Text

Non-Proprietary Rev. 0 to LTR-RCPL-05-153, Response to NRC Request for Additional Information on WCAP-16005-NP, Rev. 03, 'San Onofre Nuclear Generating Station Unit 2 RCS Pressure & Temperature Limits Report' & WCAP-16167-NP, Rev. 0.
	ML060190107
Person / Time
Site:	San Onofre
Issue date:	12/14/2005
From:	Paggen V, Slowik S; Westinghouse
To:	; Office of Nuclear Reactor Regulation
References
	CAW-05-2078, WCAP-16005-NP, Rev 3, WCAP-16167-NP, Rev. 0 LTR-RCPL-05-153
	Download: ML060190107 (117)
	v • d • e

ENCLOSURE 2 Westinghouse Non-Proprietary document: "Response to NRC Request for Additional Information on WCAP-1 6005-NP, Rev. 03, "San Onofre Nuclear Generating Station Unit 2 RCS Pressure and Temperature Limits Report" and WCAP-1 6167-NP, Rev. 0, "San Onofre Nuclear Generating Station Unit 3 RCS Pressure and Temperature Limits Report"

WESTINGHOUSE NON-PROPRIETARY CLASS 3 LTR-RCPL-05-153, Aftachment 2 Response to NRC Request for Additional Information on WCAP-16005-NP, Rev. 03, "San Onofre Nuclear Generating Station Unit 2 RCS Pressure and Temperature Limits Report"; and WCAP-16167-NP, Rev. 0, "San Onofre Nuclear Generating Station Unit 3 RCS Pressure and Temperature Limits Report" December 14, 2005 Revision 0 Prepared by:

Steven Slowik, Principal Engineer Regulatory Compliance & Plant Licensing Reviewed by:

Virgil Pag n, Prinieer Regulatory Compliance & Plant Licensing Westinghouse Electric Company LLC P.O. Box 355 \.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Table of Contents 1.0 Background..............................................................................................................................4 2.0 Quality Assurance ................................................... 4 3.0 RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION ................... ............. 4 3.1 RAI#1 ................................................... 4 3.2 RAI #2 .................................................. 11 3.3 RAI #3 .................................................. 14 3.4 RAI #4 .................................................. 17 3.5 RAI#5................................................................................................................................30 3.6 RAI#6................................................................................................................................38 3.7 RAI #7 .................................................. 39 3.8 RAI #8 .................................................. 40 3.9 RAI #9 .................................................. 45 4.0 References .................................................. 49 Appendix A .51 List of Tables Table 1: Pressure Stress Influence Coefficients, KIM .16 Table 2: Copper and Nickel Content by Weight (percent) .41 Table 3: SONGS 2 Best Estimate Weld Chemical Composition .45 Table 4: Adjusted Unit 2 Weld ART Based on Chemical Composition .46 Table 5: SONGS 3 Best Estimate Weld Chemical Composition .47 Table 6: Unit 3 Surveillance Weld ARTNDT....................................................................................... 47 Attachment 22 LTR-KUPL 153 Attachment Page 2 of 54 LT1R-XU1'L-U5-153 Page 2 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 List of Figures Figure 1: FE Models used in Computing Kg,, due to Internal Pressure Loading ............................................. 13 Figure 2: Unit 2 Heatup 60F/hr Through-wall Thermal Gradients at Crack Tips ........................................... 14 Figure 3: Unit 2 Heatup Thennal Stress Intensity Factors KIT at Outside Crack Tip .............. ........................ 15 Figure 4: Unit 2 Cooldown I 00F/hr Through-wall Thermal Gradients at Crack Tips .................................... 15 Figure 5: Unit 2 Cooldown Thermal SIF KIT at Inside Crack Tip ................................................................... 16 Figure 6: Unit 2 Steady-state P-T Curve ........................................................................... 19 Figure 7: Unit 2 Heatup P-T Curves ........................................................................... 19 Figure 8: Unit 2 Heatup P-T Curve Enveloped for SF/hr Transient ................................................................ 20 Figure 9: Unit 2 Heatup P-T Curve Enveloped for I OF/hr Transient .............................................................. 20 Figure 10: Unit 2 Heatup P-T Curve Enveloped for 30F/hr Transient ............................................................ 21 Figure 11: Unit 2 Heatup P-T Curve Enveloped for 40F/hr Transient ............................................................ 21 Figure 12: Unit 2 Heatup P-T Curve Enveloped for 6OF/hr Transient ............................................................ 22 Figure 13: Unit 2 Heatup P-T Curve Envelopes ........................................................................... 22 Figure 14: Unit 2 Cooldown P-T Curves ........................................................................... 23 Figure 15: Unit 2 Cooldown P-T Curve Enveloped for IOOF/hr Transient ..................................................... 23 Figure 16: Unit 2 Cooldown P-T Curve Envelopes ........................................................................... 24 Figure 17: Unit 3 Steady-state P-T Curve ........................................................................... 24 Figure 18: Unit 3 Heatup P-T Curves ........................................................................... 25 Figure 19: Unit 3 Heatup P-T Curve Enveloped for SF/hr Transient .............................................................. 25 Figure 20: Unit 3 Heatup P-T Curve Enveloped for I OF/hr Transient ............................................................ 26 Figure 21: Unit 3 Heatup P-T Curve Enveloped for 30F/hr Transient ............................................................ 26 Figure 22: Unit 3 Heatup P-T Curve Enveloped for 40F/hr Transient ............................................................ 27 Figure 23: Unit 3 Heatup P-T Curve Enveloped 60F/hr Transient ................................................................... 27 Figure 24: Unit 3 Heatup P-T Curve Envelopes ........................................................................... 28 Figure 25: Unit 3 Cooldown P-T Curves ........................................................................... 28 Figure 26: Unit 3 Cooldown P-T Curve Enveloped for I OF/hr Q ..................................................................... 29 Figure 27: Unit 3 Cooldown P-T Curve Envelopes ........................................................................... 29 Figure 28: Unit 2 Heatup P-T Curves with Min. Temperature Requirements, Control Room ........................ 35 Figure 29: Unit 2 Cooldown P-T Curves with Min. Temperature Requirements, Control Room ................... 35 Figure 30: Unit 2 Cooldown P-T Curves with Min. Temperature Requirements, Remote Shutdown Panel .. 36 Figure 31: Unit 3 Heatup P-T Curves with Min. Temperature Requirements, Control Room ........................ 36 Figure 32: Unit 3 Cooldown P-T Curves with Min. Temperature Requirements, Control Room ................... 37 Figure 33: Unit 3 Cooldown P-T Curves with Min. Temperature Requirements, Remote Shutdown Panel .. 37 Attachment 22 Page 3 of 54 LTR-RCPL-05-153 Attachment Page 3 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

1.0 BACKGROUND

In November 2004, WCAP-16005-NP, Rev. 03, "San Onofre Nuclear Generating Station Unit 2 RCS Pressure and Temperature Limits Report" and WCAP-16167-NP, Rev. 0, "San Onofre Nuclear Generating Station Unit 3 RCS Pressure and Temperature Limits Report" were provided to Southern California Edison. These reports were then submitted to the NRC by SCE as part of a request for license amendment.

The NRC has reviewed these submittals and has compiled a list of requests for additional information (RAIs). This document provides responses to these RAIs.

2.0 QUALITY ASSURANCE This work was completed under the requirements of the Westinghouse Quality Assurance Program (Reference 9). References are provided at the end of this document following the RAI responses.

3.0 RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION Each NRC RAI is listed by number and is followed by a response.

3.1 RAI #1 In the staff's safety evaluation (SE) on topical report CE-NPSD-683, Revision 6, dated March 16, 2001, the staff included 26 action items that would need to be addressed in a pressure-temperature (P-T) limits report (PTLR) license amendment request that invoked the methods of the topical report. Your PTLR submittal of January 28, 2005, does not specifically identify how the proposed San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3) PTLRs resolve the action items in the SE of March 16, 2001.

The staff requests that you supplement your application with your responses to these 26 action items. If your PTLR submittal already includes information that satisfies any of these action items, please specify which information in the PTLR satisfies resolution of a particular action item. If the PTLR does not include information which satisfies a particular action item, please provide supplemental information which satisfies resolution of the particular action item of concern.

The staff recognizes that several of these action items have become obsolete due to updates in the allowable editions and addenda of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section Xl, Appendix G, which have been incorporated by reference in Title 10 of the Code of Federal Regulations, Part 50 (10 CFR Part 50). If such an action item falls under this category please designate it as such.

Attachment 22 LTR-RCPL 153 Attachment Page 4 of 54 LTR-RUIL-05-153 Page 4 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

Response

Responses to the 26 action items of the SE are provided with respect to the SONGS Unit 2 and SONGS Unit 3 PTLRs prepared by Westinghouse in WCAP-16005-NP, Revision 3 for Unit 2 and WCAP-16167-NP, Revision 0 for Unit 3 (References 1 and 2, respectively). For each numbered response below the NRC action item is paraphrased and is followed by a statement as to how the action has been addressed in the respective PTLR, if it has become obsolete, or if it is addressed in a response to another RAI.

1) Describe the methodology used to calculate the neutronfluence values for the reactorvessel materials.

a. Describe whether the methodology used is consistent with Draft Regulatory Guide 1053.

Section 1.0 of References 1 and 2 state that the neutron fluence methodology is consistent with the guidance of Regulatory Guide 1. 190.

b. Describe the computer codes used to calculate the neutronfluence.

The computer codes used to calculate the neutron fluence are described in Section 1.1.1 of References I and 2.

c. Describe how the computer codes used to calculate the neutronfluence were benchmarked.

The computer codes used to calculate the neutron fluence were benchmarked as described in Section 1.4 of References 1 and 2.

2) Provide the values of neutronfluence usedfor the adjustedreference temperature calculationsincluding the valuesfor the innersurface (ID), T and 3 T locations.

a. For Unit 2, Section 4, Tables 4-2 and 4-3 and Subsection 4.4 of Reference 1 provide the following peak values at 32 EFPY: clad/base metal interface is 4.147x10l9 n/cm 2 ; 1/4 T is 2.472x10' n/cm2 ; 3/4 T is 0.878x1019 n/cm 2 .

b. For Unit 3, Section 4, Tables 4-2 and 4-3 and Subsection 4.4 of Reference 2 provide the following peak values at 32 EFPY: clad/base metal interface is 3.976x0O' 9 n/cm2 ; 1/4 T is 2.370x1019 n/cm 2 ; 3/4 T is 0.8419x10' 9 n/cm 2 .

3) Provide the surveillance capsule withdrawalschedule in the PTLR or by reference.

The surveillance capsule withdrawal schedule is provided in Section 2, Table 2-2 of References 1 and 2.

4) Reference the surveillance capsule reports by title and number if the RTNDT values are calculatedusing RPVsurveillance capsule data.

The title and number of the surveillance capsule reports are given in References 4 and 15 of Reference 1 (Unit 2) and Reference 2 (Unit 3).

PageS of 54 LTR-RCPL-05-153 LTR-RCPL Attachment 22 153 Attachment Page 5 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

5) Provide a descriptionof the analyticalmethod used in the energy addition transient analivsis.

This information is provided in Section 3.2.1.3 of the References I and 2, and also in the Reference 18 document of these references.

6) Provide a description of the analytical method used in the mass addition transient analysis, if differentfrom that in Section 3.3.5 of the topical report.

This information is provided in Section 3.2.1.2 of References I and 2. Also, this section of References I and 2 will be revised to remove the statement "...and the equivalent mass addition that results from energy additions" in order to be consistent with the supporting analyses of record. The reference to equivalent mass additions incorrectly implies additional contributions to the transient are provided by the pressurizer heaters and by decay heat.

7) Provide a description of the methodfor selection of reliefvalve setpoints.

This information is provided in Section 3.2.1.1 of References 1 and 2.

8) Provide ajustificationfor use of subcooledwater conditions or a steam volwnne in the pressurizer.

The RCS is considered water solid for the transients as described in Section 3.2.1 of References I and 2.

9) Provide ajustificationfor a less conservative methodfor determination of decav heat contribution if the method used is less conservative than the "most conservative method" described in the topical report:

The analyses of record that support the SONGS Units 2 and 3 LTOP energy addition and mass addition transients were performed using methodologies that preceded approval of the methods described in the topical report. The SONGS energy addition analysis used an assumed value of 1% decay heat, relevant to approximately 3.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months post shutdown. This is considered a conservative estimate of the cooldown time needed to achieve the LTOP enable temperature, and is therefore conservative for the decay heat contribution. As noted in Action Item 6 of the staffs safety evaluation, the SONGS mass addition transient does not include decay heat contribution.

