BVY 14-063, Relief Request ISI-06 Inservice Inspection Limited Examinations for the Fourth Ten-Year Interval Vermont Yankee Nuclear Power Station

Relief Request ISI-06 Inservice Inspection Limited Examinations for the Fourth Ten-Year Interval Vermont Yankee Nuclear Power Station

ML14237A100
Person / Time
Site:	Vermont Yankee
Issue date:	08/19/2014
From:	Chappell C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 14-063
Download: ML14237A100 (15)

Text

• 1 Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd Vernon, VT 05354 SEntergy Tel 802 257 7711 Coley C. Chappell Licensing Manager 10 CFR 50.55a(g)(5)(iii)

BVY 14-063 August 19, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Relief Request ISI-06 Inservice Inspection Limited Examinations for the Fourth Ten-Year Interval Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(g)(5)(iii), Entergy Nuclear Operations, Inc. (Entergy) requests relief from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 1998 Edition through 2000 Addenda, for 100 percent examination coverage of the components identified in the attachment to this letter due to geometric or design configuration, which limited the examination coverage which could be obtained at Vermont Yankee Nuclear Power Station (VY). The requested relief applies to examinations performed at VY during the fourth ten-year Inservice Inspection (ISI) Program interval, which concluded on August 31, 2013.

The attachment contains Relief Request ISI-06. Entergy requests review and approval of this request by August 31, 2015.

There are no new regulatory commitments being made in this submittal.

If you have any questions or require additional information, please contact me at (802) 451-3374.

Sincerely, CCC/plc A\AL

BVY 14-063 / Page 2 of 2

Attachment:

1. Relief Request ISI-06, Inservice Inspection Impracticality cc: Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Rd Vernon, VT 05354 Mr. Christopher Recchia, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, VT 05620-2601

BVY 14-063 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Relief Request ISI-06, Inservice Inspection Impracticality

BVY 14-063 / Attachment 1 / page 1 of 12 LICENSEE/UTILITY NAME- Entergy Nuclear Operations, Inc. (Entergy)

PLANT NAME, UNIT- Vermont Yankee (VY) 10-YEAR INTERVAL- Fourth REQUEST FOR RELIEF No. ISI-06 Proposed Alternative in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. American Society of Mechanical Engineers (ASME) Code Component(s) Affected Code Classes: 1 and 2

References:

Subarticle IWB-2500 Subarticle IWC-2500 Generic Letter 88-01 NUREG-0313 Code Case N-460 Information Notice 98-42 Code Case N-560 Examination Categories and Item numbers: B-A (B1.12 & B1.22), B-D (B3.90), B-F (B5.10), B-J (B9.11 & B130.10), C-A (Cl.10), C-C (C3.20) and C-F-2 (C5.51).

==

Description:==

Surface and Volumetric Examination Coverage Component Numbers: See Table 3

2. Applicable ASME Code Edition and Addenda ASME Section XI, 1998 Edition with 2000 Addenda

3. Applicable ASME Code Requirements Subarticle IWB-2500 states, in part, "Components shall be examined and tested as specified in Table IWB-2500-1."

Table IWB-2500-1 requires a volumetric, visual and surface examination be performed on the component based on Category and Item Number. The applicable examination method and requirements are shown below in Table 1:

BVY 14-063 / Attachment 1 / page 2 of 12 Table I Applicable Inspection Requirements from Table IWB-2500-1 of ASME Section XI, 1998 Edition with 2000 Addenda Examination Item Examination Requirements/Figure Examination Method Category Number Number B-A B1.12 IWB-2500-2 Volumetric B-A B13.22 IWB-2500-3 Volumetric B-D B3.90 IWB-2500-7 Volumetric Volumetric &

B-F B5.10 IWB-2500-8(c) Surface Volumetric &

B-J 89.11 IWB-2500-8(c) Surface B-J B10.10 IWC-2500-15 Surface Subarticle IWC-2500 states, in part, "Components shall be examined and pressure tested as specified in Table IWC-2500-1."

