L-11-116, Pressure and Temperature Limits Report: Difference between revisions
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| issue date = 04/27/2011 | | issue date = 04/27/2011 | ||
| title = Pressure and Temperature Limits Report | | title = Pressure and Temperature Limits Report | ||
| author name = Allen B | | author name = Allen B | ||
| author affiliation = FirstEnergy Nuclear Operating Co | | author affiliation = FirstEnergy Nuclear Operating Co | ||
| addressee name = | | addressee name = | ||
Line 16: | Line 16: | ||
=Text= | =Text= | ||
{{#Wiki_filter:b FENOC ,-A% 5501 North State Route 2 | {{#Wiki_filter:b FENOC ,-A% 5501 North State Route 2 FirstEnergyNuclear Operating Company Oak Harbor,Ohio 43449 BarryS. Allen 419-321-7676 Vice President - Nuclear Fax: 419-321-7582 April 27, 2011 L-11-116 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 | ||
-Nuclear Fax: 419-321-7582 April 27, 2011 L-11-116 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 | |||
==SUBJECT:== | ==SUBJECT:== | ||
Davis-Besse Nuclear Power Station, Unit No.1 Docket No. 50-346, License No. NPF-3 Pressure and Temperature Limits Report Enclosed please find the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)Pressure and Temperature Limits Report. Submittal of this report is in accordance with DBNPS Technical Specification 5.6.4, "Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)." There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager -Fleet Licensing, at (330) 761-6071.Sincerely, Barry S. Allen | |||
Davis-Besse Nuclear Power Station, Unit No.1 Docket No. 50-346, License No. NPF-3 Pressure and Temperature Limits Report Enclosed please find the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS) | |||
Pressure and Temperature Limits Report. Submittal of this report is in accordance with DBNPS Technical Specification 5.6.4, "Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)." | |||
There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - | |||
Fleet Licensing, at (330) 761-6071. | |||
Sincerely, Barry S. Allen | |||
==Enclosure:== | ==Enclosure:== | ||
FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE UNIT 1 PRESSURE AND TEMPERATURE LIMITS REPORT FOR THE EARLIER OF 32 EFFECTIVE FULL POWER YEARS OR APRIL 22, 2017 cc: NRC Region III Administrator NRC Resident Inspector NRR Project Manager Utility Radiological Safety Board /Zroo( | FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE UNIT 1 PRESSURE AND TEMPERATURE LIMITS REPORT FOR THE EARLIER OF 32 EFFECTIVE FULL POWER YEARS OR APRIL 22, 2017 cc: NRC Region III Administrator NRC Resident Inspector NRR Project Manager Utility Radiological Safety Board /Zroo( | ||
Enclosure L-11-116 FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE UNIT 1 PRESSURE AND TEMPERATURE LIMITS REPORT FOR THE EARLIER OF 32 EFFECTIVE FULL POWER YEARS OR APRIL 22, 2017 (Nine Pages Follow) | Enclosure L-11-116 FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE UNIT 1 PRESSURE AND TEMPERATURE LIMITS REPORT FOR THE EARLIER OF 32 EFFECTIVE FULL POWER YEARS OR APRIL 22, 2017 (Nine Pages Follow) | ||
FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE UNIT 1 PRESSURE AND TEMPERATURE LIMITS REPORT FOR THE EARLIER OF 32 EFFECTIVE FULL POWER YEARS OR APRIL 22,2017 Revision 0 Prepared by: Dennis BlakeI Reviewed by: -!d Kevin Butnworth Approved by:4Keinier | |||
32 EFPY PTLR Rev. 0 Page 3 of 9 Figure 1: Composite Normal Heatup/Cooldown Limit -Hot Leg "A" Pressure Tap 2600 | FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE UNIT 1 PRESSURE AND TEMPERATURE LIMITS REPORT FOR THE EARLIER OF 32 EFFECTIVE FULL POWER YEARS OR APRIL 22,2017 Revision 0 Prepared by: | ||
The step temperature change is defined as RC temp minus the DHR return temps to the reactor coolant system prior to stopping all pumps.5. When the decay heat removal system (DH) is operating without any RC pumps operating, indicated DH return temperature to the reactor vessel shall be used.6. The acceptable pressure and temperature combinations are below and to the right of the limit curve.7. Instrument error is not accounted for in these limits. | Dennis BlakeI Reviewed by: - !d | ||
* Kevin Butnworth Approved by:4Keinier Date: 3) iZellers K | |||
The step temperature change is defined as RC temp minus the DHR return temps to the reactor coolant system prior to stopping all pumps.5. When the decay heat removal system (DH) is operating without any RC pumps operating, indicated DH return temperature to the reactor vessel shall be used.6. The acceptable pressure and temperature combinations are below and to the right of the limit curve, 7. Instrument error is not accounted for in these limits. | |||
The step temperature change is defined as RC temp minus the DHR return temps to the reactor coolant system prior to stopping all pumps.5. When the decay heat removal system (DH) is operating without any RC pumps operating, indicated DH return temperature to the reactor vessel shall be used. | 32 EFPY PTLR Rev. 0 Page 2 of 9 FirstEnergy Nuclear Operating Company Davis-Besse Unit 1 Pressure and Temperature Limits Report for the Earlier of 32 Effective Full Power Years or April 22, 2017 1.0 Introduction This Pressure and Temperature Limits Report (PTLR) provides the information required by Davis-Besse Nuclear Power Station (DBNPS) Technical Specification 5.6.4 to ensure that the Reactor Coolant System (RCS) pressure boundary is operated in accordance with its design. | ||