10) Providejustflficationforoperatoraction time used in transientmitigation or termination.

The transient analyses of References I and 2 that support SONGS Units 2 and 3 do not assume operator action for mitigation of the transients.

11) Provide correlationsusedfor developingpolver operatedreliefvalve (POR V) discharge characteristics.

SONGS Units 2 and 3 do not have PORVs and therefore do not credit pressurizer PORV discharge characteristics in the LTOP transient analyses.

Attachment 22 Page 6 of 54 LTR-RCPL 153 Attachment LTR-RC11L-05-153 Page 6 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

12) Provide spring reliefvalve dischargecharacteristicsif differentfrom those describedin the topical report or if the peak transientpressure is above the set pressureof the valve plus 10 percent.

This information is provided in Section 3.2.1.1 of References 1 and 2.

13) Provide a description of how the reactorcoolant temperature instrumentationUncertainty was accountedfor.

Refer to the response to RAI #6.

14) Provideajustificationfor the mass and energy addition transient mitigation which credit presence of nitrogen in the pressurizer.

SONGS Units 2 and 3 do not credit the presence of nitrogen in the pressurizer in the LTOP transient analyses.

15) Identify and explain any other deviationfrom the methodology included in Section 3.0 of the topical report.

There are no other deviations from the methodology described in Section 3.0 of References 1 and 2.

16) With respect to the methods used to calculate the adjustedreference temperature, identify the limiting materialsand correspondingRTNDT values at 1/4 T and 3/4 T (where "T" is vessel thickness).

a. For Unit 2, the RTNDT values at 32 EFPY at the 1/4 T and 34 T locations are provided in Section 4 of Reference 1. Those values are 137.30 F for lower shell plate C-6405-5 and 116.6 0 F for lower shell plate C-6405-4, respectively.

b. For Unit 3, the RTNDT values at 32 EFPY at the 1/4 T and 3/4 T locations are provided in Section 4 of Reference 2. Those values are 145.8 0 F and 125.50 F respectively for intermediate shell plate C-6802-1.

17) Identify the limiting materialandcorrespondingRTpTs value calculated in accordancewith 10 CFR 50.61.

a. For Unit 2, the RTPTS value at 32 EFPY at the limiting location is provided in Section 4 of Reference 1. That value is 146.30 F for lower shell plate C-6405-5.

b. For Unit 3, the RTPTS value at 32 EFPY at the limiting location is provided in Section 4 of Reference 2. That value is 154.60 F for intermediate shell plate C-6802-1.

LTR-RCPL-05-153 Attachment 2 Page 7 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

18) Ensure that the ferritic RP V materialsthat have accumulatedneutronfluence in excess of lx 017 n/cm 2 will be assessedaccordingto Section 4 of the topicalreport (Reference 4),

regardless of ithethder the materials are locatedwithin the region inintediately surrounding the active core.

a. For both Units 2 and 3, each ferritic plate and weld material located within the region immediately surrounding the active core was evaluated to identify the limiting material at the 1/4 T and 3/4 T locations. The results of that evaluation are provided in Table 4-4 of References I and 2. The adjusted RTNDT values for the limiting materials were used to establish the heatup and cooldown limits. All of the materials assessed in Table 4-4 receive a high neutron fluence being adjacent to the active core and, therefore, are considered in the determination of the limiting beltline material.

b. For the ferritic plate and weld materials located above and below the region immediately surrounding the active core, the neutron fluence is mhuch lower than the fluence relative to the materials immediately surrounding the active core region. The initial RTNDT values of those ferritic materials are comparable to the initial RTNDT values for the materials assessed in Table 4-4. The adjustment to RTNDTwill, therefore, also be smaller than for the materials surrounding the active core. Hence, the ferritic plate and weld materials located above and below the region immediately surrounding the active core in the SONGS Units will never be limiting with respect to establishing the heat-up and cool-down limits. (Note that these additional materials comprise the upper shell course plates and welds that are located immediately above the internediate shell course plates and welds. Each of the lower and intermediate shell course plates and welds are assessed in Table 4-4.)

c. The initial RTNDT values for the ferritic plate and weld materials located above and below the region immediately surrounding the active core are used to establish other aspects of the heat-up and cool-down limits. These other limits include the bolt-up temperature, the lowest service temperature, and the flange limits.

19) Identify which method (i.e., Kic or K/, will be used to calculate the reference intensity factor (Kip) valuesfor the RP V as afiunction of temperature.

The reference stress intensity factor (SIF) used in both Units 2 and 3 is the equation for Kic given in Appendix G of the ASME Code (Reference 3). It is expressed as:

Kk = 33.2 + 20.734e 0.02(T-RTsDr)

The parameter T is the temperature of the material at the hypothetical crack tip (0 F), RTNDT is the material nil-ductility transition reference temperature (0 F), and Kic is the crack initiation fracture toughness (ksi'lin).

20) If Code Case N-640 andKIc are used as the basisfor calculating the KIR values; submit an exemption request to use the methods of Code Case N-640 and apply them to the P-T limit calculations.

The determination of the Pressure-Temperature (P-T) curves is consistent with Section XI of the 2000 Edition of the ASME Code. This Code Edition has incorporated the Kic criteria for the allowable fracture toughness. The Code of Federal Regulations part 50.55a has Page 8 of 54 LTR-RCPL-05-]

LTR-RCPL-015-]53 Attachment 22 53 Attachment Page 8 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 approved this ASME Code Edition in Reference 8. Therefore, Code Case N-640 is not used and an exemption request is not submitted.

21) Apply for an exemption againstrequirements of Section IV.A.2 of Appendix G to Part50 to apply the CE NSSS methods to their P-T curves.

a c The justification to support an exemption request for use of the CE NSSS methodology of pressure stress KIM is included as Appendix A of this document.

22) Include in the PTLRs the P-T curves for heatup, cooldown, criticality, and hydrostaticand leak tests of the reactors.

P-T curves for heatup, cooldown, hydrostatic test and criticality have been included in the Westinghouse Calculations of References 6 and 7. Details of heatup, cooldown and hydrostatic test curves for the uncorrected case are included as Figures 6 through 27 of this document. Allowable P-T limit curves for the criticality condition were obtained from References 6 and 7 and are shown in Figures 28 through 33 of this document.

23) Demonstrate how the P-T curvesforpressure testing conditionsand normal operations with the core criticaland not-criticalwill be in compliance with the appropriateminimum temperaturerequirements as given in Table 1 to Appendix G to Part50.

Minimum temperature requirements have been incorporated into the final composite P-T curve limits in Figures 5.1 through 5.3 of the PLTR reports (References 1 and 2). These figures demonstrate that the P-T curves comply with Appendix G to 10 CFR 50.

Please refer to RAI #5 of this document for a further discussion of how compliance is demonstrated.

24) With respect to the evaluation ofplant specific surveillance data, licensees need to include in theirPTLRs the supplementalsurveillance data and calculations of the chemistryfactors if the surveillance data are usedfor the calculations of the adjusted reference temperatures.

a. For Unit 2, the determination of chemistry factors is discussed in Section 4 of Reference 1 and the surveillance data are discussed in Section 7. The chemistry factors were determined in accordance with Regulatory Guide 1.99, Revision 2, using Regulatory Position 1.1. The bases for the chemical content of the vessel and surveillance plates and welds are provided in the responses to Generic Letter 92-01 (Reference 16 in Reference 1). Additional LTR-RCPL-05-153 Attachment 2 Page 9 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 information is also provided in the responses to RAIs #8 and #9. Surveillance data were evaluated but they are not used for the calculations of the adjusted reference temperatures.

b. For Unit 3, the determination of chemistry factors is discussed in Section 4 of Reference 2 and the surveillance data are discussed in Section 7. The chemistry factors were determined in accordance with Regulatory Guide 1.99, Revision 2, using both Regulatory Position 1.1 and 2.1. Additional inforniation is also provided in the response to RAI #9. No supplemental surveillance data were used.

25) Provide the evaluation of whether the surveillance data are credible in accordancewith the credibility criteriaofRG 1.99, Revision 02.

a. For Unit 2, the credibility of the surveillance data is established in Section 7 of Reference 1.

Additional information is also provided in the responses to RAIs #8 and #9.

b. For Unit 3, the credibility of the surveillance data is established in Section 7 of Reference 2.

Additional information is also provided in the response to RAI #9.

26) In addition, if licensees seek to use surveillance datafrom supplementalplant sources, licensees must identify the source of the data, and either identify bya title andnumber the safety evaluation report ....; or compare the licensee 's data ... andsubmit the proposed integratedsurveillanceprogram and evaluation of the datafor the NRCfor review and approval.

The licensee does not seek to use surveillance data from supplemental plant sources for either Units 2 or 3. In either case there is a plant-specific surveillance program. Four surveillance capsules remain in each unit, and the materials in the surveillance capsules were selected in accordance with ASTM El 85-73. In neither case was it necessary or feasible to obtain surveillance data from another reactor vessel surveillance program.

Page 10 of 54 LTR-RCPL-05-153 Attachment 22 LTR-RCPL-05-153'Attachment Page 10 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 3.2 RAI #2 The ASME Code, Section Xl, Appendix G provides a methodology for calculating stress intensity factors corresponding to membrane tension (KIM) and thermal stress (KIT) for the postulated axial defect. Calculations of KIT are based on stress influence coefficients from finite element modeling (FEM) analyses for inside (S4T) and outside (3/T) surface flaws. Calculations of the maximum allowable KIM are based on a closed-form solution to an equation such as 2KIM + KIT < K1c, where KIT has been determined from solutions based on stress influence coefficients, and Kic was determined using the equation representing the analytical approximation to the lower bound fracture toughness curve, KIc (in ksi*sqrt(in.)) = 33.2 + 20.734exp[O.02(T - RTNDT)], where RTNDT is the material nil- ductility transition reference temperature and T is the actual temperature of the material.

The Combustion Engineering (CE) nuclear steam supply system (NSSS) methodology differs from the ASME Code, Section Xl, Appendix G methodology in several respects. The CE NSSS methodology for calculating KIT is based on thermal influence coefficients from FEM analyses, as opposed to stress influence coefficients. Furthermore, the CE NSSS methodology for calculating KIM does not involve a closed-form solution based on calculations of KIT and Kc factors, and instead applies FEM methods for estimating the KIM factors.

Please supplement Section 5.0 of the SONGS 2 and 3 PTLRs with a discussion of the specific methodologies that will be applied in the PTLRs for SONGS 2 and 3 for calculating stress intensity factors at the 1/4T and 3/4T crack depth locations:

a. Discuss the methodology for calculating the thermal stress intensity factor, KIT.

b. Discuss the methodology for calculating the stress intensity factor corresponding to membrane tension resulting from pressure loading of the reactor vessel, KIM. Please specify whether KIM is determined by obtaining a closed-form solution (as prescribed by the ASME Code, Section Xl, Appendix G) or determined by applying FEM methods (as prescribed by the CE NSSS methodology).

Per your response to action item 21 in RAI 1, if your methodology applies the CE NSSS method for calculating KIM stress intensity values, then your application will need to include a request for an exemption from the requirements of 10 CFR Part 50, Appendix G for P-Tlimits. The need for an exemption for calculating P-T limits using the CE NSSS method is specified in the fourth paragraph (pages 20- 21) of Section 2.5.4 and in action item 21 (page 27) of Section 5.0 of the SE on topical report CE-NPSD-683, Revision 6, dated March 16, 2001. The CE Owners Group (CEOG) agreed to this requirement in their final version of topical report CE-NPSD-683, Revision 6. The requirement for the exemption is specified in the "Note" on page 5-15 of the topical report.

Response

Calculations of crack tip stress intensity factors due to thermal loads, KIT, are based on thermal influence coefficients developed using two dimensional (2D) finite element analyses with linear, quadratic and cubic temperature profiles across the vessel wall thickness. The influence coefficients are computed for postulated inside (1 thickness) and outside (3/4 thickness) surface flaws and are then corrected to account for the 3D elliptical geometry using the procedures of Appendix A of Section XI of the ASME Code.

C LTR-RCPL-05-153 Attachment 2 Page I11 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a,c Using the KIM values due to the applied pressure loading, the ASME Code procedure using the criteria:

2KI, +KIT< KIC was followed in computing the maximum allowable for thenrnal transient cases, and 1.5KIM < SIC for hydrostatic test cases.

Per the conditions listed in the safety evaluation for topical report CE NPSD-683 (Reference 4) a request for exemption from the requirements of 10CFR Part 50, Appendix G, is provided in Appendix A of this document.

LTR-.RCPL-05.................................53.........Attachment............................2......Page.............12........of.........54...