Table IWC-2500-1 requires a volumetric, visual and surface examination be performed on the component based on Category and Item Number. The applicable examination method and requirements are shown below in Table 2:

Table 2 Applicable Inspection Requirements from Table IWC-2500-1 of ASME Section Xl, 1998 Edition with 2000 Addenda Examination Item Examination Examination Category Number Requirements/Figure Method Number C-A C1.10 IWC-2500-1 Volumetric C-C C3.20 IWC-2500-5 Surface C-F-2 C5.51 IWC-2500-7(a) Surface & Volumetric

4. Reason for Request - Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested on the basis that the required "essentially 100 percent" coverage examination is impractical due to physical obstructions and limitations imposed by design, geometry and materials of construction of the component. Under 10 CFR 50.55a(g)(5)(iii) relief requests for these Code conformance impracticalities must be provided to the NRC not later than 12 months after the end of the active 120 month period of operation where examinations are determined to be impractical. The VY fourth ten-year Inservice Inspection Program interval ended August 31, 2013.

BVY 14-063 / Attachment 1 / page 3 of 12 Relief is requested from performing a complete coverage examination of the entire examination volume or area. Entire examination volume or area required is defined by ASME Section Xl Code Case N-460 titled "Alternative Examination Coverage for Class I and Class 2 Welds,Section XI, Division 1." Code Case N-460 states in part, " ... when the entire examination volume or area cannot be examined ... a reduction in examination coverage ... may be accepted provided the reduction in coverage for that weld is less than 10%."

The NRC, through Information Notice 98-42 (Reference 1) titled "Implementation of 10 CFR 50.55a(g) Inservice Inspection Requirements," termed the reduction in coverage of less than 10%

to be "essentially 100 percent." Information Notice 98-42 states, in part, "The NRC has adopted and further refined the definition of "essentially 100 percent' to mean 'greater than 90 percent" has been applied to all examinations of welds or other areas required by ASME Section Xl."

The physical restrictions for each component that could not receive "essentially 100 percent inspection" are listed in Table 3. These physical restrictions limit access to the examination area.

In each case, the examination performed encompassed the maximum surface area or volume that could be achieved for each component. It is impractical to achieve essentially 100 percent coverage because a redesign of the reactor and piping components would be required.

5. Burden Caused by Compliance:

The burden that would be caused to attempt to comply with the Code requirement for "essentially 100 percent coverage" would be the need to redesign and replace the reactor and subject piping systems and supports to remove the physical interferences and weld design configurations which inhibit the accessibility to perform a full examination.

Relief is requested from performing examination of "essentially 100 percent" of the required volume or area for the identified welds listed in Table 3 for the fourth 10-Year ISI interval.

6. Proposed Alternative and Basis for Use Entergy proposes that the examinations in Table 3 were performed to the maximum coverage possible and provide an acceptable level of quality and safety. VY's pre ASME Section XI design, coupled with the examinations completed to the extent practical, and with no unacceptable results documented, validate that the underlying objectives of the Inservice Inspection Program have been met.

Additionally, VT-2 examinations performed on the subject components during system pressure tests per IWB-2500-1 Examination Category B-P each refueling outage and category IWC-2500-1 Examination Category C-H each inspection period provides additional assurance that the structural integrity of the subject components is maintained.

Basis for Use VY obtained a Construction Permit on July 7, 1967. VY's piping systems and associated components were designed and fabricated before the examination requirements of ASME Section XI were formalized and published. Since this plant was not specifically designed to meet the requirements of ASME Section XI, literal compliance is not feasible or practical within the limits of the current plant design.

Physical obstructions imposed by design, geometry and materials of construction are typical of vessel appurtenances, biological shield wall, insulation support rings, structural and component support members, adjacent component weldments in close proximity, unique component configurations (valves and pumps), and dissimilar metal weldments.

BVY 14-063 / Attachment 1 / page 4 of 12 As a minimum, all components received the required examination(s) to the extent practical with regard to the limited or lack of access available. The examinations conducted confirmed satisfactory results evidencing no unacceptable flaws present, even though "essentially 100 percent" coverage was not attained in a portion of the Section Xl examinations. VY concludes that if any active degradation mechanisms or patterns of degradation were to exist in the subject welds, those degradations would have been identified in the examinations performed in adjacent weldment or similar weld configurations.

