ML13032A251

Reactor Pressure Vessel Surveillance Capsule Withdrawal Schedule Revision Due to License Renewal Amendment

ML13032A251
Person / Time
Site:	Sequoyah
Issue date:	01/10/2013
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13032A251 (45)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 January 10, 2013 10 CFR 50 Appendix H ATTN: Document Control Desk U.S.. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

References:

. 1. NRC Administrative Letter 97-04, "NRC Staff Approval for Changes to 10 CFR 50, Appendix H, Reactor Vessel Surveillance Specimen Withdrawal Schedule"

2. ASTM Standard E 185-82, "Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels"

Subject:

Sequoyah Reactor Pressure Vessel Surveillance Capsule Withdrawal Schedule Revision Due to License Renewal Amendment Tennessee Valley Authority (TVA) is submitting an application for license renewal of the Sequoyah Unit 1 and Unit 2 operation licenses for an additional 20 years. In conjunction with the renewal application, TVA requests NRC approval of a revision to the reactor vessel surveillance specimen withdrawal schedule. This request is pursuant to 10 CFR 50, Appendix H, Section III.B.3 which requires that changes to the withdrawal schedules be submitted in accordance with 10 CFR 50.4 and that the proposed schedule must be approved by the NRC prior to implementation.

Reference 1 allows NRC approval for the proposed changes to the withdrawal schedule without a license amendment if the changes conform with the American Society for Testing and Materials (ASTM) Standard Practice E 185-82 (Reference 2). Based on the technical justification for the proposed change provided in WCAP-1 7539-NP (Enclosure 3) and discussed in Enclosure 1, TVA concludes that the proposed changes comply with the recommendations of ASTM Standard Practice E 185-82.

TVA requests that NRC completed the review of this request by January 15, 2015.

There are no new regulatory commitments in this letter. If you have any questions please contact Henry Lee at (423) 751-2683.

4oo

U.S. Nuclear Regulatory Commission Page 2 January 10, 2013 I declare under penalty of perjury that the foregoing is true and correct. Executed on this 1 0 th day of January 2013.

Sinc ly, V(ceIPresident, Nuclear Licensing

Enclosures:

1. Request for Revision to Reactor Vessel Material Surveillance Capsule Withdrawal Schedule for Sequoyah Nuclear Plant Units 1 and 2

2. TVA-12-62, Westinghouse Letter to TVA SQN, "SQN Units 1 and 2 Reactor Vessel Surveillance Capsule Relocation," dated October 31, 2012, TVA Contract 4411-393260.

3. WCAP-17539-NP, Revision 0, "Sequoyah Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity" CC: (w/Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Sequoyah Nuclear Power Plant Mark Yoo, SQN LRA Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-11 F1 Washington, DC 20555-0001

ENCLOSURE1 Tennessee Valley Authority Sequoyah Nuclear Plant Units 1 and 2 Request for Revision to Reactor Vessel Material Surveillance Capsule Withdrawal Schedule for Sequoyah Nuclear Plant Units I and 2

Background

Pressure vessel steel irradiation surveillance programs were developed for the reactor vessels of Tennessee Valley Authority (TVA), Sequoyah Nuclear Plant (SQN) Units 1 and 2 in References 1 and 2. The program comprises the evaluation of radiation effects on sample materials based on comparison pre-irradiation testing of a selected group of specimens to determine toughness properties of the reactor pressure vessel. Continuous monitoring of these specimens within the reactor pressure vessel provides data on the integrity of the vessel in terms of adequate toughness properties. References I and 2 provide a description of the surveillance capsules and pre-irradiated test results for each unit.

As detailed in the Sequoyah FSAR Amendment 23, Section 5.4.3.7, the reactor vessel surveillance program uses eight specimen capsules for each of the Sequoyah units. The capsules are located in guide baskets welded to the outside of the thermal shield, about 3 inches from the vessel directly opposite the center portion of the core. The reactor vessel surveillance capsules are located at 4 degree and 40 degree in either direction from the 0 degree and 180 degree axes of the reactor vessel (see FSAR Figure 5.4.3-3, at the end of this section).

Table 1, derived from the updated SQN Unit 1 and 2 FSAR, Section 5.4.3.7, defines the existing withdrawal schedule for Sequoyah Units 1 and 2. These schedules meet the recommendations of ASTM E 185-82 (Reference 3) as required by 10 CFR 50, Appendix H (Reference 4). With the withdrawal of Capsule Y on each unit, Sequoyah Units 1 and 2 have fulfilled the surveillance capsule withdrawal recommendations contained in ASTM E 185-82 for their 40-year EOL (32 EFPY).

TVA is submitting an application for a 20-year license extension of SQN Units 1 and 2.

WCAP-17539-NP (Reference 5) has been developed by Westinghouse to perform the Time-Limited Aging Analyses (TLAA) for the SQN Units 1 and 2 reactor pressure vessels in accordance with the requirements of the License Renewal Rule, 10 CFR Part 54.

These Time-Limited Aging Analyses are calculations which evaluate some safety-related aspects of the reactor pressure vessel within the bounds of the current 40-year license that must be re-evaluated to account for an extended period of operation.

As recommended in Reference 5, Appendix 3, TVA will be relocating surveillance Capsules S (4 degree location) and W (184 degree location) to the locations formerly occupied by Capsules T (40 degree location) and X (220 degree location), respectively, in each unit's reactor vessel at Unit 1 End of Cycle (EOC) 19 or 20 and Unit 2 EOC 19 or 20.

The objective of this relocation is to place surveillance capsules in a higher fluence location in order to have meaningful data in the future. Since the relocation of the SQN Unit 1 and Unit 2 surveillance capsules screens out under 10 CFR 50.59, NRC approval is not required [See Enclosure 2].

2. Proposed Revision To The Withdrawal Schedule The proposed schedule is to withdraw the relocated Unit 1 Capsule S (40 degree location after relocation from location 4 degree) during the EOC 28 outage and the relocated Unit 2 Capsule S (40 degree location after relocation from location 4 degree) during the EOC 27 outage.

The specimen removal schedule for the relocated Capsule W (220 degree location) and Capsules V and Z in Unit 1 and Unit 2 will remain unchanged at this time.

3. Technical Justification TVA is submitting an application for the renewal of the SQN Units 1 and 2 operating licenses which proposes to extend the plant operational license for an additional 20 years.

To account for license renewal, TVA proposes to withdraw one of the remaining four capsules (Capsule S) from each unit after the capsule relocated to the 40 degree location receives neutron fluence greater than the 60-year vessel fluence or 52 EFPY, that is deemed end-of-license extension (EOLE).

Additionally, a second capsule (Capsule W) in each unit is being relocated to a higher fluence location to support a potential further life extension to 80 years. The removal schedules for capsule W on both units are not changed from the schedule defined in the FSAR.

The remaining spare capsules (Capsules V and Z, two per unit) will stay in the reactor vessel for potential future license renewals. The removal schedules for Capsules V and Z remain unchanged from the FSAR.

The proposed surveillance capsule withdrawal schedule is based on the requirements specified in ASTM E 185-82, Section 7.6. Eight surveillance capsules were installed in each unit at SQN. As noted in Table 1, four capsules have been removed per the established withdrawal schedule. With the withdrawal of Capsule Y on each unit, SQN Units 1 -and 2 fulfilled the surveillance capsule withdrawal recommendations contained in ASTM E 185-82 for their 40-year EOL (32 EFPY).

In accordance with the requirements of ASTM E 185-82, Section 7.6, after the relocation of Capsule S in Unit 1 EOC 19 or 20 and Unit 2 EOC 19 or 20, TVA proposes to withdraw Capsule S from each unit after its vessel fluence exposure exceeds the new peak end-of-life (EOLE) (52 EFPY) vessel fluence, but prior to exceeding twice that fluence exposure to support the planned application to extend the SQN operating licenses.

Reference 5, developed by Westinghouse to perform the Time-Limited Aging Analyses (TLAA) for the SQN Units 1 and 2 reactor pressure vessels in accordance with the requirements of the License Renewal Rule, 10 CFR Part 54, updated the reactor vessel fluence evaluations. The fluence evaluations included a plant and fuel cycle specific analysis for fuel cycles 1 through 18 for Unit 1 and cycles 1 through 17 for Unit 2.

Projections were then made for future operation through EOLE (60 years of plant life or 52 EFPY of operation). As a result of this updated fluence evaluation, the lead factors and the Withdrawal Times in Table 1 are revised as shown in Reference 5, Table 7-1 for Unit 1 and Table 7-2 for Unit 2.

Per Reference 5, Tables 2-1 and 2-3, the maximum reactor vessel fluence at 52 EFPY for Unit 1 is projected to be 2.66E19 n/cm 2 (E>1.0 MeV) and for Unit 2 is projected to be 2.57E19 n/cm 2 (E>1.0 MeV). In accordance with the requirements of ASTM E 185-82,

Section 7.6, the surveillance capsules should be removed when their neutron fluence exceeds the new peak EOLE vessel fluence (i.e., 2.66E19 n/cm 2 for Unit 1 at 52 EFPY, and 2.57E19 n/cm 2 for Unit 2 at 52 EFPY), but prior to exceeding twice that fluence exposure (i.e., 5.32E19 n/cm 2 for Unit 1 and 5.14E19 n/cm 2 for Unit 2). The earliest capsule withdrawal times to comply with the requirements of ASTM E 185-82 were determined in Reference 5, Appendix B, Table B.1-3 and Table B.2-3 and are provided in Table 2.

Using Reference 5, App B, Table B.1-2 and Table B.2-2, the projected EFPY at the EOC for cycles 18 through 20 were extrapolated through EOC 32 and provided in Table 3.

Since the projected 35.44 EFPY at the end of Unit 1 Cycle 28 is greater than the earliest withdrawal Unit 1 EFPY of 34.4 for the bounding Capsule S relocation time, withdrawal of Unit 1 Capsule S, relocated from the 4 degree to the 40 degree azimuthal location at either EOC 19 or 20, complies with the requirements of 10 CFR 50, Appendix H and ASTM E 185-82 for 60 years (52 EFPY) of operation.

Since the projected 35.26 EFPY at the end of Unit 2 Cycle 27 is greater than the earliest withdrawal Unit 2 EFPY of 34.7 for the bounding Capsule S relocation time, withdrawal of Unit 2 Capsule S, relocated from the 4 degree to the 40 degree azimuthal location at either EOC 19 or 20, complies with the requirements of 10 CFR 50, Appendix H and ASTM E 185-82 for 60 years (52 EFPY) of operation.

