ML033180088

Extended Power Uprate Acceptance Review

ML033180088
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png (DPR-028)
Issue date:	12/15/2003
From:	Holden C NRC/NRR/DLPM/LPD1
To:	Kansler M Entergy Nuclear Operations
Pulsifer R M, NRR/DLPM, 415-3016
References
FOIA/PA-2004-0369, TAC MC0761
Download: ML033180088 (9)

Text

December 15, 2003 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION - EXTENDED POWER UPRATE ACCEPTANCE REVIEW (TAC NO. MC0761)

Dear Mr. Kansler:

By letter dated September 10, 2003, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Entergy), licensees of the Vermont Yankee Nuclear Power Station (VYNPS), submitted the application, Technical Specification Proposed Change No. 263 Extended Power Uprate to the U.S. Nuclear Regulatory Commission (NRC). The proposed license amendment would allow an increase in the maximum authorized power level from 1593 megawatts thermal (MWT) to 1912 MWT. The purpose of this letter is to provide the results of the NRC staff's acceptance review of Entergy's extended power uprate (EPU) application for VYNPS. The acceptance review determines whether or not there is sufficient detail to allow the staff to proceed with its detailed technical review. The review also ensures that the application adequately characterizes the regulatory requirements and licensing basis of the plant.

Subsequent to the initial application dated September 10, 2003, Entergy provided a supplement dated October 1, 2003, and two supplements dated October 28, 2003. The acceptance review considered all information provided in the application and the three supplements.

The NRC staffs review has identified several areas lacking the information needed to allow the staff to complete its review of those areas. Deficiencies identified include the following:

1. Several areas are identified as being bounded by analyses performed as part of the Constant Pressure Power Uprate (CPPU) Licensing Topical Report (CLTR) or by the previous EPU Licensing Topical Report (ELTR) 1 and ELTR 2 assessments. Your application does not provide sufficient information to allow the NRC staff to be able to determine the applicability of the CPPU analyses to VYNPS. Specifically, information relating proposed VYNPS operation to the assumptions, evaluations, reviews, and assessments used in the CPPU analyses were not provided. Examples of these include:

a. In the EPU Safety Analysis Report (SAR) (Attachment 4 to the September 10, 2003 application), items are stated by General Electric Nuclear Energy (GENE) to be dispositioned based on confirmation of consistency between VYNPS and the generic description provided in the CLTR (or ELTR-1 and ELTR-2). However, no details are provided to allow the NRC staff to understand how this VYNPS to CLTR confirmation was performed. Specifically, what criteria, key parameters, etc., were examined to confirm the consistency?

M. Kansler b. It is not clear to the NRC staff if VYNPS performed any independent confirmation or oversight of the GENE dispositions or assessments in compliance with the NRC CLTR Safety Evaluation Report (SER), Section 1.5, licensee expectations or restrictions, and applicable Title 10 of the Code of Federal Regulation (10 CFR) Part 50, Appendix B requirements. For example, Entergy should have conducted reviews, audits or inspections, or examined key parameters, or performed independent calculations, to support the engineering judgements made by GENE.

c.

Items (e.g., in Section 2) of the EPU SAR are dispositioned based on experience and are stated to be confirmed because they will be evaluated for the uprated core prior to CPPU implementation. However, these evaluations will be performed by Global Nuclear Fuel close to the reload outage and will only be available in the Supplemental Reload Licensing Report and the Core Operating Limits Report. There is no discussion as to how these confirmations, prior to CPPU implementation, will be verified by Entergy (by reviews, audits, etc.) in accordance with the NRC CLTR SER, Section 1.5, licensee expectations or restrictions, and applicable 10 CFR 50, Appendix B requirements.

While these are only examples, you should provide an update for all appropriate sections of your application to address how these confirmations were performed.

2. The NRC staffs 12-month review schedule for an EPU request is based on an application using RS-001, Review Standard for Extended Power Uprates. The NRC staff intends to use the template safety evaluation (SE) in RS-001 when generating a plant-specific SE for the VYNPS power uprate. The template SE provides a draft regulatory evaluation and conclusion for each review area. The NRC staff expected that Entergy would review the template to ensure that it reflects the licensing basis for the plant. Also, you should ensure sufficient technical information is provided so that the NRC staff can verify the regulatory evaluation and develop the technical evaluation to support the conclusion. The template was developed to provide guidance so that the NRC staff review could be completed without extensive requests for additional information.

The NRC staff received your supplements dated October 1 and October 28, 2003, providing a matrix cross-referencing the design criteria within the licensing basis for VYNPS to the General Design Criteria (GDC) in 10 CFR, Part 50, Appendix A. To aid the NRC staff in preparing the plant-specific SE for the VYNPS EPU, please confirm that replacing the numerical values of the GDC in the template regulatory evaluation section of the SE with the corresponding VYNPS design criteria from your matrix would not result in an SE that is inconsistent with the VYNPS licensing basis. If inconsistencies are created by this approach, please provide markups of the template SE in RS-001 identifying and correcting any inconsistencies that would be created.

Through the acceptance review, the NRC staff also noted that in many review areas there was insufficient information provided to arrive at an adequate safety conclusion, as described in the template. Examples of these review areas include flood protection, equipment and floor drainage systems, internally generated missiles, and ultimate heat sink.

This information needs to be provided for the NRC staff to complete its review.

M. Kansler 3. As discussed in a public meeting at NRC Headquarters on October 30, 2003, Entergy stated that a supplement would be provided in the near future regarding steam dryer integrity. This information is needed by the NRC staff before the application is considered complete. Since steam dryer integrity is an emerging industry issue, you should consider if any new developments on this issue impact the VYNPS submittal and provide further supplements as deemed necessary.