The listed fluence values are based on 52 EFPY of operation. | The PTLR provides the RCS Operating Limits in Section 2.0, which satisfies Technical Specification 5.6.4.a. The Analytical Methods used to develop the limits, including determination of the vessel neutron fluence, are provided in Section 3.0, fulfilling Technical Specification 5.6.4.b. The information and formatting of Section 3 follows the guidance of Attachment 1 to Generic Letter 96-03. The PTLR requirements are provided in Section 4.0 of the report, fulfilling Technical Specification 5.6.4.c. | ||
The limits in Section 2 are administratively limited as described in Section 3.1 based on the current Operating License of Davis-Besse Nuclear Power Station.3.3 The Davis-Besse Reactor Vessel Material Surveillance Program complies with the requirements of Appendix H to 10 CFR 50 and is described in BAW-1543A (Reference 5.6). This information was approved by the NRC in the SER of Amendment 199 (Reference 5.1). The specimen capsule withdrawal schedule is contained within the supplements of the topical report. All plant specific specimen capsules have been withdrawn from the reactor vessel. The ART values were not calculated using surveillance data (Reference 5.14) since it was determined to be non-credible. | Revisions to the PTLR are to be submitted to the NRC after issuance. | ||
3.4 Low Temperature Overpressure Protection (LTOP) limits are addressed in Section 2.b, above, and Technical Specification 3.4.12 (Reference 5.3).Reference 5.7 discusses the methods used to determine the temperature at which LTOP must be active. The pressure limit was determined using ASME Section XI, Appendix G, as modified by the alternative rules provided in ASME Code Case N-588 and ASME Code Case N-640 (Reference 5.9).3.5 Table 1 provides the Adjusted Reference Temperature (ART) for each reactor vessel beltline material. | 2.0 RCS Pressure and Temperature Limits | ||
The ART values were calculated in accordance with Regulatory Guide 1.99, Revision 2. For welds in the reactor beltline region, the initial RTNDT values used (in part) to determine ART were calculated using an alternate methodology described in the NRC-approved BAW-2308, Revisions 1-A and 2-A (Reference 5.10). The NRC required licensees to obtain an exemption from 10 CFR 50.61 and 10 CFR 50, Appendix G to use the alternate initial RTNDT values provided in BAW-2308 Revisions 1-A and 2-A. The required exemption was granted by the NRC in Reference 5.17. The NRC confirmed the limits and conditions for using the methodology were satisfied in the SER of Amendment 282 (Reference 5.8).3.6 The Pressure-Temperature (P/T) limits of Section 2 and Figures 1, 2, and 3 (with applicability as stated in 3.1) were generated consistent with the requirements of 10 CFR 50 Appendix G and Regulatory Guide 1.99, Revision 2, using the methods described in BAW-10046A (Reference 5.4) and ASME Section XI, 32 EFPY PTLR Rev. 0 Page 7 of 9 Appendix G (Reference 5.9), as modified by the alternative rules provided in ASME Code Case N-588 and ASME Code Case N-640.3.6.1 The NRC has reviewed the methods described in BAW-10046A (Reference 5.4) and approved the topical report by issuance of a Safety Evaluation Report (SER) dated April 30, 1986. Section 1.2 of BAW-10046A states that it is applicable to all current B&W nuclear steam systems.3.6.2 ASME Code Cases N-640 and N-588 have been incorporated into ASME Section XI, Appendix G, 2003 Addenda, which are the edition and addenda codified in 10 CFR 50.55a (effective May 27, 2008) and thus may be used per NRC Regulatory Issue Summary (RIS) 2004-04. Specific approval for application at DBNPS is included in Ref. 5.8.3.7 The minimum temperature requirements of 10CFR50, Appendix G are included on Figures 1 and 2. Figure 3 provides the In-Service Leak and Hydrostatic (ISLH) Test Limits. These limits were calculated in accordance with the requirements of | : a. The Reactor Coolant System (except the pressurizer) temperature and pressure shall be limited in accordance with the limit lines and ramp rates shown on Figures 1, 2, and 3 (Reference 5.7) during heatup, cooldown, criticality, and in-service leak and hydrostatic (ISLH) testing with: | ||
The capsule test results have been evaluated and found to be non-credible (Reference 5.14).Consequently, ART calculations are not based on the surveillance data. The Measured ARTNDT -Predicted ARTNDT data scatter was less than 2a, so the Regulatory Guide 1.99, Rev. 2 Chemistry Table values used in the ART calculations are conservative. | : 1. A maximum heatup of 50'F in any one hour period, and | ||
4.0 PTLR Requirements 4.1 The PTLR has been prepared in accordance with the requirements of Technical Specification 5.6.4 (see Reference 5.11). The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto. Davis-Besse will continue to meet the requirements of 10 CFR 50, Appendix G, and any changes to the Davis-Besse P/T limits will be generated in accordance with the NRC approved methodologies described in TS 5.6.4. | : 2. A maximum cooldown of 100°F in any one hour period with a cold leg temperature of > 2701F and a maximum cooldown of 50°F in any one hour period with a cold leg temperature of < 270 0 F. | ||
32 EFPY PTLR Rev. 0 Page 8 of 9 Table 1: Davis-Besse Nuclear Power Station Reactor Vessel Beltline Region Data (Applicable as noted in Section 3.1)Fluence ART ART@ 52 EFPY @ | : b. During periods of low temperature operation (Tavg <280 'F), Technical Specification 3.4.12 (Reference 5.3) provides additional requirements for RCS pressure and temperature limits. Those limits are maintained in the Technical Specifications because they are not determined using methods generically approved by the NRC. | ||