Table 4 provides the proposed revised capsule removal schedule which complies with the requirements of ASTM E 185-82 for the 60 years (52 EFPY) of operation.

In summary, TVA is relocating Unit 1 and Unit 2 Capsule S from the current 4 degree locations to the higher lead locations at 40 degree at either EOC 19 or EOC 20. TVA is proposing a revised specimen S capsule withdrawal schedule to support the application for a SQN Units 1 and 2 renewed license. The proposed revised schedule is to withdraw the relocated Unit 1 Capsule S during the EOC 28 outage and the relocated Unit 2 Capsule S during the EOC 27 outage. The schedule for the relocated Unit 1 and Unit 2 Capsule W (220 degree location) will remain in standby. The schedule for the remaining Capsules V and Z in Unit 1 and Unit 2 will also remain in standby.

4. References

1) Westinghouse Report WCAP-8233, "Tennessee Valley Authority Sequoyah Nuclear Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program,"

December, 1973.

2) Westinghouse Report WCAP-8513, "Tennessee Valley Authority Sequoyah Nuclear Plant Unit No. 2 Reactor Vessel Radiation Surveillance Program,"

November, 1975.

3) ASTM E185-82, "Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels," American Society of Testing and Materials, 1982.

4) Code of Federal Regulations, 10 CFR 50, Appendix H, "Reactor Vessel Material Surveillance Program Requirements," U.S. Nuclear Regulatory Commission, Washington, D.C., Federal Register, Volume 60, No. 243, dated December 19, 1995.

5) Westinghouse Report WCAP-17539-NP, Revision 0, "SEQUOYAH NUCLEAR PLANT Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity," March 2012.

Table 1 Reactor Vessel Capsule Removal Schedule(a)

Capsule Vessel Lead Factor Withdrawal Time (EFPY)

Number Location Unit 1 Unit 2 Unit 1 Unit 2 T 400 3.39 3.33 1.03 (removed) 1.04 (removed)

U 140) 3.47 3.40 2.919 (removed) 3 (removed)

X 220" 3.47 3.39 5.6 (removed) 6 (removed)

Y 320o 3.43 3.35 10.03 (removed) 10.54 (removed)

S 4u 1.08 1.09 Standby Standby V 176o 1.08 1.09 Standby Standby W 184u 1.08 1.09 Standby Standby Z 356u 1.08 1.09 Standby Standby Note:

a) Updated SQN Units 1 and 2 FSAR, Amendment 23, Section 5.4.3.7 Table 2 Earliest Withdrawal Times Capsule Relocated from the 4 degree to the 40 degree Aximuthal Location Capsule Time (EFPY) Corresponding to 60 Years of Capsule S Relocation Operation Time (EOC) (52 EFPY)

Unit I Unit 2 19 33.4 33.7 20 34.4 34.7

Table 3 Projected EFPY at EOC for the 40 degree Azimuthal Location through Cycle 32 Projected EFPY at EOC Cycle Unit I Unit 2 18 22.14(a) 22.97(a) 19 23.47(a) 24.34(a) 20 24.80(a) 25.70(a) 21 26.13(b) 27.07(")

22 27.46()) 28.43(b) 23 28.79(b) 29.80(b) 24 30.12(b) 31.16(b) 25 31.45(b) 32.53(b) 26 32.78 33.89(")

27 34.11 (b) 35.26(bT 28 3 5 . 4 4(b) 36.62(b) 29 36.77(b) 37.99(b) 30 38.10(b) 39.35(b) 31 39.43(b) 40.72(b) 32 40.76(b) 42.08(b)

Notes:

a) Reference 5, Table B.1-2 and Table B.2-2 b) Extrapolated from the EFPY values in Table B.1-2 and Table B.2-2 Table 4 Proposed FSAR Reactor Vessel Capsule Removal Schedule Capsule Vessel Lead Factor(c) Withdrawal Time (EFPY)(c)

Number Location Unit I Unit 2 Unit I Unit 2 T 40u 3.15 3.11 1.07 (removed) 1.07 (removed)

U 1400 3.23 3.17 2.85 (removed) 2.91 (removed)

X 2200 3.22 3.18 5.26 (removed) 5.36 (removed)

Y 3200 3.18 3.15 10.02 (removed) 10.55 (removed)

S 40°(a) 3.15 3.11 EOC 28 EOC 27 V 1760 0.90 0.94 Standby Standby W 220(( 3.22 3.18 Standby Standby Z 3560 0.90 0.94 Standby Standby Notes:

a) Capsule S is relocated from the 40 location to the 400 location b) Capsule W is relocated from the 1840 location to the 2200 location c) Reference 5, Table 7-1 and Table 7-2

0o VESSEL THRMAL $SIELO CAPSULE ISO Fisure 5.4,3-3 Surveillance Capsule Plan View FSAR Figure 5.4.3-3

ENCLOSURE 2 Tennessee Valley Authority Sequoyah Nuclear Plant Units 1 and 2 TVA-1 2-62, Westinghouse Letter to TVA SQN, "SQN Units 1 and 2 Reactor Vessel Surveillance Capsule Relocation," dated October 31, 2012, TVA Contract 4411-393260

Westinghouse Electric Company O Westinghouse Nuclear Services 1000 Westinghouse Drive Cranberry Township, PA 16066 USA

TVA-

1'2-62i October 31, 2012 Mr. Todd Noe TVA Contract:

Site Engineering Director 4411 - 393260 Tennessee Valley Authority Sequoyah Nuclear Plant P.O. Box 2000 - OPS 4A Soddy Daisy, TN 37384 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT UNITS 1 & 2 Reactor Vessel Surveillance Capsule Relocation Mr. Noe:

Please find attached the following document for your use:

• LTR-PL-12 Sequoyah Units 1 & 2 - Reactor Vessel Surveillance Capsule Relocation -

10 CFR 50.59 Assessment, Suggested UFSAR Changes & NRC Notification Letter dated October 31, 2012.

If you have any questions, please contact Bernie Gergos at 412-374-5837 or me at 423-697-5052.

Very truly yours, Ronald Kucharski Customer Projects Manager cc: Dave Lafever TVA Gary Adkins TVA Dennis Lundy TVA Linda Evans WEC Elise Wright WEC Bernie Gergos WEC Rob Taylor WEC This document is the property of and contains Proprietary Information owned by Westinghouse Electric Company LLC and/or its subcontractors and suppliers. It is transmitted to you in confidence and trust, and you agree to treat this document in strict accordance with the terms and conditions of the agreement under which it was provided to you.

02012 Westinghouse Electric Company LLC All Rights Reserved Electronically Approved Records are Authenticated in the Electronic Document Management System

Westinghouse Non-Proprietary Class 3 S Westinghouse To: L.R. Evans Date: October 31, 2012 cc: R.A. Taylor From: Plant Licensing Tel: 412-374-5837 LTR-PL-12-89 Fax: 724-720-0754

Subject:

Sequoyah Units 1 & 2 - Reactor Vessel Surveillance Capsule Relocation - 10 CFR 50.59 Assessment, Suggested UFSAR Changes & NRC Notification Letter

References:

1. Letter TVA-12-54, "Sequoyah Units 1 and 2 - Reactor Vessel Surveillance Capsule Relocation",

September 29, 2012.

Attached are the Applicability Determination and 10 CFR 50.59 Screen for the relocation of the reactor vessel surveillance capsules at Sequoyah Units 1 & 2 (Attachment 1) as well as recommended UFSAR changes (Attachment 2) associated with surveillance capsule relocation. In addition, suggested text is provided for TVA to incorporate in a letter to the NRC as notification for the relocation of the surveillance capsules and the proposed withdrawal schedule (Attachment 3).

The attached documents incorporate the resolution of TVA comments on the draft documents previously provided in Reference 1.

Please transmit the attachments to TVA.

Author: B.W. Gergos Plant Licensing Attachments (total of 3)

Electronically approved records are authenticated in the electronic document management system.

Westinghouse Non-Proprietary Class 3 Attachment 1 to Letter LTR-PL-12-89 October 31, 2012 Applicability Determination andl0 CFR 50.59 Screen Supporting Surveillance Capsule Relocation and Withdrawal at Sequoyah Units 1 and 2

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 APPLICABILITY DETERMINATION Page 1 of 2 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units I and 2 - Surveillance Capsule Relocation and Withdrawal Brief Description of activity (what is being changed and why):

Sequoyah Units 1 and 2 have fulfilled the surveillance capsule withdrawal recommendations contained in ASTM El 85-73 for their 40-year end-of-license (EOL). Currently four surveillance capsules remain in each unit's reactor vessel. Since Sequoyah Units 1 and 2 are applying for a 20-year license extension, an additional surveillance capsule will need to be withdrawn prior to end-of-life-extension (EOLE) to obtain data for reactor vessel integrity assessments. However, the remaining capsules are in locations of low neutron fluence; at their current locations, the capsules will not provide conservative data to support assessments of the effects of irradiation on regions of the reactor vessel which are highly irradiated. Therefore, Westinghouse has recommended relocating several of these remaining capsules to higher lead factor locations in order to achieve higher capsule fluence data.

One of these relocated capsules in each unit should be subsequently withdrawn from the reactor vessel and tested at the time when the accumulated neutron fluence of the capsule corresponds to not less than once or greater than twice the peak 60-year vessel fluence.

Address the questions below for all aspects of the activity. Ifthe answer is yes for any portion of the activity, apply the identified process(es) to that portion of the activity. Note that it is not unusual to have more than one process apply to a given activity.

Does the proposed activity involve a change to the:

1. Technical Specifications or Operating License Z NO Ej YES (IfYES process per procedure for (see 10CFR50.90)? License Amendment Requests.)

2. Quality Assurance Plan (see 10CFR50.54(a) )? Z NO Ej YES (IfYES process per procedure for QAP and related facility or procedure changes.)

3. Security Plan (see 10CFR50.54(p) )? Z NO Ej YES (IfYES process per procedure for Security Plan and related facility or procedure changes.)

4. Emergency Plan (see 10CFR50.54(q) )? Z NO [: YES (IfYES process per procedure for Emergency Plan and related facility or procedure changes.)

5. IST Program Plan (see 10CFR50.55a(f))? Z NO E] YES (IfYES process per procedure for ASME code compliance and related facility or procedure changes.)

