ML12053A332

License Renewal Commitment to Submit a Time Limiting Aging Analysis for the Reactor Vessel Internals to the NRC for Review

ML12053A332
Person / Time
Site:	Oconee, PROJ0728
Issue date:	02/20/2012
From:	Gillespie T Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC:10:099
Download: ML12053A332 (9)

Text

Dukle Duke T. PRESTON Vice PresidentGILLESPIE, JR.

• Energy, Oconee Nuclear Station Duke Energy ON01 VP / 7800 Rochester Hwy.

Seneca, SC 29672 864-873-4478 February 20, 2012 864-873-4208 fax T.Gillespie@duke-energy.corn U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 License Renewal Commitment to Submit a Time Limiting Aging Analysis for the Reactor Vessel Internals to the NRC for Review By letter to the NRC dated December 17, 1999, Duke Energy Carolinas, LLC (Duke Energy) committed to perform a plant-specific analysis and develop data to demonstrate that the reactor vessel internals will meet the deformation limits at expiration of the renewal license. The Enclosure provides the required information. This commitment is described in NUREG-1723, Safety Evaluation Report Related to the License Renewal of Oconee Nuclear Station, Units 1, 2, and 3, March 2000 (refer to page 4-24 of Section 4.2.5.3) as follows:

"The TLAA described as 'reduction in fracture toughness' is related to the acceptability of the reactor vessel internals under LOCA and seismic loading. BAW-2248 states that Appendix E to BAW-10008, Part 1, Revision 1, 'Reactor Internals Stress & Deflection Due to LOCA & Max Hypothetical Earthquake,' concludes 'that at the end of 40 years, the internals will have adequate ductility to absorb local strain at the regions of maximum stress intensity, and that irradiation will not adversely affect deformation limits.' BAW also states that this TLAA will be resolved on a plant-specific basis per 10 CFR 54.21 (c)(1)(iii) based on results and conclusions of the planned B&WOG RVIAMP. Duke has stated that appropriate action will be taken in a timely manner to ensure continued validity of the design of the ONS reactor vessel internals. Plant-specific analysis is required to demonstrate that, under LOCA and seismic loading and irradiation accumulated at the expiration of the period of extended operation, the internals have adequate ductility to absorb local strain at the region of maximum stress intensity and will meet the deformation limits. The applicant must provide a plan to develop data to demonstrate that the internals will meet the deformation limits through the period of extended operation. This was identified as Open Item 4.2.5.3-1 in the June 16, 1999, SER. Subsequently, in a letter dated December 17, 1999, Duke committed to perform the plant-specific analysis and develop data to demonstrate that the internals will meet the deformation limits at the expiration of the renewal license. The Staff has determined this program will adequately manage the irradiation aging effects in accordance with 10 CFR 54.21 (c)(1)9iii). Thus, Open Item 4.2.5.3-1 is closed."

As part of Oconee Nuclear Stations' participation as a beta plant for MRP-227, Electric Power Research Institute (EPRI) contracted AREVA to update BAW-1 0008, Part 1, Revision 1 The enclosure to this letter contains proprietary information.

Withhold From Public Disclosure Under 10 CFR 2.390. A-Up o n re m o va l o f th e e n clo s u re s , th is lette r is u n co ntro lled . w wd k - n r y c www. duke-energy, corn

The enclosure to this letter contains proprietary information.

Withhold From Public Disclosure Under 10 CFR 2.390.

Upon removal of the enclosures, this letter is uncontrolled.

U.S. Nuclear Regulatory Commission February 20, 2012 Page 2 generically for B&W designed internals for 60 years. EPRI submitted the non-proprietary version of the update to BAW-10008, Part 1, Revision 1, as part of an RAI response to MRP-227. AREVA submitted the proprietary version to the NRC by letter dated October 29, 2010. However, the NRC declined to review the updated version citing site-specific reviews as an alternative. AREVA Document No. 51-9038244-002 titled "Update of Irradiation Embrittlement in BAW-1 0008 Part 1 Rev. 1" was the Proprietary version AREVA sent to the NRC. AREVA Document No. 47-9048125-002 is the non-proprietary version. The proprietary and non-proprietary versions, along with the AREVA letter to the NRC that accompanied the proprietary version, are contained in enclosed Duke Energy Calculation OSC-10237. This calculation provides the plant-specific analysis and data to demonstrate that the internals will meet the deformation limits at the expiration of the renewal license and fulfills the commitment made in Duke Energy letter to the NRC dated December 17, 1999 and restated in the ONS Safety Evaluation Report for License Renewal.

AREVA Document No. 51-9038244-002 is classified by AREVA NP as proprietary. The appropriate affidavit from AREVA NP was provided in the AREVA letter to the NRC dated October 29, 2010, in accordance with the provisions of 10 CFR 2.390. As such, Duke Energy considers the enclosed calculation, which contains the AREVA document, proprietary and requests it be withheld from public disclosure.

There are no additional regulatory commitments associated with this submittal. Inquiries on this submittal should be directed to Boyd Shingleton, Oconee Regulatory Compliance Group, (864) 873-4716.

Sincerely, T. Preston Gillespie, Jr.

Vice President Oconee Nuclear Station

Enclosure:

ONS Calculation OSC-10237

The enclosure to this letter contains proprietary information.

Withhold From Public Disclosure Under 10 CFR 2.390.

Upon removal of the enclosures, this letter is uncontrolled.

U.S. Nuclear Regulatory Commission February 20, 2012 Page 3 cc w/ enclosure:

Mr. Victor McCree, Regional Administrator U. S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. John Stang, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555 Mr. Andy Sabisch Senior Resident Inspector Oconee Nuclear Site Ms. Susan E. Jenkins, Manager Radioactive & Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201

ARE VA October 29, 2010 NRC:A0:099 Document Control: Desk U.S. Nuclear: Regulatory Commission Washington, D.C. 20555-0001.

