W3F1-2019-0001, Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule
| ML19115A417 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/25/2019 |
| From: | Dinelli J Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| W3F1-2019-0001 | |
| Download: ML19115A417 (11) | |
Text
Entergy Operations Inc.
17265 River Road Killona, LA 70057-3093 Tel 504-739-6660 John C. Dinelli Site Vice President Waterford 3 W3F1-2019-0001 10 CFR 50 App H April 25, 2019 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule Waterford Steam Electric Station, Unit 3 Docket No. 50-382 Renewed Facility Operating License No. NPF-38
REFERENCES:
- 1. NRC Administrative Letter 97-04, NRC Staff Approval for Changes to 10 CFR Part 50, Appendix H, Reactor Vessel Surveillance Specimen Withdrawal Schedules, dated September 30, 1997 (ADAMS Accession No. ML031210296)
- 2. Entergy Letter W3F1-2015-0056, Submittal of Reactor Vessel Material Surveillance Program Capsule Test Results, Waterford Steam Electric Station, Unit 3, dated August 6, 2015 (ADAMS Accession No. ML15222A373)
- 3. Entergy Letter W3F1-2019-0022, "Resubmittal of Reactor Vessel Material Surveillance Program Capsule Test Results," Waterford Steam Electric Station, Unit 3," dated March 14, 2019 (ADAMS Accession No. ML19073A302)
- 4. NRC, "Safety Evaluation Report Related to the License Renewal of Waterford Steam Electric Station Unit 3," dated August 2018 (ADAMS Accession No. ML18228S668)
The Waterford Steam Electric Station, Unit 3 (Waterford 3) Updated Final Safety Analysis Report (UFSAR) Table 5.3-10 provides the Waterford 3 reactor vessel surveillance capsule removal schedule.
Entergy Operations, Inc., (Entergy) requests the NRCs approval of a revision to the surveillance capsule withdrawal schedule, as required by 10 CFR Part 50, Appendix H. The revised withdrawal schedule is presented in Attachment 1, Table 2.
Attachment 1 to W3F1-2019-0001 Proposed Change to Reactor Vessel Surveillance Capsule Withdrawal Schedule
W3F1-2019-0001 Page 1 of 8 Proposed Change to Reactor Vessel Surveillance Capsule Withdrawal Schedule
- 1. INTRODUCTION The NRC has established requirements and criteria in 10 CFR 50.60, "Acceptance criteria for fracture prevention measures for lightwater nuclear power reactors for normal operation," for protecting reactor vessels against fracture. The rule requires the reactor vessel material surveillance program to meet the requirements set forth in Appendix H to 10 CFR Part 50, Reactor Vessel Material Surveillance Program Requirements.
Appendix H to 10 CFR Part 50 provides the NRCs criteria for the design and implementation of the reactor vessel material surveillance programs for operating reactors. The rule, in part, requires reactor vessel surveillance program designs and withdrawal schedules to meet the requirements of the edition of American Society of Testing and Materials Standard Practice E 185 (ASTM E 185), Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels, (Reference 5.1) which is current on the issue date of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code to which the reactor vessel was purchased, although later editions of ASTM E 185 may be used inclusive of the 1982 Edition of ASTM E 185 (ASTM E 185-82). This rule also requires proposed reactor vessel surveillance programs to be submitted to the NRC and approved prior to implementation.
On September 30, 1997, the NRC issued Administrative Letter (AL) 97-04 (Reference 5.2) to all holders of operating licenses for domestic nuclear power plants. In this AL, the NRC staff summarized the Commissions decision promulgated in Commission Memorandum and Order CLI-96-13. In this Memorandum and Order, the Commission found that, while 10 CFR Part 50, Appendix H, III.B.3, requires prior NRC approval for all withdrawal schedule changes, only certain changes require the NRC staff to review and approve the changes through the NRCs license amendment process (10 CFR 50.90 process). Specifically, only those changes that are not in conformance with the ASTM standard referenced in 10 CFR Part 50, Appendix H, are required to be approved through the license amendment process, whereas changes that are determined to conform to the ASTM standard only require the staff to document its review and verification of such conformance.
Entergy Operations, Inc. (Entergy) relocated the Waterford Steam Electric Station Unit 3 (Waterford 3) surveillance capsule withdrawal schedule from the Waterford 3 Technical Specifications (TSs) to the Waterford 3 Updated Final Safety Analysis Report (UFSAR) consistent with the provisions of Generic Letter 91-01 in Amendment 106 to the Facility Operating License (Reference 5.3). The Waterford 3 UFSAR, Table 5.3-10, provides the Waterford 3 reactor vessel surveillance capsule removal schedule.
