PLA-5528, Supplement No. 1 to Proposed Amendment No. 247 to Unit 1 License No. NPF-14 and Proposed Amendment No. 212 to Unit 2 License No. NPF-22: Revision to the RPV Material Surveillance Program PLA-5528

Supplement No. 1 to Proposed Amendment No. 247 to Unit 1 License No. NPF-14 and Proposed Amendment No. 212 to Unit 2 License No. NPF-22: Revision to the RPV Material Surveillance Program PLA-5528

ML023050270
Person / Time
Site:	Susquehanna
Issue date:	10/23/2002
From:	Shriver B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-5528
Download: ML023050270 (12)

Text

Bryce L. Shriver PPL Susquehanna, LLC Senior Vice President and 769 Salem Boulevard Chief Nuclear Officer Berwck, PA 18603 Tel. 570.542.3120 Fax 570.542.1504 blshriver@pplweb com

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• TM TM, OCT 23* 202 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION SUPPLEMENT NO. 1 TO PROPOSED AMENDMENT NO. 247 TO UNIT 1 LICENSE NO. NPF-14 AND PROPOSED AMENDMENT NO. 212 TO UNIT 2 LICENSE NO. NPF-22: REVISION TO THE RPV MATERIAL SURVEILLANCE PROGRAM Docket Nos. 50-387 PLA-5528 and 50-388

Reference:

1) Letterfrom W. H. Bateman (USNRC) to C. Terry (BWR VIP Chairman)titled, "Safety EvaluationRegardingEPRI ProprietaryReport 'BWR Vessel and InternalsProject, B WR IntegratedSurveillanceProgramPlan (B WR VIP- 78) ' and 'B WI? VIP-86: B WIR Vessel and InternalsProject,BWR IntegratedSurveillanceProgramImplementation Plan,"' dated February1, 2002.

2) RegulatoryIssue Summary No. 2002-05, "NRC Approval ofBoiling Water Reactor Pressure Vessel IntegratedSurveillanceProgram," datedApril 8, 2002.

3) PLA-5498 from R. L. Anderson to USNRC Document ControlDesk titled, "Proposed Amendment No. 247 to Unit 1 License No. NPF-14 and ProposedAmendment No. 212 to Unit 2 License No. NPF-22: Revision to the RPV MaterialSurveillance Program," dated July 25, 2002.

The purpose of this letter is to respond to NRC Staff's questions on our proposed changes to the Susquehanna Steam Electric Station Final Safety Analysis Report (Susquehanna SES FSAR) for Unit 1 and Unit 2. This proposed change revises the Reactor Pressure Vessel Material Surveillance Program in accordance with References 1 and 2. This letter supercedes Reference 3.

Document Control Desk PLA-5528 At the request of the NRC staff, Supplement 1 revised the following:

"* The Technical Analysis in Attachment 1 was revised to clearly state that the methodology used to recalculate the fluence calculations will be in accordance with the requirements of Regulatory Guide 1.190.

"* FSAR Section 4.1.4.5 was revised to state that revisions to the fluence calculations will use NRC approved methodology that meets Regulatory Guide 1.190.

"* FSAR Section 5.3 and Tables 5.3-1b, 5.3-2b and 5.3-3 were revised to state that the Integrated Surveillance Program consists of BWRVIP-86, BWRVIP-78, the BWRVIP responses to NRC RAIs dated December 22, 2001 and May 30, 2001, and NRC's Safety Evaluation dated February 1, 2002.

Supplement 1 did not change the No Significant Hazards Considerations and Environmental Assessment from the previous submittal. to this letter is the "Safety Assessment" supporting this change. is the No Significant Hazards Considerations evaluation performed in accordance with the criteria of 10 CFR 50.92 and the Environmental Assessment. to this letter contains the applicable pages of the Susquehanna SES FSAR for Unit 1 and Unit 2, marked to show the proposed change.

Consistent with the process established between the NRC and the BWRVIP, this change is being processed as a license amendment to facilitate NRC review and approval.

PPL plans to implement the proposed changes in the Spring of 2003 to support deletion of work from the Unit 2 1 1 th Refueling and Inspection Outage. Therefore, we request NRC complete its review of this change by December 1, 2002 with the changes effective 30 days after approval.

Any questions regarding this request should be directed to Mr. Cornelius T. Coddington at (610) 774-4019.

Sincerely, L. Shriver

Document Control Desk PLA-5528 Attachments: Affidavits Attachment 1 - Safety Assessment - Revision to the Reactor Pressure Vessel Material Surveillance Program Attachment 2 - No Significant Hazards Considerations and Environmental Assessment Attachment 3 - Final Safety Analysis Report Mark-Ups copy: NRC Region I Mr. D. J. Allard, PA DEP Mr. S. L. Hansell, NRC Sr. Resident Inspector Mr. E. M. Thomas, NRC Project Manager Mr. R. Janati, DEP/BRP

BEFORE THE BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of PPL Susquehanna, LLC: Docket No. 50-387 SUPPLEMENT NO. 1 TO PROPOSED AMENDMENT NO. 247 TO LICENSE NPF-14:

REVISION TO THE REACTOR PRESSURE VESSEL MATERIAL SURVEILLANCE PROGRAM UNIT NO. 1 Licensee, PPL Susquehanna, LLC, hereby files a revision to its Facility Operating License No. NPF-14 dated July 17, 1982.