For volumetric (ultrasonic) examinations, VY calculates percentage of coverage as follows:

The required examination volume is calculated. The examination is performed in accordance with an approved ultrasonic procedure satisfying the governing Code requirements for a number of angles and beam directions for each angle. For each angle/beam direction combination the volume interrogated by that beam is calculated (within the required coverage volume). One of the following methods is then used to calculate volume coverage:

1. The value is divided by the required examination volume to determine a percentage of coverage for each angle/beam-direction combination. Then those required angle/beam-direction coverage percentages are averaged to determine an overall composite coverage (typical of reactor vessel welds),

OR

2. The percentage of coverage of each segment of a weld with limited access around its circumference (typical of piping welds) is calculated and summed to determine the total weld volume percentage examined, OR

3. Where a pipe to nozzle, component or fitting can be scanned in both circumferential directions and the axial direction from the pipe side but not the axial direction from the fitting side, the coverage is listed as 75%.

For example, ASME Section V, Article 4 required 0 degree (*), 450, and 600 search units for examining vessel welds from the outer diameter (OD) of the vessel. The 450 and 600 search units are each required to be scanned in four orthogonal directions. Therefore, a total of nine angle/beam-directions are required and a coverage percentage is calculated for each of those nine angle/beam-direction combinations. Those nine values are then averaged to determine the overall composite coverage. (Note: Since Appendix VIII was invoked for vessel welds, the required number of angle/beam-direction combinations now depends on the qualified procedure, and thus the calculation may be slightly different.)

When less than 90 percent examination coverage occurred, consideration was given to changes in the examination procedure to increase coverage. However, a change in the non-destructive examination (NDE) procedure will usually not make a dramatic change in the amount of coverage. Also, the original NDE procedure is typically optimized to perform the test with the greatest amount of confidence in the results. When a change is made to the procedure to achieve greater coverage, usually compromises in the NDE technique must be made. Further, since the implementation of Appendix VIII, it is not permissible to change ultrasonic techniques in order to attain more coverage because the ultrasonic testing (UT) technique would then not be qualified. It is more important to be confident in

BVY 14-063 / Attachment 1 / page 5 of 12 the results that are obtained, rather than to compromise the technique to obtain a small increase in percent of coverage.

Typically VY did not select alternative welds when coverage was limited on the scheduled weld. A sample plan implies a certain amount of random choice in the selection of welds for examination - unless there are more conservative ways to select the sample, such as selecting high stress points or welds where industry experience indicates that damage mechanisms are more likely. This is why for Category C-F-2, terminal end welds are singled out; they are more typically high stressed. The reason the plant design includes physical interferences with examination coverage is usually independent of the potential flaw mechanisms. However, there may be cases where this is not true. For example, valve-to-pipe welds and pump-to-pipe weld geometries may inhibit coverage. But, these welds may actually have higher stresses because of their configurations. In these cases, if alternative welds were selected, the sample of higher stressed welds in the population would be diluted. If alternative welds are chosen, the selection randomness decreases. Flaw mechanisms associated with test limitations may be missed. It may be more conservative to accept the limited coverage than to select alternative welds.

There is Code precedent for allowing limited coverage due to inaccessibility. The VY fourth interval Code of Record (ASME Section Xl 1998 Edition through 2000 Addenda) allows certain Class 1 and Class 2 welds to be exempt based on the criteria that they are inaccessible. Paragraphs IWB-1220(d) and IWC-1 223 exempt examination requirements of welds that are inaccessible due to being encased in concrete, are buried underground, located inside a penetration, or are encapsulated by guard pipe. The Code recognizes that examination of these welds is not possible and, therefore, that a Relief Request would not be necessary. The same logic applies to portions of welds that are inaccessible and where examination of those portions of welds is not possible.

There is VY precedent for allowing limited examination coverage due to inaccessibility.

