ML080870346: Difference between revisions
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| issue date = 03/26/2008 | | issue date = 03/26/2008 | ||
| title = Request for License Amendment - Revision to the Reactor Pressure Vessel (RPV) Material Surveillance Program | | title = Request for License Amendment - Revision to the Reactor Pressure Vessel (RPV) Material Surveillance Program | ||
| author name = West R | | author name = West R | ||
| author affiliation = Tennessee Valley Authority | | author affiliation = Tennessee Valley Authority | ||
| addressee name = | | addressee name = | ||
Line 665: | Line 665: | ||
Internals Project, BWR Integrated Surveillance | 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. | 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 | : 4. Regulatory Guide 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron | ||
Revision as of 14:12, 12 July 2019
ML080870346 | |
Person / Time | |
---|---|
Site: | Browns Ferry |
Issue date: | 03/26/2008 |
From: | West R 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
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:/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
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.]