ML18302A121

Response to Request for Additional Information, Revised Reactor Vessel Materials Surveillance Capsule Withdrawal Schedules

ML18302A121
Person / Time
Site:	Surry
Issue date:	10/18/2018
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
18-098B
Download: ML18302A121 (13)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 October 18, 2018 10 CFR 50 Appendix H U.S. Nuclear Regulatory Commission. Serial No.: 18-0988 Attention: Document Control Desk NRA/GDM: R1 Washington, DC 20555-0001 Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)

SURRY POWER STATION UNITS 1 AND 2 .

REVISED REACTOR VESSEL MATERIALS SURVEILLANCE CAPSULE WITHDRAWAL SCHEDULES RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated July 28, 2017, Serial No.17-243 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17213A080), as supplemented by letters dated March 19, 2018, Serial No.18-098 (ADAMS Accession No. ML18085A159), and June 5, 2018, Serial No. 18-098A (ADAMS Accession No. ML18162A099), Dominion Energy Virginia requested revision of the reactor vessel materials surveillance capsule withdrawal schedules for Surry Power Station (Surry)

Units 1 and 2 in accordance with Title 10 of the Code of Federal Regulations (10 CFR)

Part 50, Appendix H, "Reactor Vessel Material Surveillance Program Requirements,"

Section 111.B.3. The proposed withdrawal schedules address revisions to the surveillance capsule withdrawal schedules approved for the 40 to 60-year period of extended operation.

The U.S. Nuclear Regulatory Commission (NRG) staff has reviewed the information provided in these letters and determined that additional information is required to complete its review. On September 27, 2018, the NRG Surry Project Manager provided a request for additional information (RAI) to facilitate staff review of the submittal.

Dominion Energy Virginia's response to the RAI is provided in the attachment.

Should you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Commitments made in this letter: None

Serial Number 18-0988 Docket Nos. 50-280/281 Page 2 of 2

Attachment:

Response to NRC Request for Additional Information, Revised Reactor Vessel Materials Surveillance Capsule Withdrawal Schedules Enclosure to

Attachment:

Westinghouse Letter LTR-SDA-18-093, Rev. 0, dated October 3, 2018, entitled "ASTM E185 Edition Applicable to Surry Units 1 and 2" cc: U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station Ms. A. Schiller NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North

• Mail Stop 07 E5 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. J. R. Hall NRC Senior Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 81A 11555 Rockville Pike Rockville, MD 20852-2738

Serial Number 18-0988 Docket Nos. 50-280/281 Attachment RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REVISED REACTOR VESSEL MATERIALS SURVEILLANCE CAPSULE WITHDRAWAL SCHEDULES Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Power Station Units 1 and 2

Serial Number 18-0988 Docket Nos. 50-280/281 Attachment RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAil REVISED REACTOR VESSEL MATERIALS SURVEILLANCE CAPSULE WITHDRAWAL SCHEDULES SURRY POWER STATION UNITS 1 AND 2 By letter dated July 28, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17213A080), as supplemented by letters dated March 19, 2018 (ADAMS Accession No. ML16085A159), and June 5, 2018 (ADAMS Accession No. ML18162A099), Virginia Electric and Power Company (Dominion Energy Virginia) requested revision of the reactor vessel materials surveillance capsule withdrawal schedules for Surry Power Station (Surry) Units 1 and 2 in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H, "Reactor Vessel Material Surveillance Program Requirements," Section 111.B.3. The proposed withdrawal schedules address revisions to the surveillance capsule withdrawal schedules approved for the 40 to 60:-year period of extended operation.

The U.S. Nuclear Regulatory Commission (NRG) staff has reviewed the information provided in these letters and determined that additional information is required to complete its review. On September 27, 2018, the NRG Surry Project Manager provided a request for additional information (RAI) to facilitate staff review of the submittal.

• The NRG RAI and the Dominion Energy Virginia response are provided below.

NRC Request for Additional Information In its request, the licensee stated that the proposed withdrawal schedule conforms to AS TM Standard E-185-82, "Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels," as required by 10 CFR Part 50, Appendix H. Changes that do not conform to the ASTM standard referenced in Appendix H (ASTM E-185- 82) will require approval by the license amendment process.

1. Please describe in detail how the proposed capsule withdrawal* schedule is in conformance with ASTM E-185-82 requirements for both Unit 1 and Unit 2.

