ML080870346

Request for License Amendment - Revision to the Reactor Pressure Vessel (RPV) Material Surveillance Program

ML080870346
Person / Time
Site:	Browns Ferry
Issue date:	03/26/2008
From:	West R G Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TVA-BFN-TS-439
Download: ML080870346 (15)

Text

March 26, 2008

TVA-BFN-TS-439

10 CFR 50.90

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

Mail Stop: OWFN, P1-35

Washington, D.C. 20555-0001

Gentlemen:

In the Matter of ) Docket No. 50-259 Tennessee Valley Authority )

BROWNS FERRY NUCLEAR PLANT, BFN UNIT 1 - REQUEST FOR LICENSE AMENDMENT - REVISION TO THE REACTOR PRESSURE VESSEL (RPV) MATERIAL SURVEILLANCE PROGRAM Pursuant to 10 CFR 50.90, TVA is submitting a request for an amendment (TS-439) to license DPR-33 for BFN Unit 1.

TVA is requesting a change to the BFN Unit 1 RPV material

surveillance program, required by 10 CFR 50, Appendix H, that will incorporate the Boiling Water Reactor Vessel and

Internals Project (BWRVIP) Integrated Surveillance Program (ISP) into the BFN Unit 1 licensing basis.

The BWRVIP 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.

In NRC Regulatory Issue Summary (RIS) 2002-05, "NRC

Approval of Boiling Water Reactor Pressure Vessel

Integrated Surveillance Program," NRC approved the BWRVIP

ISP and provided guidance for BWR licensees participating U.S. Nuclear Regulatory Commission Page 2 March 26, 2008

in the ISP program. Consistent with the guidance provided

in RIS 2002-05, TVA is submitting this proposed change as

a license amendment to facilitate NRC review and approval.

This license amendment request is consistent with one

submitted for BFN Units 2 and 3 by TVA letter dated

November 6, 2002. NRC issued license amendment Nos. 279

and 238 to Facility Operating Licenses DPR-52 and DPR-68

by letter dated January 28, 2003.

TVA has determined that there are no significant hazards

considerations associated with the proposed change and

that the change qualifies for a categorical exclusion

from environmental review pursuant to the provisions of

10 CFR 51.22(c)(9). Additionally, in accordance with

10 CFR 50.91(b)(1), TVA is sending a copy of this letter

and enclosures to the Alabama State Department of Public

Health.

to this letter provides the description and

evaluation of the proposed change. This includes TVA's

determination that the proposed change does not involve

a significant hazards consideration, and is exempt from

environmental review. Enclosure 2 contains the applicable

pages of the BFN Updated Final Safety Analysis Report

marked to show the proposed change.

TVA plans to implement the proposed change in the Summer

of 2008, prior to Unit 1 reaching 8.0 Effective Full Power

Years (EFPY), to avoid the costly and technically

unnecessary mandate of removing an RPV surveillance capsule

from the Unit 1 RPV during the Fall 2008 refueling outage.

Therefore, TVA requests NRC approval of this change by

September 2, 2008, and that implementation of the change be

within 30 days of NRC approval.

There are no new regulatory commitments in this submittal.

If you have any questions about this change, please

telephone D. T. Langley at (256) 729-2636.

U.S. Nuclear Regulatory Commission Page 3 March 26, 2008

I declare under penalty of perjury that the foregoing is

true and correct. Executed on this 26th day of March 2008.

Sincerely,

Original signed by:

R. G. West

Site Vice President

Enclosures

cc: (Enclosures)

State Health Officer Alabama Department of Public Health RSA Tower - Administration P.O. Box 303017 Montgomery, Alabama 36130-3017

Ms. Eva A. Brown, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739

Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931

NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970

U.S. Nuclear Regulatory Commission Page 4 March 26, 2008

DTL:JEE:JWD:BAB

Enclosures

cc (Enclosures):

