ML052200223

From kanterella
Jump to navigation Jump to search
Letter to Anthony Z. Roisman Regarding Request for Documents
ML052200223
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 08/03/2005
From: Poole B
NRC/OGC
To: Roisman A
National Legal Scholars Law Firm, PC
SECY RAS
References
50-271-OLA
Download: ML052200223 (21)


Text

- w o UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 3, 2005 Anthony Z. Roisman, Esq.

National Legal Scholars Law Firm, P.C.

84 East Thetford Road Lyme, NH 03768 In the Matter of ENTERGY NUCLEAR VERMONT YANKEE LLC and ENTERGY NUCLEAR OPERATIONS, INC.

(Vermont Yankee Nuclear Power Station)

Docket No. 50-271 -OLA

Dear Mr. Roisman:

This responds to your letter dated July 20, 2005, in which you requested nine documents that were identified in the NRC Staff's Deliberative Process Privilege Log dated July 7, 2005.' In response to your letter, the Staff is producing some of the requested information. Each document is discussed in turn below.

(1) ML051640030 - The Staff is producing 2 of 21 pages. The remaining 19 pages consist of draft requests for additional information ("RAls") generated by the Office of Nuclear Reactor Regulation, Reactor Systems Branch, regarding the analytical methods used to predict Vermont Yankee's core and fuel performance for steady state and design basis event conditions. The Staff declines to produce these draft RAls, as they constitute predecisional, deliberative information that reflects a consultative process. To the extent that the draft RAls contain factual material, it is "inextricably intertwined" with the opinion portion. Further, it is the Staff's view that the Vermont Department of Public Service

("DPS") has no need for the draft RAls, which do not pertain to DPS's admitted contentions regarding the use of containment overpressure.

(2) ML051640036 - The Staff is producing 2 of 35 pages. The remaining 33 pages consist of draft RAls generated by the Office of Nuclear Reactor Regulation, Reactor Systems Branch, regarding the analytical methods used to predict Vermont Yankee's core and fuel performance for steady state and design basis event conditions. The Staff declines to produce these draft RAls, as they constitute predecisional, deliberative information that reflects a consultative process. To the extent that the draft RAls contain factual material, it is "inextricably intertwined" with the opinion portion. Further, it is the Staff's view that DPS has no need for the draft RAls, which do not pertain to DPS's admitted contentions.

1 The Deliberative Process Privilege Log is Enclosure 3 to Hearing File Supplement 10, filed by the Staff in this proceeding on July 7, 2005. Due to an error in service, Supplement 10 was re-served on the parties on July 13, 2005.

Anthony Z. Roisman, Esq. August 3, 2005 (3) ML056140046 - The Staff is producing this document in its entirety.

(4) ML051610421 - The Staff is producing this document in its entirety.

(5) ML051670410 - The Staff declines to produce this document. The deliberative process privilege is designed to protect, among other things, interagency communications "reflecting advisory opinions, recommendations and deliberations comprising part of a process by which governmental decisions and policies are formulated." Georgia Power Co. (Vogtle Electric Generating Plant, Units 1 & 2), CLI-94-5, 39 NRC 190,197 (1994),

quoting NLRB v. Sears, Roebuck & Co., 421 U.S. 132, 150 (1975). This internal memorandum pertains to the prioritization and organization of NRC staff resources relative to the applicant's computational fluid dynamics analysis which, in turns, supports the steam dryer analysis performed in connection with the EPU amendment. As such, it is protected by the deliberative process privilege. Further, it is the Staff's view that the DPS has no need for the memorandum, which does not pertain to DPS's admitted contentions.

(6) ML051730236 - The Staff is producing 2 of 4 pages. The remaining two pages consist of draft RAls generated by the Office of Nuclear Reactor Regulation, Plant Systems Branch, regarding (a) the spent fuel pool cooling and cleanup system, (b) reactor auxiliary cooling water systems, (c) the condensate and feedwater system, and (d) the power ascension and testing plan. The Staff declines to produce these draft RAls, as they constitute predecisional, deliberative information that reflects a consultative process. To the extent that the draft RAIs contain factual material, it is "inextricably intertwined" with the opinion portion. Further, it is the Staff's view that DPS has no need for the draft RAls, which do not pertain to DPS's admitted contentions.

(7) ML051750320 - The Staff is producing 3 of 12 pages. The remaining nine pages consist of draft RAls generated by the Office of Nuclear Reactor Regulation, Mechanical and Civil Engineering Branch, regarding the applicant's revised steam dryer analysis.

The Staff declines to produce these draft RAls, as they constitute predecisional, deliberative information that reflects a consultative process. To the extent that the draft RAls contain factual material, it is "inextricably intertwined" with the opinion portion.

Further, it is the Staff's view that DPS has no need for the draft RAls, which do not pertain to DPS's admitted contentions.

(8) ML051810386 - The Staff is producing this document in its entirety. It should be noted that this document contains information proprietary to Entergy's contractor, General Electric, and its disclosure and use is therefore governed by the Atomic Safety and Licensing Board's ("Licensing Board") March 1, 2005 Protective Order Governing Non-Disclosure of Proprietary Information. A redacted version of this document will be released to the public as an update to the Staff's mandatory disclosures.

Anthony Z. Roisman, Esq. August 3, 2005 (9) ML051800109 - The Staff is producing this document in its entirety. The document references an attachment that was not requested by DPS, but that is also identified in the July 7, 2005 Deliberative Process Privilege Log, is identified as ADAMS accession number ML051800444. 2 The attachment contains draft RAls pertaining to the applicant's steam dryer analysis.

At this time, the documents identified above are being produced to you in hard copy as enclosures to this letter. The hearing file will be updated in accordance with NRC rules and the Licensing Board's April 5, 2005 Order. If you have any questions regarding these disclosures, please call me at (301) 415-1556.

Sincerely, Brooke D. Poole Counsel for NRC Staff

Enclosures:

As stated cc w/enclosures: Sarah Hofmann, Esq.

cc w/o enclosures: Jay E. Silberg, Esq.

2 ML051800444 is identified as an attachment to ML051800109 in the Deliberative Process Privilege Log (at 5).

I Rick Ennis - Emamling: VY-RAI-Set2-Thur-June 9-2005-rev2.wpd - - ------ - -- - --- Paa e i g

_ i, _

ML051640030 From: Zena Abdullahi To: Rick Ennis Date: 619105 1:46PM

Subject:

Emailing: W-RAlSet2-Thur-June 9-2005-rev2.wpd Rick, The VY second RAI set Is attached. Frank had made changes and Is ready to concur. I am e-mailing you the RAI so that we can expedite the process. SRXB would be issuing the RAls formally to Projects.

Your files are attached and ready to send with this message.

CC: Frank Akstulewicz; Jennifer Uhle

I c:Item;AGWI0000I.TMPX Page 1 Paae iil I c:temrAGW1OOOO1.TMP Mail Envelope Properties (42A8808D.986 :23: 35280)

Subject:

Emailing: VY-RAI-Set2-Thur-June 9-2005-rev2. ypd Creation Date: 6/9/05 1:46PM From: Zena Abdullahi Created By: ZXA~nrc.gov Recipients nrc.gov OWGNVPOOI.HQGWDOO1 FMA CC (Frank Akstulewicz) nrc.gov TWGWPO02.HQGNVDOOI JXUI CC (Jennifer Uhle) nrc.gov owvf4_po.OIVFN DO RXE (Rick Ennis)

Post Office Route OWGNVPOOI.HQGWDOOI nrc.gov TWGNYPO02.HQGWDOO1 nrc.gov oivf4_po.ONVFNDO nrc.gov Files Size Date & Time MESSAGE 769 06/09105 01:46PM VY-RAI-Set2-Thur-June 9-2005-rev2.wpd 88186 06109/05 01:44PM Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed

Subject:

No Security: Standard

Rick Ennis - VY EPU - Revised SRXB RAls Page 1 ML051640036 From: Rick Ennis To: Frank Akstulewicz; Zena Abdullahl Date: 619105 6:41PM

Subject:

VY EPU - Revised SRXB RAls FranklZena, Attached Is my revised version of Zena's RAls and a redlinelstrikeout showing the changes I made. I will be providing them In draft form to the licensee tonight. If you see any errors In the changes I made let me know so we can make corrections before the RAI Is Issued formally (hopefully In next week or so).

thanks, Rick 415-1420 CC: Jennifer Uhle

j 7 r t . ._ _ _*_..*I I c:\temDAGW00001 .TMP Paae 1 I -- -.-.

Mail Envelope Properties (42A8C5AB.28A:15: 20516)

Subject:

VY EPU - Revised SRXB RAIs Crcation Date: 619105 6:41PM From: Rick Ennis Created By: RXE~nrc.gov Recipients Aetion Date & Time OWGWPO010.HQGWDO01 Delivered 06/09/05 06:41PM FMA (Frank Akstulewicz)

ZXA (Zena Abdullahi)

TWGWPO02.HQGNVDOO1 Delivered 06109105 06:41PM JXUI CC (Jennifer Uhle)

Post Office Delivered Route OWGWVPO01.HQGWDO01 06/09/05 06:4 1PM TNVGWPO02.HQGWDOO1 06/09/05 06:41PM Files Size Date & Time MESSAGE 980 06109/05 06:41PM revised zena rais.wpd 77604 06109/05 06:41PM srxb zena rai redline.wrpd 107254 06/09/05 06:34PM Options Auto Delete: No Ex piration Date: None Notify Recipients: Yes Priority: Standard Reply Requested: No Return Notification: None Concealed

Subject:

No Sccurity: Standard To Be Delivered: Immediate Status Tracking: Delivered & Opened

J.

LRick Ennis - Re: VY EPU - Revised SRXB RAls ML051640046 Page 1 From: Zena Abdullahl To: RXE@nrc.gov,FMA.OWGWPOOI.HQGWDOOIZXA.OWGWPOOl.HQGWDOO1 Date: 6110105 9:06AM

Subject:

Re: VY EPU - Revised SRXB RAls Rick, The RAls are draft both In content and editorial. I would give review them before we Issue formally. Thank you for the changes.

>>> Rick Ennis 06109105 18:41 PM >>>

FranklZena.

Attached is my revised version of Zena's RAls and a redlinelstrikeout showing the changes I made. I will be providing them in draft form to the licensee tonight. If you see any errors in the changes I made let me know so we can make corrections before the RAI Is Issued formally (hopefully In next week or so).

thanks, Rick 415-1420 CC: JXUI.TWGWPOO2.HQGWDOOI

-r r Jg IcjtempIGWVQ00001.TMP Page 1 Mail Envelope Propertics (42A99038.7A6: 23: 35984)

Subject:

Re: VY EPU - Revised SRXB RAls Creation Datc: 6/10105 9:06AM From: Zena Abdullahi Created By: zxaenrc.gov Recipients nrc.gov OWGWPOO1 .HQGWDOOI FMA (Frank Akstulewicz)

ZXA (Zena Abdullahi) nrc.gov TNVGWP002.HQGWDOOI JXUI CC (Jennifer Uhle) nrc.gov oivf4_po.ONWFN DO RXE (Rick Ennis)

Post Office Route OWGWP1OOI.HQGWDOOI nrc.gov TnVGWPO02.HQGWDOOI nrc.gov owvf4_po.OWFNDO nrc.gov Files Size Date & Time MESSAGE 529 06110105 09:06AM Options Expiration Date: None Priority: Standard Reply Rcquested: No Return Notification:

Send Mail Receipt when Undeliverable Concealed

Subject:

No Security: Standard

J t ML051610421 June 10, 2005 MEMORANDUM TO: James E. Dyer, Director Office of Nuclear Reactor Regulation FROM Carl J. Paperiello, Director IRA/by C. Miller for Office of Nuclear Regulatory Research

SUBJECT:

USER NEED REQUEST FOR REVIEW OF COMPUTATIONAL FLUID DYNAMICS (CFD) ANALYSIS RELATING TO VERMONT YANKEE POWER UPRATE AMENDMENT (NRR-2005-006)

The Office of Nuclear Regulatory Research (RES) will provide technical expertise to support the Office of Nuclear Reactor Regulation (NRR) in the review of the CFD analysis relating to the Vermont Yankee (VY) extended power uprate (EPU) request. This support is outlined in the user need request from J. Dyer to Carl J. Paperiello dated June 4, 2005.

Background

The NRC staff is reviewing a license amendment request from Entergy to operate the VY Nuclear Power Station at EPU conditions (20% above the original licensed thermal power).

Entergy has submitted a revised steam dryer analysis that includes an acoustic circuit analysis, computational fluid dynamics (CFD) analysis, scale model testing and validation of the acoustic model and the computer code that generates the final forcing functions used in the dryer analysis. Technical expertise from RES to assist in the review of the licensee's CFD analysis is requested by the NRR staff.

Scope and Schedule of RES Products RES will review the licensee's CFD analysis and, as necessary, develop a Request for Additional Information (RAI) to support the staff's audit of the analyses performed by the licensee. RES will also prepare inputs for a Safety Evaluation (SE) related to the CFD section of the amendment that will contain a discussion of the RAI and an assessment of the licensee's response to the RAI. Specific tasks are outlined below.

June 15-16, 2005 RES plans on reviewing the supplied report and being prepared to support the audit of the licensee's documentation on June 15 and 16, 2005. Draft RAI inputs will be prepared prior to the audit but, as agreed upon with NRR staff, will not be delivered on June 10, 2005.

J r A.

J. Dyer 2 July 1, 2005 Final RAI inputs from RES will be completed by July 1, 2005.

August 12, 2005 Draft SE input will be completed by August 12, 2005, or two weeks after receipt of the licensee's RAI response (whichever is later). Adjustments to this input will be made as necessary prior to the final SE input.

RES and NRR staff have met and discussed the requested support in detail. RES acknowledges the potential need to support additional audits of the licensee's documentation and responses to the RAI as well as the need to support NRR during ACRS meetings.

RES anticipates up to 3 staff months of effort to support the user need request. All support is expected to be completed by the end of December 2005.

.I r- i, J. Dyer 2 July 1, 2005 Final RAI inputs from RES will be completed by July 1, 2005.

August 12, 2005 Draft SE input will be completed by August 12, 2005, or two weeks after receipt of the licensee's RAI response (whichever is later). Adjustments to this input will be made as necessary prior to the final SE input.

RES and NRR staff have met and discussed the requested support in detail. RES acknowledges the potential need to support additional audits of the licensee's documentation and responses to the RAI as well as the need to support NRR during ACRS meetings.

RES anticipates up to 3 staff months of effort to support the user need request. All support is expected to be completed by the end of December 2005.

Distribution:

SMSAB R/F DSARE R/F DSARE #90 RES Action #2005306 C. Grimes, RES E:\Filenet\ML051610421.wpd OAR in ADAMS? (Y or N) Y ADAMS ACCESSION NO.: TEMPLATE NO. RES-.00 Publicly Available? (Y or N) N DATE OF RELEASE TO PUBLIC_ SENSITIVE? N To receive a copy of this document, indicate inthe box: 'C" = Copy without enclosures 'E" =Copy with enclosures "N' = No copy OFFICE SMSAB ic SC:SMSAB- c C:SMSAB* D:DSAREl DD:RES* D:RES* I NAME CBoyd:mb RHogan PBaranowsky FEtawila CMiller CPaperiello by CMiller for DATE 6/10/05 6/10/05 6/10/05 6/10/05 6/10/05 6110 /05

Rick Enhis - VY EPU Questions Page 1 ML051730236 From: James Tatum To: Rick Ennis Date: 6121105 10:16AM

Subject:

VY EPU Questions Rick, Attached are the last of our questions for VY EPU request. I will be in training the next two days from 8:30 to 4, but can discuss the questions with the licensee either during a lunch break, after 4, or anytime on Friday. Jim CC: Chang Li; Devender Reddy' Steve Jones

I c:\lemnp\GWIOOOOI.TMP b_ - Pace IIII Paae c:lJemD\GWIOQOOI.TMP Mail Envelope Propertics (42B82145.92B: 21: 20440)

Subject:

VY EPU Questions Creation Date: 6/21/05 10:16AM From: James Tatum Crcated By: JETI enrc.gov Recipients OWGWPO02.HQGWDOOI SRJ CC (Steve Jones)

TWVGWPOOI .HQGWDOOI DKR2 CC (Devender Reddy) ov12_po.OWFNDO CYLI CC (Chang Li) owf4_po.OWFNDO RXE (Rickl Ennis)

Post Office Routc OWGIPO002.HQGWDOOI TWGWPO01.HQGWDO0I oi'12po.0NFN_D0 owf4_po.OWFNDO Files Size Date & Time MESSAGE 656 06/21/05 10:16AM VY EPU RAI.%pd 8383 06/21/05 10:12AM Options Expiration Datc: None Priority: Standard Reply Requested: No

-Return Notification: None Concealed

Subject:

No Security: Standard

ML051800109 June 29, 2005 MEMORANDUM TO: Eugene Imbro, Chief Mechanical & Civil Engineering Branch Division of Engineering Office of Nuclear Reactor Regulation FROM: Patrick Baranowski, Chief IRA/by R. Hogan for Safety Margins and Systems Analysis Branch Division of Systems Analysis and Regulatory Effectiveness Office of Nuclear Regulatory Research

SUBJECT:

RAI INPUTS FROM RES REVIEW OF COMPUTATIONAL FLUID DYNAMICS (CFD) ANALYSIS RELATING TO VERMONT YANKEE POWER UPRATE AMENDMENT (USER NEED NRR-2005-006)

A careful review of the CFD related analysis supporting the Vermont Yankee (VY) extended power uprate (EPU) request has been completed by the Office of Nuclear Regulatory Research (RES). A list of 20 RAI questions is attached to this memorandum. Development of this RAI list fulfills part of the user need request outlined in the memorandum from J. E. Dyer to Carl J. Paperiello dated June 4, 2005, (NRR-2005-006)

The NRC staff is reviewing a license amendment request from Entergy to operate the VY Nuclear Power Station at EPU conditions (20% above the original licensed thermal power).

Entergy has submitted a revised steam dryer analysis that includes an acoustic circuit analysis, computational fluid dynamics (CFD) analysis, scale model testing and validation of the acoustic model and the computer code that generates the final forcing functions used in the dryer analysis. RES staff has reviewed the submitted CFD analysis and attended an audit covering this analysis at the General Electric offices in Washington, DC on June 15, 2005.

RES will continue to support the VY EPU request as outlined in the user need request.

Comments regarding these specific RAI questions should be addressed to Christopher Boyd (DSARE/SMSAB) at 415-0244.

Attachment:

As stated

June 29, 2005 MEMORANDUM TO: Eugene Imbro, Chief Mechanical & Civil Engineering Branch Division of Engineering Office of Nuclear Reactor Regulation FROM: Patrick Baranowski, Chief IRA! by R. Hogan for Safety Margins and Systems Analysis Branch Division of Systems Analysis and Regulatory Effectiveness Office of Nuclear Regulatory Research

SUBJECT:

RAI INPUTS FROM RES REVIEW OF COMPUTATIONAL FLUID DYNAMICS (CFD) ANALYSIS RELATING TO VERMONT YANKEE POWER UPRATE AMENDMENT (USER NEED NRR-2005-006)

A careful review of the CFD related analysis supporting the Vermont Yankee (VY) extended power uprate (EPU) request has been completed by the Office of Nuclear Regulatory Research (RES). A list of 20 RAI questions is attached to this memorandum. Development of this RAI list fulfills part of the user need request outlined in the memorandum from J. E. Dyer to Carl J. Paperiello dated June 4, 2005, (NRR-2005-006)

The NRC staff is reviewing a license amendment request from Entergy to operate the VY Nuclear Power Station at EPU conditions (20% above the original licensed thermal power).

Entergy has submitted a revised steam dryer analysis that includes an acoustic circuit analysis, computational fluid dynamics (CFD) analysis, scale model testing and validation of the acoustic model and the computer code that generates the final forcing functions used in the dryer analysis. RES staff has reviewed the submitted CFD analysis and attended an audit covering this analysis at the General Electric offices in Washington, DC on June 15, 2005.

RES will continue to support the VY EPU request as outlined in the user need request.

Comments regarding these specific RAI questions should be addressed to Christopher Boyd (DSARE/SMSAB) at 415-0244.

Attachment:

As stated Distribution: SMSAB R/F DSARE R/F FEltawila SBahadur JStarefos CGrimes MMa TScarbrough, NRR E:\Filenet\ML051800109.wpd OAR in ADAMS? (Y or N) v ADAMS ACCESSION NO.: n518010l Mtoll TEMPLATE NO. RES-1106, Publicly Available? (Y or N) N DATE OF RELEASE TO PUBLIC_ SENSITIVE? v To receive a copy of this document, indicate In the box: "C" = Copy without enclosures "E' = Copy with enclosures 'N" = No copy OFFICE *SMSAB l E *SC:SMSAB I *C:SMSAB LI NAME CBoyd:mb RHogan PBaranowsky by RHogan for DATE 6/29105 6/29/05 6/29/05

issue Paae I I J'M-61 - Re: Summary Ennis -R-e:-S-um-Rick Eniiis of 6128 conference im-ary-o-f-6/2-8-c-o-n-f iirenceca-l -

GE--methods callI- GE m e-thod's lmsue- Pane I1 From: Zena Abdullahi To: Brian Sheron; Rick Ennis Date: 6/29105 9:51AM

Subject:

Re: Summary of 6/28 conference call - GE methods Issue Rick, You did a good summary. I modified Item 9, adding additional explanation.

>>> Rick Ennis 06128105 06:14PM >>>

Brian, Attached for your information Is a summary documenting our call today with Entergy and GE concerning the GE methods Issue.

thanks, Rick 415-1420 CC: Alan Wang; Anthony Ulses; Brooke Poole; Cornelius Holden; Darrell Roberts; Frank Akstulewicz; James Lyons; Jared Wermiel; Jennifer Uhle; John Stang; Sheila Ray; Tad Marsh; Thomas Martin

I c:\tempIGW)00002.TMP fPage Pane II II I c:tempGWjOOOO2.TMP Mail Envelope roperties (42C2A73D.291: 23: 35280)

Subject:

Re: Summary of 6/28 conference call - GE methods issue Creation Date: 6/29/05 9:50AM From: Zena Abdullahi Crcated By: ZXA~nrc.gov Recipients nrc.gov OWGWPOOI .HQGWDOOI FMA CC (Frank Akstulewicz) nrc.gov TWGWPOOI.HQGWDOO1 SXR4 CC (Sheila Ray) nrc.gov TWGNWP002.HQGWDOO I JSWI CC (Jared Wermiel)

JXU1 CC (Jennifer Uhle) nrc.gov owf4_po.OWFNDO ABW CC (Alan Wang)

BWS (Brian Sheron)

CFH CC (Cornelius Holden)

DJR CC (Darrell Roberts)

JEL CC (James Lyons)

JFS2 CC (John Stang)

LBM CC (Tad Marsh)

RXE (Rick Ennis) nrc.gov o-f5..po.ONVFNDO BDP CC (Broo~ke Poole) nrc.gov twf4po.TNNTNDO TOM2 CC (Thomas Martin) nrc.gov twf5_po.TWVFNDO APU CC (Anthony Ulses)

J9 A.

c:\temrp\GW)0O002.TMP Paae 2 rost Office Route OWGWPOO1 .HQGWDOOI nrc.gov TWGWPOO 1.HQGWDOO 1 nrc.gov TWGNWP002.HQGWDOO1 nrc.gov owvf4_po.OWFNDO nrc.gov oNfS_po.OWF:NDO nrc.gov t1vf4_po.TWFN DO nrc.gov -

twf5_po.TWFNDO nrc.gov Files Size Date & Time MESSAGE 1010 06/29105 09:50AM GE Methods 6-28-05 call. vpd 8062 06/29/05 09:48AM Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed

Subject:

No Security: Standard

Summary of 6128105 Call Regarding GE Methods Issue For Vermont Yankee EPU Participants NRC - TMarsh, ZAbdullahi, JWermlel, TUlses, JUhle, SRay, JStang Entergy - CNichols, JMcCann, JDreyfus, RVida, LGucwa, EDuda GE - IQuintana, MHarding, BMoore, JKlapproth, JTuttle, MDick Purpose Followup call to 6/23 management call between Entergy and NRC to discuss the GE methods issue as it relates to the VY EPU and to make the 6/30 public meeting more productive.

Call Summary

1) VY's EPU submittal relies on GE's interim process. Based on draft RAls issued recently, Entergy believe the overall EPU schedule would be delayed significantly if all the RAt issues were to be addressed.
2) In order to have more timely resolution of the issues, Entergy/GE will propose an alternate approach to resolve the staff's concerns pending long-term resolution of the Issue.
3) The staffs concerns relate to lack of confirmatory data from gamma scans. The parameters that GE will verify for long-term resolution of the Issue via gamma scans are: local pin power and exposure, relative fuel pin power, and bundle power allocation.
4) GE determined that taking a penalty on the SLMCPR would be an appropriate approach to resolve the issue until the gamma scan data was obtained.
5) GE reviewed the uncertainties in the SLMCPR methodology using a statistical approach and, using existing gamma scan data from 8x8 fuel, determined a SLMCPR impact of 0.02.
6) GE will use previous approved methods for propagation of the uncertainties.
7) Entergy preliminary review indicates that the core design will not be affebted, however, they may need to do rod pattern adjustments.
8) Entergy will commit to a 0.02 SLMCPR penalty as a license condition for the EPU. They would like to establish some sort of "sunset clause' in order to remove the license condition in the future.
9) SRXB staff indicated that the alternate approach still does not address all the staff concerns.

Specifically, the proposed approach does not address the accuracy of their lattice physics code in predicting the isotopic composition of the fuel with exposure and propagating the errors in the nodal powers and reactivity with exposure to the safety analyses. !GE stated that accumiulted error with exposrels rimasura'ble "iri the hot arIid cod 'eigenvalu'e cor'nparisons2 Diffeiirices remain between the staff and GE obi'whetherjcore:wid6ehot and c6ld bigenvalue calculations are ad6qute .in dmbinitratingtlie uncertainties associat&d with'&dletion jo 60.GWD/ST uiird&

high-Vo'id cbnditions (hard 6peciffirfi), when th6-6c'cwrh6jbtf tH'dutrbA16'cod6`W6s'not benchmarkeid against heavy lsotope m6dsurinfenti:

10) The staff will review the existing RAls and determine which RAls would still need to be answered given the alternate approach and will revise the RAls as needed. The staff will try to complete this effort prior to the 6130 meeting and provide the revised RAls to Entergy.
11) Entergy and GE will continue discussions and determine if they would like another conference call prior to the meeting. Entergy will contact the staff if another call is desired.
12) It was agreed that the goals for the 6/30 meeting were: (a) Entergy/GE will restate the proposed alternative approach; (b) the staff will decide which RAls need to be addressed either on the VY docket, or by GE generically.; (c) Entergy will determine the response time on the VY RAls so that the staff can re-establish the EPU review schedule.