2. Based on the submittal for Unit 2, it appears that capsule W has been withdrawn but has not been tested. If the capsule has been tested, please provide the capsule test report, and describe in detail how the status of capsule W affects the conformance of the proposed withdrawal schedule with ASTM E-185-82.

For each request above, please explain *the original design and licensing basis requirements and how 10 CFR 50, Appendix H is met for each unit including any voluntary changes that have been incorporated up to ASTM E 185-82. '

Page 1 of 7

Serial Number 18-098B Docket Nos. 50-280/281 Attachment NRC RAI # 1 - Please describe in detail how the proposed capsule withdrawal schedule is in conformance with ASTM E-185-82 requirements for both Unit 1 and Unit 2.

Dominion Energy Virginia Response to NRC RAI # 1 The Surry Units 1 and 2 Reactor Vessel Materials Surveillance Program (RVMSP) was developed by Westinghouse Electric Company (Westinghouse) prior to issuance of 10 CFR 50, Appendix H, (Reactor Vessel Materials Surveillance Program Requirements) and consists of two elements. The first element is related to the number of capsules, location of capsules, and specimen content, and the second element is related to the capsule test methods and testing schedule.

For the first element, Westinghouse documented the design considerations in WCAP-7723 (Reference 1) and WCAP-8085 (Reference 2) for Surry Units 1 and 2, respectively. WCAP-8085 states that the Unit 2 RVMSP meets ASTM E 185-70.

WCAP-7723 does not include a reference to a specific ASTM E 185 version; however, based on the date of issuance of WCAP-7723 (1971 ), the Surry Unit 1 program was developed to meet either ASTM E 185-66 or 70. (See Enclosure.)

Subsequent to initial plant licensing of Surry Unit 1 (May 5, 1972) and Surry Unit 2 (January 29, 1973), on July 17, 1973, the Atomic Energy Commission (AEC) published in the Federal Register amendments to its regulations in 10 CFR 50 to add Appendices G and H effective August 16, 1973 (Reference 3). Prior to the time of Surry plant licensing, testing method requirements had not been mandated by the NRC through a particular version of ASTM E 185. When a capsule was removed from the reactor vessel, it was customary at the time to document the version of ASTM E 185 used for testing. As a result, many of the early surveillance capsule testing reports simply stated that the program meets ASTM E 185-73. The NRC amended 10 CFR 50, Appendix H, again in 1983 to endorse ASTM E 185-73, -79, and -82 (Reference 4). Following NRC endorsement of ASTM E 185-82 in 10 CFR 50, Appendix H, surveillance capsule testing reports began to state that the program met ASTM E 185-82. Some of the surveillance capsule reports, but not all, included information on the withdrawal schedule. The formal surveillance capsule withdrawal schedule contained in the Updated Final Safety Analysis Report (UFSAR) requires NRC approval for any change.

Currently, 10 CFR 50, Appendix H, states:

"The design of the surveillance program and the withdrawal schedule must meet the requirements of the edition of ASTM E 185 that is current on the issue date of the ASME Code to which the reactor vessel was purchased. Later editions of ASTM E 185 may be used, but including only those editions through 1982. For each capsule withdrawal, the test procedures and reporting requirements must meet the requirements of ASTM E 185-82 to the extent practicable for the configuration of the specimens in the capsule."

Page 2 of 7

Serial Number 18-0988 Docket Nos. 50-280/281 Attachment The Surry reactor vessels were purchased to the 1968 ASME Code. Since ASTM E 185-66 was current on the issue date of the 1968 ASME Code, versions of ASTM E 185 from the 1966 version to the 1982 version are allowable for the design of the Surry RVMSP and withdrawal schedule. As previously stated, ASTM E 185-66 and 70 are the versions applicable to the initial design of the Surry Units 1 and 2 surveillance programs.

A review of ASTM E 185-66 and 70 indicates that three surveillance capsules were required for the design of each unit's RVMSP. However, even though ASTM E 185-66 and 70 only required three surveillance capsules, the Surry RVMSP originally consisted of eight capsules in each reactor vessel. While not a regulatory commitment, capsule W1, which included materials for Unit 1 and Unit 2, was installed into Unit 2 in 1991 to proactively participate in the Master Integrated Reactor Vessel Materials Surveillance Program. Capsule Wt was removed and tested in. 1997, and information pertaining to capsule W1 is included in BAW-2350-P (Reference 5).

To date, for testing and schedule considerations, the NRG has approved three ASTM E 185 editions: 73, 79, and 82. Currently, the Surry Units 1 and 2 RVMSP complies with ASTM E 185-82 for testing and scheduling. It is important to note that the schedule outlined in ASTM E 185-82 applies to a "design life of 32 EFPY" (i.e., a 40-year lifetime).