During the VY third ten-year Inservice Inspection Program interval, relief for augmented limited examination coverage was granted by the NRC for Category B-A reactor pressure vessel shell welds by Reference 2. This prior approval concluded that limited examination percentage was performed to the maximum extent practical and constituted an acceptable level of quality and safety in accordance with 10 CFR 50.55a(g)(6)(ii)(A)(5). In addition, relief was also granted by the NRC for limited examination coverage for Category B-D reactor nozzle to vessel welds, Category B-F nozzle to safe end welds, Category B-H reactor support skirt weld, Category B-J piping circumferential welds, Category B-K lug welds, Category B-O CRD housing to flange welds, Category C-A RHR heat exchanger shell to flange welds, Category C-C RHR heat exchanger welded support, Category C-F-2 pipe to component welds and NUREG 0313 pipe to flange welds by Reference 3. This prior approval concluded that imposing 100% coverage of these examinations would require components to be redesigned which would be a significant burden upon the licensee, and that examinations performed provide a reasonable assurance of structural integrity of the subject welds. Relief was granted pursuant to 1 OCFR 50.55a(g)(6)(i) for the third 10-year ISI interval of VY.

Note that the Inservice Inspection Program implicitly assumes that the inspection program is a sampling program in that it is spread over ten years. If no flaws were acceptable, 100%

of the safety related components in the plant would have to be inspected each inspection cycle.

The impact that a reduction of coverage would have is not significant when one takes the above implicit assumptions into account. Compliance with the proposed alternatives

BVY 14-063 / Attachment 1 / page 6 of 12 described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.

7. Duration of Proposed Alternative Relief is requested for the fourth ten-year interval of the Inservice Inspection Program for VY, which began September 1, 2003 and concluded August 31, 2013.

BVY 14-063 / Attachment 1 / page 7 of 12 Table 3 FOURTH INTERVAL COMPONENTS WITH LESS THAN "ESSENTIALLY 100%" COVERAGE Section X1 System & Condition Limiting Exam & Exam Category Component Component Description Coverage Coverage Performed

& Item Number Percent Number Core spray pipe &

B-A Nuclear RPV Longitudinal Shell FDW Sparger UT B1.12 Er Weld Interference to 78.75%

E2 Transducer Access Nuclear Core Shroud Tie B-A Boiler RPV Longitudinal Shell Rod Obstruction UT RF24 B1.12 Bl Weld Makes Weld 0%

F1 Inaccessible Nuclear Core Shroud Tie B-A Boiler RPV Longitudinal Shell Rod Obstruction UT RF24 B1.12 Bl Weld Makes Weld 0%

F2 Inaccessible Nuclear Core spray pipe &

B-A Boiler RPV Longitudinal Shell FDW Sparger UT RF24 B1.12 Bol Weld Interference to 78.58%

El Transducer Access Nuclear Tool Reach Limited B-A Boiler RPV Bottom Head by Proximity of UT RF24 B1.12 Bl Meridional Weld Reactor Internal Jet 88.31%

G2 Pumps Tool Reach Limited to 28" above HJ B-A Nuclear RPV Bottom Head Weld due to UT B1.22 Boiler Meridional Weld Permanent 38.5% RF26 H1 Insulation Interference above the Skirt Weld Tool Reach Limited to 28" above HJ Weld due to Nuclear Permanent B-A Nucler RPV Bottom Head Insulation UT B1.22 Bl Meridional Weld Interference above 38.5%

H2 the Skirt Weld Tool Reach Limited B-A Nuclear RPV Bottom Head to 28" above HJ UT B1.22 Bl Meridional Weld Weld due to 38.5%

H3 Permanent

BVY 14-063 / Attachment 1 / page 8 of 12 Section XI System & Exam & Exam Category Component Component Description Condition Limiting Coverage Performed

& Item Number Percent Number Insulation Interference above the Skirt Weld Tool Reach Limited to 28" above HJ B-A Nuclear Boiler RPV Bottom Head Weld due to Permanent UT R2 B1.22 H4 Meridional Weld Inslt 36.9%

H4 Insulation Interference above the Skirt Weld Tool Reach Limited to 28" above HJ B-A Nuclear Boiler RPV Bottom Head Weld due to Permanent UT R2 B1.22 H5 Meridional Weld Inslt 38.5%