The NRC staff notes that the original application was incomplete in several other areas.

However, these areas were addressed by supplements as follows:

In the area of EPU testing, your application did not adequately cover the scope of areas identified in draft Standard Review Plan, Section 14.2.1, "Generic Guidelines for Extended Power Uprate Testing Programs," which was issued in December 2002 for interim use and public comment. Specifically, your application did not provide sufficient information to allow the NRC staff to conduct a review of your basis for not reperforming certain tests that were performed during the initial startup test program. In addition, your application did not provide a sufficient description of testing you plan to perform to confirm that plant equipment modified to support the EPU will perform in a manner consistent with your Updated Final Safety Analysis Report. However, subsequent to the initial application, the NRC staff inquired about these testing issues and you submitted Supplement 3, dated October 28, 2003. The NRC staff determined that the information provided in Supplement 3 was sufficient to allow the detailed review of your EPU test program to continue.

As noted in your letter dated September 10, 2003, an assessment of the effects of the EPU on plant and transmission grid stability was not complete at the time of the initial application.

However, this information was provided in Supplement 2 on October 28, 2003.

Based on the deficiencies described in items 1, 2, and 3, above, the NRC staff does not consider your application to be complete at this time. Upon receipt of information that adequately addresses these deficiencies, the NRC staff will consider your application acceptable such that the detailed technical review can be completed. The NRC staff will continue its review in the areas for which sufficient information has already been provided; however, the 12-month review schedule will start when a complete application is received. This position is consistent with my letter to Mr. Andrew C. White of GENE dated June 25, 2003, which stated that if an EPU submittal is made in parts, the NRC can only commit to completing our review 12 months from the time that the latest supplement to the application was provided.

Copies of this letter were provided to all Boiling Water Reactor licensees. The letter is available electronically at the NRCs website in the Agencywide Documents Access and Management System (ADAMS) under accession no. ML031780157.

The NRC staff would also like to note that it is currently reviewing two licensing actions with potential impacts on the power uprate application. These are the Average Power Range Monitor/Rod Block Monitor/Technical Specification/Maximum Extended Load Line Limit Analysis (ARTS/MELLLA) and Alternative Source Term (AST) applications. These licensing actions must be completed prior to the power uprate; therefore, timely resolution of issues related to these licensing actions is important to prevent any delays in the review of your EPU application.

M. Kansler If you have any questions, please contact the VYNPS Project Manager, Mr. Richard Ennis, at (301) 415-1420.

Sincerely,

/RA/

Cornelius F. Holden, Director Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271 cc: See next page

M. Kansler If you have any questions, please contact the VYNPS Project Manager, Mr. Richard Ennis, at (301) 415-1420.

Sincerely,

/RA/

Cornelius F. Holden, Director Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271 cc: See next page DISTRIBUTION PUBLIC TChan REckenrode HWalker PDI-2 Reading RDavis JBongarra MHart DRoberts LLund JTappert FAkstulewicz REnnis KParczewski SImboden EKendrick AMcMurtray KManoly DSolorio CHolden CAnderson, RGN I CWu DReddy ELeeds EMarinos DThatcher SWeerakkody TMarsh HGarg RPettis RGallucci BSheron RJenkins KCoyne MRubin MShuaibi NTrehan EWeiss MStutzke JJolicoeur SCoffin RPedersen RDennig BElliot DTrimble RLobel ACCESSION NO.: ML033180088

• See previous concurrence OFFICE PDI-2/PM PDI-2/LA LPM*

PDI-2/SC(A)

PD-I/D NAME REnnis SLittle for CRaynor AMcMurtray DRoberts CHolden DATE 12/15/03 12/15/03 12/12/03 12/15/03 12/15/03 OFFICIAL RECORD COPY

Vermont Yankee Nuclear Power Station cc:

Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. David R. Lewis Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.

Washington, DC 20037-1128 Ms. Christine S. Salembier, Commissioner Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601 Mr. Michael H. Dworkin, Chairman Public Service Board State of Vermont 112 State Street Montpelier, VT 05620-2701 Chairman, Board of Selectmen Town of Vernon P.O. Box 116 Vernon, VT 05354-0116 Mr. Michael Hamer Operating Experience Coordinator Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 G. Dana Bisbee, Esq.

Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 Ms. Deborah B. Katz Box 83 Shelburne Falls, MA 01370 Mr. Raymond N. McCandless Vermont Department of Health Division of Occupational and Radiological Health 108 Cherry Street Burlington, VT 05402 Manager, Licensing Entergy Nuclear Vermont Yankee, LLC P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Resident Inspector Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission P.O. Box 176 Vernon, VT 05354 Director, Massachusetts Emergency Management Agency ATTN: James Muckerheide 400 Worcester Rd.

Framingham, MA 01702-5399 Jonathan M. Block, Esq.

Main Street P.O. Box 566 Putney, VT 05346-0566 Mr. John Kelly Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Gary Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213

Vermont Yankee Nuclear Power Station cc:

Mr. John Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Dan Pace Vice President, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Randall Edington Vice President, Operations Support Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Jay K. Thayer Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. Ken L. Graesser BWR SRC Consultant 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. Jim Sniezek BWR SRC Consultant 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Ron Toole BWR SRC Consultant 605 West Horner Street Ebensburg, PA 15931 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.

639 Loyola Avenue, Mail Stop L-ENT-15E New Orleans, LA 70113 Mr. Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, ME 04556 Mr. James P. Matteau Executive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301