G. P. Arent, EQB 1B-WBN W. R. Campbell, Jr. LP 3R-C S. M. Douglas, POB 2C-BFN

R. F. Marks, Jr., PAB 1C-BFN D. C. Matherly, BFT 2A-BFN L. E. Nicholson, BR 4X-C

R. G. West, NAB 2A-BFN

B. A. Wetzel, BR 4X-C

S. A. Vance, WT 6A-K

E. J. Vigluicci, ET 11A-K

NSRB Support, LP 5M-C

EDMS WT CA-K,

S:/licensing/submit/subs/Proposed License Amendment for Unit 1 RPV ISP.doc

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNIT 1 REQUEST FOR LICENSE AMENDMENT (TS-439)

REVISION TO THE REACTOR PRESSURE VESSEL (RPV)

MATERIAL SURVEILLANCE PROGRAM DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE I. Introduction Appendix H to 10 CFR Part 50, "Reactor Vessel Material Surveillance Program Requirements," requires that reactor

pressure vessels have their beltline regions monitored by

a surveillance program that complies with American Society

for Testing and Materials (ASTM) E185-82, except as

modified by Appendix H. ASTM E185-82 provides guidelines

for designing a minimum surveillance program, selecting

materials, and evaluating test results for light-water

cooled nuclear power reactor vessels. It also provides

recommendations for minimum number of surveillance

capsules and their withdrawal schedules. 10 CFR 50

Appendix H further requires that the proposed withdrawal

schedule be submitted with a technical justification and

approved by NRC prior to implementation.

Over the past several years, EPRI and BWR licensees under

the Boiling Water Reactor Vessel and Internals Project (BWRVIP) developed an Integrated Surveillance Program (ISP) and submitted it for NRC approval. The 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.

By letter dated February 1, 2002, the NRC staff completed

its review of the final BWRVIP ISP Plan and found it

acceptable. The NRC safety evaluation (SE) concluded that

the proposed ISP, if implemented in accordance with the

conditions in the SE, to be an acceptable alternative to

all existing BWR plant-specific RPV surveillance programs E1-2 for the purpose of maintaining compliance with the requirements 10 CFR 50 Appendix H through the end of

current facility 40-year operating licenses.

II. Description of the Proposed Change TVA is proposing to revise the licensing basis for BFN Unit 1 by replacing the current plant-specific RPV

material surveillance program with the Boiling Water

Reactor Vessel Internals Project (BWRVIP) Integrated

Surveillance Program (ISP), which was approved by the NRC

in its SE dated February 1, 2002 (Reference 2).

III. Reason for the Proposed Change The BWRVIP ISP was developed in response to an issue

raised by the NRC staff regarding the potential lack of

adequate unirradiated baseline 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

BWRVIP ISP, as endorsed by the NRC in Regulatory Issue

Summary No. 2002-05 (Reference 1), 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, the 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. Also, the inclusion

of data from the testing of BWR Owners' Group (BWROG)

Supplemental Surveillance Program (SSP) capsules will

improve overall quality of the data being used to evaluate

BWR RPV 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.

E1-3 IV. Safety Analysis In its safety evaluation dated February 1, 2002 (Reference 2), the NRC concluded that the proposed

BWRVIP ISP, if implemented in accordance with the

conditions in the SE, is 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. The NRC SE requires that each licensee:

(1) provide information regarding which specific

neutron fluence methodology will be implemented as

part of the ISP and (2) address the neutron fluence

methodology compatibility issue as it applies to the

comparison of neutron fluences calculated in the ISP

which are designated to represent its RPV.

Prior to Unit Restart, the BFN Improved Technical

Specifications (ITS) for Unit 1 (Amendment 256) revised

the Pressure Temperature (P/T) curves required for

reactor heatup and cooldown such that they are valid to

12 and 16 Effective Full Power Years (EFPY). BFN used

an updated fluence methodology provided by GE Nuclear

Energy (GENE) (Reference 3) and approved by NRC to

develop the revised P/T curves. This methodology has

been endorsed in Regulatory Guide 1.190 (Reference 4).