LTR-RCPL-05-153 Attachment 2 Page 12 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 MUM CRACK OUT$= CRACK Figure 1: FE Models used in Computing KIM due to Internal Pressure Loading Page 13 of 54 LTR-RCPL-U5-L'FR-RCPL-U5-153 Attachment 22 153 Attachment Page 13 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 3.3 RAI #3 In support of the NRC staff's review of the P-T limit curves contained in the PTLR submittal, please supplement your application with data for the through-wall thermal gradients (Az) and thermal stress intensities (KIT) for the 1/4T and 3/4T crack depth locations. These data are necessary for the NRC staff to perform independent calculations of P-T limits to verify that the P-T limit curves are at least as conservative as those that would be obtained as a result of applying the methods of 10 CFR Part 50, Appendix G, or as modified using the CE NSSS methodology. In addition, if you are requesting to use the CE NSSS methodology for KIM determinations, please submit the plant-specific KIM data to support the staff's review of these calculations.

Response

a, c Figure 2: Unit 2 Heatup 60F/hr Through-wall Thermal Gradients at Crack Tips LTR-RCPL-05-153 Attachment 2 Page 14 of 5-4

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 3: Unit 2 Heatup Thermal Stress Intensity Factors KIT at Outside Crack Tip a, c Figure 4: Unit 2 Cooldown 100F/hr Through-wall Thermal Gradients at Crack Tips LTR-RCPL-05-153 Attachment 2 Page 15 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 5: Unit 2 Cooldown Thermal SIF KIT at Inside Crack Tip The membrane stress intensity factor coefficients KIM due to unit (1000 psi) internal pressure loading for SONGS reactor vessel geometry with a base metal thickness of 8.625 inches for inside and outside crack tip locations are given in the following table.

Table 1: Pressure Stress Influence Coefficients, KIM a, c r

Per the topical report (Reference 4) a request for exemption from the requirements of 10CFR Part 50, Appendix G, is provided in Appendix A of this document.

LTR-RCPL-05-153 Attachment 2 Page 16 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 3.4 RAI #4 In all cases P-T limit curves must be determined using the most limiting conditions in the reactor vessel. For heatup and cooldown transients the application of the PTLR methodology and calculations of P-T limits must always take into consideration the different conditions at the 1/4T and 3/4T locations during the thermal transient, and the resulting P-T limit curves must always represent the most limiting of these conditions.

Please supplement Section 5.0 of the SONGS 2 and 3 PTLRs with a discussion of how the P-T limit curves account for the most limiting conditions in the reactor vessel. The discussion should address the following points:

a. Please discuss how the calculation of P-T limit curves for SONGS 2 and 3 addresses heatup and cooldown transients, specifically taking into consideration the different conditions at the 1/4T and 3/4T crack depth locations.

b. Please discuss how the calculation of P-T limit curves for SONGS 2 and 3 addresses the assessment of the 1/4T location for steady state conditions in addition to the 1/4T and 3/4T locations under heatup and cooldown transient conditions. Please supplement the P-Tlimit curves for SONGS 2 and 3 with a P-T limit curve representing the 1/4T location under steady state conditions.

Response: a,c LTR-RCPL-05-153 Attachment 2 Paue 17 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, C

_ag 18 of ,54 s{^

LTR-RUIL-M-153 Attachment At LI-CL-U5-153sAttachmen 22 Page 18 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a,c Figure 6: Unit 2 Steady-state P-T Curve a, c Figure 7: Unit 2 Heatup P-T Curves LTR-RCPL-05-153 Attachment 2 Page 19 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Na,c Figure 8: Unit 2 Heatup P-T Curve Enveloped for 5F/hr Transient a, c Figure 9: Unit 2 Heatup P-T Curve Enveloped for IOF/hr Transient J

LTR-RCPL-05-153 Attachment 2 Page 20 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 10: Unit 2 Heatup P-T Curve Enveloped for 3OF/hr Transient a, c 9

Figure 11: Unit 2 Heatup P-T Curve Enveloped for 4OF/hr Transient LTR-RCPL-05-153 Attachment 2 Page 21 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 12: Unit 2 Heatup P-T Curve Enveloped for 60F/hr Transient a, c Figure 13: Unit 2 Heatup P-T Curve Envelopes L:I-R-RCPL-05-153 Attachment 2 Page 22 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 14: Unit 2 Cooldown P-T Curves a, c Figure 15: Unit 2 Cooldown P-T Curve Enveloped for 1OOF/hr Transient Attachment 22 Page 23 of 54 LTR-RCPL-05-153 Attachment Page 23 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 16: Unit 2 Cooldown P-T Curve Envelopes a, c J

Figure 17: Unit 3 Steady-state P-T Curve Attachment 22 Page 24 0154 L'1R-RCI'L-05-153 Attachment LTR-RUPL-05-153 Page 24 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 18: Unit 3 Heatup P-T Curves a, c Figure 19: Unit 3 Heatup P-T Curve Enveloped for 5F/hr Transient L`I'R-RCFL-U5-153 Attachment 2 Page 25 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 20: Unit 3 Heatup P-T Curve Enveloped for 1OF/hr Transient a, c Figure 21: Unit 3 Heatup P-T Curve Enveloped for 3 OF/hr Transient J

Attachrnent:Z Page 26 of154

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Figure 22: Unit 3 Heatup P-T Curve Enveloped for 40F/hr Transient a, c

-I1 Figure 23: Unit 3 Heatup P-T Curve Enveloped 6OF/hr Transient LTR-RCPL-05-153 Attachment 2 Page 27 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 24: Unit 3 Heatup P-T Curve Envelopes a, c r

Figure 25: Unit 3 Cooldown P-T Curves LTR-RCPL-05-153 Attachment 2 Page 28 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 26: Unit 3 Cooldown P-T Curve Enveloped for LOOF/hr a, c Figure 27: Unit 3 Cooldown P-T Curve Envelopes Page 29 of 54 LTR-RCPL-05-153 Attachmnent 2 LTR-RCPL-05-153 Attachment 2 Page 29 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 3.5 RAI #5 Table 1 of 10 CFR Part 50, Appendix G, specifies six different minimum temperature requirements that must be met when generating the pressure-temperature (P-T) limits for U.S. operating pressurized water reactors (PWRs):

a. Those for pressure test conditions with the Reactor Coolant System (RCS) pressure less than or equal to 20% of the reactor's preservice hydrostatic test pressure.

b. Those for pressure test conditions with the RCS pressure greater than 20% of the reactor's preservice hydrostatic test pressure.

c. Those for normal operating conditions (including heatups and cooldowns of the reactor and transient operating conditions) with the RCS pressure less than or equal to 20% of the reactor's preservice hydrostatic test pressure, at times the reactor is not in the critical operating mode.

d. Those for normal operating conditions (including heatups and cooldowns of the reactor and transient operating conditions) with the RCS pressure greater than 20% of the reactor's preservice hydrostatic test pressure at times the reactor is not in the critical operating mode.

e. Those for normal operating conditions (including heatups and cooldowns of the reactor and transient operating conditions) with the RCS pressure less than or equal to 20% of the reactor's preservice hydrostatic test pressure at times the reactor is in the critical operating mode.

f. Those for normal operating conditions (including heatups and cooldowns of the reactor and transient operating conditions) with the RCS pressure greater than 20% of the reactor's preservice hydrostatic test pressure at times the reactor is in the critical operating mode.

Criterion 6 in Attachment I to GL 96-03 states that the above minimum temperature requirements of 10 CFR Part 50, Appendix G shall be incorporated into the P-T limit curves, and PTLRs shall identify minimum temperatures on the P-T limit curves such as the minimum boltup temperature and the hydrotest temperature.

Section 6.0 of the SONGS 2 and 3 PTLRs, provides a listing and brief discussion of the minimum temperature requirements that have been incorporated into the P-T limit curves for SONGS 2 and

3. However, the discussion does not adequately demonstrate how the P-T limit curves for pressure testing conditions and normal operations with the core critical and core not critical will be in compliance with the appropriate minimum temperature requirements as given in Table I to Appendix G to 10 CFR Part 50. This information is needed to satisfy action item 23 from staff's safety evaluation (SE) on topical report CE-NPSD-683, Revision 6.

Per your response to action item 23 in RAI 1, update Section 6.0 of the PTLRs for SONGS 2 and 3 to provide a discussion on how the P-T limit curves will meet all of the minimum temperature requirements mandated by Table 1 of 10 CFR Part 50, Appendix G. Include in this discussion the value for the highest reference temperature of the material in the closure flange region that is highly stressed by the bolt preload and how this value is applied along with minimum permissible hydrostatic test temperature to determine minimum temperature requirements that will be applied to the P-T limit curves for SONGS 2 and 3. This information is necessary to ensure that the SONGS 2 and 3 P-T limit curves will continue to comply with the minimum temperature requirements of Table I of 10 CFR Part 50, Appendix G, and that the PTLR will conform to the provisions of Criterion 6 in Attachment I to Generic Letter (GL) 96-03.

Attachment 22 Page 30 of 54 LTR-RCPL-05-153 Attachment LTR-ItClIL-05-153 Page 30 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

Response

The P-T limit curves for pressure testing conditions and normal operations with the core critical and core not critical are in compliance with the appropriate minimum temperature requirements given in Table 1 of Appendix G to 10 CFR Part 50. This is demonstrated by the explanation and figures provided hereafter. Each of the six minimum temperature requirements a) through f) are specifically identified for clarity.

Unit 2 Design pressure = 2,500 psia (2,485.3 psig)

Normal operating pressure = 2,250 psia (2,235.3 psig)

Preservice hydrostatic pressure = 3,125 psia (3,110.3 psig)

Minimum bolt-up temperature = 650 F (Ref. 12)

Flange region RTNDT = 20'F (Ref.1 1)

Initial piping, pumps and valves RTNDT = 90'F (Ref. 13)

Adjusted RTNDT at 14 t for 32 EFPY = 137.3 0 F Adjusted RTNDT at3/4t for 32 EFPY = 116.60 F 20% Preservice hydrostatic pressure = 0.2 (3,125 psia) = 625 psia Preservice hydrostatic pressure with correction for instrument uncertainty

= 20% preservice hydro pressure + RCS instrument uncertainty

= 625 psia - 97.8 psi = 527.2 psia Inservice hydrostatic pressure= 1.1 (Operating Pressure) + Pressurizer instrument uncertainty

= 1.1 (2,250 psia) + 81 psi = 2,556 psia a, c LTR-RCPL-05-153 Attachment 2 Page 31 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 28 shows the minimum pressure and temperature requirements for hydrostatic test and heatup transients for Unit 2. Minimum requirements for cooldown transients for control room and remote shutdown panel are shown in Figures 29 and 30, respectively.

Page 32 of 54 LTR-RCPL LTR-RCIIL-05-153 Attachment 2 153 Attachment 2 Page 32 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Unit 3 Design Pressure = 2,500 psia (2,485.3 psig)

Normal Operating Pressure = 2,250 psia (2,235.3 psig)

Preservice Hydrostatic Pressure = 3,125 psia (3,110.3 psig)

Minimum Bolt-up Temperature = 65 0 F (Ref. 12)

Flange Initial RTNDT = 40'F (Ref. 15)

Initial piping, pumps and valves RTNDT = 90'F (Ref.13 & 16)

Adjusted RTNDT at 14 t for 32 EFPY = 145.8 0 F Adjusted RTNDTat3/4t for 32 EFPY = 125.5 0 F 20% Preservice hydrostatic pressure = 0.2 (3,125 psia) = 625 psia Preservice hydrostatic pressure with correction for instrument uncertainty

= 20% preservice hydro pressure + RCS instrument uncertainty

= 625 psia - 97.8 psi = 527.2 psia Inservice hydrostatic pressure= 1.1 (Operating Pressure) + Pressurizer instrument uncertainty

= 1.1 (2,250 psia) + 81 psi = 2,556 psia a, c Page 33 ot54 LXR-RUPL-0-153 Attachment 2 LTR-RCPL-U5-153 Attachment 2 Page 33 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 31 shows the minimum pressure and temperature requirements for hydrostatic test and heatup transients for Unit 3. Minimum requirements for cooldown transients for control room and remote shutdown panel are shown in Figures 32 and 33, respectively.