6. ISI Program Plan (see 10CFR50.55a(g) )? Z NO Li YES (If YES process per procedure for ASME code compliance and related facility or procedure changes.)

7. Fire protection program (see applicable license Z NO LI YES (If YES process per procedure for condition)? Fire Protection Program changes.)

11. Does the proposed activity involve:

1. Maintenance which restores SSCs to their Z NO [] YES (If YES process per procedures for original condition plant maintenance.)

2. A temporary alteration supporting maintenance Z NO E] YES (If YES process per procedures for that will be in effect during at-power operations plant maintenance.)

for 90 days or less?

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 APPLICABILITY DETERMINATION Page 2 of 2 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) &Title: Sequoyah Units 1 and 2 - Surveillance Capsule Relocation and Withdrawal II1. Does the proposed activity involve a change to the [ NO [] YES (If YES process per procedure for UFSAR (including documents incorporatedby revising the FSAR.)

reference) excluded from requirement to perform a 10 CFR 50.59 Review by NEI 96-07 or NEI 98-03?

IV. Does the proposed activity involve a change to the:

1. Managerial or administrative procedures Z NO El YES (If YES process per procedure for governing the conduct of facility operations revising procedures.)

(subject to the control of 10CFR50, Appendix B)

2. Regulatory commitment not covered by another Z NO [:] YES (If YES process per procedure for regulation based change process (see NEI 99- commitment management.)

04)?

V. Does the activity impact other plant specific " NO [] YES (If YES process per the procedure(s) programs (e.g., the ODCM) which are controlled by for the appropriate activity.)

regulations, the Operating License or the Technical Specifications?

El All aspects of the activity are.controlled by one or more of the processes above; therefore a 10 CFR 50.59 review is not required.

ED Some portion of the activity is not controlled by one or more of the processes above, therefore a 10 CFR 50.59 review is required and should be initiated by completing the 10 CFR 50.59 Screen.

Westinghouse WCAP-17539-P presents the recommended locations for surveillance capsule relocation and provides recommendations for capsule withdrawal prior to end-of-life-extension (EOLE). Since none of the processes listed above apply for the proposed activity (surveillance capsule relocation), a 10 CFR 50.59 Screen is required to document that the proposed surveillance capsule locations and withdrawal schedule will assure an accurate assessment of reactor vessel integrity through the end of plant life.

This 10 CFR 50.59 Applicability Determination (AD) was prepared by Westinghouse Electric Company. The responses are based on Westinghouse review of the subject matter and available plant licensing documentation (UFSAR and Technical Specifications). Experience and judgment was applied in answering AD Questions 1.2 through 1.7, IV, and V. Because these questions address site-specific documentation not available for Westinghouse review, the utility should review these Westinghouse responses for concurrence.

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(Print name) (Sign) V" Reviewer: )bevyo 1,6i~v Aej Date: jig (Print name) - (Sign) a

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 1 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units l and 2 - Surveillance Capsule Relocation and Withdrawal I. Brief Description of activity (what is being changed and why):

Sequoyah Units 1 and 2 have fulfilled the surveillance capsule withdrawal recommendations contained in ASTM E185-73 for their 40-year end-of-license (EOL). Currently four surveillance capsules remain in each unit's reactor vessel. Since Sequoyah Units 1 and 2 are applying for a 20-year license extension, an additional surveillance capsule will need to be withdrawn prior to end-of-life-extension (EOLE) to obtain data for reactor vessel integrity assessments. However, the remaining capsules are in locations of low neutron fluence; at their current locations, the capsules will not provide conservative data to support assessments of the effects of irradiation on regions of the reactor vessel which are highly irradiated. Therefore, Westinghouse has recommended relocating several of these remaining capsules to higher lead factor locations-in order to achieve higher capsule fluence data.

One of these relocated capsules in each unit should be subsequently withdrawn from the reactor vessel and tested at the time when the accumulated neutron fluence of the capsule corresponds to not less than once or greater than twice the peak 60-year vessel fluence.

II. Applicability Determination Other applicable processes identified during the applicabilitydetermination: N/A III. 10 CFR 50.59 Screening Questions (Check correct response.

1. Does the proposed activity involve a change to an SSC that adversely E] YES E NO affects an UFSAR described design function?

Surveillance capsules will be relocated from their current locations to previously used (currently empty) capsule locations. Each location (as shown in Figure 5.3.3-4 of the UFSAR) was designed to hold a surveillance capsule. Therefore, the relocation of the surveillance capsules to previously occupied locations will have no effect on the UFSAR-described design functions of the reactor vessel, reactor internals, or reactor coolant flow within the reactor vessel. No changes to any component are required to relocate the capsules. Therefore, the proposed relocation of surveillance capsules and the suggested withdrawal times in Reference 1 do not involve a change to an SSC that adversely affects an UFSAR described design function.

2. Does the proposed activity involve a change to a procedure that adversely Ej YES E NO affects how UFSAR described SSC design functions are performed or controlled?

Relocation of the surveillance capsules has no effect on the procedures used to control plant operation, nor will their revised locations have any effect on plant performance or the performance of any SSC design functions.

Therefore, the recommendation for surveillance capsule relocation will not involve a change to a procedure that adversely affects how UFSAR described SSC design functions are performed or controlled.

3. Does the proposed activity involve revising or replacing an UFSAR Ej YES E NO described evaluation methodology that is used in establishing the design bases or used in the safety analyses?

The methods for conducting reactor vessel material surveillance, as described in UFSAR Section 5.4.3.7, are not changed by relocation of the remaining surveillance capsules or the future withdrawal of a capsule to support assessments of reactor vessel integrity prior to plant EOLE. The recommendations for surveillance

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 2 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) &Title: Sequoyah Units 1 and 2 - Surveillance Capsule Relocation and Withdrawal capsule relocation and withdrawal in support of plant life extension contained in WCAP-1 7539-P (Reference 1) do not involve a change to an UFSAR described evaluation methodology that is used in establishing the design bases or used in the safety analyses.

4. Does the proposed activity involve a test or experiment not described in the Ej YES Z NO UFSAR, where an SSC is utilized or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with analyses or descriptions in the UFSAR?

Surveillance capsules will be relocated from their current locations to previously used (now empty) capsule locations. Each location was designed to hold a surveillance capsule. Relocation of the surveillance capsules does not required any SSC to be utilized or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with analyses or descriptions in the UFSAR.

5. Does the proposed activity require a change to the Technical Specifications? E] YES Z NO The plant Technical Specifications do not address the reactor vessel radiation surveillance program, capsule locations or capsule withdrawal schedule. Therefore, the proposed changes per Reference 1 do not require any updates to the Technical Specifications.

IV. If all questions are answered NO, then implement the activity per the applicable plant procedure for the type of activity without obtaining a License Amendment.

If screen question 5 is answered YES, then request and receive a License Amendment prior to implementation of the activity.

If screen question 5 is answered NO and question 1, 2, 3 or 4 is answered YES, then a 10 CFR 50.59 Evaluation shall be performed.

10 CFR 50.59 Evaluation Number: N/A V. List the documents (UFSAR, TechnicalSpecifications, and other documents) reviewed where relevant information was found, including section numbers:

Sequoyah Units 1 and 2 UFSAR, Amendment 23, Sections 5.2.4.4 ("Compliance with Reactor Vessel Materials Surveillance Program Requirements") and 5.4.3.7 ("Reactor Vessel Material Surveillance Program Requirements").

Sequoyah Nuclear Plant Unit 1 Technical Specifications, Amendment 328.

Sequoyah Nuclear Plant Unit 2 Technical Specifications, Amendment 321.

Westinghouse Report WCAP-8233, "Tennessee Valley Authority Sequoyah Unit No. I Reactor Vessel Radiation Surveillance Program", December, 1973.

Westinghouse Report WCAP-8513, "Tennessee Valley Authority Sequoyah Unit No. 2 Reactor Vessel Radiation Surveillance Program", November, 1975.

Westinghouse Report WCAP-17539-NP, Revision 0, "Sequoyah Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity", March 2012.

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 3 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units 1 and 2 - Surveillance Capsule Relocation and Withdrawal VI. If the conclusion of the screening questions is that a 10 CFR 50.59 evaluation is not required, provide justification for that determination:

As detailed in UFSAR Section 5.4.3.7, the reactor vessel surveillance program uses eight specimen capsules for each of the Sequoyah units. The capsules are located in guide baskets welded to the outside of the thermal shield, about 3 inches from the vessel directly opposite the center portion of the core. The reactor vessel surveillance capsules are located at 40 and 400 in either direction from the 00 and 1800 axes of the vessel. The capsules can be removed when the vessel head is removed, and can be replaced when the internals are removed. The capsules contain reactor vessel steel specimens oriented in the major working direction and normal to the major working direction from the limiting SA-508 Class 2 shell forging located in the core region of the reactor and associated weld metal and heat affected zone metal.

Tables 1 and 2 provide the recommended surveillance capsule withdrawal schedules for Sequoyah Units 1 and 2, respectively (from Reference 1). These schedules meet the recommendations of ASTM E185-73 (Reference 2) as required by 10 CFR 50, Appendix H (Reference 3). With the withdrawal of Capsule Y, Sequoyah Units 1 and 2 fulfilled the surveillance capsule withdrawal recommendations contained in ASTM El 85-73 for their 40-year EOL (32 EFPY). Since Sequoyah Units 1 and 2 are applying for a 20-year license extension, Westinghouse has recommended that several remaining capsules be relocated to higher lead factor locations for each unit. One of these relocated capsules in each unit should be subsequently withdrawn from the reactor vessel and tested at the time when the accumulated neutron fluence of the capsule corresponds to not less than once or greater than twice the peak 60-year vessel fluence.

Capsules S, V, W and Z currently remain in each reactor vessel at Sequoyah Unit 1 and 2. Either Capsule 5, V, W, or Z should be withdrawn S from

, 19each unit 2 so that the capsule fluence 19 corresponds 2 to at least one times the 60-year EOL vessel fluence.(26x1i 0 9 n/cm. for Unit I and 2.57*x*10" n/cm 2,for Unit 2), but less than two times the 60-year EOL vessel fluence (5.32 x 1019 n/ for Unit l*and 5.14 x 1 /cm for Unit 2). However, none of these n0 remaining capsules are predicted to experience a neutron fluence of 2.66 x 1019 n/cm2 for Unit 1 or 2.57 x 1019 n/cm 2 for Unit 2 prior to EOLE in their current locations; therefore, it is recommended to relocate several of these remaining capsules to higher lead factor locations in order to achieve higher capsule fluence data.