I .32 EFPY PTLR Rev. 0 Page 9 of 9 5.0 References 5.1 Safety Evaluation by the NRC Office of Nuclear Reactor Regulation Related to Amendment No. 199 to Facility Operating License No. NPF-3 Davis-Besse Nuclear Power Station, Unit No. 1, attached to correspondence dated July 20, 1995.5.2 Technical Specification 5.6.4, "Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)." 5.3 Technical Specification 3.4.12, "Low Temperature Overpressure Protection." 5.4 BAW- 10046A, Revision 2 "Methods of Compliance with Fracture Toughness and Operational Requirements of 10 CFR 50 Appendix G." 5.5 BAW-2241 P-A, "Fluence and Uncertainty Methodologies," dated April 1999.5.6 BAW-1 543A, "Master Integrated Reactor Vessel Material Surveillance Program." 5.7 ANP-2718, Revision 3, "Appendix G Pressure-Temperature Limits for 52 EFPY, Using ASME Code Cases for Davis-Besse Nuclear Power Station," dated August 2010.5.8 Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 282 to Facility Operating License No. NPF-3, FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station, Unit No. 1, (FENOC Ltr. RI 1-030), dated 01/28/2011. | |||
5.9 ASME Code Section XI, Appendix G, as modified by the alternate rules provided in ASME Code Case N-640 and ASME Code Case N-588. ASME Code Cases N-640 and N-588 have subsequently been incorporated into ASME Section XI, Appendix G, 2003 Addenda, which are the edition and addenda codified in 10 CFR 50.55a (effective May 27, 2008).5.10 BAW-2308, Revision 1-A and Revision 2-A, "Initial RTNDT of Linde 80 Weld Materials," dated August 2005 (1-A) and March 2008 (2-A).5.11 Calculation C-NSA-064.02-037, Revision 0, "Davis-Besse 52 EFPY PT Limits -Midland RV Closure Head," dated 2/23/2011. | 32 EFPY PTLR Rev. 0 Page 3 of 9 Figure 1: Composite Normal Heatup/Cooldown Limit - Hot Leg "A" Pressure Tap Vt 2600 Te-D Press I ,i NAJ .V A 70 180 540 r" | ||
5.12 AREVA Report 86-9015129-000, "DB1 -Cycles 13-15 Fluence Analysis Report," dated 4/21/2006. | S-qj 2400 B C 190 540 957 F- - 411-D 195 1165 2200 2000 E | ||
5.13 AREVA Report 51-9123331-000, "Davis-Besse | F G | ||
-EOL Fluence Reconciliation," dated 10/8/2009. | H II 205 210 215 220 1832 2064 2190 2329 x-3 Notes: | ||
5.14 AREVA Document 32-9031157-000, "Davis-Besse Revised ART Values at 52 EFPY," dated 9/20/2006. | 1.Allowable heatup rate is 50 °F/hr (Ramp), limited by a 15 F step change followed by an 18-minute hold. | ||
5.15 AREVA Document 32-9017744-003, "Davis-Besse ART Values at 52 EFPY," dated 10/29/2009. | : 2. Allowable cooldown rate at or above 270 TF is 100 °F/hr 228 2467 (Ramp), limited by a 15 F step change followed by a 9-J 270 2467 minute hold. | ||
5.16 AREVA Document 32-9123247-000, "RTpTs Values of Davis-Besse Unit I for 52 EFPY, Including Extended Beltline," dated 11/12/09.5.17 NRC Letter to FirstEnergy Nuclear Operating Company, "Davis-Besse Nuclear Power Station, Unit 1-Exemption from the Requirements of 10 CFR Parl 50.61 and 10 CFR Part 50, Appendix G," (FENOC Ltr. RI0-298) dated December 14, 2010.}} | 1800 K L | ||
270 220 2500 0 | |||
: 3. Allowable cooldown rate below 270 F is 50 °F/hr (Ramp), limited by a 15 TF step change followed by an ca 1600 M | |||
N 220 230 54W 957 _ 1.i _ | |||
18-minute hold. | |||
: 4. A maximum step temperature change of 15 T is 0 235 1165 allowable when removing all RC pumps from operation P 245 1832 with the DHR system operating. The step temperature | |||
-1400 a R | |||
250 255 2064 2190 change is defined as RC temp minus the DHR return temps to the reactor coolant system prior to stopping all | |||
= 1200 S T | |||
260 268 2329 2467 pumps. | |||
: 5. When the decay heat removal system (DH) is operating U 310 2467 Lu, without any RC pumps operating, indicated DH return V 310 2500 temperature to the reactor vessel shall be used. | |||
t1000 N | |||
: 6. The acceptable pressure and temperature combinations are below and to the right of the limit curve. | |||
: n. 800 7. Instrument error is not accounted for in these limits. | |||
600 A: / If 400 Heatup/Cooldown Limit 200 -U--- Criticality Limit... L I _ _ _ I_ _ _ _ _ _ _ _ i_ _ __I_ _ _ _ | |||
0 50 100 150 200 250 300 350 400 450 Temperature, °F | |||
32 EFPY PTLR Rev. 0 Page 4 of 9 Figure 2: Composite Normal Heatup/Cooldown Limit - Hot Leg "B" Pressure Tap 2600 Point Temo L | |||
I1 A 70 565 * -m M | |||
" 7-i' 2400 B 180 565 C | |||
D E | |||
190 195 205 982 1190 1857 He CS i Notes: | |||
2200 F 210 2064 1. Allowable heatup rate is 50 °F/hr (Ramp), limited by a G 215 2190 :F 15 °F step change followed by an 18-minute hold. | |||
: 2. Allowable cooldown rate at or above 270 OF is 100 'F/hr 2000 P | |||
H 220 2329 228 2492 (Ramp), limited by a 15 OF step change followed by a 9-J 270 2492 __ * ,,__ e minute hold. | |||
: 3. Allowable cooldown rate below 270 OF is 50 °F/hr 1800 K L | |||
270 220 2525 0 A': (Ramp), limited by a 15 OF step change followed by an M 220 556 E-4 18-minute hold. | |||
: 4. A maximum step temperature change of 15 °F is | |||
"; 1600 N 0 | |||
230 235 982 1190 allowable when removing all RC pumps from operation P 245 1857 with the DHR system operating. The step temperature change is defined as RC temp minus the DHR return S1400 250 2064 2190 temps to the reactor coolant system prior to stopping all R 255 pumps. | |||
S 260 2329 | |||
= 1200 T 268 2492 Or%* 5. When the decay heat removal system (DH) is operating without any RC pumps operating, indicated DH return U 310 2492 temperature to the reactor vessel shall be used. | |||
V 3.10 2525 1000 6. The acceptable pressure and temperature combinations | |||
=" 800 , . | |||
J : | |||
are below and to the right of the limit curve, | |||
: 7. Instrument error is not accounted for in these limits. | |||
; ' I 600 400 - -- Heatup/Cooldown Limit . | |||
200 -I- Criticality Limit ' | |||
.. . *......i __ L _ r _ L _ +/- ,,, | |||
0 50 100 150 200 250 300 350 400 450 Temperature, °F | |||
