Text

Letters from Luis A. Reyes to Six Massachusetts State Officials Responding to Their March 22, 2006 Letter Re Safety Assessment of Vermont Yankee
	ML061300389
Person / Time
Site:	Vermont Yankee
Issue date:	04/27/2006
From:	Reyes L; NRC/EDO
To:	Bosley D, Donelan C, Guyer D, Kulik S, Nuciforo A, Rosenberg S; State of MA, House of Representatives, State of MA, Senate
	Byrdsong A T
References
	50-271-OLA, ASLBP 04-832-02-OLA, RAS 11635
	Download: ML061300389 (50)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMlSSlON DOCKETED WASHINGTON, D.C. 20555-0001 USNRC A p r i l 27, 2006 May 10,2006 (8:03am)

OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF The Honorable Christopher J. Donelan State Representative Docket No. 50-271-0LA The Commonwealth of Massachusetts House of Representatives State House SERVED May 10,2006 Boston, MA 02133

Dear Representative Donelan:

On behalf of the Nuclear Regulatory Commission (NRC), I am writing in response to your letter to NRC Chairman Nils J. Diaz, of March 22, 2006, in which you expressed concerns about the implementation of the extended power uprate (EPU) at the Vermont Yankee Nuclear Power Station (Vermont Yankee). Specifically, your letter requested that the NRC conduct a comprehensive independent safety assessment of Vermont Yankee.

I am enclosing a copy of a letter that Chairman Diaz sent to the Vermont Public Service Board (PSB), dated May 4, 2004, explaining the NRC's approach in response to the PSB's request for an independent engineering assessment of Vermont Yankee. As noted in the letter, the NRC staff concluded that its detailed technical review of the proposed amendment, combined with the inspections prescribed by the reactor oversight process, as enhanced by an improved engineering inspection, was determined to be the most effective method of informing the staff decision on whether Vermont Yankee could operate safely under uprated power conditions.

On March 2, 2006, the NRC staff issued its safety evaluation documenting the results of the technical review for the power uprate. A copy of this 335 page report is available on the NRC's Web site at http://adamswebsearch.nrc.qov/doloqin.htm by searching for accession number ML060050028. Section 1.6 of the safety evaluation discusses the engineering inspection that was completed in September 2004. The NRC staff spent over 11,000 hours0 days 0 hours 0 weeks 0 months on the technical review of the proposed power uprate. In addition, over 900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months were spent on the engineering inspection effort. 'Ne believe that the Vermont Yankee engineering inspection responds appropriately to requests to conduct an independent assessment of Vermont Yankee.

The NRC Advisory Committee on Reactor Safeguards (ACRS) reviewed the engineering inspection results in the context of its evaluation of the Vermont Yankee power uprate request.

The ACRS is a statutory committee that reports directly to the Commission and is structured to provide a forum where experts representing many technical perspectives can provide advice that is factored into the NRC's decision-making process. The ACRS Subcommittee on Power Uprates held a meeting on November 15 and 16, 2005, in Brattleboro, Vermont to receive input from the public, Entergy, and the NRC staff regarding the proposed power uprate. During this meeting the NRC staff provided the results of the engineering inspection, including a discussion of all relevant inspection findings. Many members of the public asked for a more extensive inspectiori, sirniiai to that peri'oiriied at the Maine Yaiikee piant. li-i a letter to NRC Chairmai-i

Diaz dated January 4,2006, the ACRS recommended approval of the Vermont Yankee power uprate. As noted in the letter, the ACRS concluded that based on the results of the inspection that was performed and the performance of Vermont Yankee as determined by the NRC's reactor oversight process, a more extensive inspection is not warranted.

The NRC's approval of the Vermont Yankee EPU included a license condition that provides for monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of power uprate operation on structures, systems, and components (including verifying the continued structural integrity of the steam dryer). The license condition is implemented through the procedural steps, performance criteria, and required actions specified in the Vermont Yankee steam dryer monitoring plan and power ascension test procedure.

On March 4, 2006, Entergy began slowly increasing reactor power at Vermont Yankee following the NRC's approval of the EPU amendment on March 2, 2006. Since that time, the plant has suspended the power ascension twice (at 105O/0 and 112.5% of original licensed thermal power) when administrative limits specified in the steam dryer monitoring plan were reached. When an administrative limit is reached, the monitoring plan requires that an engineering evaluation be performed prior to further increases in power. As documented in the NRC staff's Safety Evaluation for the EPU, Entergy formally committed to not increase power above the applicable hold point, if any safety concerns were identified during the NRC staff's review of the power ascension data. The NRC staff reviewed the evaluation and the power ascension data at 105%, 110%, 112.5'/0, and 115% to determine if it had any safety concerns. On April 25, the NRC approved continued ascension to 120% power level.