Assuming a capsule is relocated at the end of Cycle 18, 19ior 20, the projected EFPY corresponding to the time when the capsule experiences the peak EOLE vessel fluence value (2.66 x 1019 n/cm 2 for Unit 1 and 2.57 x 1019 n/cm 2 for Unit 2) is approximately 32.5, 33.4, or 34.4 EFPY at the end of.Cycle 18, 19, or 20 respectively for Unit 1, and approximately 32.6, 33.7, or 34.7 EFPY, respectively for Unit 2.

Appendix B of Reference 1 provides the detailed evaluations which support the Westinghouse recommendations regarding surveillance capsule relocation for Sequoyah Units 1 and 2. A summary of the evaluation for each unit is provided below.

Sequoyah Unit 1 Capsules T, U, X and Y in the Sequoyah Unit 1 reactor vessel were positioned at the 400 azimuthal location, and were considered to be radiologically equivalent. Similarly, Capsules W, V, S, and Z are currently located at the 40 azimuthal location in the Unit 1 reactor vessel, and are considered to be radiologically equivalent. Note that the 40 azimuthal location is a lag (less than one) factor location; therefore, at this time, the Sequoyah Unit 1 reactor vessel is being irradiated slightly faster than the remaining capsules. In order for Sequoyah Unit 1 to have meaningful metallurgical capsule data in the future, it is recommended that several of the remaining capsules be relocated to any of the empty 40' azimuthal capsule locations:

Capsule neutron fluence projections are summarized in Table 3 for the 40 and 400 azimuthal capsule locations at Sequoyah Unit 1. The fluence values listed in Table 3 are used to determine neutron fluence projections assuming capsule relocation from a 40 to a 400 location beginning at end-of-cycles (EOC) 18, 19, and 20. Table 4 summarizes

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 4 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units I and 2 - Surveillance Capsule Relocation and Withdrawal the projected neutron fluence values for any of the remaining Sequoyah Unit 1 capsules assuming they are relocated from their 40 locations to any of the 40' locations at various relocation times.

Since Sequoyah Unit 1 is applying for a 20-year license extension, an additional capsule is expected to satisfy the same criteria as the EOL capsule, as described in ASTM E185-73, with the EOL fluence at 60 years (52 EFPY).

Therefore, a capsule should be withdrawn so that the capsule fluence corresponds to at least one times the 60-year EOL vessel fluence (2.66 x 1019 n/cm 2, per Table 2-5 of Reference 1), but less than two times the 60-year EOL vessel fluence (5.32 x 1019 n/cm 2). Based on the fluence projections in Table 3, none of the remaining Sequoyah Unit 1 capsules, in their current azimuthal locations (40), would experience a neutron fluence of 2.66 x 101 n/cm2 prior to EOLE.

However, based on the fluence projections in Table 4, the peak 52 EFPY calculated vessel fluence of 2.66 x 1019 n/cm 2 (E > 1.0 MeV) would occur at approximately 32.5, 33.4, or 34.4 EFPY, assuming the capsule was relocated to a 40' azimuthal location at the EOCs 18, 19, or 20, respectively. Furthermore, based on the fluence projections in Table 4, two times the peak 52 EFPY calculated vessel fluence of 5.32 x 1019 n/cm 2 (E > 1.0 MeV) would occur at approximately 52 EFPY for a relocated capsule, assuming the capsule was relocated at the EOCs 18, 19, or 20 to a 400 azimuthal location.

Additionally, it is anticipated at this time that if an additional 20-year license extension was sought, another capsule would be needed to be withdrawn from the reactor vessel in order to satisfy the same criteria as the EOL capsule with an EOL fluence at 80 years (72 EFPY). The extrapolated maximum neutron fluence value at 72 EFPY for Sequoyah Unit 1 is approximately 3.61 x 1019 n/cm2 (E 19 > 1.0 MeV).

2 Based on the fluence projections in Table 4, the peak 72 EFPY calculated vessel fluence of 3.61 x 10 n/cm (E > 1.0 MeV) would occur at approximately 39.0, 39.9, or 40.9 EFPY, assuming the capsule was relocated to a 400 azimuthal location at the EOC 18, 19, or 20, respectively.

In summary, it is recommended that several of the Sequoyah Unit 1 remaining capsules be relocated to higher lead factor locations. One of these relocated capsules should be subsequently withdrawn from the reactor vessel and tested at the time when the accumulated neutron fluence of the capsule corresponds to not less than once or greater than twice the peak 60-year vessel fluence. Another relocated capsule could be used for future testing, if additional license extensions are sought. Table 5 summarizes the range of proposed removal times for the relocated capsules based on license extension out to 60 and 80 years of operation. These dates are based on the capsule fluence being equivalent to one times the peak vessel fluence at 60 years (2.66 x 1019 n/cm 2) as well as one times the peak vessel fluence at 80 years (3.61 x 1019 n/cm 2).

Seciuovah Unit 2 Capsules T, U, X and Y in the Sequoyah Unit 2 reactor vessel were positioned at the 400 azimuthal location, and were considered to be radiologically equivalent. Similarly, Capsules W, V, S, and Z are currently located at the 40 azimuthal location in the Unit 1 reactor vessel, and are considered to be radiologically equivalent. Note that the 40 azimuthal location is a lag (less than one) factor location; therefore, at this time, the Sequoyah Unit 2 reactor vessel is being irradiated slightly faster than the remaining capsules. In order for Sequoyah Unit 2 to have meaningful metallurgical capsule data in the future, it is recommended that several of the remaining capsules be relocated to any of the empty 40' azimuthal capsule locations.

Capsule neutron fluence projections are summarized in Table 6 for the 40 and 40' azimuthal capsule locations at Sequoyah Unit 2.

The fluence values listed in Table 6 are used to determine neutron fluence projections assuming capsule relocation from a 40 to a 400. location beginning at end-of-cycles (EOC) 18,19, and 20. Table 7 summarizes the projected neutron fluence values for any of the remaining Sequoyah Unit 2 capsules assuming they are relocated from their 40 locations to any of the 40' locations at various relocation times.

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 5 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units 1 and 2 - Surveillance Capsule Relocation and Withdrawal Since Sequoyah Unit 2 is applying for a 20-year license extension, an additional capsule is expected to satisfy the same criteria as the EOL capsule, as described in ASTM El 85-73, with the EOL fluence at 60 years (52 EFPY).

Therefore, a capsule should be withdrawn so that the capsule fluence corresponds to at least one times the 60-year EOL vessel fluence (2.57 x 1019 n/cm2, per Table 2-5 of Reference 1), but less than two times the 60-year EOL vessel fluence (5.14 x 1019 n/cm 2). Based on the fluence projections in Table 6, none of the remaining Sequoyah Unit 2 capsules, in their current azimuthal locations (40), would experience a neutron fluence of 2.57 x 1019 n/cm 2 prior to EOLE.

However, based on the fluence projections'in Table 7, the peak 52 EFPY calculated vessel fluence of 2.57 x 1019 n/cm 2 (E > 1.0 MeV) would occur at approximately 32.6, 33.7, or 34.7 EFPY, assuming the capsule was relocated to a 400 azimuthal location at the EOCs 18, 19, or 20, respectively. Furthermore, based on the fluence projections in Table B.2-2, two times the peak 52 EFPY calculated vessel fluence of 5.14 x 1019 n/cm 2 (E > 1.0 MeV) would occur at approximately 52 EFPY for a relocated capsule, assuming the capsule was relocated at the EOCs 18, 19, or 20 to a 400 azimuthal location.

Additionally, it is anticipated at this time that if an additional 20-year license extension was sought, another capsule would be needed to be withdrawn from the reactor vessel in order to satisfy the same criteria as the EOL capsule with an EOL fluence at 80 years (72 EFPY).19 2The extrapolated maximum neutron fluence value at 72 EFPY for Sequoyah Unit 2 is approximately 3.52 x 10 n/cm (E 19 > 1.0 MeV).

2 Based on the fluence projections in Table B.2-2, the peak 72 EFPY calculated vessel fluence of 3.52 x 10 n/cm (E > 1.0 MeV) would occur at approximately 39.3, 40.4 or 41.4 EFPY, assuming the capsule was relocated to a 400 azimuthal location at the EOC 18, 19, or 20, respectively.

In summary, it is recommended that several of the Sequoyah Unit 2 remaining capsules be relocated to higher lead factor locations. One of these relocated capsules should be subsequently withdrawn from the reactor vessel and tested at the time when the accumulated neutron fluence of the capsule corresponds to not less than once or greater than twice the peak 60-year vessel fluence. Another relocated capsule could be used for future testing, if additional license extensions are sought. Table 8 summarizes the range of proposed removal times for the relocated capsules based on license extension out to 60 and 80 years of operation. These dates are based on the capsule fluence being equivalent to one times the peak vessel fluence at 60 years (2.57 x 1019 n/cm 2) as well as one times the peak vessel fluence at 80 years (3.52 x 1019 n/cm 2).

PTLR Considerations Surveillance capsule data from the first four capsules withdrawn from both units (T, U, X and Y) have been used in the development of heatup and cooldown pressure-temperature limits and Pressure-Temperature Limit Reports (PTLRs) for Sequoyah Units 1 and 2. Section 6.9.1.15 of the Technical Specifications for Sequoyah Units 1 and 2 references Westinghouse reports that are used in the development of the PTLRs. These include References 6 and 7, which document the development of the heatup and cooldown pressure-temperature limit curves for normal operation and PTLR support documentation. Appendix F of References 6 and 7 contains summaries of the updated surveillance capsule removal schedule for each unit. The summary table in Appendix F of References 6 and 7 lists the location and lead factor for each capsule, removal time and fluence for the four capsules (T, U, X, and Y) already withdrawn from each unit. The current locations and lead factors for those locations are also listed for capsules S, V, W and Z. However, data from those capsules and locations are not used in the calculations for the current heatup and cooldown pressure-temperature limits. In support of plant life extension, TVA plans to update the PTLRs for each unit and data from at least two of the remaining surveillance capsules will be collected and analyzed for future modifications of the PTLRs to support operation during the license renewal period. However, no changes to the plant Technical Specifications or to the existing reports (References 6 and 7) are required to relocate any of the remaining surveillance capsules to locations of higher fluence in support of these future assessments.