LIK-KCPL-U5-153 Attachment 22 Page 34 of 54 LTR'-RCPJL-05-153 Attachment Page 34 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

-a, c Figure 28: Unit 2 Heatup P-T Curves with Min. Temperature Requirements, Control Room a,c Figure 29: Unit 2 Cooldown P-T Curves with Min. Temperature Requirements, Control Room LTR-RCPL-05-153 Attachment 2 Page 35 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a,c Figure 30: Unit 2 Cooldown P-T Curves with Min. Temperature Requirements, Remote Shutdown J1 Panel a,c F

Figure 31: Unit 3 Heatup P-T Curves with Min. Temperature Requirements, Control Room LTR-RCPL-05-153 Attachment 2 Page 36 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 32: Unit 3 Cooldown P-T Curves with Min. Temperature Requirements, Control Room a, c Figure 33: Unit 3 Cooldown P-T Curves with Min. Temperature Requirements, Remote Shutdown Panel LTR-RCPL-05-153 Attachment 2 Page 37 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 3.6 RAI #6 Section 5.0 of the PTLRs for SONGS 2 and 3 provides a footnote indicating that pressure and temperature limit values are adjusted for instrument uncertainty, and for RCS pressure and elevation effects. Please supplement Section 5.0 of the SONGS 2 and 3 PTLRs with a detailed discussion of how instrument uncertainties are treated in the development of the PTLR P-T limit curves for SONGS 2 and 3. Include in this discussion numerical values for the instrument uncertainties as well as numerical values for factors that compensate for RCS pressure and elevation effects. Please discuss how these factors are applied in the calculation of the P-T limit curves.

Response

Tables 5-1, 5-2 and 5-3 of the SONGS PTLRs (References I and 2) each have a footnote explaining that the tabulated values have been adjusted for instrument uncertainty and for RCS pressure and elevation effects. Additional detail as below will be added to Section 5 of References I and 2 to explain these footnotes.

The calculated reactor vessel pressure and temperature limit values are adjusted for instrument uncertainty, and for RCS pressure and elevation effects. Section 3.4.2 of the topical report (Reference 4) provides a description of the development of these RCS pressure and elevation effects.

These adjustments ensure that the analytical beltline P-T limits are conservatively interpreted by pressurizer pressure and RCS temperature instrumentation. The pressure values are adjusted using pressure correction factors (PCF), and the temperature values are adjusted for temperature instrumentation uncertainty.

The pressure correction factors applied to Tables 5-1, 5-2 and 5-3 consist of three components:

1. pressure differential corresponding to water head between the pressurizer water level and the reference point in the reactor vessel (APELEV),

2. flow-induced pressure drop between the reactor vessel downcomer and the surge nozzle in the hot leg (APFLOW; a value that depends on the number of operating RCPs), and

3. pressurizer pressure instrumentation loop uncertainty (APINSTR).

These components are individually established using conservative assumptions, then summed into the PCF. The PCF values are subtracted from the analytical values to conservatively reduce the allowable pressure limit. The explicit PCF values used for the SONGS units are dependent upon the number of operating RCPs and on the available instrumentation. Thus, the following PCFs are applied to the analytical pressure limits:

LT..R..-R......PL.-....O.....................Attachment......................2.....Page...........38.......of.......54 .

LTR-RCPL-05-153 Attachment 2 Page 3 8 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Pressure Correction Factors (with instrument uncertainty)

Low Range Wide Ranae Control Room: < 700 psia

< 340 'F (2 RCP Operating) PCF = 97.8 151.3 psid

> 340 'F (3 RCP Operating) PCF = 117.8 171.3 psid Remote Shutdown Panel: < 1600 psia

< 340 'F (2 RCP Operating) PCF = 146.3 151.3 psid

> 340 'F (3 RCP Operating) PCF = 166.3 171.3 psid The data in Tables 5-1, 5-2 and 5-3 of References 1 and 2 are also adjusted for temperature instrumentation uncertainty. For SONGS, a conservative temperature uncertainty of 18.5 0 F is added to the analytical values for both the control room and the remote shutdown panel instrumentation.

3.7 RAI #7 The proposed P-T limit curves included in Section 5.0 of the PTLRs for SONGS 2 and 3 are proposed to be effective through 32 effective full poweryears of operation (EFPY). The existing P-T limit curves contained in the Technical Specifications (TS) are stated to be effective through 20 EFPY. Confirm whether the changes to the P-T limit curves included in Section 5.0 of the PTLRs for SONGS 2 and 3 reflect only the increase in the EFPY for which the curves will be applied. If there are other factors, such as different parameters or methods, which contribute to the changes to the curves, provide a detailed discussion of these factors and how they affect the PTLR P-T limit curves.

Response

The changes to the P-T limit curves included in Section 5.0 of the SONGS 2 and 3 PTLRs reflect the combined effect of the increase in the EFPY, via a higher RTNDT shift from 20 to 32 EFPY, in conjunction with the use of the crack arrest allowable, Kic, instead of the crack initiation allowable, KLA. The P-T limit curves included in Section 5.0 of the PTLRs are effective through 32 effective full power years of operation and are based on a 32 year RTNDT shift using the K1c allowable. The P-T limit curves contained in the Technical Specifications (TS) are effective through 20 EFPY and are based on a RTNDT shift of 20 years using the KIA allowable.

ae3 f5 LTR-RCPL-05-153 Attachment 22 LT-CL0-5 Atahmn Page 39 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 3.8 RAI #8 Criterion 7 of the Table in Attachment I to GL 96-03 specifies that an analysis of the credibility of the surveillance data must be provided in the PTLR. Regulatory Position 2.1 of Regulatory Guide (RG) 1.99, Revision 2 specifies that when two or more credible surveillance data sets become available from the reactor in question, they may be used to determine the Adjusted Reference Temperature (AR7) values. If the procedure of Regulatory Position 2.1 for determining the ART values based on the surveillance data results in a higher value for the ART than that given by using the procedures of Regulatory Position 1.1 of the RG, RG 1.99, Revision 2 specifies that the surveillance data should be used for the ART and chemistry factor determination. If the procedure of Regulatory Position 2.1 results in a lower value for the ART, either may be used.

Please confirm that the credibility analysis of the SONGS 2 surveillance data from Section 7.0 of the SONGS 2 PTLR demonstrated that the surveillance data sets for SONGS 2 are credible.

Section 7.0 of the SONGS 2 PTLR states that the surveillance data were not used to generate a chemistry factor in accordance with the methodology prescribed in Regulatory Position 2.1 of RG 1.99, Revision 2. Please confirm whether the ART values for the limiting materials were calculated using the procedure of Regulatory Position 1.1 of RG 1.99, Revision 2.

If the procedure of Regulatory Position 1.1 of RG 1.99, Revision 2 was used to calculate the ART values for the limiting materials, please indicate why this is an acceptable procedure, given the credibility of the surveillance data.

Please supplement Section 7.0 of the PTLR for SONGS 2 with the following information:

a. Table 7-1 of the SONGS 2 PTLR provides chemistry factors for the two surveillance materials plate C-6404-2 and weld 9-203. Please indicate how these chemistry factors were derived.

b. There is no explicit calculation in the SONGS 2 PTLR demonstrating that chemistry factor values for the limiting materials derived from the tables in RG 1.99, Revision 2 would result in limiting ART values that are more conservative than those determined using chemistry factors derived from surveillance data. Peryourresponse to action item 24 in RA I please supplement Section 7.0 of the PTLR for SONGS 2 with detailed calculations of the chemistry factors for each of the surveillance materials based on the calculation methods specified in Regulatory Position 2.1 of RG 1.99, Revision 2.

The calculations of the chemistry factors for the surveillance materials for SONGS 3, provided in Table 7-1 of the SONGS 3 PTLR represent an acceptable format for presenting surveillance material chemistry factor calculations.

Response

It is confirmed that a credibility analysis was performed in accordance with Regulatory Guide 1.99, Revision 2, and it was determined that all of the credibility criteria were met for the SONGS 2 surveillance base plate (Plate C-6404-2) and surveillance weld (Weld 9-203). It is also confirmed that ART values for all the SONGS 2 reactor vessel beltline materials were calculated using Regulatory Position 1.1 of RG 1.99, Revision 2. The results of that calculation are reported in Table 4-4 of Reference 1. Additional details are provided in the specific responses to questions 8.a and 8.b.

Pag 40 of 54,

_T-CL05 Atahn LTR-RCPL-05-153 Attachment 22 Page 40 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Information on the selection of materials for inclusion in the Unit 2 surveillance program is provided in Reference 17. The selection followed the procedures of ASTM E-185-73, Annex A-1. Two surveillance capsules have been removed from Unit 2, those from the 970 and 263° locations. Data from those capsules were used to compute an Adjusted Reference Temperature (ART) using Regulatory Guide 1.99, Revision 2, Regulatory Position 2.1. The ART values for plate C-6404-2 and the surveillance weld determined from the surveillance data were less than that predicted for plate C-6404-5 using Position 1.1 of RG 1.99. That is, the two surveillance data sets do not represent the limiting vessel material. The responses to questions 8.a and 8.b below provide additional information regarding the treatment of the surveillance data.

The heatup and cooldown limits and the assessment of RTPTs require the determination of the highest (i.e., limiting) value of ART. These values are reported in Section 4 of Reference 1.

The limiting material (highest ART value at 1/4T or 3/4T based on Regulatory Position 1.1 of RG 1.99, Revision 2) for the SONGS 2 reactor vessel beltline is plate C-6404-5. The ART for plate C-6404-2 based on the credible surveillance data and Regulatory Position 2.1 is lower than that for the limiting plate. The ART for the surveillance weld based on the credible surveillance data and Regulatory Position 2.1 is also lower than that for the limiting plate. The predicted values of RTpTs are in the same relative order as the ART values. Hence, the procedure used produces a more conservative value for the SONGS 2 reactor vessel than that obtained using the credible surveillance data and Regulatory Position 2.1. New surveillance data will be reviewed in accordance with the requirements in effect.

a. Response to RAT #8.a The chemistry factors for the surveillance materials provided in Table 7-1 of Reference 1 are obtained from Tables 1 and 2 of RG 1.99, Revision 2, based on the following copper and nickel content:

CF = 650 F for Plate C-6404-2, based on 0.10% copper content and 0.60% nickel content per Reference 18. Also, refer to Table 2 in the response to 8.b, below.

CF = 31.1 0 F for Weld 9-203, based on 0.03% copper content and 0.14% nickel content. These represent the average values of the 970 and the 2630 surveillance capsules per Reference 20. Baseline analysis showed 0.03% copper content and 0.12% nickel content (Reference 20), which corresponds to a slightly lower CF =

29.8 0F.

b. Response to RAI #8.b Two analyses were performed by Combustion Engineering Chattanooga Laboratory on Unit 2 reactor vessel beltline plates and welds (Reference 18), including intermediate shell Plate C-6404-2 and lower shell Plate C-6404-5. The copper and nickel content based on these analyses results are provided in Table 2.

Table 2: Copper and Nickel Content by Weight (percent)

Plate First Analysis Second Analysis Average Cu Ni Cu Ni Cu Ni C-6404-2 0.10 0.58 0.10 0.60 0.10 0.59 C-6404-5 0.11 0.62 0.11 0.67 0.11 0.65 LI-ULU5 Atahmn .ag .1 . t,_

LFR-KUPL-W-153 Attachment 2 2 Page 41 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Per Table 2 of Regulatory Guide 1.99 (Reference 19), the chemistry factor for Plate C-6404-2 is 650 F, and the chemistry factor for C-6404-5 is 750 F based on the average Cu and Ni values provided in Table 2 above.

b.l ART for Intermediate Shell Plate C-6404-2 The following two surveillance data sets are available for intermediate shell Plate C- 6404-2:

i) The 970 surveillance capsule, which was removed from the reactor vessel during the Cycle 4 refueling outage, i.e., at the end of Fuel Cycle 3, and ii) The 263° surveillance capsule, which was removed from the reactor vessel during the Cycle 11 refueling outage, i.e., at the end of Fuel Cycle 10.