Your letter also raised a concern regarding an unexpected plant shutdown at Vermont Yankee related to failure of a transformer. This event received significant scrutiny by the NRC. On June 18, 2004, an electrical fault on the 22 kilovolt (kV) electrical system forced the reactor to automatically shut down from 100% power. Arcing and heat generated during the fault caused a main transformer fire. The fire was extinguished through the combined efforts of the automatic fire suppression system, the site's fire brigade, and the local volunteer fire department. The NRC's resident inspectors immediately responded to the event, and the Region I Incident Response Center was staffed to support the residents and follow Entergy's response to the fire. The fire caused no damage to safety systems and Entergy restarted the plant on July 6, 2004, after making necessary repairs. In its November 8, 2004, quarterly inspection report, the NRC discussed Entergy's failure to incorporate operating experience into preventive maintenance of the 22 kV eiecirical sysiem. Entergy is managing this issue through its corrective action program.

Your letter also referenced the views expressed by Commissioner Jaczko in a memorandum to his fellow Commissioners, concerning the Vermont Yankee EPU. The memorandum reflects the views of Commissioner Jaczko and not the entire Commission's view on any particular matter. On March 3, 2006, the Commission declined to stay the issuance of the requested EPU amendment, pending completion of the adjudicatory proceeding on this application; Commissioner Jaczko concurred in that decision.

The NRC's primary missicm is to ensure adequate protection of public healtn and safety. The NRC will not approve any proposed change to any plant license unless our technical staff can conc!de that it has reasmab!e assurance that adeq~lateproteztiori of public h e d i h aiid szifety will be ensured. W e have taken great care in co~ductinr;the tech~izalreviews and inspections

regarding the Vermont Yankee power increase in order to ensure that these reviews and inspections will identify and address any potential safety concerns for operating the plant at uprated power conditions. We will continue to closely monitor the Vermont Yankee power ascension process and will take any actions deemed appropriate for continued protection of public health and safety. I trust that this letter addresses your concerns.

Sincerely,

Enclosure:

As stated

Identical letters sent to:

The Honorable Stan Rosenberg Commonwealth of Massachusetts Senate Boston, MA 02133 The Honorable Andrea Nuciforo Commonwealth of Massachusetts Senate Boston, MA 02133 The Honorable Denis Guyer Commonwealth of Massachusetts House of Representatives Boston, MA 02133 The Honorable Stephen Kulik Commonwealth of Massachusetts House of Representatives Boston, MA 02 133 The Honorable Daniel Bosley Commonwealth of Massachusetts House of Representatives Boston, MA 02133

UNITED STATES NUCLEAR REGULATORY CONlMlSSlON WASHINGTON, D.C. 20555-0001 CHAIRMAN May 4,2004 Mr. Michael H. Dworkin, Chairman Vermont Public Service Board 112 State Street, Drawer 20 Montpelier, Vermont 05620-2701

Dear Mr. Dworkin:

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I am responding on behalf of, th@,~?$,. *$ ..

t L: - N.@jl@r;Regylatory ,.* q v-,2s. ,. Commission (NRC) to your letters dated March 15 and 3?, god$.iggarding the request6f~ntergy Nuclear Vermont Yankee, LLC, and ~ntergy-f@Gc~&d'r " , ~- <a Operations, Inc. ( ~ n t e r ~ y ) ) - ? c i athe ~ n Vermont d Yankee Nuclear Power Station li~ense"loincrease the power level of the Tar$?~ In those letters, the Vermont Public service-$?ard cl:.u-iz... requested that the NRC conduct its recgw of the proposed power uprate in a way that-yould provide Vermont a level of assura_?ce,qb.out plant reliability equivalent to an ind4@$nd&z;&cJneering * = -*+. assessment. The N,F$?@$ d$<@ed to conduct a detailed engineerit&ijispectiB+3-Katw =F=~-s-q ~- believe will be apgtc$%i tgfor

+,+Y~-~ addressing our oversight responsibilities and3also resp~@&h~ ,. -- = A ~ the,Boards~ =-~:ys+;l !

. co~~i~c@@3flhis ..=~.-> . insp&Egn will be performed as p a & 2 f a new engseBBg e~inspk3@n zpro&ai%zTF& - :~;z=2 .) . the NRC @&,been developing or

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.~- re@(inires, t8@ever, that there is some overlap betweetj.attri6$e$?hat.r&s~lt;1n :z.,zf---c ~~..*:-.z-*z, Sqfe &4- operation-Gpdthose - t$at.contribute to

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Vermont Yankee following~;an:increase in power level, especially iq'light of operational issues that have occurred at some2%&r plants that have recently i m p & h n t e d extended power uprates. The NRC recognizes the'Ej$portgnce -:s

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and is taking steps to ensure that they are satisfactorily addressed to;fiait%a~n sgzi$ty:iEpr $ample, in response to instances of steam dryer cracking at some boiling water reactor< outside technical experts are assisting NRC staff in performing an audit of General Electric's analyses related to steam dryer performance and specific issues related to Vermont Yankee. We continue to engage the industry to ensure resolution of these issues and will consider additional regulatory action, if needed.

The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A description of the review process is enclosed. Engineering assessments have always been an integral part of the NRC's safety activities. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organization to determine whether engineering analyses adequately support safe operation. Over the past several months, the NRC has been developing a new engineering inspection program which we intend to pilot at selected plants. The NRC staff considered a number of factors, including the Board's request for an independent engineering assessment, and concluded it is appropriate to conduct this engineering inspection at Vermont Yankee. This new engineering assessment inspection incorporates the best practices of the existing and past engineering inspections. The NRC will use this inspection to verify that design bases have been correctly implemented for a sampling of components across multiple systems and to ,i&nJify .+ .*- latent design issues. The inspection process uses operating experience, risk assessmeet, . . - *

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.. ~3 -.engineering analysis to select risk-7 significant components and opera&i$ctidns, and will ekiisure that adequate safety margins exist. Although the specific s&$tTng 4q -;----- of components is still b&rscj.$eyeloped, it will include components from multip~e~sy~Tems that are potentially affected bf a$ower uprate such as the emergency core cooling'~sy~ems, ......~-- the containment system, power corjv&sion systems, and auxiliary systems. The:inspection will be performed by a team of appro-xtfiately six inspectors, including some N R @ ~ ~ ~ .- ~ -C % = <=%~ do= -~not S ~have & Orecent oversighSexperiebe with Vermont Yankee and at lea&t$o contF@f-*ith -,

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The NRC will not approve the ~ e r m o n t - ~ a n k uprate, ee or any proposed change to a plant license, unless the NRC staff can conclude that the proposed change will be executed in a manner that assures the public's health and safety. In response to your request, the NRC staff has taken a close look at proposed inspections and technical reviews to ensure that they will identify and address potential safety concerns for operating at uprated power conditions. The staff has concluded that the detailed technical review, prescribed in the Extended Power Uprate Review Standard, coupled with the normal associated program of power uprate and engineering inspections, will provide the information necessary for the NRC staff to make a

decision on the safety of operation of Vermont Yankee under uprated power conditions. The Commission believes that the results of NRC reviews and inspections, particularly the new engineering inspection, will assist in addressing the Board's concerns regarding the future reliability of Vermont Yankee. The NRC staff is prepared to meet with the Board to explain further our review process and scope, including the engineering assessment inspection.

Sincerely, Nils J. Diaz

Enclosure:

Established

Established NRC Power Uprate Review Process The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A team of engineers with specialties in a minimum of 17 different technical areas will review the Vermont Yankee power uprate application. The NRC plans to expend about 4000 hours0.0463 days 1.111 hours 0.00661 weeks 0.00152 months to perform a comprehensive assessment of the engineering, design, and safety analyses related to the uprate. The NRC's "Review Standard for Extended Power Uprates" guides the staff in its review of the application. The Review Standard also provides guidance for determining when and what type of audits should be performed at the plant or vendor sites, as well as for performing our own confirmatory analyses and independent calculations to supplement the review.

The NRC's review of the power uprate application also includes on-site inspections. NRC inspections will review selected activities and modificatior;~made to allow operation at higher power levels to verify that changes to plan?~~systgms~will support safe plant operation and are in accordance with Vermont ~ankee',s..licensina $ ~ d e ~?-~* ~-w @ b a sThe e s . NRC will use Inspection Procedure 71004, "Power ~ ~ r a--t ~ s ~ ? [ ~ aas~ a