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 6 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units I and 2- Surveillance Capsule Relocation and Withdrawal Conclusions References 4 and 5 summarize the reactor vessel radiation surveillance programs for Sequoyah Units 1 and 2. In.

accordance with surveillance programs outlined References 4 and 5, as-well as Section 5.4.3.7 of the UFSAR, both units have fulfilled the surveillance capsule withdrawal recommendations contained in ASTM E185-73 for their 40-year EOL (32 EFPY). In support of the plants' applications for a 20-year license extension, it is recommended that several of the remaining capsules be relocated to higher lead factor locations for each unit. Relocation of the capsules from the 40 to the 400 azimuthal capsule locations, which experience higher vessel fluences such that the subsequent withdrawal of one capsule from each unit will provide the necessary data for irradiation assessment to demonstrate vessel integrity for the 60-year EOLE. An additional capsule can also be withdrawn at a later time if it is desired to obtain addition data to suppor another plant life extension.

Relocation of the capsules in accordance with the recommendations of Reference 1 and capsule withdrawal per the suggested times in Tables 5 and 8 for Sequoyah Units 1 and 2, respectively, will assure that accurate vessel fluences are obtained for the EOLE.

The proposed surveillance capsule relocations and withdrawal schedules have no adverse effects on SSC design functions described in the UFSAR and no effect on procedures that affect the control or performance of any SSC design functions. There are no changes to methods of evaluation previously described in Section 5.4.3.7 of the UFSAR or the original reactor vessel radiation surveillance program as summarized in Reference 4 and 5.

Relocation of the surveillance capsules does not required any SSC to be utilized or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with analyses or descriptions in the UFSAR. No changes to the plant Technical Specifications are required.

Based on the information above and on the responses to the Screening questions in Section III above, it is concluded that a1 CFR 5059 Evaluation is not required.;

References

1) Westinghouse Report WCAP-17539-NP, Revision 0, "Sequoyah Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity", March 2012.

2) ASTM E185-73, "Standard Recommended Practice for Surveillance Tests for Nuclear Reactor Vessels",

American Society of Testing and Materials.

3) Code of Federal Regulations, 10 CFR 50, Appendix H, "Reactor Vessel Material Surveillance Program Requirements," U.S. Nuclear Regulatory Commission, Washington, D.C., Federal Register, Volume 60, No.

243, dated December 19, 1995.

4) Westinghouse Report WCAP-8233, "Tennessee Valley Authority Sequoyah Unit No. 1 Reactor Vessel Radiation Surveillance Program", December, 1973.

5) Westinghouse Report WCAP-8513, "Tennessee Valley Authority Sequoyah Unit No. 2 Reactor Vessel Radiation Surveillance Program", November, 1975.

6) Westinghouse Report WCAP-15293, Revision 2, "Sequoyah Unit 1 Heatup and Cooldown Limit Curves for Normal Operation and PTLR Support Documentation", July 2003.

7) Westinghouse Report WCAP-1 5321, Revision 2, "Sequoyah Unit 2 Heatup and Cooldown Limit Curves for Normal Operation and PTLR Support Documentation", July 2003.

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 7 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units I and 2 - Surveillance Capsule Relocation and Withdrawal VII. Screen Signoffs:

Author: I // -

Date:

(Print name) (Sign) V Reviewer: Date: //3I ]4 ,

.(Print name) () (Sign)

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 8 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units I and 2 - Surveillance Capsule Relocation and Withdrawal Table I Sequoyah Unit I Surveillance Capsule Withdrawal Summary (Reference 1)

Withdrawal EFPY(b) Flue n ce 1a)

Capsule Capsule Location Lead Factor(a) Wx019 n/cm2 , E > 1.0 MeV)

T 400 3.15 1.07 0.241 U 1400 3.23 2.85 0.693 X 2200 3.22 5.26 1.16 Y 3200 3.18 10.02 1.97 S 40 0.90 (c) (c)

V 1760 0.90 (c) (c)

W 1840 0.90 (c) (c)

Z 3560 0.90 (c) (c)

Notes:

(a) Updated as part of the time-limited aging analyses (TLAA) fluence evaluation.

(b) EFPY from plant startup.

(c) Capsules S, V, W and Z are currently in the Sequoyah Unit 1 reactor vessel. Either Capsule S, V, W, or Z should be withdrawn so that the capsule fluence corresponds to at least one times the 60-year EOL vessel fluence (2.66 x 1019 n/cm 2), but less than two times the 60-year EOL vessel fluence (5.32 x 1019 n/cm 2).

However, none of these remaining capsules are predicted to experience a neutron fluence of 2.66 x 1019 n/cm 2 prior to EOLE in their current locations; therefore, it is recommended to relocate several of these remaining capsules to higher lead factor locations in order to achieve higher capsule fluence data. Assuming a capsule was relocated at the end of cycle 18, 19, or 20, the EFPY that corresponds to the time when the capsule experiences the peak EOLE vessel fluence value (2.66 x 1019 n/cm 2) is approximately 32.5, 33.4, or 34.4 EFPY, respectively. See Appendix B for further details on capsule relocation recommendations.

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 9 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: . Sequoyah Units 1 and 2 - Surveillance Capsule Relocation and Withdrawal Table 2 Sequoyah Unit 2 Surveillance Capsule Withdrawal Summary (Reference 1)

Fluence(a)

Capsule Capsule Location Lead Factor(a) Withdrawal EFPY(b) (xl0'9 n/cm 2, E> 1.0 MeV)

T 400 3.11 1.07 0.244 U 1400 3.17 2.91 0.654 X 2200 3.18 5.36 1.16 Y 3200 3.15 10.55 2.02 S 40 0.94 (c) (c)

V 1760 0.94 (c) (c)

W 1840 0.94 (c) (c)

Z 3560 0.94 (c) (c)

Notes:

(a) Updated as part of the TLAA fluence evaluation.

(b) EFPY from plant startup.

(c) Capsules S, V, W and Z are currently in the Sequoyah Unit 2 reactor vessel. Either Capsule S, V, W, or Z should be withdrawn so that the capsule fluence corresponds to at least one times the 60-year EOL vessel fluence (2.57 x 1019 n/cm 2 )' but less than two times the 60-year EOL vessel fluence (5.14 x 1019 n/cm2 ) However, none of these remaining capsules are predicted to experience a neutron fluence of 2.57 x 1019 n/cm2 prior to EOLE in their current locations; therefore, it is recommended to relocate several of these remaining capsules to higher lead factor locations in order to achieve higher capsule fluence data. Assuming a capsule was relocated at the end of cycle 18, 19, or 20, the EFPY that corresponds to the time when the capsule experiences the peak EOLE vessel fluence value (2.57 x 1019 n/cm2 ) is approximately 32.6, 33.7, or 34.7 EFPY, respectively. See Appendix B for further details on capsule relocation recommendations.

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 10 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units 1 and 2 - Surveillance Capsule Relocation and Withdrawal Table 3 Projected Neutron Fluence Values at the Geometric Center of the Surveillance Capsule Locations for Sequoyah Unit 1 (Reference 1)

Capsule Fluence Cycle EFPY (xl019 n/cm 2, E > 1.0 MeV) 40 Azimuthal 400 Azimuthal Location Location 18 22.14 1.14 4.02 19 23.47 1.20 4.21 20 24.80 1.25 4.41

--- 28.00 1.38 4.88

--- 32.00 1.54 5.46

-- 36.00 1.70 6.05 40.00 1.87 6.64

--- 44.00 2.03 7.23

--- 48.00 2.19 7.81

--- 52.00 2.35 8.40

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 11 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units 1 and 2 - Surveillance Capsule Relocation and Withdrawal Table 4 Sequoyah Unit I Projected Capsule Neutron Fluence Values Associated With Capsule Relocation from the 40 to the 400 Azimuthal Location (Reference 1)

Capsule Fluence (x10 19. n/cm 2 , E > 1.0 MeV)

Cycle EFPY Relocation at the Relocation at the Relocation at the EOC 18 EOC 19 EOC 20 18 22.14 1.14 1.14 1.14 19 23.47 1.33 1.20 1.20 20 24.80 1.53 1.40 1.25

--- 28.00 2.00 1.87 1.72

--- 32.00 2.58 2.45 2.30

--- 36.00 3.17 3.04 2.89

--- 40.00 3.76 3.63 3.48 44.00 4.35 4.22 4.07

--- 48.00 4.93 4.80 4.65

--- 52.00 5.52 5.39 5.24

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 12 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units 1 and 2 - Surveillance Capsule Relocation and Withdrawal Table 5 Sequoyah Unit I - Range of Proposed Capsule Withdrawal Times Associated With Capsule Relocation from the 40 to the 400 Azimuthal Location (Reference 1)

Life(a)

Capsule Capsule Time (EFPY) Corresponding to Vessel Relocation Time 60 Years of Operation 80 Years of Operation (52 EFPY) (72 EFPY)

EOC 18 32.5 39.0 EOC 19 33.4 39.9 EOC 20 34.4 40.9 Notes:

(a) These dates are based on the capsule fluence being equivalent to one times the peak vessel fluence at 60 years (2.66 x 1019 n/cm 2) as well as one times the peak vessel fluence at 80 years (3.61 x 1019 n/cm 2).

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 13 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units I and 2 - Surveillance Capsule Relocation and Withdrawal Table 6 Projected Neutron Fluence Values at the Geometric Center of the Surveillance Capsule Locations for Sequoyah Unit 2 (Reference 1)

Capsule Fluence Cycle EFPY (x019 n/cm 2, E > 1.0 MeV) 40 Azimuthal 400 Azimuthal Location Location 18 22.97 1.18 3.91 19 24.34 1.24 4.13 20 25.70 1.30 4.32

--- 28.00 1.40 4.65

--- 32.00 1.58 5.22 36.00 1.76 5.78

--- 40.00 1.94 6.35

--- 44.00 2.12 6.92 48.00 2.30 7.48 52.00 2.48 8.05

Westinghouse Non-Proprietary Class 3.

WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 14 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units 1 and 2 - Surveillance Capsule Relocation and Withdrawal Table 7 Sequoyah Unit 2 Projected Capsule Neutron Fluence Values Associated With Capsule Relocation from the 40 to the 400 Azimuthal Location (Reference 1)

Capsule Fluence (xW0 19 n/cm 2, E > 1.0 MeV)

Cycle EFPY__ Relocation at the _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Relocation at the Relocation at the EOC 18 EOC 19 EOC 20 18 22.97 1.18 1.18 1.18 19 24.34 1.40 1.24 1.24 20 25.70 1.59 1.43 1.30

--- 28.00 1.92 1.76 1.62

--- 32.00 2.49 2.33 2.19

--- 36.00 3.05 2.89 2.75

--- 40.00 3.62 3.46 3.32

--- 44.00 4.19 4.03 3.89

--- 48.00 4.75 4.59 4.45 52.00 5.32 5.16 5.02

Westinghouse Non-Proprietary Class 3 WESTINGHOUSE ELECTRIC COMPANY 10 CFR 50.59 SCREEN Page 15 of 15 Document Number: EVAL-12-96 Revision Number: 0 Plant(s) & Title: Sequoyah Units I and 2 - Surveillance Capsule Relocation and Withdrawal Table 8 Sequoyah Unit 2 - Range of Proposed Capsule Withdrawal Times Associated With Capsule Relocation from the 40 to the 400 Azimuthal Location (Reference 1)

Capsule Capsule Time (EFPY) Corresponding to Vessel Life(a)

Relocation Time 60 Years of Operation 80 Years of Operation (52 EFPY) (72 EFPY)

EOC 18 32.6 39.3 EOC 19 33.7 40.4 EOC 20 34.7 41.4 Notes:

(a) These dates are based on the capsule fluence being equivalent to one times the peak vessel fluence at 60 years (2.57 x 1019 n/cm 2) as well as one times the peak vessel fluence at 80 years (3.52 x 1019 n/cm 2).

Westinghouse Non-Proprietary Class 3 Attachment 2 to Letter LTR-PL-12-89 October 31, 2012 Suggested UFSAR Changes Accompanying EVAL-12-96, "Sequoyah Units 1 and 2 - Surveillance Capsule Relocation and Withdrawal" Westinghouse has recommended relocating reactor vessel surveillance capsules to areas of higher fluence, in conjunction with TVA's application for license renewal for Sequoyah Units 1 and 2.

Section 7.0 and Appendix B of Westinghouse Report WCAP-17539-NP, Revision 0, "Sequoyah Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity", March 2012, support the proposed relocation of capsules and provide tables with proposed capsule withdrawal times prior to end-of-life-extension (EOLE). The following changes are recommended to Section 5.4.3.7 ("Reactor Vessel Material Surveillance Program Requirements") of the Sequoyah Units 1 and 2 UFSAR, Amendment 22, "Reactor Vessel Material Surveillance Program Requirements".

There are no changes recommended to UFSAR Section 5.2.4.4, "Compliance with Reactor Vessel Materials Surveillance Program Requirements".

On page 5.4-7 of Section 5.4.3.7, the following changes are recommended:

2 ndparagraph,make changes as highlightedbelow:

The eight reactor vessel surveillance capsules a-e were located at 40 and 400 as shown in Figure 5.4.3-3.

Existing table on page 5.4-77:

CAPSULE VESSEL NUMBER LOCATION LEAD FACTOR WITHDRAWAL TIME (EFPY)

Ul U2 Ul U2 T 400 3.39 3.33 1.03 1.04 (removed) (removed)

U 1400 3.47 3.40 2.919 3 (removed) (removed)

X 2200 3.47 3.39 5.6 6 (removed) (removed)

Y 3200 3.43 3.35 10.03 10.54 (removed) (removed)

S40 (1) 1.08 1.09 STBY STBY 400 (2) See additional information below. See additional information below.

(Note to TVA: delete this line andsuperscript (1) above if capsule S is not relocated)

Attachment 2 to Letter LTR-PL-12-89 October 31, 2012 V 1760 (1) 1.08 1.09 STBY STBY 1400 (2) See additional information below. See additional information below.

(Note to TVA: delete this line and superscript(1) above if capsule V is not relocated)

W 1840 (1) 1.08 1.09 STBY STBY 2200 (2) See additional information below. See additional information below.

(Note to TVA: delete this line and superscript(1) above if capsule W is not relocated)

Z 3560 (1) 1.08 1.09 STBY STBY 3200 (2) See additional information below. See additional information below.

(Note to TVA.- delete this line and superscript(1) above if capsule Z is not relocated)

Notes:

(1) Original vessel location prior to relocation at End-of-Cycle X. (substitute appropriate Cycle number)

(2) New vessel location after relocation at Enid-of-Cycle X. (substitute appropriate Cycle number)

Bottom ofpage 5.4-7 (immediatelyprecedingSection 5.4.3.7.1), after the sentence "Each specimen capsule upon removal after radiationexposure will be transferredto a post-irradiation test facilityfor disassembly of the capsule and testing of all specimens ",add the following paragraphsand tables:

With the withdrawal of Capsule Y, Sequoyah Units 1 and 2 fulfilled the surveillance capsule withdrawal recommendations contained in ASTM E 18 5-73 for their 40-year end-of-life (EOL)

(32 EFPY). To support the 20-year life extension for Sequoyah Units 1 and 2, the capsules designated above have been relocated to higher lead factor locations for each unit as indicated in the footnotes in the table above.

Relocation of Capsules [S, V, W, and Z (insert whichever capsules are relocated)] places them at locations of higher fluence, to support future capsule withdrawal for irradiation assessments. One from the reactor vessel of these relocated capsules in each unit should be subsequently withdrawn and tested at the time when the accumulated neutron fluence of the capsule corresponds to not less than once or greater than twice the peak 60-year vessel fluence: Reference 6 provides the bases for capsule relocation and the withdrawal times recommended in support of plant life extension for both units.

For Sequoyah Unit 1, the potential capsule withdrawal times associated with capsule relocation from'the 4' to the 400 azimuthal location (from Reference 6) .are:

Capsule Capsule Time (EFPY) Corresponding to Vessel Life(a)

Relocation 60 Years of Operation 80 Years of Operation Time (52 EFPY) (72 EFPY)

EOC 18 32.5 39.0 EOC 19 33.4 39.9 EOC 20 34.4 40.9

Attachment 2 to Letter LTR-PL-12-89 October 31, 2012 These dates are based on the capsule fluence being equivalent to one times theipeak vessel fluence at 60 y*a* s (2.66 x I10' o "9/ ) a4§we11 as .one times the peak vesselfiiuence at 80 5year (361 x 10~ n91/cm11).

For :Sequoya Unit 2, the potntial capsule times associated with capsule relocat~ion tiihdrayai from the 4' to the 40' aziiii'thal location (4WonReference 6) are:

CapsuleTime (EFPY)Correspondii .,tdVesSelLifer, Relocatio-T 60 Years of Operation' 0oYears of Operation

..Time (52 PY) (72 EFPY)

EOC 18 32.6 39.3 Eoc 19 33.7 40.4 These dates are based theonme capsule fluence belmg--q,,ivaient to one times the peak ývese:

fluence at 60 years (.2.57 , m10

)aswelias o times the peak vessel flUence at ye A(3.5.2 -x 101 cmtn .

Add to Section 5.4.5, "References "

6. WestinWghJouse IZep~ort \V(A P-7519.1, Rec\Ision 0, "eqUoyah~ Units I od 2 Time-ELimited Aging Analysis nReactor \ Y,ýe ntgity" March 201.-

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 Draft Content for Letter to Inform NRC of Intent to Relocate Reactor Vessel Surveillance Capsules at Sequoyah Units 1 and 2 References

1) Westinghouse Report WCAP-8233, "Tennessee Valley Authority Sequoyah Unit No. 1 Reactor Vessel Radiation Surveillance Program", December, 1973.

2) Westinghouse Report WCAP-8513, "Tennessee Valley Authority Sequoyah Unit No. 2 Reactor Vessel Radiation Surveillance Program", November, 1975.

3) Westinghouse Report WCAP-1 7539-NP, Revision 0, "Sequoyah Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity", March 2012.

4) ASTM El 85-73, "Standard Recommended Practice for Surveillance Tests for Nuclear Reactor Vessels," American Society of Testing and Materials.

5) Code of Federal Regulations, 10 CFR 50, Appendix H, "Reactor Vessel Material Surveillance Program Requirements," U.S. Nuclear Regulatory Commission, Washington, D.C., Federal Register, Volume 60, No. 243, dated December 19, 1995.

6) Westinghouse Report WCAP-1 5293, Revision 2, "Sequoyah Unit 1 Heatup and Cooldown Limit Curves for Normal Operation and PTLR Support Documentation", July 2003.

7) Westinghouse Report WCAP-1 5321, Revision 2, "Sequoyah Unit 2 Heatup and Cooldown Limit Curves for Normal Operation and PTLR Support Documentation", July 2003.

Background

Pressure vessel steel irradiation surveillance programs were developed for the reactor vessels of Tennessee Valley Authority, Sequoyah Units 1 and 2 in References 1 and 2. The surveillance programs were developed to obtain information on the effects of radiation on the reactor vessel material during operating conditions. The program comprises the evaluation of radiation effects on sample materials based on comparison pre-irradiation testing of a selected group of specimens to determine toughness properties of the reactor pressure-vessel. Continuous monitoring of these specimens within the reactor pressure vessel provides data on the integrity of the vessel in terms of adequate toughness properties. References 1 and 2 provide a description of the surveillance capsules and pre-irradiated test results for each unit.

As detailed in the Sequoyah Units 1 and 2 UFSAR, Section 5.4.3.7, the reactor vessel surveillance program uses eight specimen capsules for each of the Sequoyah units. The capsules are located in guide baskets welded to the outside of the thermal shield, about 3 inches from the vessel directly opposite the center portion of the core. The reactor vessel surveillance capsules are located at 40 and 400 in either direction from the 0° and 1800 axes of the vessel.

The capsules can be removed when the vessel head is removed, and can be replaced when the internals are removed. The capsules contain reactor vessel steel specimens oriented in the major working direction and normal to the major working direction from the limiting SA-508 Class 2 shell forging located in the core region of the reactor and associated weld metal and heat affected zone metal.

Recommendations for Capsule Relocation in Support of Plant Life Extension Tables 1 and 2 provide the surveillance capsule withdrawal schedules for Sequoyah Units 1 and 2, respectively (from Reference 3). These schedules meet the recommendations of ASTM E185-73 (Reference 4) as required by 10 CFR 50, Appendix H (Reference 5). With the withdrawal of Capsule Y at each unit, Sequoyah Units 1 and 2 have fulfilled the surveillance capsule withdrawal recommendations contained in ASTM El 85-73 for their 40-year EOL (32 EFPY). Since

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 Sequoyah Units 1 and 2 are applying for a 20-year license extension, Westinghouse has recommended in Reference 3 that several remaining capsules be relocated to higher lead factor locations for each unit. One of these relocated capsules in each unit would be subsequently withdrawn from the reactor vessel and tested at the time when the accumulated neutron fluence of the capsule corresponds to not less than once or greater than twice the peak 60-year vessel fluence.

