ML19282D892
| ML19282D892 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/15/2019 |
| From: | April Pulvirenti Plant Licensing Branch IV |
| To: | Entergy Operations |
| Pulvirenti A | |
| References | |
| EPID L-2019-LLL-0017 | |
| Download: ML19282D892 (8) | |
Text
October 15, 2019 Site Vice President Entergy Operations, Inc.
Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REVISION TO REACTOR VESSEL SURVEILLANCE CAPSULE WITHDRAWAL SCHEDULE (EPID L-2019-LLL-0017)
Dear Sir or Madam:
By letter dated April 25, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19115A417), Entergy Operations, Inc. (Entergy, the licensee),
requested revision of the reactor vessel material surveillance capsule withdrawal schedule for the Waterford Steam Electric Station, Unit 3 (Waterford 3). The proposed changes were submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements,Section III.B.3, which requires that: (1) withdrawal schedules be submitted, as specified in 10 CFR 50.4, Written Communications, and (2) the proposed schedule must be approved by the Nuclear Regulatory Commission (NRC) prior to implementation. Specifically, the licensee proposed to change the withdrawal of Capsule W-277 from Standby to 48 effective full power years.
The NRC staff has reviewed the submittal and concludes that the proposed revision of the surveillance capsule withdrawal schedule for Capsule W-277 is acceptable and consistent with the intent and requirements of the applicable regulations and guidance found in Appendix H to 10 CFR Part 50, as well as American Society for Testing and Materials Standard E185-82, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels, dated July 1, 1982. Furthermore, the proposed change meets the guidance in NUREG-1801, Revision 1, Generic Aging Lessons Learned (GALL) Report,Section XI.M31, and is therefore acceptable for implementation for the current 60-year term. The NRC staffs related safety evaluation is enclosed.
If you have any questions, please contact me at 301-415-1390 or via e-mail at April.Pulvirenti@nrc.gov.
Sincerely,
/RA/
April L. Pulvirenti, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
Safety Evaluation cc: Listserv
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR REVISED REACTOR VESSEL SURVEILLANCE CAPSULE WITHDRAWAL SCHEDULE ENTERGY OPERATIONS, INC WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382
1.0 INTRODUCTION
By letter dated April 25, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19115A417), Entergy Operations, Inc. (Entergy, the licensee),
requested revision of the reactor vessel (RV) material surveillance capsule withdrawal schedule for the Waterford Steam Electric Station (Waterford 3), in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements,Section III.B.3.
Specifically, the licensee proposed to change the withdrawal of Capsule W-277 from Standby to 48 effective full power years (EFPY).
2.0 REGULATORY EVALUATION
The following regulations and guidance govern licensee requests to revise the capsule removal schedule.
2.1 Section 50.60 of 10 CFR and Appendix H to 10 CFR Part 50 The U.S. Nuclear Regulatory Commission (NRC) has established requirements and criteria in 10 CFR 50.60 for protecting the RVs of U.S. light-water reactors (LWRs) against fracture. The rule requires U.S. LWRs to meet the RV materials surveillance program requirements set forth in Appendix H, Reactor Vessel Material Surveillance Program Requirements, to 10 CFR Part 50.
Appendix H to 10 CFR Part 50 provides the NRC staffs criteria for the design and implementation of RV material surveillance programs for operating LWRs.
Enclosure
Section I of this regulation states, in part:
The purpose of the reactor vessel material surveillance program required by this appendix is to monitor changes in the fracture toughness properties of ferritic materials in the reactor vessel beltline region of light water nuclear power reactors which result from exposure of these materials to neutron irradiation and the thermal environment. Under the program, fracture toughness test data are obtained from material specimens exposed in surveillance capsules, which are withdrawn periodically from the reactor vessel.
Section III(B)(1) states, in part:
The design of the surveillance program and the withdrawal schedule must meet the requirements of the edition of [American Society for Testing and Materials]
ASTM E185 that is current on the issue date of the [American Society of Mechanical Engineers] ASME Code to which the reactor vessel was purchased.
Later editions of ASTM E185 may be used, but including only those editions through 1982.
Section III(B)(3) states, in part:
A proposed withdrawal schedule must be submitted with a technical justification as specified in 10 CFR 50.4. The proposed schedule must be approved prior to implementation.
2.3 ASTM E185-82 ASTM E185-82 provides specific criteria for removal of surveillance capsules, specifically, the removal times and number of capsules that must be removed. Surveillance capsules must be removed after a certain amount of power operation has elapsed or at various times when the RV shell is projected to achieve certain levels of neutron fluence. The intent of the Standard Practice is to achieve a set of testing data over a range of neutron fluences for the RV that bounds the current life of the plant.