W3F1-2019-0001 Page 2 of 8 The removal of the withdrawal schedule from the TSs did not result in the loss of any regulatory control because changes to the schedule are controlled by the requirements of 10 CFR Part 50, Appendix H.
After Waterford 3 withdrew its second surveillance capsule, W-263, and concurrent with its extended power uprate to 3716 MWt, it proposed a change to the capsule withdrawal schedule. The proposed change was to withdraw the third surveillance capsule (W-83) at approximately 26 Effective Full-Power Years (EFPY), where previously, W-83 was listed as Standby." In the Safety Evaluation for Amendment 199 to the Waterford 3 Facility Operating License, (Reference 5.4), the NRC concluded that the schedule change was in accordance with ASTM E 185-82.
In addition, Waterford 3 License Renewal Commitment No. 34 to enhance the Reactor Vessel Surveillance Program as described in LRA Section B.1.34 within one year following issuance of the renewed operating license requires the following action:
Revise Reactor Vessel Surveillance Program procedures to specify submittal of a withdrawal schedule for Capsule 277° to the NRC for review and approval within one (1) year following the receipt of the renewed license.
Section 7.6 of ASTM E 185-82 provides the requirements for the number of surveillance capsules and withdrawal schedule. The standard requires a sufficient number of surveillance capsules be provided to monitor the effects of neutron irradiation on the reactor vessel throughout its operating lifetime and a withdrawal schedule to meet the monitoring requirements. It should be noted that the recommended withdrawal schedule assumed the design life of the vessel to be 32 Effective Full Power Years (EFPY). In accordance with Table 1 of the standard, the Waterford 3 program was developed using the column for three specimen capsules and the associated schedule.
- 2. PROPOSED CHANGES TO SCHEDULE Entergy is proposing to make four changes to the capsule removal schedule. The first, second, and third are considered to be editorial changes. The Removal Time for capsule W-83 is changed from 26 EFPY to the measured interval determined in the Time-Limited Aging Analysis (TLAA) for the Period of Extended Operation (24.66 EFPY). Correspondingly, the Target Fluence is changed from 2.47 x 1019 n/cm2 (E>1 MeV) to 2.42 x 1019 n/cm2 (E>1 MeV), which was also determined in the TLAA.
The second proposed revision is to change the lead factors for capsules W-83 and W-277 to 1.20 from 1.19. This reflects the most recent neutron fluence calculations performed and reported in WCAP-17969-NP, the capsule W-83 surveillance specimen test report (Reference 5.5).
W3F1-2019-0001 Page 3 of 8 The third proposed revision is to revise the as-removed neutron fluence and EFPY values for capsule W-97 to match those calculated and reported in WCAP-17969-NP, the capsule W-83 surveillance specimen test report. The EFPY will be changed from 4.44 to 4.41, and the fluence will be changed from 6.47 x 1018 n/cm2 (E>1 MeV) to 6.31 x 1018 n/cm2 (E>1 MeV).
The fourth proposed revision to the schedule is to change the Target Removal Time for capsule W-277 from STANDBY to 48 EFPY, as recommended by the TLAA. This is based on a 60-year operating life (equivalent to approximately 55 EFPY). The Target Fluence will also be updated to 4.51 x 1019 n/cm2 (E>1 MeV), which is approximately the 60-year (55 EFPY) peak vessel fluence (Reference 5.10).
The current capsule removal schedule is shown in Table 1, while Table 2 provides a revised capsule removal schedule that incorporates the proposed changes. Note that the only remaining capsules are listed as STANDBY capsules.
W3F1-2019-0001 Page 4 of 8 TABLE 1 CURRENT CAPSULE REMOVAL SCHEDULE (UFSAR Table 5.3-10)
Azimuthal Removal Target Capsule Location Lead Time Fluence No./ID (deg.) Factor (EFPY)* (n/cm2) 1/W-83 83 1.18 26 2.47 x 1019 2/W-97 97 1.18 4.44** 6.47 x 1018**
3/W-104 104 0.83 Standby --
4/W-263 263 1.18 13.83** 1.45 x 1019**
5/W-277 277 1.18 Standby --
6/W-284 284 0.83 Standby --
- EFPY - Effective Full Power Years, withdrawal time may be modified to coincide with those refueling outages or plant shutdowns most closely approaching the withdrawal schedule.