Capsules S, V, W and Z currently remain in each reactor vessel at Sequoyah Unit 1 and 2. Per Reference 3, either Capsule S, V, W, or Z should be withdrawn from each unit so that the capsule fluence corresponds to at least one times the 60-year EOL vessel fluence (2.66 x 1019 n/cm 2 for Unit 1 and 2.57 x 1019 n/cm2 for Unit 2), but less than two times the 60-year EOL vessel fluence (5.32 x 1019 n/cm2 for Unit 1 and 5.14 x 1019 n/cm2 for Unit 2). However, none of these remaining capsules are predicted to experience a neutron fluence of 2.66 x 1019 n/cm 2 for Unit 1 or 2.57 x 1019 n/cm2 for Unit 2 prior to EOLE in their current locations; therefore, it is recommended in Reference 3 to relocate several of these remaining capsules to higher lead factor locations in order to achieve higher capsule fluence data. Assuming a capsule is relocated at the end of Cycle 18, 19, or 20, the projected EFPY corresponding to the time when the capsule experiences the peak EOLE vessel fluence value (2.66 x 1019 n/cm for Unit 1 and 2.57 x 1019 n/cm 2 for Unit

2) is approximately 32.5, 33.4, or 34.4 EFPY at the end of Cycle 18, 19, or 20 respectively for Unit 1, and approximately 32.6, 33.7, or 34.7 EFPY, respectively for Unit 2.

Appendix B of Reference 3 provides the detailed evaluations which support the Westinghouse recommendations regarding surveillance capsule relocation for Sequoyah Units 1 and 2. A summary of the evaluation for each unit is provided below.

Sequoyah Unit 1 Capsules T, U, X and Y in the Sequoyah Unit 1 reactor vessel were positioned at the 400 azimuthal location, and were considered to be radiologically equivalent. Similarly, Capsules W, V, S, and Z are currently located at the 40 azimuthal location in the Unit 1 reactor vessel, and are considered to be radiologically equivalent. Note that the 40 azimuthal location is a lag (less than one) factor location; therefore, at this time, the Sequoyah Unit 1 reactor vessel is being irradiated slightly faster than the remaining capsules. In order for Sequoyah Unit 1 to have meaningful metallurgical capsule data in the future, it is recommended that several of the remaining capsules be relocated to any of the empty 40' azimuthal capsule locations.

Capsule neutron fluence projections are summarized in Table 3 for the 40 and 40' azimuthal capsule locations at Sequoyah Unit 1. The fluence values listed in Table 3 are used to determine neutron fluence projections assuming capsule relocation from a 40 to a 40' location beginning at end-of-cycles (EOC) 18, 19, and 20. Table 4 summarizes the projected neutron fluence values for any-of the remaining Sequoyah Unit 1 capsules assuming they are relocated from their 4' locations to any of the 400 locations at various relocation times.

Since Sequoyah Unit 1 is applying for a 20-year license extension, an additional capsule is expected to satisfy the same criteria as the EOL capsule, as described in ASTM E185-73, with the EOL fluence at 60 years (52 EFPY). Therefore, a capsule should be withdrawn so that the capsule fluence corresponds to at least one times the 60-year EOL vessel fluence (2.66 x 1019 n/cm 2 , per19Table 2-5 of Reference 3), but less than two times the 60-year EOL vessel fluence (5.32 x 10 n/cm 2 ). Based on the fluence projections in Table 3, none of the remaining Sequoyah Unit 1 capsules,2in their current azimuthal locations (40), would experience a neutron fluence of 2.66 x 10 n/cm prior to EOLE.

However, based on the fluence projections in Table 4, the peak 52 EFPY calculated vessel fluence of 2.66 x 1019 n/cm 2 (E > 1.0 MeV) would occur at approximately 32.5, 33.4, or 34.4 EFPY, assuming the capsule was relocated to a 400 azimuthal location at the EOCs 18, 19, or

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 20, respectively. Furthermore, based on the fluence projections in Table 4, two times the peak 52 EFPY calculated vessel fluence of 5.32 x 1019 n/cm 2 (E > 1.0 MeV) would occur at approximately 52 EFPY for a relocated capsule, assuming the capsule was relocated at the EOCs 18, 19, or 20 to a 400 azimuthal location.

Additionally, it is anticipated at this time that if an additional 20-year license extension was sought, another capsule would be needed to be withdrawn from the reactor vessel in order to satisfy the same criteria as the EOL capsule with an EOL fluence at 80 years (72 EFPY). The extrapolated maximum neutron fluence value at 72 EFPY for Sequoyah Unit 1 is approximately 3.61 x 1019 n/cm 2 (E > 1.0 MeV). Based on the fluence projections in Table 4, the peak 72 EFPY calculated vessel fluence of 3.61 x 10 19 n/cm 2 (E > 1.0 MeV) would occur at approximately 39.0, 39.9, or 40.9 EFPY, assuming the capsule was relocated to a 400 azimuthal location at the EOC 18, 19, or 20, respectively.

In summary, it is recommended that several of the Sequoyah Unit 1 remaining capsules be relocated to higher lead factor locations. One of these relocated capsules should be subsequently withdrawn from the reactor vessel and tested at the time when the accumulated neutron fluence of the capsule corresponds to not less than once or greater than twice the peak 60-year vessel fluence. Another relocated capsule could be used for future testing, if additional license extensions are sought. Table 5 summarizes the range of proposed removal times for the relocated capsules based on license extension out to 60 and 80 years of operation. These dates are based on the19capsule 2 fluence being equivalent to one times the peak vessel fluence at 60 years (2.66 x 10 2 n/cm ) as well as one times the peak vessel fluence at 80 years (3.61 x 1019 n/cm ).

Sequoyah Unit 2 Capsules T, U, X and Y in the Sequoyah Unit 2 reactor vessel were positioned at the 400 azimuthal location, and were considered to be radiologically equivalent. Similarly, Capsules W, V, S, and Z are currently located at the 40 azimuthal location in the Unit 1 reactor vessel, and are considered to be radiologically equivalent. Note that the 40 azimuthal location is a lag (less than one) factor location; therefore, at this time, the Sequoyah Unit 2 reactor vessel is being irradiated slightly faster than the remaining capsules. In order for Sequoyah Unit 2 to have meaningful metallurgical capsule data in the future, it is recommended that several of the remaining capsules be relocated to any of the empty 40' azimuthal capsule locations.

Capsule neutron fluence projections are summarized in Table 6 for the 4V and 40* azimuthal capsule locations at Sequoyah Unit 2.

The fluence values listed in Table 6 are used to determine neutron fluence projections assuming capsule relocation from a 4' to a 40' location beginning at end-of-cycles (EOC) 18, 19, and 20.

Table 7 summarizes the projected neutron fluence values for any of the remaining Sequoyah Unit 2 capsules assuming they are relocated from their 40 locations to any of the 400 locations at various relocation times.

Since Sequoyah Unit 2 is applying for a 20-year license extension, an additional capsule is expected to satisfy the same criteria as the EOL capsule, as described in ASTM El 85-73, with the EOL fluence at 60 years (52 EFPY). Therefore, a capsule should be withdrawn so that the 1019 capsule fluence corresponds to at least one times the 60-year EOL vessel fluence (2.57 x 2

n/cm , per Table 2-5 of Reference 3), but less than two times the 60-year EOL vessel fluence (5.14 x 1019 n/cm 2). Based on the fluence projections in Table 6, none of the remaining Sequoyah Unit 2 capsules, in their current azimuthal locations (40), would experience a neutron fluence of 2.57 x 1019 n/cm 2 prior to EOLE.

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 However, based on the fluence projections in Table 7, the peak 52 EFPY calculated vessel fluence of 2.57 x 1019 n/cm 2 (E > 1.0 MeV) would occur at approximately 32.6, 33.7, or 34.7 EFPY, assuming the capsule was relocated to a 40° azimuthal location at the EOCs 18, 19, or 20, respectively. Furthermore, based on the fluence projections in Table B.2-2, two times the peak 52 EFPY calculated vessel fluence of 5.14 x 1019 n/cm 2 (E > 1.0 MeV) would occur at approximately 52 EFPY for a relocated capsule, assuming the capsule was relocated at the EOCs 18, 19, or 20 to a 400 azimuthal location.

Additionally, it is anticipated at this time that if an additional 20-year license extension was sought, another capsule would be needed to be withdrawn from the reactor vessel in order to satisfy the same criteria as the EOL capsule with an EOL fluence at 80 years (72 EFPY). The extrapolated maximum neutron fluence value at 72 EFPY for Sequoyah Unit 2 is approximately 3.52 x 1019 n/cm 2 (E > 1.0 MeV). Based on the fluence projections in Table B.2-2, the peak 72 EFPY calculated vessel fluence of 3.52 x 1019 n/cm 2 (E > 1.0 MeV) would occur at approximately 39.3, 40.4 or 41.4 EFPY, assuming the capsule was relocated to a 400 azimuthal location at the EOC 18, 19, or 20, respectively.

In summary, it is recommended that several of the Sequoyah Unit 2 remaining capsules be relocated to higher lead factor locations. One of these relocated capsules should be subsequently withdrawn from the reactor vessel and tested at the time when the accumulated neutron fluence of the capsule corresponds to not less than once or greater than twice the peak 60-year vessel fluence. Another relocated capsule could be used for future testing, if additional license extensions are sought. Table 8 summarizes the range of proposed removal times for the relocated capsules based on license extension out to 60 and 80 years of operation. These dates are based on the capsule fluence being equivalent to one times the peak vessel fluence at 60 years (2.57 x 19101 n/cm2 ) as well as one times the peak vessel fluence at 80 years (3.52 x 1019 n/cm 2).