32 EFPY PTLR Rev. 0 Page 5 of 9 Figure 3 Reactor Coolant System Pressure-Temperature Heatup and Cooldown Limits for In-Service Leak and Hydrostatic Tests 2600 Notes: | |||
2400 "A"Tao .13I1..Ta 1. Allowable heatup rate is 50 °F/hr (Ramp), limited by a 15 °F step change Point om Press Press followed by an 18-minute hold. | |||
2200 A 70 540 565 2. Allowable cooldown rate at or above 270 OF is 100 "F/hr (Ramp), limited by B 160 540 565 a 15 OF step change followed by a 9-minute hold. | |||
2000 C 175 1165 1190 3. Allowable cooldown rate below 270 "F is 50 "F/hr (Ramp), limited by a 15 D 190 2165 2190 OF step change followed by an 18-minute hold. | |||
1800 E 195 2382 2382 | |||
: 4. A maximum step temperature change of 15 "F is allowable when removing F 200 2507 2507 all RC pumps from operation with the DHR system operating. The step | |||
*; 1600 temperature change is defined as RC temp minus the DHR return temps to the reactor coolant system prior to stopping all pumps. | |||
1400 5. When the decay heat removal system (DH) is operating without any RC pumps operating, indicated DH return temperature to the reactor vessel shall be used. | |||
1200 -.--- "A" Tap Press] 6. The acceptable pressure and temperature combinations are below and to 1000 "B" Tap Press] the right of the limit curve. | |||
: 7. Instrument error is not accounted for in these limits. | |||
800 * - - . I5 ,. | |||
iii - i I 600 _ _:, _________,, | |||
400 r . 7 r 1 I I I 200 0 | |||
50 100 150 200 250 300 350 400 Temperature, OF | |||
32 EFPY PTLR Rev. 0 Page 6 of 9 3.0 Analytical Methods 3.1 The limits provided in Section 2 and Figures 1, 2, and 3 are valid until the Reactor Vessel has accumulated 32 Effective Full Power Years (EFPY) of fast (E> 1 MeV) neutron fluence or April 22, 2017, whichever comes first. | |||
3.2 The neutron fluence is calculated (Reference 5.12 with Reference 5.13) consistent with Regulatory Guide 1.190 using the NRC-approved methodology described in BAW-2241P-A (Reference 5.5). Table 1 provides the neutron fluence values used in the adjusted reference temperature calculations. The listed fluence values are based on 52 EFPY of operation. The limits in Section 2 are administratively limited as described in Section 3.1 based on the current Operating License of Davis-Besse Nuclear Power Station. | |||
3.3 The Davis-Besse Reactor Vessel Material Surveillance Program complies with the requirements of Appendix H to 10 CFR 50 and is described in BAW-1543A (Reference 5.6). This information was approved by the NRC in the SER of Amendment 199 (Reference 5.1). The specimen capsule withdrawal schedule is contained within the supplements of the topical report. All plant specific specimen capsules have been withdrawn from the reactor vessel. The ART values were not calculated using surveillance data (Reference 5.14) since it was determined to be non-credible. | |||
3.4 Low Temperature Overpressure Protection (LTOP) limits are addressed in Section 2.b, above, and Technical Specification 3.4.12 (Reference 5.3). | |||
Reference 5.7 discusses the methods used to determine the temperature at which LTOP must be active. The pressure limit was determined using ASME Section XI, Appendix G, as modified by the alternative rules provided in ASME Code Case N-588 and ASME Code Case N-640 (Reference 5.9). | |||
3.5 Table 1 provides the Adjusted Reference Temperature (ART) for each reactor vessel beltline material. The ART values were calculated in accordance with Regulatory Guide 1.99, Revision 2. For welds in the reactor beltline region, the initial RTNDT values used (in part) to determine ART were calculated using an alternate methodology described in the NRC-approved BAW-2308, Revisions 1-A and 2-A (Reference 5.10). The NRC required licensees to obtain an exemption from 10 CFR 50.61 and 10 CFR 50, Appendix G to use the alternate initial RTNDT values provided in BAW-2308 Revisions 1-A and 2-A. The required exemption was granted by the NRC in Reference 5.17. The NRC confirmed the limits and conditions for using the methodology were satisfied in the SER of Amendment 282 (Reference 5.8). | |||
3.6 The Pressure-Temperature (P/T) limits of Section 2 and Figures 1, 2, and 3 (with applicability as stated in 3.1) were generated consistent with the requirements of 10 CFR 50 Appendix G and Regulatory Guide 1.99, Revision 2, using the methods described in BAW-10046A (Reference 5.4) and ASME Section XI, | |||
32 EFPY PTLR Rev. 0 Page 7 of 9 Appendix G (Reference 5.9), as modified by the alternative rules provided in ASME Code Case N-588 and ASME Code Case N-640. | |||
3.6.1 The NRC has reviewed the methods described in BAW-10046A (Reference 5.4) and approved the topical report by issuance of a Safety Evaluation Report (SER) dated April 30, 1986. Section 1.2 of BAW-10046A states that it is applicable to all current B&W nuclear steam systems. | |||
3.6.2 ASME Code Cases N-640 and N-588 have been incorporated into ASME Section XI, Appendix G, 2003 Addenda, which are the edition and addenda codified in 10 CFR 50.55a (effective May 27, 2008) and thus may be used per NRC Regulatory Issue Summary (RIS) 2004-04. Specific approval for application at DBNPS is included in Ref. 5.8. | |||
3.7 The minimum temperature requirements of 10CFR50, Appendix G are included on Figures 1 and 2. Figure 3 provides the In-Service Leak and Hydrostatic (ISLH) Test Limits. These limits were calculated in accordance with the requirements of 10CFR50, Appendix G and ASME Code Section XI, Appendix G, 1995 Edition, with Addenda through 1996 and ASME Code Cases N-588 and N-640. | |||
3.8 Davis-Besse has removed more than two surveillance capsules. The capsule test results have been evaluated and found to be non-credible (Reference 5.14). | |||