- - Values represent actual data on removed capsule NOTE: As required by 10CFR50 Appendix H, Section III.B.3, submit a proposed withdrawal schedule with technical justification as specified in 10CFR50.4 for NRC approval prior to implementation.
W3F1-2019-0001 Page 5 of 8 TABLE 2 Proposed Revision To CAPSULE REMOVAL SCHEDULE Azimuthal Removal Target Capsule Location Lead Time Fluence No./ID (deg.) Factor (EFPY)* (n/cm2) 1/W-83 83 1.20 24.66 2.42 x 1019**
2/W-97 97 1.19 4.41** 6.31 x 1018**
3/W-104 104 0.83 Standby --
4/W-263 263 1.19 13.83** 1.45 x 1019**
5/W-277 277 1.20 48 4.51 x 1019 6/W-284 284 0.83 Standby --
- EFPY - Effective Full Power Years, withdrawal time may be modified to coincide with those refueling outages or plant shutdowns most closely approaching the withdrawal schedule.
- - Values represent actual data on removed capsule NOTE: As required by 10CFR50 Appendix H, Section III.B.3, submit a proposed withdrawal schedule with technical justification as specified in 10CFR50.4 for NRC approval prior to implementation.
W3F1-2019-0001 Page 6 of 8
- 3. TECHNICAL ANALYSIS Section 5.3.1.2, Compliance with Appendix H, 10 CFR 50, of the NUREG-0787 Safety Evaluation Report Supplement No. 8 (Reference 5.7), states the Waterford 3 materials surveillance program complies with 10 CFR 50 Appendix H.
ASTM E 185-73 requires three surveillance capsules with a fourth and fifth capsule listed as STANDBY. Waterford 3 was constructed with six surveillance capsules, three as part of the program, and three as STANDBY.
To date, Waterford 3 has removed the three surveillance capsules, Capsules W-97, W-263 and W-83. The test results for the plates and welds in the capsules were submitted to the NRC in the following topical reports (References 5.8, 5.11 and 5.12):
Capsule W-97 data reported in Babcock and Wilcox Topical Report BAW-2177, Analysis of Capsule W-97 Entergy Operations, Inc. Waterford Generating Station Unit 3 - Reactor Vessel Material Surveillance Program, W3F1-92-0369, dated November 25, 1992.
Resubmitted in W3F1-2004-0075, dated September 13, 2004 (Reference 5.8).
Capsule W-263 data reported in Westinghouse Report WCAP-16002, Analysis of Capsule 263°(Reference 5.9) from the Entergy Operations Waterford Unit 3 Reactor Vessel Radiation Surveillance Program, W3F1-2003-0020, dated March 28, 2003 (Reference 5.11).
Capsule W-83 data reported in Westinghouse Topical Report WCAP-17969-NP, Rev 0, Analysis of Capsule 83° from the Entergy Operations, Inc. Waterford Unit 3 Reactor Vessel Radiation Surveillance Program, W3F1-2015-0056, dated August 6, 2015.
Resubmitted in W3F1-2019-0022, dated March 14, 2019 (Reference 5.12).
The results of the last data report will be used to develop revised Waterford 3 Technical Specification Figure 3.4-2 and 3.4-3 Reactor Coolant System Pressure - Temperature limits.
The proposed revision to the surveillance capsule withdrawal schedule will ensure that the remaining capsules accumulate sufficient fluence to meet the requirements of ASTM E 185-82.
Waterford 3 is currently licensed to operate for 60 years. Waterford 3 will enter the period of extended operation in December of 2024. The Generic Aging Lessons Learned (GALL) Report (NUREG-1801, Revision 2) provides guidance related to the reactor vessel surveillance program for renewed licenses.Section XI.M31, Item 4 states:
The plant-specific or integrated surveillance program shall have at least one capsule with a projected neutron fluence equal to or exceeding the 60-year peak reactor vessel wall neutron fluence prior to the end of the period of extended operation. The program withdraws one capsule at an outage in which the capsule receives a neutron fluence of
W3F1-2019-0001 Page 7 of 8 between one and two times the peak reactor vessel wall neutron fluence at the end of the period of extended operation and tests the capsule in accordance with the requirements of ASTM E 185-82.
It is recommended that the program retain additional capsules within the reactor vessel to support additional testing if, for example, the data from the required surveillance capsule turn out to be invalid or in preparation for operation beyond 60 years. If the projected neutron fluence for these additional capsules is expected to be excessive if left in the reactor vessel, the program may propose to withdraw and place one or more untested capsules in storage for future reinsertion and/or testing.
Based on operating history and current operations, 48 EFPY is expected to occur in the year 2038 with a fluence of 4.51 x 1019 n/cm2 (E>1 MeV). Since the peak 60 calendar-year fluence (55 EFPY) is predicted to be 4.32 x 1019 n/cm2 (E>1 MeV), the 48 EFPY fluence satisfies the GALL report Section XI.M31, Item 4 requirement. Therefore, with the proposed revised withdrawal schedule, a standby capsule (W-277) will be withdrawn during the period of extended operation and tested in accordance with the above guidance.
Capsule W-104 contains some Standard Reference Materials in place of Waterford 3-specific reactor vessel material. The material in this capsule is consistent with the material that was in Capsule W-263 (the second capsule withdrawn and tested in the Waterford 3 surveillance program). The contents in Capsules W-277 and W-284 are identical. Capsule W-277 was chosen from these two options because it is the only remaining capsule with a lead factor >1.
The remaining two capsules, W-284 and W-104, are in positions with lead factors <1. If operation to 80 calendar years is desired, these capsules must be relocated. Any requests pertaining to relocating capsules at Waterford 3 will be made in a separate submittal. At 48 EFPY, the fluence on Capsule W-277 will have reached the projected 60-year peak vessel fluence (4.51 E 19 n/cm2, E>1 MeV).
Both Capsules W-104 and W-284 need to remain in the vessel as STANDBY capsules.
- 4. CONCLUSIONS Based on the above discussions it is concluded that the proposed surveillance capsule withdrawal schedule meets the requirements of ASTM E 185-82 for an operating period of up to 60 years.
W3F1-2019-0001 Page 8 of 8
- 5. REFERENCES 5.1 American Society of Testing and Materials (ASTM) Standard Practice E 185, Standard Practice for Conduction Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels," (ASTM E 185) 5.2 NRC Administrative Letter 97-04, NRC Staff Approval for Changes to 10 CFR Part 50, Appendix H, Reactor Vessel Surveillance Specimen Withdrawal Schedules, dated September 30, 1997 (ADAMS Accession No. ML031210296) 5.3 NRC Letter to Entergy Operations, Inc, Issuance of Amendment 106 to Facility Operating License, dated May 8, 1995 (ADAMS Accession No. ML021770550) 5.4 NRC Letter to Entergy Operations, Inc, Issuance of Amendment 199 RE:
Extended Power Uprate, dated April 15, 2005 (ADAMS Accession No. ML051030068) 5.5 Westinghouse Report WCAP-17969-NP Revision 2, Analysis of Capsule 83° from the Entergy Operations, Inc. Waterford Unit 3 Reactor Vessel Radiation Surveillance Program, dated November 2017 5.6 NUREG-0787, Supplement No. 1, "Safety Evaluation Report Related to Operation of Waterford Steam Electric Station Unit No. 3," dated October 1981 (ADAMS Accession No. ML8110280181) 5.7 NUREG-0787, Supplement No. 8, "Safety Evaluation Report Related to Operation of Waterford Steam Electric Station Unit No. 3," dated December 1984 (ADAMS Accession No. ML8412260149) 5.8 Entergy Letter, W3F1-2004-0075, Reissue of Report BAW-2177, "Analysis of Capsule W-97 Entergy Operations, Inc. Waterford Generating Station Unit 3 - Reactor Vessel Material Surveillance Program," dated September 13, 2004 (ADAMS Accession No. ML042710435) 5.9 WCAP-16002-NP, "Analysis of Capsule 263 from the Entergy Operations Waterford Unit 3 Reactor Vessel Radiation Surveillance Program," dated March 2003 5.10 WCAP-18002-NP, Revision 0, Waterford Unit 3 Time-Limited Aging Analysis on Reactor Vessel Integrity, dated July 2015 5.11 Entergy Letter, W3F1-2003-0020 Submittal of Second Reactor Vessel Surveillance Capsule Report," dated March 28, 2003 (ADAMS Accession No. ML042710435) 5.12 Entergy Letter, W3F1-2019-0022, "Resubmittal of Reactor Vessel Material Surveillance Program Capsule Test Results," dated March 14, 2019 (ADAMS Accession No. ML19073A302)