PTLR Considerations Surveillance capsule data from the first four capsules withdrawn from both units (T, U, X and Y) have been used in the development of heatup and cooldown pressure-temperature limits and Pressure-Temperature Limit Reports (PTLRs) for Sequoyah Units 1 and 2. Section 6.9.1.15 of the Technical Specifications for Sequoyah Units 1 and 2 references Westinghouse reports that are used in the development of the PTLRs. These include References 6 and 7, which document the development of the heatup and cooldown pressure-temperature limit curves for normal operation and PTLR support documentation. Appendix F of References 6 and 7 contains summaries of the updated surveillance capsule removal schedule for each unit. The summary table in Appendix F of References 6 and 7 lists the location and lead factor for each capsule, removal time and fluence for the four capsules (T, U, X, and Y) already withdrawn from each unit.

The current locations and lead factors for those locations are also listed for capsules S, V, W and Z. However, data from those capsules and locations are not used in the calculations for the current heatup and cooldown pressure-temperature limits. In support of plant life extension, TVA plans to update the PTLRs for each unit and data from at least two of the remaining surveillance capsules will be collected and analyzed for future modifications of the PTLRs to support operation during the license renewal period. However, no changes to the plant Technical Specifications or to the existing reports (References 6 and 7) are required to relocate any of the remaining surveillance capsules to locations of higher fluence in support of these future assessments.

Regulatory Considerations The guidance of 10 CFR 50 Appendix H does not require that capsule relocation be reported to or approved by the NRC. Nevertheless, by this letter, TVA has elected to inform the NRC of TVA's plans to relocate the surveillance capsules and to provide the proposed schedule for removing the capsules for analysis, in conjunction with TVA's application for License Renewal.

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 This letter serves to inform the NRC of the proposed withdrawal schedule for surveillance capsules in support of plant life extension, in accordance with 10 CFR 50 Appendix H, and provides the technical justification for the proposed withdrawal schedule. TVA has performed a 10 CFR 50.59 Screen for the proposed relocation of surveillance capsules and has concluded:

• The proposed surveillance capsule relocations and withdrawal schedules have no adverse effects on SSC design functions described in the UFSAR and no effect on procedures that affect the control or performance of any SSC design functions.

• There are no changes to methods of evaluation previously described in Section 5.4.3.7 of the UFSAR or the original reactor vessel radiation surveillance program as summarized in Reference 1 and 2.

Relocation of the surveillance capsules does not required any SSC to be utilized or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with analyses or descriptions in the UFSAR.

No changes to the plant Technical Specifications are required.

Therefore, TVA has concluded that relocation of the reactor vessel surveillance capsules at Sequoyah Units 1 and 2 screens out under 10 CFR 50.59, and that NRC approval is not required for the proposed change. The enclosed summary is being provided for information purposes in conjunction with TVA's application for license renewal and to satisfy the 10 CFR 50 Appendix H requirements for communicating and providing a technical justification for additional capsule withdrawals in support of plant life extension.

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 Table 1 Sequoyah Unit I Surveillance Capsule Withdrawal Summary (Reference 3)

Lead Factor(a) Withdrawal EFPY(b) Fluence(a)

Capsule Capsule Location (xl0 n/cm 2, E > 1.0 MeV) 19 T 400 3.15 1.07 0.241 U 1400 3.23 2.85 0.693 X 2200 3.22 5.26 1.16 Y 3200 3.18 10.02 1.97 S 40 0.90 (c) (c)

V 1760 0.90 (c) (c)

W 1840 0.90 (c) (c)

Z 3560 0.90 (c) (c)

Notes:

(a) Updated as part of the time-limited aging analyses (TLAA) fluence evaluation.

(b) EFPY from plant startup.

(c) Capsules S, V, W and Z are currently in the Sequoyah Unit I reactor vessel. Either Capsule S, V, W, or Z should be withdrawn so that the capsule fluence corresponds to at least one times the 60-year EOL vessel fluence (2.66 x 1019 n/cm 2), but less than two times the 60-year EOL vessel fluence (5.32 x 1019 n/cm 2). However, none of these remaining capsules are predicted to experience a neutron fluence of 2.66 x 1019 n/cm 2 prior to EOLE in their current locations; therefore, it is recommended to relocate several of these remaining capsules to higher lead factor locations in order to achieve higher capsule fluence data. Assuming a capsule was relocated at the end of cycle 18, 19, or 20, the EFPY that corresponds to the time when the capsule experiences the peak EOLE vessel fluence value (2.66 x 1019 n/cm 2) is approximately 32.5, 33.4, or 34.4 EFPY, respectively. See Appendix B for further details on capsule relocation recommendations.

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-1 2-89 October 31, 2012 Table 2 Sequoyah Unit 2 Surveillance Capsule Withdrawal Summary (Reference 3)

Withrawa EFP~b)Fluence(a)

Capsule Location Lead Factor(a) Withdrawal EFPY(b)/cE>.M Capsule (xl019 n/cm2 , E > 1.0 MeV)

T 400 3.11 1.07 0.244 U 1400 3.17 2.91 0.654 X 2200 3.18 5.36 1.16 Y 3200 3.15 10.55 2.02 S 40 0.94 (c) (c)

V 1760 0.94 (c) (c)

W 1840 0.94 (c) (c)

Z 3560 0.94 (c) (c)

Notes:

(a) Updated as part of the TLAA fluence evaluation.

(b) EFPY from plant startup.

(c) Capsules S, V, W and Z are currently in the Sequoyah Unit 2 reactor vessel. Either Capsule S, V, W, or Z should be withdrawn so that the capsule fluence corresponds to at least one times the 60-year EOL vessel fluence (2.57 x 1019 n/cm 2)' but less than two times the 60-year EOL vessel fluence (5.14 x 1019 n/cm 2)* However, none of these 2

remaining capsules are predicted to experience a neutron fluence of 2.57 x 10'9n/cm prior to EOLE in their current locations; therefore, it is recommended to relocate several of these remaining capsules to higher lead factor locations in order to achieve higher capsule fluence data. Assuming a capsule was relocated at the end of cycle 18, 19, or 20, the EFPY that corresponds to the time when the capsule experiences the peak EOLE vessel fluence value (2.57 x 1019 n/cm 2) is approximately 32.6, 33.7, or 34.7 EFPY, respectively. See Appendix B for further details on capsule relocation recommendations.

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 Table 3 Projected Neutron Fluence Values at the Geometric Center of the Surveillance Capsule Locations for.Sequoyah Unit 1 (Reference 3)

Capsule Fluence (xlO' 9 n/cm 2, E > 1.0 MeV) 40 Azimuthal 400 Azimuthal Location Location 18 22.14 1.14 4.02 19 23.47 1.20 4.21 20 24.80 1.25 4.41

--- 28.00 1.38 4.88

--- 32.00 1.54 5.46

--- 36.00 1.70 6.05

--- 40.00 1.87 6.64

--- 44.00 2.03 7.23 48.00 2.19 7.81 52.00 2.35 8.40

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-1 2-89 October 31, 2012 Table 4 Sequoyah Unit 1 Projected Capsule Neutron Fluence Values Associated With Capsule Relocation from the 40 to the 400 Azimuthal Location iReference 3)

Capsule Fluence Cycle EFPY (xlO' 9 n/cm 2, E > 1.0 MeV)

Relocation at the Relocation at the Relocation at the EOC 18 EOC 19 EOC 20 18 22.14 1.14 1.14 1.14 19 23.47 1.33 1.20 1.20 20 24.80 1.53 1.40 1.25 28.00 2.00 1.87 1.72 32.00 2.58 2.45 2.30

--- 36.00 3.17 3.04 2.89

--- 40.00 3.76 3.63 3.48

--- 44.00 4.35 4.22 4.07 48.00 4.93 4.80 4.65 52.00 5.52 5.39 5.24

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 Table 5 Sequoyah Unit I - Range of Proposed Capsule Withdrawal Times Associated With Capsule Relocation from the 40 to the 400 Azimuthal Location (Reference 3)

Life(a)

Capsule Time (EFPY) Corresponding to Vessel Capsule Relocation Time 60 Years of Operation 80 Years of Operation (52 EFPY) (72 EFPY)

EOC 18 32.5 39.0 EOC 19 33.4 39.9 EOC 20 34.4 40.9 Notes:

(a) These dates are based on the capsule fluence being equivalent to one times the peak vessel fluence at 60 years (2.66 x 1019 n/cm 2) as well as one times the peak vessel fluence at 80 years (3.61 x 1019 n/cm 2).

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 Table 6 Projected Neutron Fluence Values at the Geometric Center of the Surveillance Capsule Locations for Sequoyah Unit 2 (Reference 3)

Capsule Fluence (xl019 n/cm 2, E > 1.0 MeV) 40 Azimuthal 400 Azimuthal Location Location 18 22.97 1.18 3.91 19 24.34 1.24 4.13 20 25.70 1.30 4.32

--- 28.00 1.40 4.65

--- 32.00 1.58 5.22

--- 36.00 1.76 5.78

--- 40.00 1.94 6.35

--- 44.00 2.12 6.92

--- 48.00 2.30 7.48

--- 52.00 2.48 8.05

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 Table 7 Sequoyah Unit 2 Projected Capsule Neutron Fluence Values Associated With Capsule Relocation from the 40 to the 400 Azimuthal Location (Reference 3)

Capsule Fluence (xl019 n/cm 2, E > 1.0 MeV)

Cycle EFPY Relocation at the Relocation at the Relocation at the EOC 18 EOC 19 EOC 20 18 22.97 1.18 1.18 1.18 19 24.34 1.40 1.24 1.24 20 25.70 1.59 1.43 1.30

--- 28.00 1.92 1.76 1.62

--- 32.00 2.49 2.33 2.19

--- 36.00 3.05 2.89 2.75

--- 40.00 3.62 3.46 3.32

--- 44.00 4.19 4.03 3.89 48.00 4.75 4.59 4.45

--- 52.00 5.32 5.16 5.02

Westinghouse Non-Proprietary Class 3 Attachment 3 to Letter LTR-PL-12-89 October 31, 2012 Table 8 Sequoyah Unit 2 --Range of Proposed Capsule Withdrawal Times Associated With Capsule Relocation from the 40 to the 400 Azimuthal Location (Reference 3)

Capsule Relocation Capsule Time (EFPY) Corresponding to Vessel Life(a)

Time 60 Years of Operation 80 Years of Operation (52 EFPY) (72 EFPY)

EOC 18 32.6 39.3 EOC 19 33.7 40.4 EOC 20 34.7 41.4 Notes:

(a) These dates are based on the capsule fluence being equivalent to one times the peak vessel fluence at 60 years (2.57 x 1019 n/cm 2) as well as one times the peak vessel fluence at 80 years (3.52 x 1019 n/cm 2).