This amendment involves a revision to the Susquehanna SES Final Safety Analysis Report Specifications.

? *--- "--- PPL Susquehanna, LLC

- -. .- By:

B. 4. Shn'*er Sr. Vice-President and Chief Nuclear Officer Sworn to and subscribed before me Noctaial Seal this day of Ab.-', 2002. Laurie Minto, Notary Public Salem T'wp,. Luzem County My Commluion Expires July 24, 2006 Memrr ,m*wtmfAa=scWn tNoarWles Notary Public

BEFORE THE BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of PPL Susquehanna, LLC: Docket No. 50-388 SUPPLEMENT NO. 1 TO PROPOSED AMENDMENT NO. 212 TO LICENSE NPF-22:

REVISION TO THE REACTOR PRESSURE VESSEL MATERIAL SURVEILLANCE PROGRAM UNIT NO. 2 Licensee, PPL Susquehanna, LLC, hereby files a revision to its Facility Operating License No. NPF-22 dated March 23, 1984.

This amendment involves a revision to the Susquehanna SES Final Safety Analysis Report.

-,< -,'-. .. - .. . ./ f PPL Susquehanna, LLC Sr L.S V river Sr. Vice-President and Chief Nuclear Officer Sworn to and subscribed before me this A!) day of Oe.,4 o0e, 2002.

1 Notarial Seal laurie Minto, Notary Public Salem Twp.. Luzerne County My Commnilon Expires July 24, 2006 J

ier ,Ponnanqot atgon of NMoft Notary Public

Attachment I to PLA-5528 Safety Assessment Revision to the Reactor Pressure Vessel Material SSurveillance Program

Attachment 1 to PLA-5528 Page 1 of3 Safety Assessment Revision to the Reactor Pressure Vessel Material Surveillance Program The following provides the basis for the proposed revision to the reactor pressure vessel material surveillance program.

1.0 DESCRIPTION

OF THE PROPOSED CHANGE PPL Susquehanna, LLC (PPL) proposes to revise the licensing basis for Susquehanna Steam Electric Station Units 1 and 2 (SSES) by replacing the current plant-specific reactor pressure vessel (RPV) material surveillance program with the Boiling Water Reactor (BWR) Integrated Surveillance Program (ISP), which was approved by the NRC in its Safety Evaluation (SE) dated February 1, 2002 (Reference 1). The proposed revision to the SSES Final Safety Analysis Report reflecting this change is provided for information in Attachment 3.

2.0 REASON FOR THE PROPOSED CHANGE The BWR ISP was developed in response to an issue raised by the NRC staff regarding the potential lack of adequate unirradiated baseline Charpy V-notch (CVN) data for one or more materials in plant-specific RPV surveillance programs at several BWRs. The lack of baseline properties would inhibit a licensee's ability to effectively monitor changes in the fracture toughness properties of RPV materials in accordance with Appendix H to 10 CFR 50. The BWR ISP, as approved by the NRC, resolves this issue.

Implementation of the ISP will provide additional benefits. When the original surveillance materials were selected for plant-specific surveillance programs, the state of knowledge concerning RPV material response to irradiation and post irradiation fracture toughness was not the same as it is today. As a result, many facilities did not include what would be identified today as the plant's limiting RPV materials in their surveillance programs. Hence, this effort to identify and evaluate materials from other BWRs, which may better represent a facility's limiting materials, should improve the overall evaluation of BWR RPV embrittlement. Second, the inclusion of data from the testing of BWR Owners' Group (BWROG) Supplemental Surveillance Program (SSP) capsules will improve the overall quality of the data being used to evaluate BWR RPV

Attachment 1 to PLA-5528 Page 2 of 3 embrittlement. Finally, implementation of the ISP is also expected to reduce the cost of surveillance testing and analysis since surveillance materials that are of little or no value (either because they lack adequate unirradiated baseline CVN data or because they are not the best representative materials) will no longer be tested.

3.0 TECHNICAL ANALYSIS

Reference I concludes that the proposed ISP, if implemented in accordance with the conditions in the SE, has been determined to be an acceptable alternative to all existing BWR plant-specific RPV surveillance programs for the purpose of maintaining compliance with the requirements of Appendix H to 10 CFR Part 50 through the end of current facility 40 year operating licenses. Reference 1 requires that each licensee (1) provide information regarding what specific neutron fluence methodology will be implemented as part of participation in the ISP and (2) address the neutron fluence methodology compatibility issue as it applies to the comparison of neutron fluences calculated for its RPV versus the neutron fluences calculated for surveillance capsules in the ISP which are designated to represent its RPV. This information is provided in the following discussion.