For the second-to-last required capsule in a withdrawal schedule, ASTM E185-82 requires that the capsules be removed at either 15 EFPY or at the time when the capsule fluence is equivalent to the limiting fluence projected for the clad-based metal interface of the RV at end of life (EOL), whichever time comes first. For the final capsule that is required for removal, ASTM E185-82 requires that the capsule be removed at a time when the neutron fluence projected for the capsule is between the limiting fluence value projected for the RVs at the EOL (32 EFPY) and two times that value.
2.4 NRC Memorandum and Order CLI-96-13 and NRC Administrative Letter (AL)97-004 On December 6, 1996, the Commission issued Memorandum and Order CLI-96-13 as part of the decision In the Matter of the Cleveland Electric Illuminating Company, et al (Perry Nuclear Power Plant, Unit 1). On September 30, 1997, the NRC summarized this Order in AL 97-004, NRC Staff Approval for Changes to 10 CFR Part 50, Appendix H, Reactor Vessel Surveillance Specimen Withdrawal Schedules. The AL clarifies the NRC review process for changes in the capsule removal schedule by stating, in part:
The Commission found that, while 10 CFR Part 50, Appendix H, II.B.3 requires prior NRC approval for all withdrawal schedule changes, only certain changes require licensee amendments as the process to be followed for such approval. Specifically, those changes that do not conform to the ASTM standard referenced in Appendix H (ASTM E-185, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels) will require approval by the license amendment process, whereas changes that conform to the ASTM standard require only staff verification of such conformance.
2.5 Generic Aging Lessons Learned (GALL) Guidelines By letters dated March 23, 2016 (ADAMS Accession Nos. ML16088A331, and ML16088A332 and ML16088A325), the licensee submitted a license renewal application (LRA) Waterford 3 based on NUREG-1801, Revision 2, Generic Aging Lessons Learned Report. By letter dated December 27, 2018 (ADAMS Accession No., ML18275A234), the NRC granted license renewal to Waterford for a term expiring December 18, 2044.Section XI.M31 of the Generic Aging Lessons Learned report, Reactor Vessel Surveillance, includes recommended changes to the surveillance capsule withdrawal schedule to address the period of extended operation.
3.0 NRC STAFF EVALUATION 3.1 Licenses Proposed Changes for Capsule Removal at Waterford 3 The current capsule withdrawal schedule is found in the Section 5.3, Reactor Vessel, of the Waterford 3 Updated Final Safety Analysis Report (UFSAR) (ADAMS Accession No. ML16256A115) as Table 5.3-10, Capsule Assembly Removal Schedule, and is included as Table 1 of the licensees submittal. In its submittal, the licensee proposed to alter the current withdrawal schedule for Capsule W-277, which is the second-to-last capsule, from Standby to Year 2038 (48 EFPY with a neutron fluence of 4.51 x 1019 n/cm2 (E > 1 MeV)). The proposed capsule withdrawal schedule is provided in Table 2 of the submittal.
Along with this change in withdrawal schedule for Capsule W-277, some minor changes are also proposed to reflect the most recent fluence calculations performed and reported in WCAP-17969-NP, Analysis of Capsule 83° from the Entergy Operations, Inc. Waterford Unit 3 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML19073A302):
Capsule W-83 removal time is revised from 26 EFPY to 24.66 EFPY with the target fluence changed from 2.47 x 1019 n/cm2 (E > 1 MeV) to 2.42 x 1019 n/cm2 (E > 1 MeV).
The lead factor for Capsules W-83 and W-277 is revised from 1.19 to 1.20.
Capsule W-97 removal time is revised from 4.44 EFPY to 4.41 EFPY with the target fluence changed from 6.47 x 1018 n/cm2 (E > 1 MeV) to 6.31 x 1018 n/cm2 (E > 1 MeV).
3.2 NRC Staff Review The NRC staff notes that, as part of its LRA, the licensee committed to provide to the NRC, within 1 year of receipt of its renewed license, a withdrawal schedule for Capsule W-277. The NRC also notes that this submission was provided to fulfill the licensees commitment. As such, the NRCs review of this submittal: first, evaluated the consistency of the licensees submittal
with its license renewal commitment; and second, evaluated the consistency of the licensees submittal with the requirements of 10 CFR Part 50 Appendix H.
With respect to consistency between the current submission and the licensees license renewal commitment, the NRC staff notes that the license renewal of Waterford Steam Electric Station, Unit 3 (ADAMS Accession No. ML18228A668) states under Section 3.3.3.1.15:
The staff finds the applicants response acceptable because (1) the applicant provided the baseline information on the current EFPY compared to the withdrawal schedule for Capsule 277° at 48 EFPY; (2) the applicant identified a program enhancement to submit the withdrawal schedule for Capsule 277° for staff review and approval within 1 year following the receipt of the renewed license; (3) the applicant confirmed that the capsule withdrawal schedule is consistent with the guidance on the capsule fluence range in GALL Report AMP XI.M31 (i.e., between one and two times the peak reactor vessel wall fluence projected at the end of extended operation).
