ML20209G385

Safety Evaluation Supporting Amend 182 to License DPR-35

ML20209G385
Person / Time
Site:	Pilgrim
Issue date:	07/15/1999
From:	NRC (Affiliation Not Assigned)
To:
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ML20209G382	List: ML20209G378 ML20209G385
References
NUDOCS 9907190146
Download: ML20209G385 (5)

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UNITED 3TATES I{

' NUCLEAR REGULATORY COMMISSION -

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- SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

- RELATED TO AMENDMENT NO.182 TO FACILITY OPERATING LICENSE NO. DPR-35 I

BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 o

1.0 ' INTRODUCTION By letter dated March 3,1999 [1], Boston Edison Company (BECo, the licensee), requested that the Nuclear Regulatory Commission (NRC) review and approve its proposed Technical Specification (TS) change to modify its reactor pressure vessel (RPV) surveillance capsule

' withdrawal schedule. The proposed change would change the date of withdrawal of the next surveillance capsule in TS Table,4.6-3 from 15 effective full power years (EFPY) of operation to 18 EFPY. BECo's submittal was made in accordance with the provision of Title 10 of the Code of Federal Reaulations, (10 CFR), Section 50.90, which specifies that when license holders desire to amend their license, an amendment application must be filed with the Commission, as specified in.10 CFR 50.4. This provision is invoked since the facility TSs are incorporated directly as part of the facility's license.

2.0 ~ REGULATORY REQUIREMENTS AND STAFF POSITIONS Nuclear power plant licensees are required by 10 CFR Part 50, Appendix H, to implement RPV surveillance programs to " monitor changes in the fracture toughness properties of ferritic materials in the reactor vessel beltline region...which result from exposure of thcoe materials to neutron irradiation and the thermal environment." Regarding RPV surveillance program design and specimen testing,10 CFR Part 50, Appendix H, incorporates by reference the editions of the American Society for Testing and Materials (ASTM) Standard Practice E 185, " Conducting Surveillance Tests for Light-Water Coolet Nuclear Power Reactor Vessls," through the 1982 edition.. Under 10 CFR Part 50, Appendix H, the licensee's RPV surveillance program design and withdrawal schedule is required to meet the requirements of the edition of ASTM E 185 that

, is current on the issue date of the American Society of Mechanical Engineers (ASME) Code to which the RPV was purchased, although later editions may be used, up to and including the 1982 edition. The test procedures and reporting requiremeats must however mee. the requirements of the 1982 edition of ASTM E185, to the' extent practical for the configuration of the specimens in the capsules.

As referenced in Pilgrim TS 4.6.A., the edition of ASTM E 185 to which the Pilgrim RPV surveillance' program wAs designed was the 1966 edition (ASTM E 185-66). Paragraph 4.6 of the ASTM E 185-66 addresses the withdrawal schedule as follows, "[i]t is recommended that sets of specimens be withdrawn at three or more separate times. One of the data points obtained shall correspond to the neutron exposure of the component near the end of its design 9907190146 990715 PDR ADOCK 05000293 P.

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2 life." As apparent from the March 3,1999, submittal, and as verified in subsequent discussions with BECo via teleconference on April 8,1999, the licensee indicated that although it was not directly incorporated in the Pilgrim licensing basis, Table 1 from the 1982 edition of E 185 had been used for additional guidance when the 15 EFPY withdrawal date in TS Table 4.6-3 for the second capsule was originally established.

3.0 LICENSEE'S DETERMINATION in its March 3,1999, submittal, BECo stated that its reason for requesting this TS change was that after the removal of the second capsule, only one additional capsule would be available from the Pilgrim RPV surveillance program and that it must remain in the RPV until the end of the vessel's life. In addition, BECo stated their intent, at this time, to participate in a Boiling Water Reactor Vessel and Internals Project (BWRVIP) initiative to develop an integrated j

surveillance program for BWRs. The BWRVIP intends to submit this program by the end of 1999 for the NRC staff review and approval. BECo noted that to take full advantage of this j

program, a deferral of the withdrawal of the next Pilgrim surveillance capsule is needed.

1 With regard to the impact of the surveillance capsule deferral on RPV integrity, BECo determined that the capsule deferral would not challenge their ability to operate the RPV safely.

However, it does defer a TS required surveillance. BECo noted that the Pilgrim operational

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practices would not be changed as a result of the deferral and that the existing TS pressure-temperature (P-T) limit curves which were reviewed and approved by the NRC in 1992 were expected to r6,.un conservative and not be affected by the proposed capsule deferral. BECo 1

statd that this would be the case since the method incorporated in the Pilgrim TS for establishing P-T limits does not rely on credit being given for the use of surveillance data, but rather uses the generic methodology of Regulatory Guide (RG) 1.99, Revision 2 [2].

4.0 STAFF EVALUATION The NRC staff reviewed the information supplied by the licensee and the regulatory requirements stated in section 2.0 above. The staff agrees with the licensee that the deferral of i

the second capsule withdrawal from 15 to 18 EFPY is acceptable from both a regulatory and technical standpoint. The staff reached these conclusions because compliance with the ASTM E 185-66, as required for Pilgrim by 10 CFR Part 50, Appendix H, is non-prescriptive with regard to withdrawal of the second surveillance capsda. As noted in Section 2.0, the only i

specific withdrawal requirement in E 185-66 is that one capsule (data point) be obtained at near end-of-license exposure levels. Therefore, withdrawal of the second capsule at 18 EFPY is in compliance with 10 CFR Part 50, Appendix H. In addition, the staff agrees that the establishment of P-T limits based on the procedures of RG 1.99, Revision 2, will continue to provide an appropriately conservative assessment of the RPV P-T limits. The staff has also been informed of the BWRVIP's intent to submit an ISP by the end of 1999 (3) and agrees that it is technically appropriate for Pilgrim to defer its second capsule withdrawal in order to fully participate in the !SP.

The NRC staff has concluded that deferral of the withdrawal of the second Pilgrim RPV surveillance capsule from 15 EFPY to 18 EFPY is acceptable. Therefore, the proposed change to the Pilgrim TS Table 4.6-3 is acceptable.

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5.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Massachusetts State Official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes the surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazaids consideration, and there has been no public comment on such finding (64 FR 27316). According!y, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (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.

Principal Contributor: M. Mitchell Date: July 15,1999

4 8.0. REFERENCES

[1]

T. A. Sullivan, BECo, to U.S. Nuclear Regulatory Commission, Document Control Desk,

" Request for Technical Specification Change Concerning Vessel Material Surveillance interval (Capsule Pull)," March 3,1999.

-(2), U.S. Nuclear Regulatory Commission Regulatory Guide 1.99, Revision 2, " Radiation Embrittlement of Reactor Vessel Materials," May 1988.

[3]

M. A. Mitchell, USNRC, to K. R. Wichman USNRC, " Trip Report, BWRVIP Meeting on Integrated Surveillance Program, March 30 - April 1,1999," April 7,1999.

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DATED:

.n ny 15 1909 AMENDMENT NO.182 TO FACILITY OPERATING LICENSE NO. DPR-35, PlLGRIM NUCLEAR POWER STATION DISTRIBUTION:

Docket File s PUBLIC PDI-2 r/f E. Adensam (EGA1)

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J. Clifford T Clark A. Wang OGC G. Hill (2)

W. Beckner ACRS M. Oprendak, RI M. Mitchell R. Scholl (email SE to RFS) l