RS-14-225, Stations, Units 1 & 2 - Response to NRC Request for Additional Information, Set 37, Dated July 7, 2014, License Renewal Application
| ML14209A045 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 07/28/2014 |
| From: | Gallagher M Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-14-225 | |
| Download: ML14209A045 (13) | |
Text
Michael P. Gallagher Vice President. License Renewal Exelon Generation Exelon Nuclear 200 Exelon Way Kennett Square. PA 19348 610 765 5958 Office 610 765 5956 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50 10 CFR 51 10 CFR 54 RS-14-225 July 28, 2014 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455
Subject:
Response to NRC Request for Additional Information, Set 37, dated July 7, 2014, related to the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application
References:
- 1. Letter from Michael P. Gallagher, Exelon Generation Company LLC (Exelon) to NRC Document Control Desk, dated May 29, 2013, "Application for Renewed Operating Licenses"
- 2. Letter from Lindsay R. Robinson, US NRC to Michael P. Gallagher, Exelon, dated July 7, 2014, "Request for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 37 (TAC Nos. MF1879, MF1880, MF1881, and MF1882)"
In Reference 1, Exelon Generation Company, LLC (Exelon) submitted the License Renewal Application (LRA) for the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2 (BBS). In Reference 2, the NRC requested additional information to support staff review of the LRA.
Enclosure A contains the response to this request for additional information.
Enclosure B contains updates to sections of the LRA (except for the License Renewal Commitment List) affected by the responses.
Enclosure C provides an update to the License Renewal Commitment List (LRA Appendix A, Section A.5). There are no other new or revised regulatory commitments contained in this letter.
July 28, 2014 U.S. Nuclear Regulatory Commission Page 2 If you have any questions, please contact Mr. Al Fulvio, Manager, Exelon License Renewal, at 610-765-5936.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on 7 - d 6 _.) O/<f Respectfully,
Enclosures:
A. Response to Request for Additional Information B. Updates to affected LRA sections C: License Renewal Commitment List Change cc: Regional Administrator - NRC Region Ill NRC Project Manager (Safety Review}, NRR-DLR NRC Project Manager (Environmental Review), NRR-DLR NRC Senior Resident Inspector, Braidwood Station NRC Senior Resident Inspector, Byron Station NRC Project Manager, NRR-DORL-Braidwood and Byron Stations Illinois Emergency Management Agency - Division of Nuclear Safety
RS-14-225 Enclosure A Page 1 of 2 Enclosure A Byron and Braidwood Stations (BBS), Units 1 and 2 License Renewal Application Response to Request for Additional Information RAI B.2.1.19-1b
RS-14-225 Enclosure A Page 2 of 2 RAI B.2.1.19-1b Applicability:
Byron Station (Byron) and Braidwood Station (Braidwood), Units 1 and 2
Background:
By letter dated May 23, 2014, the applicant responded to request for additional information (RAI) B.2.1.19-1a that requested an updated surveillance capsule withdrawal schedule for each unit at Byron and Braidwood.
Issue:
In its response, the applicant deleted information regarding the next capsule withdrawal schedule (e.g., capsules and capsule fluences) from the updated final safety analysis report (UFSAR) supplement, program enhancement, and commitment. The staff cannot determine the adequacy of the applicants Reactor Vessel Surveillance program because the deleted information is necessary to confirm the programs compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H.
Request:
Provide a basis for the deletion of the information regarding the capsule withdrawal schedule from the UFSAR supplement, program enhancement, and commitment. In addition, provide alternative information upon which the staff could assess the programs compliance with 10 CFR Part 50, Appendix H.
Exelon Response:
Upon further consideration, information regarding the capsule withdrawal schedule is being included in the UFSAR supplement (LRA Appendix A), program enhancement (LRA Appendix B), and commitment tabulation (LRA Appendix A.5).
LRA Appendix A, Section A.2.1.19, Appendix B, Section B.2.1.19, and Appendix A.5, commitment 19, are revised as shown in Enclosures B and C.
RS-14-225 Enclosure B Page 1 of 6 Enclosure B Byron and Braidwood Stations, Units 1 and 2 License Renewal Application Updates resulting from the response to the following RAI:
RAI B.2.1.19-1b Note: To facilitate understanding, portions of the original LRA have been repeated in this Enclosure, with revisions indicated. Existing LRA text, as modified by subsequent submittals, is shown in normal font. Changes are highlighted with bolded italics for inserted text and strikethroughs for deleted text.