The SSES Technical Specifications, as discussed in Amendment No. 200 to SSES Unit 1 Operating License (NPF-14) and Amendment No. 174 to SSES Unit 2 Operating License (NPF-22) require that new P-T curves be implemented based on updated fluence calculations by May 1, 2005 and May 1, 2006 (Unit 2 and Unit 1 respectiviely). See Reference 2 for additional information. The methodology used for the recalculation of the fluence will be in accordance with the requirements of Regulatory Guide 1.190.

PPL intends to use the BWRVIP RAMA code or other NRC approved methodology that meets Regulatory Guide 1.190 to revise the calculations for both Units 1 and 2. The RAMA code will perform a full 3D-neutron transport solution to determine fluence within the vessel. The analysis will use the BUGLE-96 data library as recommended by Regulatory Guide 1.190. It will perform a full uncertainty analysis to determine the accuracy of the calculation. The Susquehanna SES FSAR will be updated to include reference to the requirements of Regulatory Guide 1.190 when the new fluence calculation methodology is utilized.

Attachment 1 to PLA-5528 Page 3 of 3 The BWRVIP's anticipated schedule for completion of the BWRVIP RAMA code is December 2002. The BWRVIP intends to submit a topical report on the RAMA code to the NRC for review, with the objective of receiving a safety evaluation in 2003 approving use of the methodology.

The first surveillance capsule to be tested under the ISP is the River Bend 1830 capsule. The test report is scheduled to be submitted to the NRC by February 2003. Coincidentally, these capsules, according to the ISP, are the substitute capsules for SSES Unit 2. Thus in accordance with the ISP, the SSES Unit 2 capsule will not be removed and tested.

The ISP requires the Unit 1 surveillance capsules be removed in 2012 and tested in 2013. The Unit 1 fluence calculations will be reevaluated both in 2006 and after this ISP testing.

REFERENCES:

1. Letter, W. H. Bateman (USNRC) to C. Terry (BWRVIP Chairman), "Safety Evaluation Regarding EPRI Proprietary Report 'BWR Vessel and Internals Project, BWR Integrated Surveillance Program Plan (BWRVIP-78)' and

'BWRVIP-86: BWR Vessel and Internals Project, BWR Integrated Surveillance Program Implementation Plan"', dated February 1, 2002.

2. Letter, D. S. Collins (USNRC) to R. G. Byram (PPL), "Susquehanna Steam Electric Station Units 1 and 2 - Issuance of Amendment RE: Reactor Pressure Vessel Pressure-Temperature Limit Curves", dated February 7, 2002.

Attachment 2 to PLA-5528 No Significant Hazards Considerations and Environmental Assessment

Attachment 2 to PLA-5528 Page 1 of 2 No Significant Hazards Considerations and Environmental Assessment The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

PPL proposes to revise the licensing basis for SSES by replacing the plant-specific RPV material surveillance program with the BWR ISP. This change is acceptable because the BWR ISP has been approved by the NRC staff as meeting the requirements of paragraph III.C of Appendix H to 10 CFR 50 for an integrated surveillance program.

In accordance with the criteria set forth in 10 CFR 50.92, PPL has evaluated the proposed TS change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.

1. Does the proposed change involve a significantincrease in the probabilityor consequences of an accidentpreviously evaluated?

No. The proposed change implements an integrated surveillance program that has been evaluated by the NRC staff as meeting the requirements of paragraph III.C of Appendix H to 10 CFR 50. Consequently, the proposed change does not significantly increase the probability of any accident previously evaluated. The proposed change provides the same assurance of RPV integrity. As a result, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accidentfrom any accidentpreviously evaluated?

No. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in methods governing normal plant operation. The proposed change maintains an equivalent level of RPV material surveillance and does not introduce any new accident initiators. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Attachment 2 to PLA-5528 Page 2 of 2

3. Does the proposedchange involve a significantreduction in a margin ofsafety?

No. The proposed change has been evaluated as providing an acceptable alternative to the plant-specific RPV material surveillance program that meets the requirements of the regulations for RPV material surveillance. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

ENVIRONMENTAL CONSIDERATION 10 CFR 51.22(c)(9) identifies certain licensing and regulatory actions, which are eligible for categorical exclusion from the requirement to perform an environmental assessment.

A proposed amendment to an operating license for a facility does not require an environmental assessment if operation of the facility in accordance with the proposed amendment would not (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; or (3) result in a significant increase in individual or cumulative occupational radiation exposure. PPL has evaluated the proposed change and has determined that the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Accordingly, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with issuance of the amendment. The basis for this determination, using the above criteria, follows:

Basis

1. As demonstrated in the No Significant Hazards Consideration Evaluation, the proposed amendment does not involve a significant hazards consideration.

2. There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation.

There is no significant increase in individual or cumulative occupational radiation exposure. The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation.