ML051860217

Summary of June 30, 2005, Meeting with Entergy Nuclear Operations, Inc. on General Electric Neutronic and Thermal/Hydraulic Analysis for Vermont Yankee Nuclear Power Station

ML051860217
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	07/26/2005
From:	Richard Ennis NRC/NRR/DLPM/LPD1
To:	Entergy Nuclear Operations
Ennis R, NRR/DLPM, 415-1420
References
TAC MC0761
Download: ML051860217 (11)

Text

July 26, 2005 LICENSEE: Entergy Nuclear Operations, Inc.

FACILITY: Vermont Yankee Nuclear Power Station

SUMMARY

OF JUNE 30, 2005, MEETING WITH ENTERGY NUCLEAR OPERATIONS, INC. ON GENERAL ELECTRIC NEUTRONIC AND THERMAL/HYDRAULIC ANALYSIS FOR VERMONT YANKEE NUCLEAR POWER STATION (TAC NO. MC0761)

On June 30, 2005, a Category 1 meeting was held between the Nuclear Regulatory Commission (NRC) and representatives of Entergy Nuclear Operations, Inc. (Entergy or the licensee) at NRC Headquarters in Rockville, Maryland.

The purpose of the meeting was to discuss issues related to the methods used by Entergys fuel vendor, General Electric (GE), to perform reactor neutronic and thermal/hydraulic analysis for Vermont Yankee Nuclear Power Station (VYNPS). This analysis is being used to support Entergy's license amendment request for a 20% power uprate at VYNPS. The extended power uprate (EPU) request was submitted by Entergy to the NRC on September 10, 2003.

Since GE proprietary information was discussed during the meeting, the meeting was held in two portions. The first portion was open to the public, either present in the meeting room, or via a teleconference bridge line. The second portion of the meeting was closed to the general public and included participation by individuals representing organizations who had previously been granted access to GE proprietary information.

The lists of attendees for the meeting is provided as Enclosure 1. The slides used by Entergy are provided as Enclosure 2.

Open Portion of Meeting Mr. Richard Ennis, Project Manager for the VYNPS in the NRCs Office of Nuclear Reactor Regulation (NRR) Division of Licensing Project Management (DLPM), provided introductory remarks. Mr. Ennis explained that the NRC sent Entergy a letter on December 21, 2004, containing a request for additional information (RAI) pertaining to the VYNPS EPU. The letter included an RAI question that asked Entergy to justify that the analytical methods and computer codes used by their fuel vendor, GE, at current plant operating conditions, are still valid and applicable at the proposed EPU operating conditions. The specific RAI question is shown on page 6 of the enclosure to the December 21, 2004, letter (Agencywide Document Access and Management System (ADAMS) Accession No. ML043370049).

Mr. Ennis stated that Entergy provided a response to the RAI in a letter dated March 10, 2005 (ADAMS Accession No. ML050750140). Based on the NRC staffs review of that submittal, the NRC staff provided draft RAI questions to Entergy on June 9, 2005. Mr. Ennis explained that consistent with the NRCs license amendment review process, the staff provides draft RAI

questions to a licensee so that conference calls can be held to ensure the licensee understands the scope of the questions and so that the licensee can provide a schedule for responding to the questions.

Mr. Ennis stated that in a conference call between the NRC, Entergy, and GE on June 28, 2005, Entergy indicated that, based on the amount of time they expected they would need to obtain the necessary information and respond to the draft RAI, there would be a significant impact on the overall EPU schedule. In order to resolve the issues originally raised in the NRC staffs December 2004 RAI in a more timely manner, Entergy decided to use an alternate technical approach to demonstrate that the GE methods and computer codes are valid and applicable under EPU operating conditions.