H5 Insulation Interference above the Skirt Weld Tool Reach Limited to 28" above HJ B-A Nuclear Boiler RPV Bottom Head Weld due to Permanent UT R2 B1.22 H6 Meridional Weld Inslt 38.5%

H6 Insulation Interference above the Skirt Weld Tool Reach Limited to 28" above HJ B-A Nuclear Boiler RPV Bottom Head Weld due to Permanent UT R2 B1.22 H7 Meridional Weld Inslt 36.7%

H7 Insulation Interference above the Skirt Weld Tool Reach Limited to 28" above HJ B-A Nuclear Boiler RPV Bottom Head

.. Weld due to Permanent UT R2 B1.22 Bl Meridional Weld Inslt 38.5%

H8 Insulation Interference above the Skirt Weld Exam Limited by Nuclear Presence of CRD B-A Boiler RPV Bottom Head Guide Tubes to 20" UT B1.22 Meridional Weld on Each End of 23.1%

J1 Weld Nuclear Exam Limited by B-A Nucler RPV Bottom Head Presence of CRD UT RF26 B1.22 Bl Meridional Weld Guide Tubes to 20" 24.4%

J2

_____________________onEachEnd of______

BVY 14-063/ Attachment 1 / page 9 of 12 Section Xl System & Exam & Exam Category Component Component Description Condition Limiting Coverage Performed

& Item Number Percent Number Weld Nozzle to Vessel B-D Nuclear Weld Configuration UT Boiler Nozzle to Vessel Weld Limits Transducer RF27 N3A Access to a Portion of the Weld Nozzle to Vessel B-D Nuclear Weld Configuration UT Boiler Nozzle to Vessel Weld Limits Transducer RF27 N3B Access to a Portion of the Weld Nozzle to Vessel B-D Nuclear Weld Configuration UT Boiler Nozzle to Vessel Weld Limits Transducer RF27 N3C Access to a Portion of the Weld Nozzle to Vessel B-D Nuclear Weld Configuration UT Boiler Nozzle to Vessel Weld Limits Transducer RF27 N3D Access to a Portion of the Weld Nozzle to Vessel B-D Nuclear Weld Configuration UT Boiler Nozzle to Vessel Weld Limits Transducer RF26 N4A Access to a Portion of the Weld Nozzle to Vessel B-D Nuclear Weld Configuration UT Boiler Nozzle to Vessel Weld Limits Transducer RF26 N4B Access to a Portion of the Weld Nozzle to Vessel B-D Nuclear Weld Configuration UT Boiler Nozzle to Vessel Weld Limits Transducer RF26 N4C Access to a Portion of the Weld Nozzle to Vessel Weld Configuration Nuclear Limits Transducer B-D Access to a Portion UT B39 Boiler Nozzle to Vessel Weld of the th W 70.2% RF26 B3.90 NDof Weld 70.2%

N4D Nuclear Nozzle to Vessel B-D Boiler Nozzle to Vessel Weld Weld Configuration UT RF27 B3.90 Bie Limits Transducer 76.3%

N5A_ Access to a Portion

BVY 14-063 / Attachment 1 / page 10 of 12 Section Xl System & Exam & Exam Category Component Component Description Condition Limiting Coverage Performed

& Item Number Percent Number of the Weld As-welded OD B-F Nuclear Boiler 9" nozzle to Safe End Surface of the Weld UT R2 B5. 10 BoAle Butt Weld Prevents Full 67% RF25 N6A.-SE Transducer Scan Weld Configuration B-J Core Spray Valve to Pipe Limits Exam UT B9.1 1 CS4B-MF5 Circumferential Weld Access to One Side 50%