RS-14-225 Enclosure B Page 2 of 6 As a result of changes to the Reactor Vessel Surveillance aging management program identified in the response to B.2.1.19-1b, LRA Appendix A, Section A.2.1.19, page A-25 is revised as shown below. Revisions are indicated with bolded italics for inserted text and strikethroughs for deleted text:
A.2.1.19 Reactor Vessel Surveillance The Reactor Vessel Surveillance aging management program is an existing condition monitoring program that extends the scope of 10 CFR Part 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements. The program provides sufficient material and dosimetry data to monitor loss of fracture toughness due to neutron irradiation embrittlement until the end of the period of extended operation, and determine the need for operating restrictions on the irradiation temperature (i.e., cold leg operating temperature), neutron spectrum, and neutron fluence. There were six (6) specimen capsules installed in each Byron and Braidwood Station (BBS) reactor pressure vessel (RPV) prior to plant start-up. The capsules contain representative RPV material specimens, neutron dosimeters, and thermal monitors (eutectic alloy).
All six (6) specimen capsules have been withdrawn from each of the BBS RPVs.
Three (3) specimen capsules from each RPV were tested and the remaining three (3) untested specimen capsules from each RPV are currently stored in the spent fuel pool.
Of the three (3) untested specimen capsules from each RPV at least one (1) untested specimen capsule has been irradiated in excess of the projected peak neutron fluence of the associated RPV at the end of the period of extended operation. Capsules that have been withdrawn will be tested as necessary to fulfill the surveillance capsule recommendations contained in ASTM 185-82 as required by 10 CFR Part 50, Appendix H. Operating restrictions will be established to ensure that the plant is operated under the conditions to which the surveillance capsules were exposed. All capsules tested for the period of extended operation will meet the test procedures and reporting requirements of ASTM E 185-82, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule withdrawal schedule, including spare capsules, must be approved by the NRC prior to implementation. Untested capsules placed in storage must be maintained for possible future insertion.
The program also monitors plant operating conditions to ensure appropriate steps are taken if reactor vessel exposure conditions are altered, such as the review and updating of 60-year fluence projections to support upper shelf energy calculations and pressure-temperature limit curves. The program also includes condition monitoring by removal and analysis of ex-core neutron dosimetry sensor sets to validate neutron exposure projection calculations through the period of extended operation in accordance with Regulatory Guide 1.190, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence. These measures are effective in monitoring the extent of neutron irradiation embrittlement to prevent significant degradation of the reactor pressure vessel during the period of extended operation.
The Reactor Vessel Surveillance aging management program will be enhanced to:
- 1. Establish operating restrictions to ensure that the plant is operated under the conditions to which the surveillance capsules were exposed. The operating
RS-14-225 Enclosure B Page 3 of 6 restrictions are as follows:
Byron Station, Unit 1:
- Cold leg operating temperature limitation: 525 degrees Fahrenheit (minimum) to 590 degrees Fahrenheit (maximum)
- RPV beltline material fluence: 3.21E+19 n/cm2 (E >1.0 MeV)
(maximum)
Byron Station, Unit 2; Braidwood Station Unit 1:
- Cold leg operating temperature limitation: 525 degrees Fahrenheit (minimum) to 590 degrees Fahrenheit (maximum)
- RPV beltline material fluence: 3.19E+19 n/cm2 (E >1.0 MeV)
(maximum)
Braidwood Station Unit 2:
- Cold leg operating temperature limitation: 525 degrees Fahrenheit (minimum) to 590 degrees Fahrenheit (maximum)
- RPV beltline material fluence: 3.16E+19 n/cm2 (E >1.0 MeV)
(maximum)
If the reactor pressure vessel exposure conditions (neutron fluence, neutron spectrum) or irradiation temperature (cold leg inlet temperature) are altered, then the basis for the projection to the end of the period of extended operation needs to be reviewed and, if deemed appropriate, updates are made to the Reactor Vessel Surveillance program. Any changes to the Reactor Vessel Surveillance program must be submitted for NRC review and approval in accordance with 10 CFR Part 50, Appendix H.
- 2. One (1) specimen capsule per reactor vessel, as designated below, irradiated to a neutron fluence of one (1) to two (2) times the projected peak neutron fluence at the end of the period of extended operation will be withdrawn from the spent fuel pool, tested, and the summary technical report submitted to the NRC within one (1) year of receipt of the renewed license. Alternatively, if a request for extension of the testing schedule is submitted in accordance with 10 CFR Part 50, Appendix H and granted by the Director, Office of Nuclear Reactor Regulation, specimen testing will be performed in accordance with that approved extension.
RS-14-225 Enclosure B Page 4 of 6 Reactor Vessel Capsule ID Capsule Fluence (Station, Unit) (n/cm2)(E>1.0 MeV)
Byron, Unit 1 Y 3.97E+19 Byron, Unit 2 Y 4.19E+19 Braidwood, Unit 1 V 3.71E+19 Braidwood, Unit 2 V 3.73E+19 Theseis enhancements will be implemented prior to the period of extended operation, with the testing of the reactor vessel specimen capsules performed in accordance with the schedule described above.
RS-14-225 Enclosure B Page 5 of 6 As a result of changes to the Reactor Vessel Surveillance aging management program identified in the response to B.2.1.19-1b, LRA Appendix B, Section B.2.1.19, pages B-127 through B-128, Enhancements are revised as shown below. Revisions are indicated with bolded italics for inserted text:
Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:
- 1. Establish operating restrictions to ensure that the plant is operated under the conditions to which the surveillance capsules were exposed. The operating restrictions are as follows:
Byron Station, Unit 1:
- Cold leg operating temperature limitation: 525 degrees Fahrenheit (minimum) to 590 degrees Fahrenheit (maximum)
- RPV beltline material fluence: 3.21E+19 n/cm2 (E >1.0 MeV)
(maximum)
Byron Station, Unit 2; Braidwood Station, Unit 1:
- Cold leg operating temperature limitation: 525 degrees Fahrenheit (minimum) to 590 degrees Fahrenheit (maximum)
- RPV beltline material fluence: 3.19E+19 n/cm2 (E >1.0 MeV)
(maximum)
Braidwood Station, Unit 2:
- Cold leg operating temperature limitation: 525 degrees Fahrenheit (minimum) to 590 degrees Fahrenheit (maximum)
- RPV beltline material fluence: 3.16E+19 n/cm2 (E >1.0 MeV)
(maximum)
If the reactor pressure vessel exposure conditions (neutron fluence, neutron spectrum) or irradiation temperature (cold leg inlet temperature) are altered, then the basis for the projection to the end of the period of extended operation needs to be reviewed and, if deemed appropriate, updates are made to the Reactor Vessel Surveillance program. Any changes to the Reactor Vessel Surveillance program must be submitted for NRC review and approval in accordance with 10 CFR Part 50, Appendix H. Program Elements Affected: Parameters Monitored/Inspected (Element 3),
Detection of Aging Effects (Element 4), Monitoring and Trending (Element 5), Acceptance Criteria (Element 6)
RS-14-225 Enclosure B Page 6 of 6
- 2. One (1) specimen capsule per reactor vessel, as designated below, irradiated to a neutron fluence of one (1) to two (2) times the projected peak neutron fluence at the end of the period of extended operation will be withdrawn from the spent fuel pool, tested, and the summary technical report submitted to the NRC within one (1) year of receipt of the renewed license. Alternatively, if a request for extension of the testing schedule is submitted in accordance with 10 CFR Part 50, Appendix H and granted by the Director, Office of Nuclear Reactor Regulation, specimen testing will be performed in accordance with that approved extension.