The SONGS Unit 2 surveillance data were evaluated to show that the base plate and the weld met the five credibility criteria provided in RG 1.99, Revision 2. The Adjusted Reference Temperature (ART) can be calculated for intermediate shell Plate C-6404-2 and Weld 9-203 based on the two credible surveillance data sets as follows:

Per Reference 20, the fluence values are 0.507 for the 970 surveillance capsule, and 2.188 for the 2630 surveillance capsule (units:1019 n/cm 2 ). The corresponding fluence factor (ff= p0.28 - 0.1 log 0) values are calculated per Position 1.1. It follows that:

ff= 0.8 10 based on the 970 surveillance capsule, and ff= 1.212 based on the 2630 surveillance capsule The sum of the squares, X ff2, is given by:

y ff = 0.812 + 1.2122= 2.127

Per Reference 8.4, the measured ARTNDT values are:

ARTNDT= 41'F for the 970 surveillance capsule ARTNDT = 88F for the 2630 surveillance capsule It follows that:

v (ffx ARTNDT) = 0.810 x 41 + 1.212 x 88 = 139.9WF

Per Position 2.1, the chemistry factor, CF, is given by:

CF = X (ff x ARTNDT)/ X ff' = 65.8OF

The values off, ff and ARTNDT projected for 32 EFPY are calculated using Position 1.1 methodology with x = 2.375 inches at the 1/4 T location:

f= 2.4436(xlO' 9 n/cm 2 )

ff= 1.2405 ARTNDT= CF x ff= 81.67F Atahmn 22 LT-CP 5 15 Attachment ae4 f5 LTR-RUL-05-153 Page 42 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

The projected Adjusted Reference Temperature (ART) for Plate C-6404-2 for 32 EFPY at the 1/4 T location is calculated based on Position 1.1 as follows:

ART = Initial RTNDT + ARTNDT + Margin where Initial RTNDT = 20'F per Reference 18 Margin = 17'F per Position 2.1 Therefore, ART= 20 + 81.6 + 17 = 118.6 0F In the above analysis, the fluence value for the intermediate shell plates was used.

b.2 ART for Lower Shell Plate C-6404-5

Per Table 2 of Reference 19, CF = 750 F for lower shell Plate C-6404-5.

Per Reference 8.2, the projected surface fluence for 32 EFPY = 4.3707 (x10' 9 n/cm 2 ).

Using Position 1.1 calculation methodology, the projected fluence for 32 EFPY at the 1/4T location for lower shell plates is:

f= 2.4717 (x lO9 n/cm2 )

ff= 1.2434

The projected shift, ARTNDT, is given by:

ARTNDT = CF x ff= 93.3 0 F Initial RTNDT= 100 F (Reference 18)

Margin = 340 F (per Position 1.1)

It follows that ART for Plate C-6404-5 projected for 32 EFPY at the 1/4 T location is given by:

ART = Initial RTNDT + ARTNDT + Margin

= 10 + 93.3 + 34 = 137.31F In the calculation above, the fluence values for the lower shell plates were used.

Based on the analyses results in Sections b. 1 and b.2 above, the ART for Plate C-6404-5 (137.30 F) is higher then that for Plate C-6404-2 (118.60 F), so Plate C-6404-5 is bounding.

b.3 ART for Lower Shell Weld 9-203

Per Reference 18, the results of the chemical analysis performed by Combustion Engineering on Weld 9-203 showed an as-deposited copper content of 0.07% and nickel content of 0.29% by weight. The chemistry factor CF = 69 per Table 1 of Reference 19.

Using the values of f= 2.4717 (xlO' 9 n/cm 2 ), and ff= 1.2434 calculated for the lower shell at the 1/4T location in Section b.2 above, ART for Weld 9-203 can be calculated as follows:

ART = Initial RTNDT + ARTNDT + Margin

..-men t..........................2......Page R. R CP L-0....5-1 5................................Attach

_LT 43 o.........54...

LTR-RCPL-05-153 Attachment 2 Page 43 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 where Initial RTNDT = -60'F per Reference 18 Margin = 560 F per Position 1.1 ARTNDT= CF x ff= 85.80 F Therefore, ART= -60 + 85.8 + 56 = 81.8 0 F

Alternatively, two sets of surveillance data exist for Weld 9-203. Using Position 2.1, Weld 9-203 ART of 8.4 0 F is calculated in the response to RAI #9.

Therefore, the value of CF = 690 F calculated based on Position 1.1 is higher than that based on Position 2.1 using the surveillance data, CF = 32.5. Hence, the bounding estimate of ART for Weld 9-203 is 81.80 F. Note that the ART value of 137.37F for Plate C-6404-5 is actually bounding and was used to generate the P-T curves.

New surveillance data will be reviewed in accordance with the requirements in effect.

Attachment 2 5.3 Attachment LTR-KUPL-tLi-I 53 Page 44 of 54 LTX-RUFL-05-1 2 Page 44 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 3.9 RAI #9 Regulatory Position 2.1 of RG 1.99, Revision 2 states that if there is clear evidence that the copper or nickel content of the surveillance weld differs from that of the vessel weld, the measured values of ART should be adjusted by multiplying them by the ratio of the chemistry factor for the vessel weld to that for the surveillance weld.

Please indicate in the SONGS 2 and 3 PTLRs whether the copper and nickel content of the surveillance weld differs from that of the vessel weld. If so, please supplement Section 7.0 of the PTLRs for SONGS 2 and 3 with detailed calculations for determining the adjustments to the measured values for DRT for the surveillance weld, and indicate whether these adjusted values of DRT were used in the determination of the chemistry factor for the surveillance weld.

Response

SONGS Unit 2 The copper and nickel content for the surveillance weld for Unit 2 differs from the as-deposited vessel weld, Weld 9-203, as shown in Table 3. Table 3 also provides the chemistry factor obtained using Table 2, RG 1.99, Revision 2.

Table 3: SONGS 2 Best Estimate Weld Chemical Composition Weld Cu % Ni % (OCF)

Vessel Weld 9 -203'") 0.07 0.29 69 Surveillance Weld(2) 0.03 0.12 30 Surveillance Weld(3 ) 0.03 0.15 32 (1) Reference 18.

(2) Reference 21.

(3) Reference 18 provided these values based on analysis of the 970 capsule.

The value CF = 31.1 F was reported in Reference 20, and is considered reasonable based on the data in Table 3 above.

Table 4 provides the fluence values, the fluence factors and the measured ARTNDT values for the 970 and the 2630 surveillance capsules. The table also provides the adjusted ARTNDT values obtained per Position 2.1 as follows:

Adjusted ARTNDT = measured ARTNDT values multiplied by the ratio of chemistry factors; where the ratio is the vessel weld chemistry factor divided by the surveillance weld chemistry factor. It follows that the ratio of chemistry factors = 69/31.1= 2.22.

Attachment 22 Page 45 of 54 LIK-RCPL-US-153 Attachment 1AR-RUPL-0-153 Page 45 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Table 4: Adjusted Unit 2 Weld ART Based on Chemical Composition f X) Measured Adjusted (I0' n/cm2 ) ff ARTNDT

)

ARTNDT (OF )

_ _ _ __ __ _ _ __ __ _ _ _ _ _ _ _ _(OF 970 capsule 0.507 0.810 4.0 8.9 2630 capsule 2.188 1.212 23.0 51.0 (2) The fluence values were obtained from Reference 20.

Using the two sets of data in Table 4, the value of ART for 32 EFPY is calculated as follows:

Z fe =2.127 F(ffx ARTNDT) = 0.8 10 x 8.9 + 1.212 x 51.0 = 69.17F Per Position 2.1, the chemistry factor, CF, is given by:

CF = X (ffx ARTNDT)/ X ff = 32.50F Per Reference 20, the extrapolated fluence value (f) for the lower shell for 32 EFPY is 2.472 (xI019 n/cm2 ), and the corresponding fluence factor (ff) is 1.243. It follows that:

ARTNDT= 32.5 x 1.243 = 40.40 F Therefore, the projected ART value for 32 EFPY is given by:

ART = Initial RTNDT + ARTNDT + Margin

= -60 + 40.4 + 28 = 8.40F where Initial RTNDT = -60'F per Reference 18 Margin = 28 0 F per Position 2.1 The projected ART value of 8.40 F calculated for Weld 9-203 for 32 EFPY is significantly lower than the limiting ART of 137.3 0 F for Plate C-6404-5, calculated as part of the response to RAI

8 above. The ART value of 137.30 F was used to generate the P-T curves.

SONGS Unit 3 The copper and nickel content for the surveillance weld for Unit 3, Weld 9-203, differs from the as-deposited vessel weld as shown in Table 5. Table 5 also provides the chemistry factor obtained using Table 2, RG 1.99, Revision 2.

For the purpose of this calculation, the vessel as-deposited weld CF = 33.67F and surveillance weld CF = 27.27F are conservatively used to maximize the adjustment to ARTNDT.

Attachment 22 53 Attachment Page 46 of 54 LTR-RUPL-05-I UIR-RUPL-05-153 Page 46 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Table 5: SONGS 3 Best Estimate Weld Chemical Composition Cu% Ni % CF l

_ __ __ _ _ _(OF)

Vessel Weld 9-203 (l1 0.06 0.04 33.6 Vessel Weld 9-203 (1) 0.05 0.04 30.6 Surveillance Weld (1) 0.03 0.11 29.2 Surveillance Weld (l) 0.03 0.09 27.9 Surveillance Weld (2) 0.03 0.08 27.2 (1) Reference 18.

(2) Reference 22.

Examination of Table 5 shows that the available chemical analysis measurements for the surveillance weld and the vessel weld are essentially the same, and no adjustment to the values of ARTNDT is warranted. Table 6 provides the fluence values, the fluence factors and the measured ARTNDT values for the 970 and the 2630 surveillance capsules.

Table 6: Unit 3 Surveillance Weld ARTNDT f (l) ff Measured ARTNDT (10 " n/cm2 ) (OF) 970 capsule 0.8 0.937 29 2630 capsule 2.471 1.243 72 (1) The fluence values were obtained from Reference 23.

Using the two sets of data in Table 6, the value of ART for 32 EFPY is calculated as follows:

E ff2 = 2.424 FE(ffx ARTNDT) = 0.937 x 29 + 1.243 x 72 = 116.70 F Per Position 2.1, the chemistry factor, CF, is given by:

CF = X(ff xARTNDT) = 48.1 1F y ff2 Per Reference 23, the extrapolated fluence value (f) for the lower shell for 32 EFPY is 2.37 (x1019 n/cm2 ), and the corresponding fluence factor (ff) is 1.233. It follows that:

ARTNDT= 48.1 x 1.233 = 59.3 0 F Therefore, the projected ART value for 32 EFPY is given by:

Pag 47 of5

_T-CL05 Atahmn LTR-RCPL-05-153 Attachment 22 Page 47 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 ART = Initial RTNDT + ARTNDT + Margin

= -50 + 59.3 + 28 = 37.30 F where Initial RTNDT = -50 0F The higher of the two values reported in Reference 18 and Margin= 28 0F Per Position 2.1.

The projected ART value of 37.37F calculated for Weld 9-203 for 32 EFPY is significantly lower than the limiting ART of 145.8 0F for Plate C-6802-1, which was used to generate the P-T curves for Unit 3. The projected ART value calculated using Position 1.1 is 33.3 0F, which is similar to that calculated using Position 2.1.

Page 48 of 54 LIR-KUPL-U-153 LIK-RUFL-U-5-153 AttachmentZ2 Attachment Page 48 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

4.0 REFERENCES

1. WCAP-16005-NP, Rev. 03, "San Onofre Nuclear Generating Station Unit 2 RCS Pressure and Temperature Limits Report," dated November 2004, Westinghouse Electric Company.

2. WCAP-16167-NP, Rev. 00, "San Onofre Nuclear Generating Station Unit 3 RCS Pressure and Temperature Limits Report," dated November 2004, Westinghouse Electric Company.

3. ASME Code Section XI, Division 1, Appendix G, July 1999.

4. CEOG Task 1174 Final Report CE NPSD-683-A, Rev. 06, "Development of a RCS Pressure and Temperature Limits Report for the Removal of P-T Limits and LTOP Requirements from the Technical Specifications," April 2001.

5. ABB Report 063-PENG-ER-096, Rev. 00, "Technical Methodology Paper Comparing ABB/CE PT Curve to ASME Section III, Appendix G," January 22, 1998.

6. Westinghouse CalcNote CN-CI-02-54, Rev. 03, "SONGS Unit 2 RCS Pressure-Temperature Limits and LTOP Enable Temperatures for 32 EFPY," October 08, 2004.

7. Westinghouse CalcNote CN-CI-04-37, Rev. 01, "SONGS Unit 3 RCS Pressure-Temperature Limits and LTOP Enable Temperatures for 32 EFPY," October 29, 2004.

8. Code of Federal Regulations 10 CFR Part 50.55a Codes and Standards, Section 1 Background, September 26, 2002.

9. Westinghouse Policies & Procedures, Nuclear Services Edition, Revision 21.

10. CE Instruction Manual, "Reactor Vessel Assembly, San Onofre Unit No. 2, Southern California Edison," Book No. 71170, Vol. 1.

11. SCE Calculation No. M-00 11-071, Rev. 2, "SONGS Unit 2 Adjusted Referenced Temperature for 20 & 32 EFPY," November 20, 2003.

12. SCE Calculation No. M-001 1-063, Rev. 01, "Revised PT Curves for 20 EFPY," May 31, 1994

13. Westinghouse Correspondence, S-MCM-80-126, "Materials Data for SoCal 2&3 Pressure Temperature Limit Curves," February 8, 1980.

14. CE Design Report CENC-1292 "Analytical Report for Southern California, San Onofre Unit 3 Reactor Vessel," August 1977.