Information In Support of the EPRI MaterialsReliability Program (MRP): Pressurized Water ReactorInternals Inspection and Evaluation:Guidelines (MPR-227-Rev. 0) Review AREVA NP Inc. (AREVA) is hereby :providing :the:enclosed Engineering Information' Record, Document Number 51-9038244-002, entitled "Update of Irradiation Embrittlement in: BAW-1:0008 Part 1 Rev. 1" to the NRC for information. This document is provided to:the NRC in support of the EPRI Materials Reliability Program: Pressurized Water Reactor Internals.

Inspection and: Evaluation:Guidelihes ::(MPR-227-Rev. O) review. This document demonstrates:

that for the irradiation levels at the: end of 60-year lifetime, there will be adequate ductility at operating temperature to absorb local strains at the regions of maximum stress intensity and that irradiation will not adverselyvaffect:deform:ation::limnits.:

This document is being submitted: for information only. No safety evaluation (SE): is expected and therefore, no review fees should be Incurred.

The non-proprietary report, AREVA Document Number 47-9048125-002, is being provided underza separate submittal through the EPRI MRP.

AREVA:considers some of the material :contained in the enclosed document to be proprietary.

AS requir.ed by410 CFR 2390(b), an affidavit:is :enclosed to :support the withholding of the information:from public disclosure.

Ifyou have: any:questions related to this submittal, please contact: Ms. GayleaElliott, Product Licensing Manager. She may be reached :by telephone at 434-832-3347,: or by e-mall at payle.eiliott(,areva.com.

Sincerely, 4

Ronnie L. Gardner, Manager Corporate Regulatory Affairs AREVAXNP Inc.

Enclosure cc: H. D. Cruz Project 728.

AREVA NP INC.

An ARLVAna d Siemensýearom any._ ........ _.__...._.._.._....._.__._...

3315-Old Forest Road, P.O. Box 10935, Lynchburg, VA 24506-0935 Tel.: 434 832 3000 - www areva."om Pje / of .5

bo~o: NRC:iO:Og9

. . Ji BLiryziyI M.

M, JI Doyan jm 9 t~a-/

S. Fyfito;ý R. L.. Ga'rdner A. B. NMeginnia

0. L Pannell M. A. Ri".kel

8. M. Sloan H. Xu

[4 3/4

[4 vs 4

I 3/4 I 'Of 5

AFF:F:I1D A VIT COMMONWEALTH OF VIRGINIA

) ss.

CITY OF LYNCHBURG 1, Myname IstGayle:F. Elliott. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to:execute this.Affidavit.

2. Iamn familiar with the criteria applied by AREVANPtodeterminewhether certain AREVA:NP:informiation: is poprietary. I am familiar with the policies established by:

AREVA NP to ensure1the proper application of these criteria. F

3. 1am familiar with the AREVA NP Engineering Information: Record, Document Number 51-9038244, Revision 002,: entitled "Update of Irradiation Embrittlement in BAW-10008 Part I Rev. V," dated October:2010 and referred to herein as "Document."

Information contained in this: Document has been ciassified by:AREVA NP as proprietary in accordance:with the policies: established by AREVA:NP for:the control and protection of proprietary: and 'confidential Information.

4. This Document contains: Information of a proprietary and confidential :nature and is: of the type customarily held in confidence by AREVA NP and not made available to the public :Based on: my:experience, I am aware that other companies. regard Information of the kind contalned In this Document :as proprietary and confidential.

5. This Document. has been made available.to the: U.S. Nuclear RegulatoryT Commission: in confidence with the request that the information: contained: in,this Document be withheld from public disclosure. The request for withholding of proprietary information: is made in, accordance:with 10 CFR 2.390. The Informationjfor which withholding from disclosure is Pk7 r 3 al

I requested .qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial.

information.'

6. The following criteria are customarily applled by AREVA NP to determine.

whether: Information.0should be classified as proprietary:

(a)! The. information reveals details of AREVA NP's research anddevelopment plans and programs or thelr results.

(b): Use of the information:by a competitor would permit the competitor to significantly redUce its:expenditures,, In: time

.or resources, toý design, produce, or market a similar product or. service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results:in a competitive: advantage for AREVA NP.

(d)ý The Information reveals: certain distinguishing: aspects: ofa process, j:I methodology, or component,Athe exclusive use of which provides. a competitive advantage: for AREVA NP in product optimization Or marketability.:I (e) The Information Is: vital to a competitive. advantage: held by AREVA. NP,: Would be ýhelpful to competitors to AREVA NP,:and would likely cause substantial harm to the competitivle position: of AREVA NP; The information in the Document Isconsidered proprietary for the reasons set:forth In paragraphs 6(b) and 6(c) above.

7. Inmaccordance with AREVA NP's policies governing the protection and control of Information, proprletary information contained In: this Document have been. made available, on a limited basis, to othems outside AREVA NP only as required. and under suitable agreement providing for nondisclosure and limited use of the information.

8. :AREVA NPpollicy requires: thatlproprietary Information be kept In asecured file or: area aniddistributed on a need-to-know. basis.

I

$Paf

6

9. The foregoing statements are true and correct to the: best of my knowledge, Information, and bellef.

SUBSORIBE0 before nme thlsc;-

day of i ~ .210.

Kathleen Ann Bennett NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MYCOMMISSION EXPIRES: 8/31/111 Reg. #110864 I-INAjefw AJcc Wo 0 t: ibrow I

-I 5aE "o f'