided for 1,070 psig.

The limiting ART applied to the beltline P-T curves is 11O.7°F, for the Shell #2 axial weld.

Pressure is calculated to include hydrostatic pressure for a full vessel:

P 1,070 psig + (H - B)*0.036 1 psi/inch (H=vessel height; B=elevation of BAF)

=

1,070 + (831. 75 - 208.56)

• 0.0361 1,092.5 psig Pressure Stress:

Mm

=

=

PRit (P=pressure; R=vessel radius; t=vessel thickness) 1.093

• 110.19 / 5.4 1 22.26 ksi 0.926../t 0.926../5.4 1

=

2.15in l/2 The stress intensity factor, Kit, is calculated as described in Section 4.3.2.2.4 of Reference 2, except that "G" is 20°F/hr instead of 100°F/hr.

Mt Kit 0.2753 ksi-in I 1210F, from ASME Appendix G, Figure G-2214-1 GC2 1 2~

G = coolant heatup/cooldown rate of20°F/hr C = minimum vessel thickness including clad = 5.41 "+0. 125"=5.535"=0.46 ft

~ = thermal diffusivity at 550°F = 0.354 ft2/hr (20*(0.46)2) 1 (2*0.354) 5.98°F Mt

• tJ.T 0.2753

• 5.98 1.65 ksi-in 1/2 45

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

KIm a

• Mm T-RTNDT 22.26

• 2.15 47.9 ksi-in l/2

=

In[( 1.5*Klm + Kit - 33.2)/20.734]/0.02 In[(1.5*47.9 + 1.65 - 33.2)/20.734]/0.02 33.2°F T is calculated by adding the ART:

T 33.2 + 110.7 143.9°F for P = 1,070 P ig at 54 EFPY This temperature is the limiting value and is shown in Figure I.

Core Not Critical (Curve B) at 1,070 psig for 54 EFPY As discussed above and in Section 5.0 and shown in Table B-6, the limiting ART applied to the beltline Curve B is 118.9°F for the Shell #2 axial weld, including the adjustment of 8.2°F to bound the thickness discontinuity.

The ~T term is calculated as shown above for the pressure test case, but the temperature rate change is 100°F/hr instead of20°F/hr. Therefore, ~T equals 30°F.

P

=

1,070 psig + (H - B)*0.0361 psilinch (H=vessel height; B=elevation of BAF) 1,070 + (831.75 - 208.56)

• 0.0361 1,092.5 psig Pressure Stress:

a PRit (P=pressure; R=vessel radius; t=vessel thickness) 1.093

• 110.19 / 5.41 22.26 ksi KIm a

• Mm

=

=

22.26

• 2.15 47.9 ksi-in 1/2 Ml * ~T(forthe 100°F/hrcase) 0.2753

• 30 8.3 ksi-in l/2 46

T-RTNDT NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

In[(2.0*Klm + KIt - 33.2)/20.734]/0.02 In[(2.0*47.9 + 8.3 - 33.2)/20.734]/0.02 61.5°F T is calculated by adding the ART:

T 61.5 + 118.9 180AoF for P = 1070 psig at 54 EFPY This temperature is the limiting value and is shown in Figure I.

47

NEDO-33882 Revision I Non-Proprietary Information - Class I (Public)

N4 Feedwater Nozzle Calculations An evaluation was performed for the FW nozzle as described in Section 4.3.2.1.3 of Reference 2.

The first part of the evaluation is as described earlier, where it is assured that the limiting component that is represented by the upper vessel curve is bounded by the ((

)). A second evaluation was performed using the RB -specific FW nozzle dimensions; this evaluation is shown below to demonstrate that the baseline curve is applicable to RBS:

Vessel radius to base metal, Rv rr Vessel thickness, tv Vessel pressure, Pv Pressure stress = PRlt = ((

))

Dead weight + thermal restricted free end stress Total stress = rr

))

))

The factor F(a/rn) from Figure AS-I of P VRC Recommendations on Toughness Requirements for Ferritic Materials, WRC-175, is determined where:

a = 14 (tn2 + t} ) y, rr tn = th ickness of nozzle tv = thickness of vessel rn = apparent radius of nozzle = n + O.29*rc n = actual inner radius of nozzle rc = nozzle radius (nozzle corner radius) 11 Therefore, a/rn = ((

WRC-175 for an ((

)). The value F(a/rn), taken from Figure A5-1 of

)). Including the safety factor of 1.5, the stress intensity factor, KI, is 1.5 cr Cna) 112

• F(a/rn):

RBS Plant-Specific Nominal KI = 1.5 * ((

))

A detailed upper vessel example calculation for core not critical conditions is provided 111 Section 4.3.2.1.4 of Reference 2. Section 4.3.2.1.3 of Reference 2 defines the baseline nominal KI to be ((

)) for the FW nozzle evaluation upon which the baseline non-shifted upper vessel P-T curve is based.

The nominal KI from this RBS evaluation is

((

)). Therefore, it has been shown that the nominal KI for the RBS-specific FW nozzle is less than the baseline KI, demonstrating applicability of the FW nozzle curve for RBS.

48

RBG-47824 Page 1 of 4 RBG-47824 GEH Letter NEDC-33882P Affidavit from General Electric Hitachi (GEH)

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Lisa K. Schichlein, state as follows:

(I) I am a Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in GEH proprietary report NEDC-33882P, " Entergy Operations, Inc. River Bend Station Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full-Power Years," Revision I, dated November 2017. GEH proprietary information in NEDC-33882P Revision 1 is identified by a dotted underline inside double square brackets.

[lr~j~.. ~.~m.~n~~..i.~. '<U).. ~.~.<.tm.p.-'-~:?: )).

GEH proprietary information in figures and large objects is identified by double square brackets before and after the object.

In each case, the superscript notation PI refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. §552(b)(4), and the Trade Secrets Act, 18 U.S.c.

§ 1905, and NRC regulations 10 CFR 9. 17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. Cir. 1983).

(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a and (4)b. Some examples of categories of information that fit into the definition of proprietary information are:

a.

Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without a license from GEH constitutes a competitive economic advantage over other companies;

b.

Information that, if used by a competitor, would reduce its expenditure of resources or improve its competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c.

Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH; NEDC-33882P Revision I Affidavit Page I of 3

GE-Hitachi Nuclear Energy Americas LLC

d.

fnformation that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.

(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort cu tomarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by G H, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions for proprietary or confidentiality agreements or both that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraph (6) and (7).

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside G H are limited to regulatory bodies, cu tomers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary and/or confidentiality agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains the detailed GEH methodology for pressure-temperature curve analysi for the GEH Boiling Water Reactor (BWR). These methods, techniques, and data along with their application to the design, modification, and analyses associated with the pressure-temperature curves were achieved at a significant cost to GEH.

The development of the evaluation processes along with the interpretation and application of the analytical re ults is derived from the extensive experience databases that constitute a major GEH asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.

The value of the technology base goes beyond the extensive physical database and NEDC-33882P Revision I Affidavit Page 2 of3

GE-Hitachi Nuclear Energy Americas LLC analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation proce s. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own proce s or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to G H would be lost if the information were di closed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large inve tment in developing and obtaining these very valuable analytical tools.

1 declare under penalty of perjury that the foregoing is true and correct.

Executed on this 10th day of November 2017.

EDC-33882P Revision I Lisa K. chichlein Senior Project Manager, NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 390 I Castle Hayne Road Wilmington, NC 2840 I Lisa.Schichlein@ge.com Affidavit Page 3 of 3

RBG-47824 Page 1 of 5 RBG-47824 GEH Letter NEDC-33882P Affidavit from Electric Power Research Institute (EPRI)

1-~f21 1 ELECTRIC POWER 1-RESEARCH INSTITUTE Ref. EPRI Project Number 669 November 17, 2017 Document Control Desk Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 BWRVIP 2017-138, Attachment 1 NEIL W ILMSHURST Vice Pre~ident and Chief Nucle<Jr Officer

Subject:

Request for Withholding of the following Proprietary Information Included in:

GE Hitachi Nuclear Energy Report for Entergy Operations, Inc., River Bend Station, titled:

"Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full-Power Years",

NEDC-33882P, Revision 1, dated November 2017 To Whom It May Concern:

This is a request under 10 C.F.R. §2.390(a)(4) that the U.S. Nuclear Regulatory Commission ("NRC")

withhold from public disclosure the report identified in the enclosed Affidavit consisting of the proprietary information owned by Electric Power Research Institute, Inc. ("EPRI") identified above in the attached report. Proprietary and non-proprietary versions of the Report and the Affidavit in support of this request are enclosed.

EPRI desires to disclose the Proprietary Information in confidence to assist the NRC review of the enclosed submittal to the NRC by Entergy. The Proprietary Information is not to be divulged to anyone outside of the NRC or to any of its contractors, nor shall any copies be made of the Proprietary Information provided herein. EPRI welcomes any discussions and/or questions relating to the information enclosed.

If you have any questions about the legal aspects of this request for withholding, please do not hesitate to contact me at (704) 595-2732. Questions on the content of the Report should be directed to Andy McGehee of EPRI at (704) 502-6440.