15. Attachment I, Calculation M-DSC-373, "Reactor Pressure Vessel Minimum Bolt-up Temperature" to Southern California Edison Letter to U.S. Nuclear Regulatory Commission, "Docket Nos. 50-361 and 50-362, Proposed Technical Specification Change Number NPF-10115-516, Reduce the Minimum Bolt-up Temperature for Reactor Vessel Head Bolts when they are Tensioned, San Onofre Nuclear Generating Station Units 2 and 3," sent May 3, 2000.

16. Westinghouse Correspondence S-MCM-130, "RCP Material Data for San Onofre III," August 1, 1980.

17. CE Report TR-S-MCM-001-P (SCE Document Control / Transmittal Number C780501G0078),"Summary Report on Manufacture of Test Specimens and Assembly of Capsules for Irradiation Surveillance of San Onofre - Unit 2 Reactor Vessel Materials."

18. Letter from Walter C. March, SCE, to U. S. Nuclear Regulatory Commission Dated June 22, 1994.

Subject:

Docket Nos. 50-361 and 50-362, Revision to Supplemental Response to Generic Letter 92-01, Revision 1,"Reactor Vessel Structural Integrity, 10 CFR 50.54(f)" San Onofre Nuclear Generating Station Units 2 and 3.

LTR-RCPL-05-153 Attachment 2 Page 49 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

19. Regulatory Guide 1.99, Revision 2.

20. SCE Report S023-901-C264, Revision l,"Analysis of the 263° Capsule, Southern California Edison Company, San Onofre Unit 2 Nuclear Generating Station."

21. CE Report S-TR-MCS-002 dated May 27, 1978 (SCE Document CDCC 56396), "Southern California Edison San Onofre Unit 2, Evaluation of Baseline Specimens, Reactor Vessel Materials Irradiation Surveillance Program."

22. CE Report TR-S-MCM-004 (SCE Document Control / Transmittal Number C791130G0097),"Southern California Edison San Onofre Unit 3, Evaluation of Baseline Specimens."

23. SCE Report S023-901-C274, Rev. 1, "Analysis of the 2630 Capsule, Southern California Edison Company, San Onofre Unit 3 Nuclear Generating Station."

U of _54 Pae LI OF.

LI A'L-S-I%

K-1kL;FL-U_')-1.)J Attachment __

AR Att......................_achen 2 Page 50 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Appendix A Justification for Exemption to Apply Alternate Method of Calculating the Stress Intensity Factor KINI due to Internal Pressure Loading for San Onofre Units 2 and 3 Introductory Statements:

Pursuant to 10CFR50.90, Southern California Edison (SCE) hereby requests the use of an alternate methodology for calculation of crack tip stress intensity factor KIM for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 reactor vessel beltline regions subjected to internal pressure loading. This alternate methodology by Westinghouse has been used in topical report CE NPSD-683, Revision 6, dated March 16, 2001. This methodology was developed and used in 1998 for Indian Point Unit 3 in a previous submittal report (Docket No. 50-286, TAC No. M99928). The approach was reviewed by the NRC and concluded to be acceptable (Section 2.5.4 paragraph 4 of the report).

A justification for the application of this alternate method to SONGS is given below.

Justification for Exemption 10 CFR 50.60(b) allows usage of alternatives to the requirements described in Appendix G and H of 10 CFR 50 when the exemption is granted by the NRC.

In accordance with 10 CFR 50.12(a), Southern California Edison (SCE) requests an exemption from the regulations of 10CFR 50.60, "Acceptance Criteria for Fracture Prevention Measures for Light-Water Nuclear Power Reactors for Normal Operation." The exemption request would allow SONGS Units 2 and 3 to use an alternate methodology for calculation of crack tip stress intensity factor KIM for SONGS reactor vessel beltline regions subjected to internal pressure loading, in lieu of the methodology cited in ASME Boiler and Pressure Vessel Code, Appendix G.

10 CFR 50.12(a) states that the NRC may grant exemptions from the requirements of the regulations contained in 10CFR50 which are:

1) authorized by law;

2) will not present an undue risk to the public health and safety;

3) consistent with the common defense and security; and

4) special circumstances, as defined by 10 CFR 50.12(a)(2) are present.

The standards for the exemption are justified, as described below.

1) The requested exemption is authorized by law.

The NRC is authorized by law to grant this exemption. Requirements in 10 CFR 50.60 state that the use of alternative methods to 10 CFR 50, Appendix G is acceptable when an exemption is granted by the NRC.

LIarm UA-'L-U)-Dic A._tta __lnl .L Pg 51 of 54 LJK-XUFL-U.:)-1_)J Attachmenl.,_' Pages5 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

2) The requested exemption does not present an undue risk to the public health and safety.

The proposed exemption request has no impact on the safe operation of the plant. An exemption from the requirements would allow the use of an alternate methodology to calculate the membrane loading stress intensity factor. Specifically, this methodology uses a finite element base influence function under internal pressure loading. The results of this methodology are comparable to the results obtained using the ASME Appendix G methodology as demonstrated below.

ASME Code uses the procedure in Article G-2214 for axial surface flaws. In this procedure, stress intensity factor under internal pressure loading is given by (U.S. Customary units)

KiM = MAm (P) t The magnification factor MM for inside axial flaws is given by:

MA, =1.85 for .1t<2 or t<4 MA, = 0.926A/; for 2*<1t3.464 or 4< t < 12 MA, = 3.21 for t > 3.464 or t > 12 and for outside flaws by:

MM =1. 7 7 for t<2 or t<4 MM = 0.893fth for 2 < t < 3.464 or 4 < t < 12 MM = 3.09 for 17>3.464 or t >12 where:

KIM is the stress intensity factor for membrane loads (ksilin);

p is the internal pressure (ksi);

Ri is the vessel inner radius (in); and t is the vessel wall thickness (in).

a, c

[ km = Mxf R t

I and the applied stress intensity factor Kim for any given pressure, p, in ksi, is given by LTR-RCPL-05-153 Attachment 2 Page 52 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 KIl = pk,lA, a, c u$ CRACK OUT$=E CR*A FEMs used in Computing klM due to Internal Pressure Loading LTR-RCPL-05-153 Attachment 2 Page 53 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Therefore, this exemption request does not present an undue risk to the public health and safety.

3) The requested exemption will not endanger the common defense and security.

The common defense and security are not affected by this exemption request.

4) Special Circumstances, as defined by 10 CFR 50.12(a)(2) are present.

10 CFR 50.12(a)(2) states that the NRC will not consider granting an exemption unless special circumstances are present. This exemption meets the special circumstances listed in 10 CFR 50.12(a)(2)(ii).

10 CFR 50.12(a)(2)(ii) - Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

The primary purpose of 10 CFR 50.60 is to protect the reactor vessel against non-ductile failure. The use of the Westinghouse alternate methodology requested by this exemption provides greater operational flexibility while still maintaining reactor vessel integrity. In addition, use of the Westinghouse methodology to generate pressure-temperature curves yields comparable results to the use of the ASME Appendix G methodology. Therefore, the reactor vessel is protected against non-ductile failure and the underlying purpose of the rule is achieved.

Conclusion The use of the Westinghouse alternate methodology to calculate the membrane stress intensity factor, KIM, provides comparable results to that of the ASME Section XI, Division I, Appendix G, and provides adequate protection of the reactor vessel against non-ductile failure.

Page 54 of 54 LTRK-I1(FL-U.5-1.53 Attachiment ZZ LIK-K(.A'L-1J-Di Attachment Page 54 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 LTR-RCPL05-153, Aftachment 2 Response to NRC Request for Additional Information on WCAP-16005-NP, Rev. 03, "San Onofre Nuclear Generating Station Unit 2 RCS Pressure and Temperature Limits Report"; and WCAP-16167-NP, Rev. 0, "San Onofre Nuclear Generating Station Unit 3 RCS Pressure and Temperature Limits Report" December 14, 2005 Revision 0 Prepared by:

Steven Slowik, Principal Engineer Regulatory Compliance & Plant Licensing Reviewed by: -A P."

Virgil Pagtrn, Princip l Lngineer Regulatory Compliance & Plant Licensing Westinghouse Electric Company LLC P.O. Box 355 Pittsburgh, PA 15230-0355 C 2005 Westinghouse Electric Company LLC All Rights Reserved

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Table of Contents 1.0 Background ................................................. 4 2.0 Quality Assurance .................................................. 4 3.0 RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION ..................... ........... 4 3.1 RAI#1 ................................................. 4 3.2 RAI#2.........................................................................................................................2..

R . ..... 11 3.3 RAI #3 ................................................. 14 3.4 RAI #4 ................................................. 17 3.5 RAI #5 ................................................. 30 3.6 RAI #6 ...... . 38 3.7 RAI #7 ...... 39 3.8 RAI #8 ...... 40 3.9 RAI #9 ...... 45 4.0 References ...... 49 Appendix A .51 List of Tables Table 1: Pressure Stress Influence Coefficients, KIM .16 Table 2: Copper and Nickel Content by Weight (percent) .41 Table 3: SONGS 2 Best Estimate Weld Chemical Composition .45 Table 4: Adjusted Unit 2 Weld ART Based on Chemical Composition .46 Table 5: SONGS 3 Best Estimate Weld Chemical Composition .47 Table 6: Unit 3 Surveillance Weld ARTNDT....................................................................................... 47 Attachment 22 LIR-RCPL-05-153 Attachment L'I'R-RCPL-05-153 Page 2 of 54 Page 2 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 List of Figures Figure 1: FE Models used in Computing KINI due to Internal Pressure Loading ...................................... ....... 13 Figure 2: Unit 2 Heatup 60F/hr Through-wall Thermal Gradients at Crack Tips .................................... ....... 14 Figure 3: Unit 2 Heatup Thermal Stress Intensity Factors KIT at Outside Crack Tip ............................... ....... 15 Figure 4: Unit 2 Cooldown 100F/hr Through-wall Thermal Gradients at Crack Tips ............................. ....... 15 Figure 5: Unit 2 Cooldown Thermal SIF KIT at Inside Crack Tip ............................................................. ...... 16 Figure 6: Unit 2 Steady-state P-T Curve ......................................................................... 19 Figure 7: Unit 2 Heatup P-T Curves ......................................................................... 19 Figure 8: Unit 2 Heatup P-T Curve Enveloped for SF/hr Transient ......................................................... ....... 20 Figure 9: Unit 2 Heatup P-T Curve Enveloped for IOF/hr Transient ...................................................... ........ 20 Figure 10: Unit 2 Heatup P-T Curve Enveloped for 3OF/hr Transient ............................................................ 21 Figure 11: Unit 2 Heatup P-T Curve Enveloped for 40F/hr Transient ............................................................ 21 Figure 12: Unit 2 Heatup P-T Curve Enveloped for 60F/hr Transient .................................................... ........ 22 Figure 13: Unit 2 Heatup P-T Curve Envelopes ......................................................................... 22 Figure 14: Unit 2 Cooldown P-T Curves ......................................................................... 23 Figure 15: Unit 2 Cooldown P-T Curve Enveloped for 100F/hr Transient ..................................................... 23 Figure 16: Unit 2 Cooldown P-T Curve Envelopes ......................................................................... 24 Figure 17: Unit 3 Steady-state P-T Curve ......................................................................... 24 Figure 18: Unit 3 Heatup P-T Curves ......................................................................... 25 Figure 19: Unit 3 Heatup P-T Curve Enveloped for 5F/hr Transient .............................................................. 25 Figure 20: Unit 3 Heatup P-T Curve Enveloped for 10F/hr Transient ............................................................ 26 Figure 21: Unit 3 Heatup P-T Curve Enveloped for 3OF/hr Transient ............................................................ 26 Figure 22: Unit 3 Heatup P-T Curve Enveloped for 40F/hr Transient ............................................................ 27 Figure 23: Unit 3 Heatup P-T Curve Enveloped 60F/hr Transient .................................................................. 27 Figure 24: Unit 3 Heatup P-T Curve Envelopes ......................................................................... 28 Figure 25: Unit 3 Cooldown P-T Curves ......................................................................... 28 Figure 26: Unit 3 Cooldown P-T Curve Enveloped for 100F/hr ..................................................................... 29 Figure 27: Unit 3 Cooldown P-T Curve Envelopes ......................................................................... 29 Figure 28: Unit 2 Heatup P-T Curves with Min. Temperature Requirements, Control Room ........................ 35 Figure 29: Unit 2 Cooldown P-T Curves with Min. Temperature Requirements, Control Room ................... 35 Figure 30: Unit 2 Cooldown P-T Curves with Min. Temperature Requirements, Remote Shutdown Panel .. 36 Figure 31: Unit 3 Heatup P-T Curves with Min. Temperature Requirements, Control Room ........................ 36 Figure 32: Unit 3 Cooldown P-T Curves with Min. Temperature Requirements, Control Room ................... 37 Figure 33: Unit 3 Cooldown P-T Curves with Min. Temperature Requirements, Remote Shutdown Panel .. 37 LTR-RCPL-05-153 Attachment 2 Page 3 Of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

1.0 BACKGROUND

In November 2004, WCAP-16005-NP, Rev. 03, "San Onofre Nuclear Generating Station Unit 2 RCS Pressure and Temperature Limits Report" and WCAP-16167-NP, Rev. 0, "San Onofre Nuclear Generating Station Unit 3 RCS Pressure and Temperature Limits Report" were provided to Southern California Edison. These reports were then submitted to the NRC by SCE as part of a request for license amendment.