Consequently, ART calculations are not based on the surveillance data. The Measured ARTNDT - Predicted ARTNDT data scatter was less than 2a, so the Regulatory Guide 1.99, Rev. 2 Chemistry Table values used in the ART calculations are conservative. | |||
4.0 PTLR Requirements 4.1 The PTLR has been prepared in accordance with the requirements of Technical Specification 5.6.4 (see Reference 5.11). The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto. Davis-Besse will continue to meet the requirements of 10 CFR 50, Appendix G, and any changes to the Davis-Besse P/T limits will be generated in accordance with the NRC approved methodologies described in TS 5.6.4. | |||
32 EFPY PTLR Rev. 0 Page 8 of 9 Table 1: Davis-Besse Nuclear Power Station Reactor Vessel Beltline Region Data (Applicable as noted in Section 3.1) | |||
Fluence ART ART | |||
@ 52 EFPY @ VT @ 3/4T (Wetted Surface) (OF) (OF) Limiting RTyrs Reactor Vessel Material (n/cm2 ) @52 EFPY @52 EFPY Mat'l? (OF) | |||
Location Identification (E> 1 MeV) (Note 1) (Note 1) (Yes/No) (Note 2) | |||
Nozzle Belt Forgoing ADB 203 2.29E+18 74.8 64.8 No 81.2 Nozzle Belt to Upper Shell Weld WF-232 2.29E+18 Note 3 Note 3 No 157.9 (ID9%) | |||
Nozzle Belt to Upper Shell Weld WF-233 2.29E+18 100.4* 67.8* No Note 4 (OD 91%) ...... | |||
Upper Shell AKJ 233 1.69E+19 71.8 57.3 No 79.4 Forging ........ | |||
Upper Shell to Lower Shell WF-182-1 1.69E+19 156.2* 106.4* Yes 182.2* | |||
Weld I LowerBCC 241 1.70E+19 89.9 78.8 Yes 95.7 Forging __ 1.70E_19 _F Note 1: Reported ART values are based on Regulatory Guide 1.99, Revision 2 (Ref. 5.15). P/T Limit calculation was based on a temperature value which is more conservative than the listed ART value. (Ref. 5.13) | |||
Note 2: Values from Ref. 5.16, which are based on the location specific clad to vessel interface fluence at 52 EFPY. | |||
Note 3: This weld material does not extend out to the 1/44T or 3/4T location. | |||
Note 4: This weld material is not present at the clad to vessel interface, so RTprs does not apply to it. | |||
* Based on the initial RTNDT provided in the NRC Safety Evaluation Reports to BAW-2308, Rev. 1-A and 2-A (Ref. 5.10). | |||
I . | |||
32 EFPY PTLR Rev. 0 Page 9 of 9 5.0 References 5.1 Safety Evaluation by the NRC Office of Nuclear Reactor Regulation Related to Amendment No. 199 to Facility Operating License No. NPF-3 Davis-Besse Nuclear Power Station, Unit No. 1, attached to correspondence dated July 20, 1995. | |||
5.2 Technical Specification 5.6.4, "Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)." | |||
5.3 Technical Specification 3.4.12, "Low Temperature Overpressure Protection." | |||
5.4 BAW- 10046A, Revision 2 "Methods of Compliance with Fracture Toughness and Operational Requirements of 10 CFR 50 Appendix G." | |||
5.5 BAW-2241 P-A, "Fluence and Uncertainty Methodologies," dated April 1999. | |||
5.6 BAW-1 543A, "Master Integrated Reactor Vessel Material Surveillance Program." | |||
5.7 ANP-2718, Revision 3, "Appendix G Pressure-Temperature Limits for 52 EFPY, Using ASME Code Cases for Davis-Besse Nuclear Power Station," dated August 2010. | |||
5.8 Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 282 to Facility Operating License No. NPF-3, FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station, Unit No. 1, (FENOC Ltr. RI 1-030), dated 01/28/2011. | |||
5.9 ASME Code Section XI, Appendix G, as modified by the alternate rules provided in ASME Code Case N-640 and ASME Code Case N-588. ASME Code Cases N-640 and N-588 have subsequently been incorporated into ASME Section XI, Appendix G, 2003 Addenda, which are the edition and addenda codified in 10 CFR 50.55a (effective May 27, 2008). | |||
5.10 BAW-2308, Revision 1-A and Revision 2-A, "Initial RTNDT of Linde 80 Weld Materials," dated August 2005 (1-A) and March 2008 (2-A). | |||
5.11 Calculation C-NSA-064.02-037, Revision 0, "Davis-Besse 52 EFPY PT Limits - | |||
Midland RV Closure Head," dated 2/23/2011. | |||
5.12 AREVA Report 86-9015129-000, "DB1 - Cycles 13-15 Fluence Analysis Report," dated 4/21/2006. | |||
5.13 AREVA Report 51-9123331-000, "Davis-Besse - EOL Fluence Reconciliation," | |||
dated 10/8/2009. | |||
5.14 AREVA Document 32-9031157-000, "Davis-Besse Revised ART Values at 52 EFPY," dated 9/20/2006. | |||
5.15 AREVA Document 32-9017744-003, "Davis-Besse ART Values at 52 EFPY," | |||
dated 10/29/2009. | |||
5.16 AREVA Document 32-9123247-000, "RTpTs Values of Davis-Besse Unit I for 52 EFPY, Including Extended Beltline," dated 11/12/09. | |||
5.17 NRC Letter to FirstEnergy Nuclear Operating Company, "Davis-Besse Nuclear Power Station, Unit 1-Exemption from the Requirements of 10 CFR Parl 50.61 and 10 CFR Part 50, Appendix G," (FENOC Ltr. RI0-298) dated December 14, 2010.}} |
Latest revision as of 04:00, 11 March 2020
ML11122A091 | |
Person / Time | |
---|---|
Site: | Davis Besse ![]() |
Issue date: | 04/27/2011 |
From: | Allen B FirstEnergy Nuclear Operating Co |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
References | |
L-11-116 | |
Download: ML11122A091 (11) | |
Text
b FENOC ,-A% 5501 North State Route 2 FirstEnergyNuclear Operating Company Oak Harbor,Ohio 43449 BarryS. Allen 419-321-7676 Vice President - Nuclear Fax: 419-321-7582 April 27, 2011 L-11-116 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Davis-Besse Nuclear Power Station, Unit No.1 Docket No. 50-346, License No. NPF-3 Pressure and Temperature Limits Report Enclosed please find the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)
Pressure and Temperature Limits Report. Submittal of this report is in accordance with DBNPS Technical Specification 5.6.4, "Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)."