Based upon the Plant-Specific Evaluation contained in

BWRVIP-135 (Reference 5), representative material for

the limiting plate for BFN Unit 1 is contained in BFN

Unit 2 Capsules, and representative material for the

limiting weld for BFN Unit 1 is contained in

Supplemental Surveillance Program (SSP) Capsules A, B, D, G, E, and I. Thus, in accordance with the ISP, no

capsules will be removed and tested from BFN Unit 1.

All surveillance capsules in the BFN Unit 1 RPV will be

deferred indefinitely to be removed at a future date if

required.

To increase fluence per NRC staff recommendations, representative material for the limiting weld for BFN

Unit 1 was removed and tested. SSP Capsules A and B

were installed within the Cooper Nuclear Station (CNS)

in November 1991 and removed in March 2003 (Reference 6). SSP Capsules D and G were installed

within the Oyster Creek Nuclear Power Station in

February 1993 and removed in September 1996 (References 7 and 8). SSP Capsules E and I were also

installed within the Oyster Creek Nuclear Power Station E1-4 in February 1993, but were removed in October 2000 (Reference 9). Fluence calculations for the limiting

weld for BFN Unit 1 will be reevaluated using a

methodology approved by the NRC and demonstrated to be

compatible with the methodology provided by GENE for

the revised P/T curves. Only one capsule containing

the representative material for the limiting plate

for BFN Unit 1 (BFN Unit 2 surveillance capsule at 30°

azimuth) has been removed and tested to date (Reference 10). The next surveillance capsule

withdrawal for BFN Unit 2 is scheduled for the Spring

of 2011 during the Unit 2 Cycle 16 Refueling Outage.

Material contained in this capsule will be removed and

tested in 2011. As with the limiting weld, fluence

calculations for the limiting plate for BFN Unit 1 will

also be reevaluated using a methodology approved by the

NRC and demonstrated to be compatible with the

methodology provided by GENE for the revised P/T

curves.

In summary, participation in the ISP will improve

compliance with the regulatory requirements in

Appendix H to 10 CFR 50 while reducing cost, personnel

exposure, and outage time associated with capsule

removal, shipping, and testing.

V. No Significant Hazards Consideration Determination TVA is proposing to revise the licensing basis for the

Browns Ferry Nuclear Plant Unit 1 by replacing the

plant-specific reactor pressure vessel (RPV) material

surveillance program with the Boiling Water Reactor

Vessel Internals Project (BWRVIP) Integrated

Surveillance Program (ISP). This change is acceptable

because the BWRVIP 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, TVA has evaluated the proposed license amendment

and determined it does not represent a significant

hazards consideration. The following is provided in

support of this conclusion.

A. The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

E1-5 The proposed change implements a 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

change does not significantly increase the

probability of any accident previously evaluated.

The change provides the same assurance of RPV

integrity. The change will not cause the reactor

pressure vessel or interfacing systems to be

operated outside their design or testing limits.

Also, the change will not alter any assumptions

previously made in evaluating the radiological

consequences of accidents. Therefore, the proposed

change does not involve a significant increase in

the probability or consequences of an accident

previously evaluated.

B. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change revises the BFN Unit 1 licensing basis to reflect participation in the BWRVIP ISP.

The proposed change does not involve a modification

of the design of plant structures, systems, or

components. The change will not impact the manner

in which the plant is operated as plant operating

and testing procedures will not be affected by the

change. The change will not degrade the reliability

of structures, systems, or components important to

safety as equipment protection features will not be

deleted or modified, equipment redundancy or

independence will not be reduced, supporting system

performance will not be increased, and increased or

more severe testing of equipment will not be

imposed. No new accident types or failure modes

will be introduced as a result of this proposed

change. Therefore, the proposed change does not

create the possibility of a new or different kind of

accident from that previously evaluated.

C. The proposed amendment does not involve a significant reduction in a margin of safety.

The proposed change has been evaluated as providing an acceptable alternative to the plant-specific RPV

material surveillance program and meets the

requirements of 10 CFR 50 Appendix H for RPV

material surveillance.

E1-6 Appendix G to 10 CFR 50 describes the conditions that require pressure temperature (P/T) limits and

provides the general bases for these limits. Until

the results from the Integrated Surveillance Program

become available, RG 1.99, Revision 2 will be used

to predict the amount of neutron irradiation damage.