Sincerely, \\\\iuv Attachment(s)

Together... Shaping the Future of Electricity 1300 West W.T. Harris Boulevard, Charlotte, NC 28262-8550 USA. 704.595.2732

• Mobile 704.490.2653

• nwilm~hurst@epri.com

._ ~~I I elECTRIC POWER I-I~ RESEARCH INSTITUTE AFFIDAVIT RE:

Request for Withholding of the Following Proprietarylnformation Included In:

GE Hitachi Nuclear Energy Report for Entergy Operations, Inc., River Bend Station, titled: "Pressure and Temperature Limits Report (PTLR) Up to 54 Effective Full-Power Years", NEDC-33882P, Revision 1, dated November 2017 I, Neil Wilmshurst, being duly sworn, depose and state as follows:

I am the Vice President and Chief Nuclear Officer at Electric Power Research Institute, Inc. whose principal office is located at 3420 Hillview Avenue, Palo Alto, California ("EPRI") and I have been speCifically delegated responsibility for the above-listed Report contains EPRI Proprietary Information that is sought under this Affidavit to be withheld "Proprietary Information". I am authorized to apply to the U.S. Nuclear Regulatory Commission ("NRC") for the withholding of the Proprietary Information on behalf of EPR!.

EPRI Proprietary Information is identified in the above referenced report with underlined text inside double brackets. Examples of such identification is as follows:

((This sentence is an example{E)))

Tables containing EPRI Proprietary Information are identified with double brackets before and after the object. In each case the superscript notation {E) refers to this affidavit and all the bases included below, which provide the reasons for the proprietary determination.

EPRI requests that the Proprietary Information be withheld from the public on the following bases:

Withholding Based Upon Privileged And Confidential Trade Secrets Or Commercial Or Financial Information (see e.g. 10 C.F.R. §2.390(a)(4))::

a.

The Proprietary Information is owned by EPRI and has been held in confidence by EPR!. All entities accepting copies of the Proprietary Information do so subject to written agreements imposing an obligation upon the reCipient to maintain the confidentiality of the Proprietary Information. The Proprietary Information is disclosed only to parties who agree, in writing, to preserve the confidentiality thereof.

b.

EPRI considers the Proprietary Information contained therein to constitute trade secrets of EPR!. As such, EPRI holds the information in confidence and disclosure thereof is strictly limited to individuals and entities who have agreed, in writing, to maintain the confidentiality of the Information.

c.

The information sought to be withheld is considered to be proprietary for the following reasons. EPRI made a substantial economic investment to develop the Proprietary Information and, by prohibiting public disclosure, EPRI derives an economic benefit in the form of licensing royalties and other additional fees from the confidential nature of the Proprietary Information. If the Proprietary Information were publicly available to consultants and/or other businesses providing services in the electric and/or nuclear power industry, they would be able to use the Proprietary Information for their own commercial benefit and profit and without expending the substantial economic resources required of EPRI to develop the Proprietary Information.

d.

EPRI's classification of the Proprietary Information as trade secrets is justified by the Uniform Trade Secrets Act which California adopted in 1984 and a version of which has been adopted by over forty states. The California Uniform Trade Secrets Act, California Civil Code §§3426 - 3426.11, defines a "trade secret" as follows:

Trade secret' means information, including a formula, pattern, compilation, program device, method, technique, or process, that:

(1) Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (2) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy."

e.

The Proprietary Information contained therein are not generally known or available to the public. EPRI developed the Information only after making a determination that the Proprietary Information was not available from public sources. EPRI made a substantial investment of both money and employee hours in the development of the Propretary Information. EPRI was required to devote these resources and effort to derive the Proprietary Information. As a result of such effort and cost, both in terms of dollars spent and dedicated employee time, the Proprietary Information is highly valuable to EPRI.

f.

A public disclosure of the Proprietary Information would be highly likely to cause substantial harm to EPRI's competitive position and the ability of EPRI to license the Proprietary Information both domestically and internationally. The Proprietary Information and Report can only be acquired and/or duplicated by others using an equivalent investment of time and effort.

I have read the foregoing and the matters stated herein are true and correct to the best of my knowledge, information and belief. I make this affidavit under penalty of perjury under the laws of the United States of America and under the laws of the State of California.

Executed at 1300 W WT Harris Blvd, Charlotte, NC being the premises and place of business of Electric Power Research Institute, Inc.

Datr-o~

W £ Neil Wilmshurst

(State of North Carolina)

(County of Mecklenburg)

Subscribed ~

(or affirmed) before me on this /21ay of 71~, 20J7, by 1Z..tiJ ~

, proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me.

Signature Q~ah ~" cK att<Jt My Commission Expires £'day of Ilfd (Seal)

, 20~

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NOTARY PUBLIC CABARRUS COUNTY

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