Mr. Ennis stated that the goals of the meeting were to allow Entergy to provide details to the NRC staff regarding the proposed alternate approach and to have the NRC staff provide feedback to Entergy on which of the draft RAI questions still apply based on the alternate approach. After the staff determines which RAI questions still pertain to the VYNPS EPU request, and Entergy provides a response time on the RAIs, the NRC staff will formally docket the RAI questions by letter to Entergy. Mr. Ennis explained that the detailed discussion of the approach and the discussion regarding the RAI questions would take place during the closed portion of the meeting since proprietary information would need to be discussed.

Mr. Ennis summarized the overall schedule status of the VYNPS review. He said the NRC sent a letter to Entergy on October 15, 2004, indicating that there would be a delay in the review schedule primarily to address concerns regarding the steam dryer analysis. Entergy has submitted nine supplements since October 15, 2004, and the staff continues to reassess the schedule based on all the recent submittals. Mr. Ennis concluded his remarks by stating that the GE methods issues and the steam dryer issues appear to be the critical path items at this time with respect to the schedule.

Mr. John Dreyfuss, Director of Engineering for Entergy at the VYNPS, made some introductory remarks and emphasized that Entergys first priority with respect to the proposed EPU was safety.

Mr. John McCann, Director of Licensing for Entergy Northeast, stated that Entergys goals for the meeting were to present their alternate approach and to clearly understand the NRC staff positions. He defined success for the meeting as having a clear picture of what additional information needs to be submitted to the NRC staff. He explained that Entergy does not believe that the approach described in the March 10 2005, submittal was flawed but the Entergy staff did not think they could resolve the NRC staffs concerns in a timely manner. Therefore, they decided to propose an alternate approach that would add safety margin to the core design/operation in order to address any concerns regarding the level of uncertainties in the methods, currently being used by GE, under EPU conditions.

Mr. Craig Nichols, Power Uprate Project Manager for Entergy at the VYNPS, provided an overview of the alternate approach. He stated that in order to address some of the staff's concerns, Entergy proposed a fuel-related operating restriction that would be incorporated as a condition in the VYNPS operating license. This condition would result in additional margin

being incorporated into the core design. Specifically, Entergy proposed an additional margin of 0.02 be added to the minimum critical power ratio (MCPR) required by the current Technical Specifications.

Following Entergys presentation, comments were received from members of the public in the meeting room and from those on the teleconference bridge line.

The comments from members of the public present in the meeting room are summarized as follows:

! Mr. David Lochbaum, Nuclear Safety Engineer for the Union of Concerned Scientists, made a comparison between the NRCs review of the VYNPS EPU review and the NRCs review of the issues related to the Davis-Besse reactor vessel head corrosion. With respect to Davis-Besse, he asserted that the NRC staff basically accepted what the licensee presented to the staff without asking all the questions that needed to be asked. He asked how the review of the proposed VYNPS EPU is any different. As Mr. Lochbaum was making his comments in the meeting room, members of the public on the phone line stated they could not hear him. The NRC staff asked Mr. Lochbaum to come to the microphone at the podium and restate his comments. As Mr. Lochbaum was restating his comments from the podium, the members of the public on the phone line stated they were still having problems hearing. The NRC asked Mr. Lochbaum to come sit at the conference table next to the phone, however, he decided to leave the meeting room while making a statement regarding the NRC staffs inability to work out the technical details concerning the teleconference setup. After Mr. Lochbaum left the room, Mr. Tad Marsh, the NRCs Director of the DLPM in NRR, stated that the NRC staff learned lessons from Davis-Besse but that the situations are different in that this is a license amendment review. Mr. Marsh commented that the NRC is not accepting the licensees assertions at face value but will probe the technical issues until we are satisfied that a finding of reasonable assurance can be made.

! Mr. Peter James Atherton, Nuclear Safety Consultant and former NRC employee, made several comments regarding whether Entergy feels comfortable providing operating experience information to the NRC staff rather than providing detailed technical information.

Mr. McCann stated that Entergy is not trying to bypass any questions the NRC staff is asking. He stated that they are proposing an alternate approach to provide more safety margin.

! Mr. Atherton asked why the NRC staff is doing such a detailed review of the GE methods now since other power uprates had already been granted. Mr. Marsh explained that the NRC staff concerns came to light recently during other reviews and that we were looking backward at the potential impact on operating plants, as well as forward, as part of the VYNPS EPU review.

The comments from members of the public on the teleconference bridge line are summarized as follows:

! Mr. Raymond Shadis, Staff Technical Advisor for the New England Coalition (NEC),

commented on the problems the public was having hearing the meeting proceedings over the phone line. During the meeting, the NRC staff apologized for the problems and noted

that the problems were due in part to the size of the meeting room, as well as noise generated by some of the phones connected to the bridge (e.g., phones not being on mute) as well as the beep tone generated each time a person entered or exited the bridge.

! Mr. Shadis asked Entergy to provide a simple statement describing the alternate approach.

Mr. McCann reiterated Mr. Nichols earlier statements that Entergy recognized the NRC staffs concerns regarding the level of uncertainties in the methods, currently being used by GE, under EPU conditions. Therefore, they decided to propose an alternate approach that would add safety margin to the core design/operation. This would be accomplished by proposing an operating restriction associated with the MCPR limit.

! Mr. Shadis questioned the need for the closed session and whether the information being discussed was really proprietary. Mr. Ennis stated it was very clear that the information was GE proprietary information since the draft RAIs, which would be discussed, contained information the staff had previously determined to contain GE proprietary information (including the March 10, 2005 submittal from Entergy). Mr. Ennis gave a brief explanation of the NRCs review of proprietary information under the Section 2.390 of Title 10 of the Code of Federal Regulations. Mr. Marsh said that the NRC staff would try to make as much information publicly available in the meeting summary as possible.

! Several members of the public from Vermont expressed their opinion that VYNPS was unsafe and there still needed to be an Independent Safety Assessment (ISA) like the one performed at Maine Yankee. Mr. Ennis asked that the comments be focused on the specific issues on the agenda and stated that there had been a significant amount of previous correspondence to and from the NRC on the subject of the need for an ISA, and related discussions including those at a recent Vermont Public Service Board meeting at which the NRC staff presented the results of the engineering inspection performed at VYNPS.

! Mr. Jonathan Block, legal counsel for the NEC for the pending VYNPS EPU hearing, asked that the NRC staff try to include a detailed meeting summary rather than a redacted version to provide more information to the public. Dr. Jennifer Uhle, the NRCs acting Director for Project Directorate I in the DLPM in NRR, stated that the staff would try to put as much detail in the meeting summary as possible.

! Mr. Brian Shaw, of Westminster, Vermont, stated a concern that the licensee is determining what information can and cannot be reviewed by the NRC. Dr. Uhle stated that the NRC staff has full access to review Entergys information supporting the EPU request.

! Mr. John Shadis mentioned a study that was reported in a recent Associated Press news article concerning low levels of radiation and if the NRC has considered that information in our EPU review. Mr. Ennis explained that the NRC staff reviews the information provided by the licensee against the NRCs regulations. Dr. Uhle noted that if new information comes to light that raises questions regarding the adequacy of the NRCs regulations, these questions are more appropriately addressed through the NRCs rulemaking process, which provides for public participation.

The NRC staff did not receive any Public Meeting Feedback forms following this meeting.

Closed Portion of Meeting

The NRC staff in NRRs Division of Systems Safety and Analysis (DSSA), Reactor Systems Branch (SRXB) (including Mr. Jared Wermiel, Branch Chief; Mr. Frank Akstulewicz, Section Chief; and Ms. Zena Abdullahi, Reactor Systems Engineer) and Dr. Uhle discussed the types of information the NRC needs based on Entergys proposed alternate approach. The GE staff (including Mr. Louis Quintana, Manager of Licensing; Mr. Brian Moore, Principal Engineer, and Ms. Margaret Harding, Fuel Engineering Leader), discussed GE analyses, computer codes, assumptions, and methods, related to the types of information that the NRC staff was seeking.

