ML052900235

Licensing Condition (to: Commissioner Assistants; from: M Landau Acting for W M Dean)

ML052900235
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	10/17/2005
From:	Bill Dean NRC/EDO/AO
To:	Beall J, Coe D, Holahan G, Reis T, Mohammed Shuaibi, David Skeen NRC/OCM/EXM, NRC/OCM/GBJ, NRC/OCM/JSM, NRC/OCM/NJD, NRC/OCM/PBL
S. Lee 415-1722
References
%dam200601
Download: ML052900235 (7)

Text

October 17, 2005 NOTE TO COMMISSIONERS ASSISTANTS OCM/NJD cc Janet Schlueter cc Rick Croteau cc Roger Davis Brooke Poole X Gary Holahan Chris Jackson X Mohammed Shuaibi Nancy Fragoyannis Sandra Wastler Pat Castleman Robert McOsker Clare Kasputys Vicki Bolling Linda Herr Kia Jackson Susan Abrahams OCM/EXM Heather Astwood X James Beall Linda Lewis Antoinette Waller OCM/GBJ Josh Batkin Angela Coggins X Terry Reis Greg Hatchett Jackie Raines Carolyn Harves OCM/JSM Spiros Droggitis John Thoma Kate Barber Nolan X Dave Skeen Lorna Kipfer Tojuana Fortune OCM/PBL Josie Piccone Cathy Marco X Doug Coe Rebecca Tadesse Vicki Ibarra Laurette Moorin FROM:

William M. Dean

/RA by Mindy Landau Acting For W M Dean/

Assistant for Operations, OEDO

SUBJECT:

VERMONT YANKEE LICENSING CONDITION Based on a request from the Chairmans office, the staff has provided the attached comparison of Entergys proposed license conditions to the NRC proposed license conditions associated with the Vermont Yankee power uprate. The three license conditions in the staffs October 12, 2005, letter to Entergy supercede all previous license conditions proposed by Entergy. As discussed in the October 12, 2005 letter, the license condition on minimum critical power ratio slightly modifies a condition proposed by Entergys September 28, 2005 letter. The license condition on potential adverse flow effects adds new requirements and modifies a license condition proposed by Entergys September 14, 2005 letter.

Attachment:

As stated cc: L. Reyes, EDO (w/o attachment)

SECY (w/attachment)

M. Virgilio, DEDMRS (w/o attachment)

OGC (w/attachment)

W. Kane, DEDR (w/o attachment)

DOC (w/o attachment)

J. Silber, DEDIA (w/o attachment)

OCA (w/o attachment)

W. Dean, AO (w/attachment)

OPA (w/o attachment)

T. Bergman, OEDO (w/o attachment)

OIP (w/o attachment)

S. Lee, OEDO (w/attachment)

OIS (w/o attachment)

J. Jolicoeur, OEDO (w/o attachment)

CFO (w/o attachment)

R. Ennis, NRR (w/o attachment)

EDO R/F (w/attachment)

J. Dyer, NRR (w/o attachment)

License condition related to Minimum Critical Power Ratio proposed by Entergys 9/28/05 letter:

License condition proposed by NRC letter dated 10/12/05:

K. Minimum Critical Power Ratio When operating at thermal power greater than 1593 megawatts thermal, the safety limit minimum critical power ratio (SLMCPR) shall be established by adding 0.02 to the cycle-specific SLMCPR value calculated using the NRC-approved methodologies documented in General Electric Licensing Topical Report NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel," as amended, and documented in the Core Operating Limits Report.

License condition related to potential adverse flow effects proposed by Entergys 9/14/05 letter:

License condition proposed by NRC letter dated 10/12/05:

M. Potential Adverse Flow Effects This license condition provides for monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of power uprate operation on plant structures, systems, and components (including verifying the continued structural integrity of the steam dryer).

1. The following requirements are placed on operation of the facility above the original licensed thermal power (OLTP) level of 1593 megawatts thermal (MWt):

a. Entergy Nuclear Operations, Inc. shall monitor hourly the 32 main steam line (MSL) strain gages during power ascension above 1593 MWt for increasing pressure fluctuations in the steam lines.

b. Entergy Nuclear Operations, Inc. shall hold the facility for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 105%,

110%, and 115% of OLTP to collect data from the 32 MSL strain gages required by Condition M.1.a, conduct plant inspections and walkdowns, and evaluate steam dryer performance based on these data; shall provide the evaluation to the NRC staff by facsimile or electronic transmission to the NRC project manager upon completion of the evaluation; and shall not increase power above each hold point until 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after the NRC project manager confirms receipt of the transmission.

c.

If any frequency peak from the MSL strain gage data exceeds the limit curve established by Entergy Nuclear Operations, Inc. and submitted to the NRC staff prior to operation above OLTP, Entergy Nuclear Operations, Inc. shall return the facility to a power level at which the limit curve is not exceeded. Entergy Nuclear Operations, Inc. shall resolve the uncertainties in the steam dryer analysis, document the continued structural integrity of the steam dryer, and provide that documentation to the NRC staff by facsimile or electronic transmission to the NRC project manager prior to further increases in reactor power.

d. In addition to evaluating the MSL strain gage data, Entergy Nuclear Operations, Inc. shall monitor reactor pressure vessel water level instrumentation and MSL piping accelerometers on an hourly basis during power ascension above OLTP.

If resonance frequencies are identified as increasing above nominal levels established at OLTP conditions, Entergy Nuclear Operations, Inc. shall stop power ascension, document the continued structural integrity of the steam dryer, and provide that documentation to the NRC staff by facsimile or electronic transmission to the NRC project manager prior to further increases in reactor power.

e. Following start-up testing, Entergy Nuclear Operations, Inc. shall resolve the uncertainties in the steam dryer analysis and provide that resolution to the NRC staff by facsimile or electronic transmission to the NRC project manager. If the uncertainties are not resolved within 90 days of issuance of the license amendment authorizing operation at 1912 MWt, Entergy Nuclear Operations, Inc. shall return the facility to OLTP.

2. As described in Entergy Nuclear Operations, Inc. letter BVY 05-084 dated September 14, 2005, Entergy Nuclear Operations, Inc. shall implement the following actions:

a. Prior to operation above OLTP, Entergy Nuclear Operations, Inc. shall install 32 additional strain gages on the main steam piping and shall enhance the data acquisition system in order to reduce the measurement uncertainty associated with the acoustic circuit model (ACM).

b. In the event that acoustic signals are identified that challenge the limit curve during power ascension above OLTP, Entergy Nuclear Operations, Inc. shall evaluate dryer loads and re-establish the limit curve based on the new strain gage data, and shall perform a frequency-specific assessment of ACM uncertainty at the acoustic signal frequency.

c.

After reaching 120% of OLTP, Entergy Nuclear Operations, Inc. shall obtain measurements from the MSL strain gages and establish the steam dryer flow-induced vibration load fatigue margin for the facility, update the dryer stress report, and re-establish the steam dryer monitoring plan (SDMP) limit curve with the updated ACM load definition and revised instrument uncertainty, which will be provided to the NRC staff.

d. During power ascension above OLTP, if an engineering evaluation is required in accordance with the SDMP, Entergy Nuclear Operations, Inc. shall perform the structural analysis to address frequency uncertainties up to +/-10% and assure that peak responses that fall within this uncertainty band are addressed.

e. Entergy Nuclear Operations, Inc. shall revise the SDMP to reflect long-term monitoring of plant parameters potentially indicative of steam dryer failure; to reflect consistency of the facilitys steam dryer inspection program with General Electric Services Information Letter 644, Revision 1; and to identify the NRC Project Manager for the facility as the point of contact for providing SDMP information during power ascension.

f.

Entergy Nuclear Operations, Inc. shall submit the final extended power uprate (EPU) steam dryer load definition for the facility to the NRC upon completion of the power ascension test program.

g. Entergy Nuclear Operations, Inc. shall submit the flow-induced vibration related portions of the EPU startup test procedure to the NRC, including methodology for updating the limit curve, prior to initial power ascension above OLTP.

3. Entergy Nuclear Operations, Inc. shall prepare the EPU startup test procedure to include the (a) stress limit curve to be applied for evaluating steam dryer performance; (b) specific hold points and their duration during EPU power ascension; (c) activities to be accomplished during hold points; (d) plant parameters to be monitored; (e) inspections and walkdowns to be conducted for steam, feedwater, and condensate systems and components during the hold points; (f) methods to be used to trend plant parameters; (g) acceptance criteria for monitoring and trending plant parameters, and conducting the walkdowns and

inspections; (h) actions to be taken if acceptance criteria are not satisfied; and (i) verification of the completion of commitments and planned actions specified in its application and all supplements to the application in support of the EPU license amendment request pertaining to the steam dryer prior to power increase above OLTP. Entergy Nuclear Operations, Inc. shall submit the EPU startup test procedure to the NRC by facsimile or electronic transmission to the NRC project manager prior to increasing power above OLTP.

4. When operating above OLTP, the operating limits, required actions, and surveillances specified in the SDMP shall be met. The following key attributes of the SDMP shall not be made less restrictive without prior NRC approval:

a. During initial power ascension testing above OLTP, each test plateau increment shall be approximately 80 MWt;

b. Level 1 performance criteria; and c.

The methodology for establishing the stress spectra used for the Level 1 and Level 2 performance criteria.

Changes to other aspects of the SDMP may be made in accordance with the guidance of NEI 99-04.

5. During each of the three scheduled refueling outages (beginning with the spring 2007 refueling outage), a visual inspection shall be conducted of all accessible, susceptible locations of the steam dryer, including flaws left as is and modifications.

6. The results of the visual inspections of the steam dryer conducted during the three scheduled refueling outages (beginning with the spring 2007 refueling outage) shall be reported to the NRC staff within 60 days following startup from the respective refueling outage. The results of the SDMP shall be submitted to the NRC staff in a report within 60 days following the completion of all EPU power ascension testing.

7. The requirements of paragraph 4 above for meeting the SDMP shall be implemented upon issuance of the EPU license amendment and shall continue until the completion of one full operating cycle at EPU. If an unacceptable structural flaw (due to fatigue) is detected during the subsequent visual inspection of the steam dryer, the requirements of paragraph 4 shall extend another full operating cycle until the visual inspection standard of no new flaws/flaw growth based on visual inspection is satisfied.

8. This license condition shall expire upon satisfaction of the requirements in paragraphs 5, 6, and 7 provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw or unacceptable flaw growth that is due to fatigue.