In its review of the current submission, the NRC staff finds that the proposed revision does not deviate from the 48 EFPY set for Capsule W-277 in the LRA, and is consistent with the guidance on the capsule fluence range in GALL Report AMP XI.M31 to withdraw between one and two times the peak RV wall fluence projected at the end of extended operation, which is also required by ASTM E185-82. Therefore, the NRC staff finds that the licensees proposed revision to reactor RV surveillance capsule withdrawal schedule regarding Capsule W-277 is consistent with its license renewal commitment.
With respect to consistency of the licensees proposal with respect to Appendix H, the NRC staff notes that RV material surveillance capsules are withdrawn and tested periodically as designated in the withdrawal schedule. Appendix H requires that the proposed schedule be in accordance with ASTM E185-82 and that it be approved prior to implementation.
Paragraph 7.6.2 of ASTM E185-82 requires that the second to last capsule does not exceed the peak end of life fluence and that the last capsule does not exceed twice the end or life fluence or, as more clearly stated in footnote E of Table 1, Minimum Recommended Number of Surveillance Capsules and Their Withdrawal Schedule, the final capsule is withdrawn at not less than once nor greater than twice the peak end of life vessel fluence. Paragraph 4.4 of ASTM E185-82 defines EOL as the design lifetime in terms of years, EFPY, or neutron fluence.
Based on the licensees 60-year renewed license, the NRC finds that the plant EOL is currently 60 years and that the final capsule must be withdrawn between 1 to 2 times the EFPY that will be accumulated during that operating life.
The licensee has proposed changing the withdrawal date for Capsule W-277 to 2038 (48 EFPY). The corresponding neutron fluence at this EFPY for this capsule would be 4.51 x 1019 n/cm2 (E > 1.0 MeV), which is 1.2 times the 60-year neutron fluence of 4.32 x 1019 n/cm2 as stated in the submittal. With this change, the capsule is scheduled to be withdrawn before twice the 60-year neutron peak fluence is reached.
In its review of the licensees proposal, the NRC staff found that the licensee proposes withdrawal schedule for capsule W-277 at a fluence between the peak vessel fluence at 60 years and 120 years. As such the NRC staff finds that the licensees proposal is consistent with ASTM E185-82 and, therefore, consistent with 10 CFR Part 50 Appendix H. Given that the
licensees proposal is consistent with both the license renewal commitment and 10 CFR Part 50 Appendix H, the NRC staff finds that the licensees proposal is acceptable.
The NRC staff also noted a minor discrepancy between the current lead factor for Capsules W-83 and W-277 in the licensees proposed change (Section 3.1 of this safety evaluation) and in Table 1. The NRC staff verified that the Table 1 information is correct. The NRC staff also verified that the discrepancy does not affect the current evaluation.
NRC AL 97-04 informed licensees that changes to their facility RV material surveillance capsule withdrawal schedules, as specified in 10 CFR Part 50, Appendix H, that conform to the applicable ASTM standard require only NRC staff verification of such conformance. Based on the information in the application and the safety evaluation report for the LRA for Waterford 3 (ADAMS Accession No. ML18228A668), the NRC staff finds the licensee has demonstrated that its proposed withdrawal schedule fulfills the provisions in ASTM E185-82, for the 60-year life of Waterford 3.
The NRC staff also reviewed the additional changes described in the licensee's submittal and found that these changes are based on the most recent fluence calculations reported in WCAP-17969-NP. These changes are insignificant and do not affect the current evaluation, and are unlikely to affect future evaluation regarding the remaining standby capsules withdrawal.
4.0 CONCLUSION
Based on the above evaluation, the NRC staff concludes that the revised surveillance capsule withdrawal schedule for Capsule W-277 for Waterford 3 satisfies its license renewal commitment and the requirements of ASTM E185-82 as they relate to the current 60-year operating period. The NRC staff further concludes that the licensees modified surveillance capsule withdrawal schedule for Capsule W-277 for Waterford 3 is acceptable for implementation and satisfies the requirements of 10 CFR Part 50, Appendix H, for the current 60-year license term. Therefore, the NRC staff approves the revised surveillance capsule withdrawal schedule.
Principal Contributors: Chia-Fu (Simon) Sheng Shie-Jeng Peng Date: October 15, 2019
ML19282D892 *by email dated OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DMLR/MVIB/BC* NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM PBlechman NAME APulvirenti (JBurkhardt for) DAlley* JDixon-Herrity APulvirenti DATE 10/15/2019 10/11/2019 9/20/2019 10/15/2019 10/15/2019