Mr. Dreyfuss explained how Entergy and GE looked at various parameters (e.g., MCPR, linear heat generation rate (LHGR), maximum average planar LHGR (MAPLHGR), shutdown margin (SDM), thermal/hydraulic stability) to determine how to appropriately add safety margin to the core design/operation in order to address any concerns regarding the level of uncertainties in the methods, currently being used by GE, under EPU conditions. Based on this review, they determined that an adder to the MCPR limit would be the best approach to add safety margin.

Based on a statistical approach, using existing GE fuel data, they determined that a value of 0.02 would appropriately account for the uncertainties in the GE methods. This additional MCPR margin will be added as a proposed license condition. Entergy discussed the possibility of adding words to the license condition such that it would no longer be applicable at some point in the future given any long-term efforts to more definitively define the GE methods uncertainties. The NRC staff indicated that such a sunset clause would be too difficult to define and that the appropriate way to remove the license condition in the future would be through a license amendment request.

Mr. Ennis questioned whether the upcoming supplement with the alternate approach would supercede (in its entirety) the relevant information contained in the March 10, 2005, submittal.

Mr. McCann initially indicated that Entergy would still be relying on information in that submittal.

Mr. Marsh explained the need for the licensing basis to be very clear. After further discussion, Mr. McCann stated that the new supplement would stand on its own with respect to the GE methods issue. The upcoming supplement with the alternate approach will clearly explain that it supercedes the GE methods information in the March 10, 2005, submittal in its entirety.

The NRC staff then went through each of the draft RAI questions pertaining to the GE methods issue and discussed whether the questions were still necessary based on the proposed alternate approach. Entergy and GE requested clarifications of the information that the staff was seeking and some of the questions were reworded, as needed, to more definitively describe the information needed. The NRC staff stated that a revised version of the draft RAIs would be sent to Entergy with the proprietary information marked so that GE could verify that the proposed public version would not contain any proprietary information. Entergy did not commit to a specific time-frame to respond to the GE methods RAI questions, and stated that they hoped that the response time could be provided shortly.

Based on the discussions during this meeting, the following list was developed of the information that Entergy/GE will provide in the supplement describing the proposed alternate approach:

1) Provide a discussion of the parameters of interest that were evaluated with respect to adding safety margin, including the rationale for inclusion and the phenomena covered.

Include a discussion of the reason why additional restriction/margin was determined to be, or not to be, necessary for MCPR, LHGR, MAPLHGR, SDM, thermal/hydraulic stability, and exposure.

2) Provide information addressing the following topics:

a) CASMO Simulate (how it is used, data for core follow, validation data, void fraction applicability);

b) neutron monitoring system noise from void creation high in the core; c) cold critical data from the boiling-water reactor fleet (focus on data from plants with similar void fraction, provide data for mid-cycle cold startups);

d) isotopics (provide relevant aspects of GE procedures for core burn evaluation);

e) ODYN conservatism versus TRACG; f) VYNPS steady-state data on LHGR performance; g) accuracy of transverse incore probe (TIP) system (progress from TIP measurements to pin power, Monte Carlo N-particle transport code runs);

h) conservatisms provided by SAFER (MAPLHGR);

i) VYNPS reactivity anomaly technical specification and surveillance results (include Plant E Cycle 10 discussion);

j) void reactivity effect for transients; and k) plant operational context (successful operation with greater than 70% void fraction).

Please direct any inquires concerning this meeting to me. I can be reached at (301) 415-1420, or rxe@nrc.gov.

/RA/

Richard B. Ennis, Senior Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosures:

1. List of Attendees

2. Entergy Slides cc w/Encls: See next page

Please direct any inquires concerning this meeting to me. I can be reached at (301) 415-1420, or rxe@nrc.gov.

/RA/

Richard B. Ennis, Senior Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosures:

1. List of Attendees

2. Entergy Slides cc w/Encls: See next page DISTRIBUTION:

PUBLIC FAkstulewicz BMozafari TAlexion PDI-2 Reading ZAbdullahi RGuzman JDyer JLyons SBailey BSheron TMartin BPoole, OGC RBorchardt GMiller VBucci, OIG TMarsh JStang OGC CHolden SRay ACRS JUhle JPaige RCaruso, ACRS DRoberts EBrown CAnderson, RGN-I REnnis MMarshall AUlses, RES CRaynor AWang TMensah JWermiel MChernoff SLee, EDO Package Accession No.: ML Meeting Summary Accession No.: ML051860217 Slides Accession No.:

OFFICE PDI-2/PM PDI-2/LA SRXB/BC PDI-2/SC PDI/D (A) DLPM/D NAME REnnis CRaynor JWermiel DRoberts JUhle TMarsh DATE 7/21/05 7/25/05 7/25/05 7/22/05 7/25/05 7/26/05 OFFICIAL RECORD COPY

Vermont Yankee Nuclear Power Station cc:

Regional Administrator, Region I Mr. James M. DeVincentis U. S. Nuclear Regulatory Commission Manager, Licensing 475 Allendale Road Vermont Yankee Nuclear Power Station King of Prussia, PA 19406-1415 P.O. Box 0500 185 Old Ferry Road Mr. David R. Lewis Brattleboro, VT 05302-0500 Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W. Resident Inspector Washington, DC 20037-1128 Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission Ms. Christine S. Salembier, Commissioner P.O. Box 176 Vermont Department of Public Service Vernon, VT 05354 112 State Street Montpelier, VT 05620-2601 Director, Massachusetts Emergency Management Agency Mr. Michael H. Dworkin, Chairman ATTN: James Muckerheide Public Service Board 400 Worcester Rd.

State of Vermont Framingham, MA 01702-5399 112 State Street Montpelier, VT 05620-2701 Jonathan M. Block, Esq.

Main Street Chairman, Board of Selectmen P.O. Box 566 Town of Vernon Putney, VT 05346-0566 P.O. Box 116 Vernon, VT 05354-0116 Mr. John F. McCann Director, Nuclear Safety Assurance Operating Experience Coordinator Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station 440 Hamilton Avenue 320 Governor Hunt Road White Plains, NY 10601 Vernon, VT 05354 Mr. Gary J. Taylor G. Dana Bisbee, Esq. Chief Executive Officer Deputy Attorney General Entergy Operations 33 Capitol Street 1340 Echelon Parkway Concord, NH 03301-6937 Jackson, MS 39213 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 Ms. Carla A. White, RRPT, CHP Radiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070

Vermont Yankee Nuclear Power Station cc:

Mr. John T. Herron Ms. Stacey M. Lousteau Sr. VP and Chief Operating Officer Treasury Department Entergy Nuclear Operations, Inc. Entergy Services, Inc.

440 Hamilton Avenue 639 Loyola Avenue White Plains, NY 10601 New Orleans, LA 70113 Mr. Danny L. Pace Mr. Raymond Shadis Vice President, Engineering New England Coalition Entergy Nuclear Operations, Inc. Post Office Box 98 440 Hamilton Avenue Edgecomb, ME 04556 White Plains, NY 10601 Mr. James P. Matteau Mr. Brian OGrady Executive Director Vice President, Operations Support Windham Regional Commission Entergy Nuclear Operations, Inc. 139 Main Street, Suite 505 440 Hamilton Avenue Brattleboro, VT 05301 White Plains, NY 10601 Mr. William K. Sherman Mr. Michael J. Colomb Vermont Department of Public Service Director of Oversight 112 State Street Entergy Nuclear Operations, Inc. Drawer 20 440 Hamilton Avenue Montpelier, VT 05620-2601 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. Kenneth L. Graesser 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Ronald Toole 1282 Valley of Lakes Box R-10 Hazelton, PA 18202