There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager -
Fleet Licensing, at (330) 761-6071.
Sincerely, Barry S. Allen
Enclosure:
FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE UNIT 1 PRESSURE AND TEMPERATURE LIMITS REPORT FOR THE EARLIER OF 32 EFFECTIVE FULL POWER YEARS OR APRIL 22, 2017 cc: NRC Region III Administrator NRC Resident Inspector NRR Project Manager Utility Radiological Safety Board /Zroo(
Enclosure L-11-116 FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE UNIT 1 PRESSURE AND TEMPERATURE LIMITS REPORT FOR THE EARLIER OF 32 EFFECTIVE FULL POWER YEARS OR APRIL 22, 2017 (Nine Pages Follow)
FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE UNIT 1 PRESSURE AND TEMPERATURE LIMITS REPORT FOR THE EARLIER OF 32 EFFECTIVE FULL POWER YEARS OR APRIL 22,2017 Revision 0 Prepared by:
Dennis BlakeI Reviewed by: - !d
- Kevin Butnworth Approved by:4Keinier Date: 3) iZellers K
32 EFPY PTLR Rev. 0 Page 2 of 9 FirstEnergy Nuclear Operating Company Davis-Besse Unit 1 Pressure and Temperature Limits Report for the Earlier of 32 Effective Full Power Years or April 22, 2017 1.0 Introduction This Pressure and Temperature Limits Report (PTLR) provides the information required by Davis-Besse Nuclear Power Station (DBNPS) Technical Specification 5.6.4 to ensure that the Reactor Coolant System (RCS) pressure boundary is operated in accordance with its design.
The PTLR provides the RCS Operating Limits in Section 2.0, which satisfies Technical Specification 5.6.4.a. The Analytical Methods used to develop the limits, including determination of the vessel neutron fluence, are provided in Section 3.0, fulfilling Technical Specification 5.6.4.b. The information and formatting of Section 3 follows the guidance of Attachment 1 to Generic Letter 96-03. The PTLR requirements are provided in Section 4.0 of the report, fulfilling Technical Specification 5.6.4.c.
Revisions to the PTLR are to be submitted to the NRC after issuance.
2.0 RCS Pressure and Temperature Limits
- a. The Reactor Coolant System (except the pressurizer) temperature and pressure shall be limited in accordance with the limit lines and ramp rates shown on Figures 1, 2, and 3 (Reference 5.7) during heatup, cooldown, criticality, and in-service leak and hydrostatic (ISLH) testing with:
- 1. A maximum heatup of 50'F in any one hour period, and
- 2. A maximum cooldown of 100°F in any one hour period with a cold leg temperature of > 2701F and a maximum cooldown of 50°F in any one hour period with a cold leg temperature of < 270 0 F.
- b. During periods of low temperature operation (Tavg <280 'F), Technical Specification 3.4.12 (Reference 5.3) provides additional requirements for RCS pressure and temperature limits. Those limits are maintained in the Technical Specifications because they are not determined using methods generically approved by the NRC.
32 EFPY PTLR Rev. 0 Page 3 of 9 Figure 1: Composite Normal Heatup/Cooldown Limit - Hot Leg "A" Pressure Tap Vt 2600 Te-D Press I ,i NAJ .V A 70 180 540 r"
S-qj 2400 B C 190 540 957 F- - 411-D 195 1165 2200 2000 E
F G
H II 205 210 215 220 1832 2064 2190 2329 x-3 Notes:
1.Allowable heatup rate is 50 °F/hr (Ramp), limited by a 15 F step change followed by an 18-minute hold.
- 2. Allowable cooldown rate at or above 270 TF is 100 °F/hr 228 2467 (Ramp), limited by a 15 F step change followed by a 9-J 270 2467 minute hold.
1800 K L
270 220 2500 0
- 3. Allowable cooldown rate below 270 F is 50 °F/hr (Ramp), limited by a 15 TF step change followed by an ca 1600 M
N 220 230 54W 957 _ 1.i _
18-minute hold.
- 4. A maximum step temperature change of 15 T is 0 235 1165 allowable when removing all RC pumps from operation P 245 1832 with the DHR system operating. The step temperature
-1400 a R
250 255 2064 2190 change is defined as RC temp minus the DHR return temps to the reactor coolant system prior to stopping all
= 1200 S T
260 268 2329 2467 pumps.
- 5. When the decay heat removal system (DH) is operating U 310 2467 Lu, without any RC pumps operating, indicated DH return V 310 2500 temperature to the reactor vessel shall be used.
t1000 N
- 6. The acceptable pressure and temperature combinations are below and to the right of the limit curve.
- n. 800 7. Instrument error is not accounted for in these limits.
600 A: / If 400 Heatup/Cooldown Limit 200 -U--- Criticality Limit... L I _ _ _ I_ _ _ _ _ _ _ _ i_ _ __I_ _ _ _
0 50 100 150 200 250 300 350 400 450 Temperature, °F
32 EFPY PTLR Rev. 0 Page 4 of 9 Figure 2: Composite Normal Heatup/Cooldown Limit - Hot Leg "B" Pressure Tap 2600 Point Temo L
I1 A 70 565 * -m M
" 7-i' 2400 B 180 565 C
D E
190 195 205 982 1190 1857 He CS i Notes:
2200 F 210 2064 1. Allowable heatup rate is 50 °F/hr (Ramp), limited by a G 215 2190 :F 15 °F step change followed by an 18-minute hold.
- 2. Allowable cooldown rate at or above 270 OF is 100 'F/hr 2000 P
H 220 2329 228 2492 (Ramp), limited by a 15 OF step change followed by a 9-J 270 2492 __ * ,,__ e minute hold.
- 3. Allowable cooldown rate below 270 OF is 50 °F/hr 1800 K L
270 220 2525 0 A': (Ramp), limited by a 15 OF step change followed by an M 220 556 E-4 18-minute hold.