The use of operating limits based on these criteria, as defined by applicable regulations, codes, and

standards, provide reasonable assurance that

nonductile or rapidly propagating failure will not

occur. The P/T limits are not derived from Design

Basis Accident (DBA) analyses. They are prescribed

during normal operation to avoid encountering

pressure, temperature, and temperature rate of

change conditions that might cause undetected flaws

to propagate and cause nonductile failure of the

reactor coolant pressure boundary (RCPB). Since the

P/T limits are not derived from any DBA, there are

no acceptance limits related to the P/T limits.

Rather, the P/T limits are acceptance limits

themselves since they preclude operation in an

unanalyzed condition.

The proposed change will not affect any safety

limits, limiting safety system settings, or limiting

conditions of operation. The proposed change does

not represent a change in initial conditions, or in

a system response time, or in any other parameter

affecting the course of an accident analysis

supporting the Bases of any Technical Specification.

Further, the proposed change does not involve a

revision to P/T limits but rather a revision to the

surveillance capsule withdrawal schedule such that

there are presently no plans to remove any

surveillance capsules from BFN Unit 1. The current

P/T limits were established based on adjusted

reference temperatures for RPV beltline materials

calculated in accordance with RG 1.99, Revision 2.

P/T limits will continue to be revised, as

necessary, for changes in adjusted reference

temperature due to changes in fluence when two or

more credible surveillance data sets become

available. When two or more credible surveillance

data sets become available, P/T limits will be

revised as prescribed by RG 1.99, Revision 2 or

other NRC approved guidance. Therefore, the

proposed change does not involve a significant

reduction in a margin of safety.

E1-7 VI. Environmental Impact Consideration The proposed amendment does not involve a significant hazards consideration, a significant change in the

types of, or significant increase in, the amounts of

any effluents that may be released offsite, or a

significant increase in individual or cumulative

occupational radiation exposure. Therefore, the

proposed amendment meets the eligibility criteria for

categorical exclusion set forth in 10 CFR 51.22(c)(9),

and pursuant to 10 CFR 51.22(b), an environmental

assessment of the proposed amendment is not required.

References

1. Regulatory Issue Summary No. 2002-05, "NRC Approval of Boiling Water Reactor Pressure Vessel Integrated

Surveillance Program," dated April 8, 2002.

2. NRC letter from W. H. Bateman to C. Terry (BWRVIP Chairman) titled "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. 3. NEDO-32983-A, "GE Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations," Revision 0, dated December 2001.

4. Regulatory Guide 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron

Fluence," March 2001.

5. BWRVIP-135, Revision 1, "BWR Vessel and Internals Project, Integrated Surveillance Program (ISP) -

Data Source Book and Plant Evaluations," EPRI

Technical Report 1013400, June 2007.

6. BWRVIP-169, "BWR Vessel and Internals Project -

Testing and Evaluation of BWR Supplemental

Surveillance Program (SSP) Capsules A, B, and C,"

EPRI Technical Report 1013399, March 2007.

7. BWRVIP-87, Revision 1, "BWR Vessel and Internals Project, Testing and Evaluation of BWR Supplemental

Surveillance Program Capsules D, G, and H," EPRI

Technical Report 1015000, 2007.

E1-8 8. BWRVIP-128, "BWR Vessel and Internals Project -

Updated Fluence Calculations for Supplemental

Surveillance Capsules D, G, and H Using RAMA Fluence

Methodology," EPRI Technical Report 1010997, August

2004. 9. BWRVIP-111, Revision 1, "BWR Vessel and Internals Project, Testing and Evaluation of BWR Supplemental

Surveillance Program Capsules E, F, and I," EPRI

Technical Report 1015001, 2007.

10. GE Nuclear Energy Report No. GENE-B1100639-01, "Browns Ferry Steam Electric Station Unit 2 Vessel

Surveillance Materials Testing and Fracture

Toughness Analysis," June 1995.

ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY

BROWNS FERRY NUCLEAR PLANT UNIT 1 REQUEST FOR LICENSE AMENDMENT (TS-439)

REVISION TO THE REACTOR PRESSURE VESSEL (RPV)

MATERIAL SURVEILLANCE PROGRAM PROPOSED UFSAR MARK-UP I. BFN UFSAR, Amendment 22 Affected Page List Page 4.2-16

II. Marked-up Pages See Attached Note: Deleted text shown by strike-through Added text shown in italics

BFN-22 4.2-16 Tensile and Charpy impact specimen samples were removed as indicated in Figures 3, 4, 5, 6, and 7 of attachment B to 21A1111. (See FSAR Appendices J, K, and L.)

The surveillance test plate 610-0127 was 139 in. long and 60 in. wide, and all excess

material is under TVA control in the event that additional material is needed. It is estimated that enough extra material is available for several hundred additional Charpy specimens.

No weak direction specimens were included in the reactor vessel material

surveillance program. All Charpy V-notch specimens were taken parallel to the

direction of rolling. The majority of developmental work on radiation effects has been with longitudinal specimens. This is considered the best specimen to be used for determination of changes in transition te mperature. At the low neutron fluence levels of BWR plants, no change in transve rse shelf level is expected and transition temperature changes are minimal.

The specimens and neutron monitor wires we re placed near core midheight adjacent to the reactor vessel wall where the neutron ex posure is similar to that of the vessel wall (see Subsection 3.3). The specimens were installed at startup or just prior to full-power operation. For Units 1, 2 , and 3, Integrated Surv eillance Program (ISP) implementation and surveillance spec imen schedule withdrawal and testing for the initial BWR 40-year operating period is governed and controlled by BWRVIP-86-A (Updated BWR Integrated Surveillance Progr am (ISP) Implementation Plan), BWRVIP-78 (BWR Integrated Surveillance Progr am Plan), the BWRVIP responses to NRC RAIs dated May 30, 2001, and December 22, 2001, and the NRC's Safety Evaluation dated February 1, 2002. Surveillance specimen schedule withdrawal and testing during the license renewal period is governed and controlled by BWRVIP-116 (Integrated Surveillance Program (ISP) Implementation For License Renewal), and the BWRVIP response to NRC RAIs dated January 11, 2005. Surveillance and chemistry data for all representative materials in the BWRVIP ISP have been consolidated into BWRVIP-135, Revision 1 (Integrated Surveillance Program (ISP)

Data Source Book and Plant Evaluations).

The withdrawal schedule for the second Unit 2 capsule located at azimuth 120° (to be withdrawn in 2011) and the third Unit 2 capsule (to be withdrawn duri ng the license renewal period) will be in accordance with the ISP. Presently, t here are no plans to withdrawal any capsules from Unit s 1 or 3, as the BFN Unit 2 capsule s provides the best representative weld material for both units, and the best representative plate material for Unit 3. Supplemental Surveillance Program (SSP) Capsules A, B, D, G, E, and I provide the best representative weld material for Unit 1.

Test results will provide the necessary data to monitor embrittlement for Units 1, 2 , and 3. Unit 1 is currently not in the scope of the ISP, but will be evaluat ed for inclusion prior to unit restart.

Since the predicted adjusted reference temperatur e of the reactor vessel beltline steel is less than 100°F at end-of-life, the use of t he capsules per the ISP meet s the requirements of 10 CFR 50, Appendix H, and ASTM E185-82. Revisions to fluence calculations using data

obtained from the surveillance caps ule specimens will use an NRC approved methodology that meets R egulatory Guide 1.190. [

By letter dated ??? ??, 2008 BFN-22 4.2-16 (EDMS Number XXX XXXXXX XXX), NRC issued License Amendment ??? for BFN Unit 1, and by By letter dated January 28, 2003 (EDMS RIMS Number L44 030204 001), NRC issued License Amendment Number s 279 and 238, for BFN Units 2 and 3 respectively, authorizing adoption of the BWRVIP Integrated Surveillance Program to address the requirements of Appendix H to 10 CFR Part 50.]