Reactor Vessel Capsule ID Capsule Fluence (Station, Unit) (n/cm2)(E>1.0 MeV)
Byron, Unit 1 Y 3.97E+19 Byron, Unit 2 Y 4.19E+19 Braidwood, Unit 1 V 3.71E+19 Braidwood, Unit 2 V 3.73E+19 Program Elements Affected: Parameters Monitored/Inspected (Element 3), Detection of Aging Effects (Element 4), Monitoring and Trending (Element 5), Acceptance Criteria (Element 6)
RS-14-225 Enclosure C Page 1 of 3 Enclosure C Byron and Braidwood Stations, Units 1 and 2 License Renewal Commitment List Change This Enclosure includes an update to the Byron and Braidwood Stations, Units 1 and 2, License Renewal Application (LRA) Appendix A, Section A.5 License Renewal Commitment List, as a result of the Exelon response to the following RAI:
RAI B.2.1.19-1b Note: To facilitate understanding, portions of the original LRA License Renewal Commitment List have been repeated in this Enclosure, with revisions indicated. Existing LRA text, as modified by subsequent submittals, is shown in normal font. Changes are highlighted with bolded italics for inserted text.
RS-14-225 Enclosure C Page 2 of 3 As a result of the response to RAI B.2.1.19-1b provided in Enclosure A of this letter, LRA Appendix A, Table A.5 License Renewal Commitment List, line item 19 on pages A-78 and A-79, is revised as shown below. The RAI that led to this commitment modification is listed in the SOURCE column. Any other actions described in this submittal represent intended or planned actions. They are described for the NRCs information and are not regulatory commitments.
A.5 License Renewal Commitment List NO. PROGRAM OR IMPLEMENTATION TOPIC COMMITMENT SCHEDULE SOURCE 19 Reactor Vessel Reactor Vessel Surveillance is an existing program that will be Program to be enhanced prior Section A.2.1.19 Surveillance enhanced to: to the period of extended operation.
- 1. Establish operating restrictions to ensure that the plant is Exelon Letter operated under the conditions to which the surveillance Specimen capsule testing to RS-14-002 capsules were exposed. The operating restrictions are as be performed in accordance RAI B.2.1.19-1 follows: with the schedule described 01/13/2014 in Enhancement 2.
Byron Station, Unit 1: Exelon Letter RS-14-149
- Cold leg operating temperature limitation: 525 RAI B.2.1.19-1a degrees Fahrenheit (minimum) to 590 degrees 05/23/2014 Fahrenheit (maximum).
Exelon Letter
- RPV beltline material fluence: 3.21E+19 n/cm2 (E RS-14-225
>1.0 MeV) (maximum). RAI B.2.1.19-1b 07/28/2014 Byron Station, Unit 2; Braidwood Station Unit 1:
- Cold leg operating temperature limitation: 525 degrees Fahrenheit (minimum) to 590 degrees Fahrenheit (maximum).
- RPV beltline material fluence: 3.19E+19 n/cm2 (E
>1.0 MeV) (maximum).
Braidwood Station Unit 2:
- Cold leg operating temperature limitation: 525 degrees Fahrenheit (minimum) to 590 degrees Fahrenheit (maximum).
- RPV beltline material fluence: 3.16E+19 n/cm2 (E
>1.0 MeV) (maximum).
If the reactor pressure vessel exposure conditions (neutron
RS-14-225 Enclosure C Page 3 of 3 NO. PROGRAM OR IMPLEMENTATION TOPIC COMMITMENT SCHEDULE SOURCE fluence, neutron spectrum) or irradiation temperature (cold leg inlet temperature) are altered, then the basis for the projection to the end of the period of extended operation needs to be reviewed and, if deemed appropriate, updates are made to the Reactor Vessel Surveillance program. Any changes to the Reactor Vessel Surveillance program must be submitted for NRC review and approval in accordance with 10 CFR Part 50, Appendix H.
- 2. One (1) specimen capsule per reactor vessel, as designated below, irradiated to a neutron fluence of one (1) to two (2) times the projected peak neutron fluence at the end of the period of extended operation will be withdrawn from the spent fuel pool, tested, and the summary technical report submitted to the NRC within one (1) year of receipt of the renewed license. Alternatively, if a request for extension of the testing schedule is submitted in accordance with 10 CFR Part 50, Appendix H and granted by the Director, Office of Nuclear Reactor Regulation, specimen testing will be performed in accordance with that approved extension.
Reactor Vessel Capsule ID Capsule Fluence 2
(Station, Unit) (n/cm )(E>1.0 MeV)
Byron, Unit 1 Y 3.97E+19 Byron, Unit 2 Y 4.19E+19 Braidwood, Unit 1 V 3.71E+19 Braidwood, Unit 2 V 3.73E+19