- 4. A maximum step temperature change of 15 °F is
"; 1600 N 0
230 235 982 1190 allowable when removing all RC pumps from operation P 245 1857 with the DHR system operating. The step temperature change is defined as RC temp minus the DHR return S1400 250 2064 2190 temps to the reactor coolant system prior to stopping all R 255 pumps.
S 260 2329
= 1200 T 268 2492 Or%* 5. When the decay heat removal system (DH) is operating without any RC pumps operating, indicated DH return U 310 2492 temperature to the reactor vessel shall be used.
V 3.10 2525 1000 6. The acceptable pressure and temperature combinations
=" 800 , .
J :
are below and to the right of the limit curve,
- 7. Instrument error is not accounted for in these limits.
- ' I 600 400 - -- Heatup/Cooldown Limit .
200 -I- Criticality Limit '
.. . *......i __ L _ r _ L _ +/- ,,,
0 50 100 150 200 250 300 350 400 450 Temperature, °F
32 EFPY PTLR Rev. 0 Page 5 of 9 Figure 3 Reactor Coolant System Pressure-Temperature Heatup and Cooldown Limits for In-Service Leak and Hydrostatic Tests 2600 Notes:
2400 "A"Tao .13I1..Ta 1. Allowable heatup rate is 50 °F/hr (Ramp), limited by a 15 °F step change Point om Press Press followed by an 18-minute hold.
2200 A 70 540 565 2. Allowable cooldown rate at or above 270 OF is 100 "F/hr (Ramp), limited by B 160 540 565 a 15 OF step change followed by a 9-minute hold.
2000 C 175 1165 1190 3. Allowable cooldown rate below 270 "F is 50 "F/hr (Ramp), limited by a 15 D 190 2165 2190 OF step change followed by an 18-minute hold.
1800 E 195 2382 2382
- 4. A maximum step temperature change of 15 "F is allowable when removing F 200 2507 2507 all RC pumps from operation with the DHR system operating. The step
- 1600 temperature change is defined as RC temp minus the DHR return temps to the reactor coolant system prior to stopping all pumps.
1400 5. When the decay heat removal system (DH) is operating without any RC pumps operating, indicated DH return temperature to the reactor vessel shall be used.
1200 -.--- "A" Tap Press] 6. The acceptable pressure and temperature combinations are below and to 1000 "B" Tap Press] the right of the limit curve.
- 7. Instrument error is not accounted for in these limits.
800 * - - . I5 ,.
iii - i I 600 _ _:, _________,,
400 r . 7 r 1 I I I 200 0
50 100 150 200 250 300 350 400 Temperature, OF
32 EFPY PTLR Rev. 0 Page 6 of 9 3.0 Analytical Methods 3.1 The limits provided in Section 2 and Figures 1, 2, and 3 are valid until the Reactor Vessel has accumulated 32 Effective Full Power Years (EFPY) of fast (E> 1 MeV) neutron fluence or April 22, 2017, whichever comes first.
3.2 The neutron fluence is calculated (Reference 5.12 with Reference 5.13) consistent with Regulatory Guide 1.190 using the NRC-approved methodology described in BAW-2241P-A (Reference 5.5). Table 1 provides the neutron fluence values used in the adjusted reference temperature calculations. The listed fluence values are based on 52 EFPY of operation. The limits in Section 2 are administratively limited as described in Section 3.1 based on the current Operating License of Davis-Besse Nuclear Power Station.
3.3 The Davis-Besse Reactor Vessel Material Surveillance Program complies with the requirements of Appendix H to 10 CFR 50 and is described in BAW-1543A (Reference 5.6). This information was approved by the NRC in the SER of Amendment 199 (Reference 5.1). The specimen capsule withdrawal schedule is contained within the supplements of the topical report. All plant specific specimen capsules have been withdrawn from the reactor vessel. The ART values were not calculated using surveillance data (Reference 5.14) since it was determined to be non-credible.
3.4 Low Temperature Overpressure Protection (LTOP) limits are addressed in Section 2.b, above, and Technical Specification 3.4.12 (Reference 5.3).
Reference 5.7 discusses the methods used to determine the temperature at which LTOP must be active. The pressure limit was determined using ASME Section XI, Appendix G, as modified by the alternative rules provided in ASME Code Case N-588 and ASME Code Case N-640 (Reference 5.9).
3.5 Table 1 provides the Adjusted Reference Temperature (ART) for each reactor vessel beltline material. The ART values were calculated in accordance with Regulatory Guide 1.99, Revision 2. For welds in the reactor beltline region, the initial RTNDT values used (in part) to determine ART were calculated using an alternate methodology described in the NRC-approved BAW-2308, Revisions 1-A and 2-A (Reference 5.10). The NRC required licensees to obtain an exemption from 10 CFR 50.61 and 10 CFR 50, Appendix G to use the alternate initial RTNDT values provided in BAW-2308 Revisions 1-A and 2-A. The required exemption was granted by the NRC in Reference 5.17. The NRC confirmed the limits and conditions for using the methodology were satisfied in the SER of Amendment 282 (Reference 5.8).
3.6 The Pressure-Temperature (P/T) limits of Section 2 and Figures 1, 2, and 3 (with applicability as stated in 3.1) were generated consistent with the requirements of 10 CFR 50 Appendix G and Regulatory Guide 1.99, Revision 2, using the methods described in BAW-10046A (Reference 5.4) and ASME Section XI,
32 EFPY PTLR Rev. 0 Page 7 of 9 Appendix G (Reference 5.9), as modified by the alternative rules provided in ASME Code Case N-588 and ASME Code Case N-640.
3.6.1 The NRC has reviewed the methods described in BAW-10046A (Reference 5.4) and approved the topical report by issuance of a Safety Evaluation Report (SER) dated April 30, 1986. Section 1.2 of BAW-10046A states that it is applicable to all current B&W nuclear steam systems.
3.6.2 ASME Code Cases N-640 and N-588 have been incorporated into ASME Section XI, Appendix G, 2003 Addenda, which are the edition and addenda codified in 10 CFR 50.55a (effective May 27, 2008) and thus may be used per NRC Regulatory Issue Summary (RIS) 2004-04. Specific approval for application at DBNPS is included in Ref. 5.8.
3.7 The minimum temperature requirements of 10CFR50, Appendix G are included on Figures 1 and 2. Figure 3 provides the In-Service Leak and Hydrostatic (ISLH) Test Limits. These limits were calculated in accordance with the requirements of 10CFR50, Appendix G and ASME Code Section XI, Appendix G, 1995 Edition, with Addenda through 1996 and ASME Code Cases N-588 and N-640.
3.8 Davis-Besse has removed more than two surveillance capsules. The capsule test results have been evaluated and found to be non-credible (Reference 5.14).
Consequently, ART calculations are not based on the surveillance data. The Measured ARTNDT - Predicted ARTNDT data scatter was less than 2a, so the Regulatory Guide 1.99, Rev. 2 Chemistry Table values used in the ART calculations are conservative.
4.0 PTLR Requirements 4.1 The PTLR has been prepared in accordance with the requirements of Technical Specification 5.6.4 (see Reference 5.11). The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto. Davis-Besse will continue to meet the requirements of 10 CFR 50, Appendix G, and any changes to the Davis-Besse P/T limits will be generated in accordance with the NRC approved methodologies described in TS 5.6.4.
32 EFPY PTLR Rev. 0 Page 8 of 9 Table 1: Davis-Besse Nuclear Power Station Reactor Vessel Beltline Region Data (Applicable as noted in Section 3.1)
@ 52 EFPY @ VT @ 3/4T (Wetted Surface) (OF) (OF) Limiting RTyrs Reactor Vessel Material (n/cm2 ) @52 EFPY @52 EFPY Mat'l? (OF)
Location Identification (E> 1 MeV) (Note 1) (Note 1) (Yes/No) (Note 2)
Nozzle Belt Forgoing ADB 203 2.29E+18 74.8 64.8 No 81.2 Nozzle Belt to Upper Shell Weld WF-232 2.29E+18 Note 3 Note 3 No 157.9 (ID9%)
Nozzle Belt to Upper Shell Weld WF-233 2.29E+18 100.4* 67.8* No Note 4 (OD 91%) ......
Upper Shell AKJ 233 1.69E+19 71.8 57.3 No 79.4 Forging ........
Upper Shell to Lower Shell WF-182-1 1.69E+19 156.2* 106.4* Yes 182.2*
Weld I LowerBCC 241 1.70E+19 89.9 78.8 Yes 95.7 Forging __ 1.70E_19 _F Note 1: Reported ART values are based on Regulatory Guide 1.99, Revision 2 (Ref. 5.15). P/T Limit calculation was based on a temperature value which is more conservative than the listed ART value. (Ref. 5.13)
Note 2: Values from Ref. 5.16, which are based on the location specific clad to vessel interface fluence at 52 EFPY.
Note 3: This weld material does not extend out to the 1/44T or 3/4T location.
Note 4: This weld material is not present at the clad to vessel interface, so RTprs does not apply to it.
- Based on the initial RTNDT provided in the NRC Safety Evaluation Reports to BAW-2308, Rev. 1-A and 2-A (Ref. 5.10).
I .
32 EFPY PTLR Rev. 0 Page 9 of 9 5.0 References 5.1 Safety Evaluation by the NRC Office of Nuclear Reactor Regulation Related to Amendment No. 199 to Facility Operating License No. NPF-3 Davis-Besse Nuclear Power Station, Unit No. 1, attached to correspondence dated July 20, 1995.
5.2 Technical Specification 5.6.4, "Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)."
5.3 Technical Specification 3.4.12, "Low Temperature Overpressure Protection."
5.4 BAW- 10046A, Revision 2 "Methods of Compliance with Fracture Toughness and Operational Requirements of 10 CFR 50 Appendix G."
5.5 BAW-2241 P-A, "Fluence and Uncertainty Methodologies," dated April 1999.
5.6 BAW-1 543A, "Master Integrated Reactor Vessel Material Surveillance Program."
5.7 ANP-2718, Revision 3, "Appendix G Pressure-Temperature Limits for 52 EFPY, Using ASME Code Cases for Davis-Besse Nuclear Power Station," dated August 2010.
5.8 Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 282 to Facility Operating License No. NPF-3, FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station, Unit No. 1, (FENOC Ltr. RI 1-030), dated 01/28/2011.
5.9 ASME Code Section XI, Appendix G, as modified by the alternate rules provided in ASME Code Case N-640 and ASME Code Case N-588. ASME Code Cases N-640 and N-588 have subsequently been incorporated into ASME Section XI, Appendix G, 2003 Addenda, which are the edition and addenda codified in 10 CFR 50.55a (effective May 27, 2008).
5.10 BAW-2308, Revision 1-A and Revision 2-A, "Initial RTNDT of Linde 80 Weld Materials," dated August 2005 (1-A) and March 2008 (2-A).
5.11 Calculation C-NSA-064.02-037, Revision 0, "Davis-Besse 52 EFPY PT Limits -
Midland RV Closure Head," dated 2/23/2011.
5.12 AREVA Report 86-9015129-000, "DB1 - Cycles 13-15 Fluence Analysis Report," dated 4/21/2006.
5.13 AREVA Report 51-9123331-000, "Davis-Besse - EOL Fluence Reconciliation,"
dated 10/8/2009.
5.14 AREVA Document 32-9031157-000, "Davis-Besse Revised ART Values at 52 EFPY," dated 9/20/2006.
5.15 AREVA Document 32-9017744-003, "Davis-Besse ART Values at 52 EFPY,"
dated 10/29/2009.
5.16 AREVA Document 32-9123247-000, "RTpTs Values of Davis-Besse Unit I for 52 EFPY, Including Extended Beltline," dated 11/12/09.
5.17 NRC Letter to FirstEnergy Nuclear Operating Company, "Davis-Besse Nuclear Power Station, Unit 1-Exemption from the Requirements of 10 CFR Parl 50.61 and 10 CFR Part 50, Appendix G," (FENOC Ltr. RI0-298) dated December 14, 2010.