The NRC has reviewed these submittals and has compiled a list of requests for additional information (RAIs). This document provides responses to these RAIs.

2.0 QUALITY ASSURANCE This work was completed under the requirements of the Westinghouse Quality Assurance Program (Reference 9). References are provided at the end of this document following the RAI responses.

3.0 RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION Each NRC RAI is listed by number and is followed by a response.

3.1 RAI #1 In the staff's safety evaluation (SE) on topical report CE-NPSD-683, Revision 6, dated March 16, 2001, the staff included 26 action items that would need to be addressed in a pressure-temperature (P-T) limits report (PTLR) license amendment request that invoked the methods of the topical report. Your PTLR submittal of January 28, 2005, does not specifically identify how the proposed San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3) PTLRs resolve the action items in the SE of March 16, 2001.

The staff requests that you supplement your application with your responses to these 26 action items. If your PTLR submittal already includes information that satisfies any of these action items, please specify which information in the PTLR satisfies resolution of a particular action item. If the PTLR does not include information which satisfies a particular action item, please provide supplemental information which satisfies resolution of the particular action item of concern.

The staff recognizes that several of these action items have become obsolete due to updates in the allowable editions and addenda of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section Xl, Appendix G, which have been incorporated by reference in Title 10 of the Code of Federal Regulations, Part 50 (10 CFR Part 50). If such an action item falls under this category please designate it as such.

Attachment 22 Page 4 of 54 LTR-RCPL-U5- 153 Attachment LTR-RUPL-0-153 Page 4 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

Response

Responses to the 26 action items of the SE are provided with respect to the SONGS Unit 2 and SONGS Unit 3 PTLRs prepared by Westinghouse in WCAP-16005-NP, Revision 3 for Unit 2 and WCAP-16167-NP, Revision 0 for Unit 3 (References I and 2, respectively). For each numbered response below the NRC action item is paraphrased and is followed by a statement as to how the action has been addressed in the respective PTLR, if it has become obsolete, or if it is addressed in a response to another RAI.

1) Describe the methodology used to calculatethe neutronfluence valuesfor the reactor vessel materials.

a. Describe whether the methodology used is consistent with Draft Regulatory Glide 1053.

Section 1.0 of References 1 and 2 state that the neutron fluence methodology is consistent with the guidance of Regulatory Guide 1.190.

b. Describe the computer codes used to calculatethe neutronfluence.

The computer codes used to calculate the neutron fluence are described in Section 1.1.1 of References 1 and 2.

c. Describe how the computer codes used to calculate the neutronfluence were benchmarked, The computer codes used to calculate the neutron fluence were benchmarked as described in Section 1.4 of References I and 2.

2) Provide the values ofneutronfluence usedfor the adjustedreference temperature calculations including the valuesfor the innersurface (ID), 1/4 T and 3/4 T locations.

a. For Unit 2, Section 4, Tables 4-2 and 4-3 and Subsection 4.4 of Reference I provide the following peak values at 32 EFPY: clad/base metal interface is 4.147x I019 n/cm2 ; '/4 T is 2.472x10'9 n/cm 2 ; 3/4 T is 0.878x10 19 n/cm 2 .

b. For Unit 3, Section 4, Tables 4-2 and 4-3 and Subsection 4.4 of Reference 2 provide the following peak values at 32 EFPY: clad/base metal interface is 3.976x 0 9 n/cm 2 ; 1/44 T is 2.370x10'9 n/cm 2 ; 3/4 T is 0.8419x10' 9 n/cm 2 .

3) Provide the surveillance capsule withdrawalschedule in the PTLR or by reference.

The surveillance capsule withdrawal schedule is provided in Section 2, Table 2-2 of References 1 and 2.

4) Reference the surveillance capsule reports by title andnumber if the RTNDT values are calculatedusing RPV surveillancecapsule data.

The title and number of the surveillance capsule reports are given in References 4 and 15 of Reference I (Unit 2) and Reference 2 (Unit 3).

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WESTINGHOUSE NON-PROPRIETARY CLASS 3

5) Provide a descriptionof the analyticalmethod used in the energy addition transient analysis.

This information is provided in Section 3.2.1.3 of the References 1 and 2, and also in the Reference 18 document of these references.

6) Provide a description of the analyticalmethod used in the mass additiontransient analysis, ifdifferent from that in Section 3.3.5 of the topical report.

This information is provided in Section 3.2.1.2 of References 1 and 2. Also, this section of References 1 and 2 will be revised to remove the statement "...and the equivalent mass addition that results from energy additions" in order to be consistent with the supporting analyses of record. The reference to equivalent mass additions incorrectly implies additional contributions to the transient are provided by the pressurizer heaters and by decay heat.

7) Provide a description of the methodfor selection of relief valve setpoints.

This information is provided in Section 3.2.1.1 of References 1 and 2.

8) Provide ajustificationfor use ofsubcooled water conditions or a steam volume in the pressurizer.

The RCS is considered water solid for the transients as described in Section 3.2.1 of References I and 2.

9) Provide ajustificationfor a less conservative methodfor determinationof decay heat contribution if the method used is less conservative than the "most conservative method" describedin the topicalreport; The analyses of record that support the SONGS Units 2 and 3 LTOP energy addition and mass addition transients were performed using methodologies that preceded approval of the methods described in the topical report. The SONGS energy addition analysis used an assumed value of 1% decay heat, relevant to approximately 3.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months post shutdown. This is considered a conservative estimate of the cooldown time needed to achieve the LTOP enable temperature, and is therefore conservative for the decay heat contribution. As noted in Action Item 6 of the staff's safety evaluation, the SONGS mass addition transient does not include decay heat contribution.

10) Providejustificationfor operatoraction time used in transientmitigation or termination.

The transient analyses of References I and 2 that support SONGS Units 2 and 3 do not assume operator action for mitigation of the transients.

11) Provide correlationsusedfor developingpower operatedreliefvalve (PORV) discharge characteristics.

SONGS Units 2 and 3 do not have PORVs and therefore do not credit pressurizer PORV discharge characteristics in the LTOP transient analyses.

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WESTINGHOUSE NON-PROPRIETARY CLASS 3

12) Providespringrelief valve dischargecharacteristicsif differentfrom those described in the topical report or if the peak transientpressure is above the set pressure of the valve plus 10 percent.

This information is provided in Section 3.2.1.1 of References I and 2.

13) Provide a descriptionof how the reactorcoolant temperature instrumentationuncertainty was accountedfor.

Refer to the response to RAI #6.

14) Provide ajustificationfor the mass and energy addition transientmitigation which credit presence of nitrogen in the pressurizer.

SONGS Units 2 and 3 do not credit the presence of nitrogen in the pressurizer in the LTOP transient analyses.

15) Identify and explain any other deviationfrom the methodology included in Section 3.0 of the topicalreport.

There are no other deviations from the methodology described in Section 3.0 of References l and 2.

16) With respect to the methods used to calculate the adjustedreference temperature, identify the limiting materials and correspondingRTNDT values at 1/4 T and 3/4 T (where "T" is vessel thickness).

a. For Unit 2, the RTNDT values at 32 EFPY at the 1/4 T and 3/4 T locations are provided in Section 4 of Reference 1. Those values are 137.3 0 F for lower shell plate C-6405-5 and 116.60 F for lower shell plate C-6405-4, respectively.

b. For Unit 3, the RTNDT values at 32 EFPY at the 1/4 T and 3/4 T locations are provided in Section 4 of Reference 2. Those values are 145.8 0 F and 125.5 0 F respectively for intermediate shell plate C-6802-1.

17) Identify the limiting materialand correspondingRTpTs value calculatedin accordancewith 10 CFR 50.61.

a. For Unit 2, the RTPTS value at 32 EFPY at the limiting location is provided in Section 4 of Reference 1. That value is 146.3 0 F for lower shell plate C-6405-5.

b. For Unit 3, the RTPTS value at 32 EFPY at the limiting location is provided in Section 4 of Reference 2. That value is 154.60 F for intermediate shell plate C-6802-1.

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7t_

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WESTINGHOUSE NON-PROPRIETARY CLASS 3

18) Ensure that the ferriticRPV materials that have accumulatedneutronfluence in excess of lxIO17 n/cm2 will be assessed accordingto Section 4 of the topical report (Reference 4),

regardlessof whether the materials are locatedwithin the region immediately surrounding the active core.

a. For both Units 2 and 3, each ferritic plate and weld material located within the region immediately surrounding the active core was evaluated to identify the limiting material at the 1/4 T and 3/4 T locations. The results of that evaluation are provided in Table 4-4 of References I and 2. The adjusted RTNDT values for the limiting materials were used to establish the heatup and cooldown limits. All of the materials assessed in Table 4-4 receive a high neutron fluence being adjacent to the active core and, therefore, are considered in the determination of the limiting beltline material.

b. For the ferritic plate and weld materials located above and below the region immediately surrounding the active core, the neutron fluence is much lower than the fluence relative to the materials immediately surrounding the active core region. The initial RTNDT values of those ferritic materials are comparable to the initial RTNDT values for the materials assessed in Table 4-4. The adjustment to RTNDT will, therefore, also be smaller than for the materials surrounding the active core. Hence, the ferritic plate and weld materials located above and below the region immediately surrounding the active core in the SONGS Units will never be limiting with respect to establishing the heat-up and cool-down limits. (Note that these additional materials comprise the upper shell course plates and welds that are located immediately above the intermediate shell course plates and welds. Each of the lower and intermediate shell course plates and welds are assessed in Table 4-4.)

c. The initial RTNDT values for the ferritic plate and weld materials located above and below the region immediately surrounding the active core are used to establish other aspects of the heat-up and cool-down limits. These other limits include the bolt-up temperature, the lowest service temperature, and the flange limits.

19) Identify which method (ie., Kic or KI4) will be used to calculatethe reference intensity factor (KIR) values for the RPVas afunction of temperature.

The reference stress intensity factor (SIF) used in both Units 2 and 3 is the equation for K1 c given in Appendix G of the ASME Code (Reference 3). It is expressed as:

KIc = 33.2 + 20.734e 0-02(T-RTxDT)

The parameter T is the temperature of the material at the hypothetical crack tip (0 F), RTNDT is the material nil-ductility transition reference temperature (0 F), and K1c is the crack initiation fracture toughness (ksilin).

20) If Code Case N-640 andK1 c are used as the basisfor calculatingthe KIR values, submit an exemption request to use the methods of Code Case N-640 andapply them to the P-T limit calculations.

The determination of the Pressure-Temperature (P-T) curves is consistent with Section XI of the 2000 Edition of the ASME Code. This Code Edition has incorporated the K1 c criteria for the allowable fracture toughness. The Code of Federal Regulations part 50.55a has LKRP-- 15 Attacmet _ ,,ge 8 of 5 L'1'K-KCPL-U5-153 Attachment 2 Page X of'54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 approved this ASME Code Edition in Reference 8. Therefore, Code Case N-640 is not used and an exemption request is not submitted.

21) Applyfor an exemption against requirements of Section IV.A.2 ofAppendix G to Part50 to apply the CE NSSS methods to their P-T curves.

,c The justification to support an exemption request for use of the CE NSSS methodology of pressure stress KIM is included as Appendix A of this document.

22) Include in the PTLRs the P-T curvesfor heatup, cooldown, criticality, and hydrostaticand leak tests of the reactors.

P-T curves for heatup, cooldown, hydrostatic test and criticality have been included in the Westinghouse Calculations of References 6 and 7. Details of heatup, cooldown and hydrostatic test curves for the uncorrected case are included as Figures 6 through 27 of this document. Allowable P-T limit curves for the criticality condition were obtained from References 6 and 7 and are shown in Figures 28 through 33 of this document.