of the Weld Elbow to Tee Weld B-J RHR Circumferential Weld, Configuration UT B9.1 1 RH30-1 Tee to Pipe Limited Axial Scan UT RF24 to One Side of Weld Joint Elbow to Bent Pipe B-J RHR Circumferential Weld, Weld Configuration UT B9.1 1 RH30-6 Elbow to Pipe Limited Axial Scan UT RF24 to One Side of Weld Joint Cross to Tee Weld B-J NB Circumferential Weld Configuration UT B9.1 1 RR-BD-13 Downstream of Valve Limited Axial Scan 50% RF29 to One Side of Weld Joint Cross to Tee Weld B-J NB Circumferential Weld Configuration UT B9.1 1 RR-AD-13 Downstream of Valve Limited Axial Scan 50% RF25 to One Side of Weld Joint Welded Flange to Reducer Weld B-J Nuclear Configuration UT B9.11 Boiler 4" Circumferential Weld Limited Axial Scan RF30 RV-F9A to One Side of Weld Joint Welded Flange to Reducer Weld B-J Nuclear Configuration Limited Axial Scan UT B9. Boiler 6" Circumferential Weld teOne Side Side of of L5T RF30 B9.1 1 R-93to 75%

RV-F9B Weld Joint Valve to Pipe Weld B-J RWCU 4" Circumferential Weld Geometry Limits UT RF30 B9.1 1 CU18-4 Exam Access to 50%

Pipe Side Only

BVY 14-063 / Attachment 1 / page 11 of 12 Section XI System & Exam & Exam Category Component Component Description Condition Limiting Coverage Performed

& Item Number Percent Number Support Bracket Nuclear Reactor Vessel Exterior Weld Inspection F2 B-J Boiler P ODEG RPV Integral Attachment Access is Limited 20.77% RF25 B10.10 BRKT Weld by Proximity of Bioshield Wall Welded Attachment C-A RHR Head Shell to Flange on OD Surface UT C1.10 A-HTEX10-4 Circumferential Weld Limits Transducer 80.15%

Access Pipe Support and Whip Restraint Design Geometry C-C FDW Integral Attachment Does Not Allow MT FDW-HD36 Weld Access to Half of 50% RF24 C3.20 the Integral Attachment Weld Surface Pipe Support and Whip Restraint Design Geometry C-C FDW Integral Attachment Does Not Allow MT C3.20 FDW-HD36 Weld Access to Half of 50%

the Integral Attachment Weld Surface Pipe Support and Whip Restraint Design Geometry C-C FDW Integral Attachment Does Not Allow MT C3.20 FDW-HD39 Weld Access to Half of 50%

the Integral Attachment Weld Surface C-F-2 PCAC 20" Circumferential Tee and OD UT C5.51 AC11-S50 Weld Mismatch 68.7%

CORE Valve to Pipe C-F-2 SPRAY 12" Circumferential Geometry Limits UT RF27 C5.51 CS1B-$27 Weld Scan to Pipe Side 88.65%

Only Pipe to Tee C-F-2 RHR 14" Circumferential Geometry Limits UT C5.51 RH14-$356 Weld Scan to Pipe Side 66.25% RF25 Only Proximity to C-F-2 RHR 24" Circumferential Adjacent Weld UT C5.51 RH2A-S58 Weld Limits the Available 85.5%

Examination Area

BVY 14-063/ Attachment 1 / page 12 of 12 Section Xl System & Exam & Exam Category Component Component Description Condition Limiting Coverage Performed

& Item Number Coverage Percent Number Valve to Pipe C-F-2 RHR 20" Circumferential Geometry Limits UT C5.51 RH8-S294 Weld Scan to Pipe Side 87.75%

Only Component Configuration C-F-2 RHR Circumferential Weld, Caused Access UT C5.51 RH3D-S206 Pipe to Valve Limitations for the 77%

45 Degree Transducer Scan

8.

References:

1. NRC Information Notice 98-42, "Implementation of 10 CFR 50.55a(g) Inservice Inspection Requirements," dated December 1, 1998

2. Letter, USNRC to Vermont Yankee Nuclear Power Corporation, "Augmented Examination of the Reactor Pressure Vessel Shell Welds at Vermont Yankee Nuclear Power Station (TAC No. M99389)" NVY 99-16, dated February 18, 1999

3. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation of Relief Request B-5 - Vermont Yankee Nuclear Power Station (TAC No. MC0959)," NVY 05-115, dated September 19, 2005 (ML052560006)