Table 1 of ASTM E 185-82 includes a shift consideration relative to the surveillance capsule withdrawal schedule.

~IIJb E 185 TABLE 1 Minimum Recommended Number of Surveilla~ Capsules and Their Withdrawal Schedule (Schedule in

• Tenns of Effecti,e FuD-Power Years ofilte Reactor Vessel) *

• Predicted. Transition Temperature Shift at Vessel Inside Surface

> 56°C (> I00°F)

s S6°C (:s I00°F)  ::$_ 111°c (:!:: 200°P) > I 11°C (> 200°F)

Minimun Number of Capsules 3 4 s Withdrawal Sequence:

First Second Third Fourth Fifth A Or at the lime when the accumulated neutron fluent.: of the capsule exceeds 5 x Ur n/m1 (S x L0111 n/cm2), or al 1he time when the highest predicted llRTr11rr of all encapsulated materials is approximately 28°C {S0°F). whichever oomes first.

8 9r at 1he time when the accumulated neutron fluence of the cap,ule corresponds 10 lhe approximate EOL fluence at the rcaclor vesi;cl inner wall location, whichever CQmes first.

<> Or at the lime when the accumulated neulron fluence of the capsule corresponds to the approximate EOL. fluence at the reactor vessel % T location, whichever comes first.

0 Or at lhc time when tile accumulated neutron fiuence of the capsule corresponds to a value midway between that of the rust and tWrd capsules.

8 Not less than once or greater than twice the peak EOL vessel fluence. Thfu may be modified on the basis of previous tests. This capsule may be held wilhout testing following withdrawal.

Page 3 of 7

Serial Number 18-0988 Docket Nos. 50-280/281 Attachment A review of the* shift data for the Surry capsules withdrawn to date indicate the shift is greater than 200°F for Unit 1 and less than 200°F for Unit 2 when considering credible surveillance capsule data as documented in WCAP-18242-NP, Rev. 2, Tables 4-1 and 4-2, respectively (Reference 6). Therefore, it is our understanding that to meet ASTM E 185-82 requirements, the Unit 1 RVMSP should include a minimum of five capsules, and the Unit 2 RVMSP should include a minimum of four capsules.

Table B2.1.19-1, Surveillance Capsule Withdraw Schedule for Unit 1, included in the Surry Subsequent License Renewal (SLR) submittal (Reference 7) indicates the Unit 1 program includes two standby capsules (S and U). Thus, of the eight original capsules, two are standby capsules, four capsules (T, W, V, and X) have. been withdrawn for testing and/or dosimetry measurement, and one is scheduled to be removed in 2027 (Capsule Z). Capsule Y is identified for removal during the SLR period.

Table B2.1.19-2, Surveillance Capsule Withdraw Schedule for Unit 2, included in the Surry SLR submittal indicates the Unit 2 program includes one standby capsule (Z).

Thus, of the eight original capsules, one is a standby capsule, five capsules (X, W, V, Y, and S) have been withdrawn for testing and/or dosimetry measurement, and one capsule is scheduled to be removed in 2032 (capsule U). Capsule T is identified for removal during the SLR period.

Therefore, the stipulation in ASTM E 185-82 to test five capsules in Unit 1 and four capsules in Unit 2 based upon the predicted transition temperature shift is satisfied.

Note that ASTM E 185-82 also addresses additional factors that can affect the surveillance capsule withdrawal schedule:

1) Cycle specific core loading patterns,

2) Changes in operating cycle durations,

3) New cross sectional library parameters issued by the national laboratories, and

4) Asset management objectives affecting the lifetime.

Footnote B of ASTM E 185-82 states that the second to last capsule should be withdrawn at 15 EFPY:

"Or at a time when the accumulated neutron fluence of the capsule corresponds to the approximate end of life fluence at the reactor vessel inner wall location, whichever comes first."

Footnote E of ASTM E 185-82 states that the final capsule should be withdrawn:

Page 4 of 7

Serial Number 18-0988 Docket Nos. 50-280/281 Attachment "Not less than once or greater than twice the peak [end-of-life ] EOL vessel fluence. This may be modified on the basis of previous tests. This capsule may be held without testing following withdrawal."

Since original plant licensing, the peak EOL of the vessel has been increased from 40 to 60 years. For SLR, the plant life will be extended from 60 to 80 years.

Per ASTM E 185-82, the second from last capsule is recommended to be removed at 15 EFPY or when the fluence is approximately equal to the end of life fluence. This provision and Footnote B were satisfied for the 4Q-year lifetime when Unit 1 Capsule X was removed at 16.3 EFPY 1 (Reference 8), and Unit 2 Capsule Y was removed at 20.3 EFPY (Reference 9).

Footnote E stipulates that one capsule must remain in the vessel for fluence monitoring provided the fluence of the capsule is .between one and two times the projected peak vessel fluence when the capsule is withdrawn. Each unit will withdraw and test a capsule with capsule fluence between one and two times the projected peak vessel fluence.

Additionally, Unit 1 has two standby capsules to satisfy fluence monitoring, and Unit 2 has one standby capsule to satisfy fluence monitoring. Therefore the stipulation in ASTM E 185-82 under footnote. E is satisfied.

Because both units' vessels include standby capsules for fluence monitoring, the existing RVMSPs satisfy ASTM E 185-82 for the 60-year and 80-year life. While footnote E indicates that a capsule with fluence between once and twice the end of license fluence may be held without ,testing, Dominion Energy Virginia has elected to test capsules with this amount of fluence for asset management considerations to provide early confirmation that reactor vessel material properties will continue to meet reactor vessel integrity objectives throughput the lifetime of the units. Specifically, Dominion Energy Virginia plans to withdraw and test the capsules which satisfy the 60-year end of license requirement when the fluence on the capsules is slightly greater than the 80-year peak vessel fluence, and withdraw the capsules which satisfy the 80-year end of license .

requirement when the fluence on the capsules is slightly greater than the 100-year peak vessel fluence.

For Unit 1, Capsule Z is being withdrawn in 2027 (when the capsule reaches 6:41E19 n/cm2). The peak 60-year EOL vessel fluence is 4.57E19 n/cm 2 . The peak 80-year EOL vessel fluence is 6.35E19 n/cm 2 . This fluence value (in 2027) is greater than the vessel peak fluence. at 60 years, and is also below twice the 60-year RV peak fluence, which supports the current 60-year license (48 EFPY), and therefore also satisfies the existing license requirement for surveillance capsule withdrawal and testing.

Capsule Y is also being withdrawn during the SLR period. Capsule Y will be withdrawn in 2044 when the projected fluence on the capsule is 8.14E19 n/cm 2 , which is greater than once but not greater than twice the peak 80-year EOL vessel fluence.

1 Per UFSAR Table 4.1-12, Capsule X was withdrawn at 16.3 EFPY. However, the EFPY values were reviewed and amended in support of Surry SLR. Per WCAP-18243, Revision 2, Capsule X was withdrawn at 16.1 EFPY.

Page 5 of 7

Serial Number 18-0988 Docket Nos. 50-280/281 Attachment For Unit 2, Capsule U is being withdrawn in 2032 (when the capsule reaches 7.31E19 n/cm2). The peak 60-year EOL vessel fluence is 5.01E19 n/cm 2 . The peak 80-year EOL vessel fluence is 7.26E19 n/cm 2 . This fluence value (in 2032) is greater than the vessel peak fluence at 60 years and is also below twice the 60-year RV peak fluence to support the current 60-year license (48 EFPY), and therefore also satisfies the existing license requirement for surveillance capsule withdrawal and testing. Capsule T is also being tested during the SLR period. Capsule Y will be withdrawn in 2047 when the projected fluence on the capsule is 9.66E19 n/cm 2 , which is greater than once but not greater than twice the peak 80-year EOL fluence.

The schedules for Unit 1 and Unit 2 discussed above satisfy the considerations outlined in Footnote B of ASTM E 185-82 for 60-year and 80-year vessel life.

The proposed UFSAR surveillance capsule withdrawal schedules are in compliance with ASTM E 185-82, including th,e stipulations in ASTM E185-82, Footnotes B and E, pertaining to testing of the second to last and last capsules. In addition, at least one standby capsule is available in both Units 1 and 2 to conduct in-vessel fluence monitoring throughout the 80-year lifetime.

It is also noted the NRG determined the Surry withdrawal schedules "were prepared in accordance with ASTM Standard E 185-82" as a part of BAW-1543(NP), Revision 4, Supplement 5-A (Reference 9), and the new capsule withdrawal schedules proposed by Dominion Energy Virginia provide more future capsule withdrawals than the number approved in BAW-1543(NP), Revision 4, Supplement 5-A, Table VIII, for compliance with ASTM E 185-82.

NRC RAI # 2 - Based on the submittal for Unit 2, it appears that capsule W has been withdrawn but has not been tested. If the capsule has been tested, please provide the capsule test report, and describe in detail how the status of capsule W affects the conformance of the proposed withdrawal schedule with ASTM E-185-82.

Dominion Energy Response to RAI #2 Unit 2 Capsule W was removed to measure dosimetry. The specimens have not been tested per ASTM E 185. Capsule W was withdrawn in 1979 prior to .issuance of 10 CFR 50, Appendix G, on May 27, 1983. BAW-1543(NP), Revision 4, Supplement 5-A (Reference 9), discusses Capsule W. Note 5 in the Table entitled, "Status of Westinghouse Plant-Specific Surveillance Capsules," indicates "DOSIMETRY". The design of the capsule program for Surry Unit 2 is stated in WCAP-8085, which refers to ASTM E 185-70. ASTM E 185-70 required three capsules to be tested over the lifetime of the plant. Five capsules (X, W, V, Y, and S) have been withdrawn to date, not including capsule W1. Mechanical and dosimetry testing was completed on three capsules (X, V, and Y), while dosimetry was measured for Capsules W and S. NRC Page 6 of 7

Serial Number 18-0988 Docket Nos. 50-280/281 Attachment approval of BAW-1543(NP) confirmed the withdrawal schedule conforms to ASTM E 185-82 despite only having dosimetry tested for certain capsules. Capsules U (2032) and T (2047) are scheduled to be withdrawn in the future. The number of capsules in the Surry Unit 2 surveillance capsule program exceeds the requirement for testing four capsules due to the predicted transition temperature shift being less than 200°F, as discussed in the response to Question No. 1 above. *

References:

1. WCAP-7723, "Virginia Electric and Power Co., Surry Unit No. 1 Reactor Vessel Radiation Surveillance Program," July 1971.

2. WCAP-8085, "Virginia Electric and Power Co., Surry Unit No. 2 Reactor Vessel Radiation Surveillance Program," June 1973.

3. Federal Register, Volume 38, No. 136 (19012), July 17, 1973.

4. FederalRegister, Volume 48, No. 104 (24001), May 27, 1983.

5. BAW-2350-P, "Test Results of W1 Capsule B&W Owners Group - Master Integrated Reactor Vessel Surveillance Program," April 1999.

6. WCAP-18242-NP Revision 2, "Surry Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity for Subsequent License Renewal," July 2018.

7. Letter from Virginia Electric and Power Company to USNRC dated October 16, 2018, Serial No.18-340, "Virginia Electric and Power Company, Surry Power Station Units 1 and 2, Application for Subsequent Renewed Operating Licenses."

8. WCAP-18243-NP Revision 2, "Surry Units 1 and 2 Heatup and Cooldown Limit Curves for Normal Operation," July 2018.

9. BAW-1543(NP), Revision 4, Supplement 5-A, Supplement to the Master Integrated Reactor Vessel Surveillance Program, May 2005. (ADAMS Accession No. ML052300219)

Page 7 of 7

Serial Number 18-098B Docket Nos. 50-280/281 Attachment Enclosure WESTINGHOUSE LETTER LTR-SDA-18-093, REV 0, DATED OCTOBER 3, 2018, ENTITLED "ASTM E185 EDITIONS APPLICABLE TO SURRY UNITS 1 AND 2" Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Power Station Units 1 and 2

Westinghouse Non-Proprietary Class 3

@Westinghouse To: Charles Tomes, Dominion Energy Date: October 3, 2018 cc: Thomas Zalewski From: Benjamin E. Mays Phone: ( 412) 342-1793 Our ref: LTR-SDA-18-093, Rev. 0

Subject:

ASTM E185 Editions Applicable to Surry Units 1 and 2

References:

1. ASTM E185-66, "Recommended Practice for Surveillance Tests on Structural Materials in Nuclear Reactors," dated 1966.

2. ASTM E185-70, "Standard Recommended Practice for Surveillance Tests for Nuclear Reactor Vessels," effective July 15, 1970.

3. Westinghouse Report WCAP-7723, Revision 0, "Virginia Electric and Power Co. Surry Unit No. 1 Reactor Vessel Radiation Surveillance Program," dated July 1971.

4. Westinghouse Report WCAP-8085, Revision 0, "Virginia Electric & Power Co. Surry Unit No. 2 Reactor Vessel Radiation Surveillance Program," dated June 1973.

5. Code of Federal Regulations 10 CFR 50, Appendix H, "Reactor Vessel Material Surveillance Program Requirements," Federal Register, Volume 60, No. 243, dated December 19, 1995.

6. Westinghouse Report WCAP-18242-NP, Revision 2, "Surry Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity for Subsequent License Renewal," dated July 2018.

After completing a review of relevant documentation, it is determined that the Surry Unit 1 surveillance capsule program was most likely designed to the American Society for Testing and Materials (ASTM) E185-66 [Ref. 1] standard, and the Surry Unit 2 surveillance capsule program was designed to the ASTM E185-70 [Ref. 2] standard. The relevant documentation which was reviewed included surveillance capsule reports, certified material test reports, shop order files, engineering drawings, mechanical test results, fabrication records, and other miscellaneous documentation, as available.

For Surry Unit 1, no documentation was identified that directly referenced the 1966 version of the standard. However, the vast majority of the original documentation relevant to the Surry Unit 1 surveillance program is dated in the late 1960's or early 1970 (prior to release of ASTM E185-70); thus, it is unlikely that the 1970 version (the first version released after 1966) was utilized in development of the program. For example, drawings indicating how the surveillance material would be cut and machined into specimens exist that pre-date ASTM El 85-70. Thus, significant design decisions for the surveillance program, such as which materials would be used and how many specimens would be machined, were very likely to have been made prior to the existence of ASTM E185-70. Based on the date of WCAP-7723 [Ref. 3], the Surry Unit 1 radiation surveillance program baseline report, the program would have necessarily been designed to the ASTM E185-66 or E185-70 standard. However, ASTM E185-66 and ASTM E185-70 both require a minimum of three surveillance capsules.

For Surry Unit 2, WCAP-8085 [Ref. 4], the Surry Unit 2 radiation surveillance program baseline report, specifically cites the 1970 version of the ASTM E185 standard. Additionally, the dates of relevant original documentation (late 1960's and early 1970's) support that the 1970 version of the standard was most likely utilized. It is possible that the program was originally intended to be designed to the 1966 edition; however, by the time the program was completed the ASTM E185-70 version was cited as the edition ofrecord.

© 2018 Westinghouse Electric Company LLC All Rights Reserved

Westinghouse Non-Proprietary Class 3

_, LTR-SDA-18-093, Rev. 0 Attachment A Page 2 of2 October 3, 2018 It is noted that per 10 CFR 50, Appendix H [Ref. 5]:

The design of the surveillance program and the withdrawal schedule must meet the requirements of the edition of ASTM E 185 that is current on the issue date of the ASME Code to which the reactor vessel was purchased. Later editions of ASTM E 185 may be. used, but including only those editions through 1982. For each capsule withdrawal, the test procedures and reporting requirements must meet the requirements ofASTM E 185-82 to the extent practicable/or the configuration ofthe specimens in the capsule.

The Surry Units 1 and 2 reactor vessels were purchased to the Winter 1968 Edition of the ASME Code. The 1966 version of ASTM E185 was current on the issue date of the Winter 1968 edition of the ASME Code. Thus, per 10 CFR 50, Appendix H, the Surry Units 1 and 2 surveillance program withdrawal schedules may meet the requirements of any version of the ASTM E185 standard from the 1966 version through the 1982 version.

Additionally, per WCAP-18242-NP [Ref. 6] Westinghouse confirms that Surry Unit 1 Capsule Y should be withdrawn at the vessel refueling outage nearest to but following 60 effective full-power years (EFPY) of plant operation (estimated to occur in 2044), which is when the fluence on the capsule will have reached at least the projected 100-year (88 EFPY) peak vessel fluence (8.12 x 10 19 n/cm2). Also per WCAP-18242-NP [Ref. 6] Westinghouse confirms that Surry Unit 2 Capsule T should be withdrawn at the vessel refueling outage nearest to but following 63 EFPY of plant operation (estimated to occur in 2047), which is when the fluence on the capsule will have reached at least the projected 100-year (88 EFPY) peak vessel fluence (9.51 x 10 19 n/cm2).

If you have any questions, please _contact the undersigned.

Electronically Approved1 Electronically Approved1 Benjamin E. Mays Reviewed: D. Brett Lynch Structural Design & Analysis III Structural Design & Analysis III Electronically Approved1 Approved: Lynn A. Patterson, Manager Structural Design & Analysis III 1

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