23) Demonstrate how the P-T curvesforpressure testing conditions and normal operationswith the core criticaland not-criticalwill be in compliance with the appropriateminimum temperature requirements as given in Table I to Appendix G to Part50.

Minimum temperature requirements have been incorporated into the final composite P-T curve limits in Figures 5.1 through 5.3 of the PLTR reports (References 1 and 2). These figures demonstrate that the P-T curves comply with Appendix G to 10 CFR 50.

Please refer to RAI #5 of this document for a further discussion of how compliance is demonstrated.

24) With respect to the evaluation ofplant specific surveillance data, licensees need to include in their PTLRs the supplemental surveillance data and calculationsof the chemistryfactors if the surveillance data are usedfor the calculationsof the adjustedreference temperatures.

a. For Unit 2, the determination of chemistry factors is discussed in Section 4 of Reference I and the surveillance data are discussed in Section 7. The chemistry factors were determined in accordance with Regulatory Guide 1.99, Revision 2, using Regulatory Position 1.1. The bases for the chemical content of the vessel and surveillance plates and welds are provided in the responses to Generic Letter 92-01 (Reference 16 in Reference 1). Additional Page 9 of 54 LTR-RCPL-05-153 LTR-RCPL Attachment 22 153 Attachment Page 9 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 information is also provided in the responses to RAIs #8 and #9. Surveillance data were evaluated but they are not used for the calculations of the adjusted reference temperatures.

b. For Unit 3, the determination of chemistry factors is discussed in Section 4 of Reference 2 and the surveillance data are discussed in Section 7. The chemistry factors were determined in accordance with Regulatory Guide 1.99, Revision 2, using both Regulatory Position 1.1 and 2.1. Additional information is also provided in the response to RAI #9. No supplemental surveillance data were used.

25) Providethe evaluation ofwhether the surveillance data are credible in accordancewith the credibility criteriaofRG 1.99, Revision 02.

a. For Unit 2, the credibility of the surveillance data is established in Section 7 of Reference 1.

Additional information is also provided in the responses to RAIs #8 and #9.

b. For Unit 3, the credibility of the surveillance data is established in Section 7 of Reference 2.

Additional information is also provided in the response to RAI #9.

26) In addition, if licensees seek to use surveillance datafrom supplementalplant sources, licensees must identify the source of the data, and either identify by title and number the safety evaluation report ....; or compare the licensee's data ... andsubmit the proposed integratedsurveillanceprogram and evaluation of the datafor the NRCfor review and approval.

The licensee does not seek to use surveillance data from supplemental plant sources for either Units 2 or 3. In either case there is a plant-specific surveillance program. Four surveillance capsules remain in each unit, and the materials in the surveillance capsules were selected in accordance with ASTM E185-73. In neither case was it necessary or feasible to obtain surveillance data from another reactor vessel surveillance program.

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.. s.ag L'UK-KUPL-05-153 Atacmnt LI-CL0-5 Attachment Zss Z P1age 10 ofS54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 3.2 RAl #2 The ASME Code, Section Xl, Appendix G provides a methodology for calculating stress intensity factors corresponding to membrane tension (KIM) and thermal stress (KIT) for the postulated axial defect. Calculations of KIT are based on stress influence coefficients from finite element modeling (FEM) analyses for inside (S7) and outside (S4T) surface flaws. Calculations of the maximum allowable KIM are based on a closed-form solution to an equation such as 2KIM + KIT ' Kic, where KIT has been determined from solutions based on stress influence coefficients, and Kc was determined using the equation representing the analytical approximation to the lower bound fracture toughness curve, Kc (in ksi*sqrt(in.)) = 33.2 + 20.734exp[0.02(T- RTNDT)J, where RTNDTis the material nil- ductility transition reference temperature and T is the actual temperature of the material.

The Combustion Engineering (CE) nuclear steam supply system (NSSS) methodology differs from the ASME Code, Section Xl, Appendix G methodology in several respects. The CE NSSS methodology for calculating KIT is based on thermal influence coefficients from FEM analyses, as opposed to stress influence coefficients. Furthermore, the CE NSSS methodology for calculating KIM does not involve a closed-form solution based on calculations of KIT and Kc factors, and instead applies FEM methods for estimating the KIM factors.

Please supplement Section 5.0 of the SONGS 2 and 3 PTLRs with a discussion of the specific methodologies that will be applied in the PTLRs for SONGS 2 and 3 for calculating stress intensity factors at the 114T and 3/4T crack depth locations:

a. Discuss the methodology for calculating the thermal stress intensity factor, KIT.

b. Discuss the methodology for calculating the stress intensity factor corresponding to membrane tension resulting from pressure loading of the reactor vessel, KIM. Please specify whether KIM is determined by obtaining a closed-form solution (as prescribed by the ASME Code,Section XI, Appendix G) or determined by applying FEM methods (as prescribed by the CE NSSS methodology).

Per your response to action item 21 in RAI 1, if your methodology applies the CE NSSS method for calculating KIM stress intensity values, then your application will need to include a request for an exemption from the requirements of 10 CFR Part 50, Appendix G forP-Tlimits. The need foran exemption for calculating P-T limits using the CE NSSS method is specified in the fourth paragraph (pages 20- 21) of Section 2.5.4 and in action item 21 (page 27) of Section 5.0 of the SE on topical report CE-NPSD-683, Revision 6, dated March 16, 2001. The CE Owners Group (CEOG) agreed to this requirement in their final version of topical report CE-NPSD-683, Revision 6. The requirement for the exemption is specified in the 'Note" on page 5-15 of the topical report.

Response

Calculations of crack tip stress intensity factors due to thermal loads, KIT, are based on thermal influence coefficients developed using two dimensional (2D) finite element analyses with linear, quadratic and cubic temperature profiles across the vessel wall thickness. The influence coefficients are computed for postulated inside (1/4 thickness) and outside (3/4 thickness) surface flaws and are then corrected to account for the 3D elliptical geometry using the procedures of Appendix A of Section XI of the ASME Code.

t a, c LIR-RUFL-0-153 Attachment 2 Page I11 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Using the KIM values due to the applied pressure loading, the ASME Code procedure using the criteria:

2K,1M + Kg < Kic was followed in computing the maximum allowable for thermal transient cases, and 1.5K1,1 < Kjc for hydrostatic test cases.

Per the conditions listed in the safety evaluation for topical report CE NPSD-683 (Reference 4) a request for exemption from the requirements of IOCFR Part 50, Appendix G, is provided in Appendix A of this document.

LI-CLU 5 Attoa Achment 2L Pae 1.a _rt54: rr LA R-RUFL-0-153 Attactiment P1age 12of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3

-I CRAMC OUTSM CHI Figure 1: FE Models used in Computing KIM due to Internal Pressure Loading Attachment 22 Page 13 of54 LTR-RCPL 153 Attachmcnt LTR-RCPL-05-153 Page 13 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 3.3 RAI #3 In support of the NRC staff's review of the P-T limit curves contained in the PTLR submittal, please supplement your application with data for the through-wall thermal gradients (A7) and thermal stress intensities (KIT) forthe 1/4Tand3/4Tcrackdepth locations. These data are necessary for the NRC staff to perform independent calculations of P-T limits to verify that the P-T limit curves are at least as conservative as those that would be obtained as a result of applying the methods of 10 CFR Part 50, Appendix G, or as modified using the CE NSSS methodology. In addition, if you are requesting to use the CE NSSS methodology for KIM determinations, please submit the plant-specific KIM data to support the staff's review of these calculations.

Response

a, c Figure 2: Unit 2 Heatup 60F/hr Through-wall Thermal Gradients at Crack Tips I-XR-RUFL-0-153 Attachment 2 Page 14 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 3: Unit 2 Heatup Thermal Stress Intensity Factors KIT at Outside Crack Tip a, c Figure 4: Unit 2 Cooldown 100F/hr Through-wall Thermal Gradients at Crack Tips LTR-RCPL-05-153 Attachment 2 Page 1S of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 5: Unit 2 Cooldown Thermal SIF KIT at Inside Crack Tip The membrane stress intensity factor coefficients KIM due to unit (1000 psi) internal pressure loading for SONGS reactor vessel geometry with a base metal thickness of 8.625 inches for inside and outside crack tip locations are given in the following table.

Table 1: Pressure Stress Influence Coefficients, KIM a, c Per the topical report (Reference 4) a request for exemption from the requirements of I OCFR Part 50, Appendix G, is provided in Appendix A of this document.

Attachment 22 Page 16 of 54 LTR-RCPL-05-153 Attachment LTR-RCPL-05-153 Page 16 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 3.4 RAI #4 In all cases P-T limit curves must be determined using the most limiting conditions in the reactor vessel. For heatup and cooldown transients the application of the PTLR methodology and calculations of P-T limits must always take into consideration the different conditions at the 1/4T and 3/4T locations during the thermal transient, and the resulting P-T limit curves must always represent the most limiting of these conditions.

Please supplement Section 5.0 of the SONGS 2 and 3 PTLRs with a discussion of how the P-T limit curves account for the most limiting conditions in the reactor vessel. The discussion should address the following points:

a. Please discuss how the calculation of P-T limit curves for SONGS 2 and 3 addresses heatup and cooldown transients, specifically taking into consideration the different conditions at the 1/4T and 3/4T crack depth locations.

b. Please discuss how the calculation of P-T limit curves for SONGS 2 and 3 addresses the assessment of the 1/4T location for steady state conditions in addition to the 1/4T and 3/4T locations under heatup and cooldown transient conditions. Please supplement the P-T limit curves for SONGS 2 and 3 with a P-T limit curve representing the 1/4T location under steady state conditions.

Response: IC I.,-

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153Attachment Page 17 of54 LTR-RCPL-05-153 Attachment 2 LTR-RCPL Page 17 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c li Attachment 22 LTR-RCPL-U5- 153 Attachment LTXR-RCPL-05-153 rage 180154 rage 18 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 6: Unit 2 Steady-state P-T Curve a, c Figure 7: Unit 2 Heatup P-T Curves LTR-RCPL-05-153 Attachment 2 Page 19 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 8: Unit 2 Heatup P-T Curve Enveloped for 5F/hr Transient a,c r

Figure 9: Unit 2 Heatup P-T Curve Enveloped for IOF/hr Transient Attachment _

K-KUFL-U5-1_')i A~tacflent 1A K-LP-U-D LI Pag 20 of 54.........

2 Page 20 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c "N1 Figure 10: Unit 2 Heatup P-T Curve Enveloped for 30F/hr Transient a, c Figure 11: Unit 2 Heatup P-T Curve Enveloped for 40F/hr Transient Attachment 22 153 Attachment Page 21 of54 LTR-RCPL LTR-RCPL-05-153 Page 21 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 12: Unit 2 Heatup P-T Curve Enveloped for 60F/hr Transient a,c Figure 13: Unit 2 Heatup P-T Curve Envelopes LTR-RCPL-05-153 Attachment 2 Page 22 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 14: Unit 2 Cooldown P-T Curves a, c Figure 15: Unit 2 Cooldown P-T Curve Enveloped for IOOF/hr Transient tahet2 LT-CP 5 15 Attachment ae2 f5 LTR-RCPL-05-153 2 Page 23 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 16: Unit 2 Cooldown P-T Curve Envelopes a, c Figure 17: Unit 3 Steady-state P-T Curve LTR-RCPL-05-153 Attachment 2 Page 24 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 18: Unit 3 Heatup P-T Curves a,C S

Figure 19: Unit 3 Heatup P-T Curve Enveloped for 5F/hr Transient LTR-RCPL-05-153 Attachment 2 Page 25 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 20: Unit 3 Heatup P-T Curve Enveloped for IOF/hr Transient a,c

-I1 Figure 21: Unit 3 Heatup P-T Curve Enveloped for 30F/hr Transient LTR'-RCPL-05-153 Attachment 2 Page 26 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Figure 22: Unit 3 Heatup P-T Curve Enveloped for 4OF/hr Transient L Figure 23: Unit 3 Heatup P-T Curve Enveloped 60F/hr Transient Attacflment 22 Page 27 ot 54 LTK-RCPL-(JS- I Si Attachment LI-R-RCPL-W-153 rage 27 ofM5

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 24: Unit 3 Heatup P-T Curve Envelopes a, c

-I0 Figure 25: Unit 3 Cooldown P-T Curves Page 28 of 54 LTR-RCPL-OS-1 53 Attachment 22 LTR-RCPL-05-153 Page 28 of 54

WESTINGHOUSE NON-PROPRIETARY CLASS 3 a, c Figure 26: Unit 3 Cooldown P-T Curve Enveloped for IOOF/hr N

a, c Figure 27: Unit 3 Cooldown P-T Curve Envelopes LTR-RCPL-05-153 Attachment 2 Page 29 of 54