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% e ' l l 6f.16u?bqseline inspection procedures to inspect issues s p e c i f i c a l l y ~ ~to~power ~ ~ d uprate. ~hese%s@ct~ons will assess changes that could impact the inte$?$zf barriers (e.g., higher flow rates w h i 6 ~ c o u l dincrease vibration at specific support poin&),%afety evaluations, plant modifications, po3Imaintenance and surveillance testing, h&6exchanger performance, and integrated plantloperation. Additionally, our other baseline id$p=ectio$caiy!ties, while not specifically dJeete3 at h e r uprate activities, will provide a d d i t i oa~

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stru%&res of the steam dryer. The steam dryer is $?>mpbiiant:c6@po.oG$t ,-.! . .. .:-: +-; ; :. A 3i $it%t?e . :.. 7h h pro@$Sfor .:

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= low-steam flow areas of the dryera@j.not .. .,: . _ in the a r e a s ~ ~ t $ e r ~ ~ : c ~ werea c kos b ~ r c e d at other plants that implemented extended pdwer~u.prates. NRC Ggpectors monitoCed:~dergy1ssteam dryer inspection activities, and we-kill thoroughly review Entergy's folK&-up actions as part of our evaluation of Vermont Yankee's reL&!estt90perate - _---

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Assessment of engineering has always been an integral part of the NRC's safety mission. In the 1990s, the NRC performed extensive reviews at plants across the country to determine if licensees were operating plants in accordance with their design bases. As part of this review, two team inspections were conducted at Vermont Yankee in 1997. One of these inspections was led by staff from NRC headquarters and included six contractors. In 1998, the NRC conducted an engineering inspection, as well as a team inspection to address operability issues resulting from Vermont Yankee's configuration improvement program. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organization to determine whether the engineering analyses adequately supports safe operation. Our inspectors conduct both routine engineering inspections, as well as an in-depth team inspection every two years. Since the Reactor Oversight Process was implemented in 2000, the NRC has conducted two such safety system design team inspections.

Enclosure

UN1TED STATES RY COMMISSION WASHINGTON, D.C.205550009 A p r i l 2 7 , 2006 The Honorable Stan Rosenberg State Senator The Commonwealth of Massachusetts Senate State House Boston, MA 02133

Dear Senator Rosenberg:

On behalf of the Nuclear Regulatory Commission (NRC), I am writing in response to your letter to NRC Chairman Nils J. Diaz, of March 22, 2006, in which you expressed concerns about the implementation of the extended power uprate (EPU) at the Vermont Yankee Nuclear Power Station (Vermont Yankee). Specifically, your letter requested that the NRC conduct a comprehensive independent safety assessment of Vermont Yankee.

I am enclosing a copy of a letter that Chairman Diaz sent to the Vermont Public Service Board (PSB), dated May 4, 2004, explaining the NRC's approach in response to the PSB's request for an independent engineering assessment of Vermont Yankee. As noted in the letter, the NRC staff concluded that its detailed technical review of the proposed amendment, combined with the inspections prescribed by the reactor oversight process, as enhanced by an improved engineering inspection, was determined to be the most effective method of informing the staff decision on whether Vermont Yankee could operate safely under uprated power conditions.

On March 2, 2006, the NRC staff issued its safety evaluation documenting the results of the technical review for the power uprate. A copy of this 335 page report is available on the NRC's Web site at htt~:Nadamswebsearch.nrc.uov/dolouin.htmby searching for accession number ML060050028. Section 1.6 of the safety evaluation discusses the engineering inspection that was completed in September 2004. The NRC staff spent over 11,000 hours0 days 0 hours 0 weeks 0 months on the technical review of the proposed power uprate. In addition, over 900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months were spent on the engineering inspection effort. We believe that the Vermont Yankee engineering inspection responds appropriately to requests to conduct an independent assessment of Vermont Yankee.

The NRC Advisory Committee on Reactor Safeguards (ACRS) reviewed the engineering inspection results in the context of its evaluation of the Vermont Yankee power uprate request.

The ACRS is a statutory committee that reports directly to the Commission and is structured to provide a forum where experts representing many technical perspectives can provide advice that is factored into the NRC's decision-making process. The ACRS Subcommittee on Power Uprates held a meeting on November 15 and 16, 2005, in Brattleboro, Vermont to receive input from the public, Entergy, and the NRC staff regarding the proposed power uprate. During this meeting the NRC staff provided the results of the engineering inspection, including a discussion ef all relevant inspectien findings. F?/ianyrnembers ef the nllb!ic rU askec! for a lTl9t-e extensive inspection, similar to that performed at the Maine Yankee plant. In a letter to NRC Chairman

Diaz dated January 4, 2006, the ACRS recommended approval of the Vermont Yankee power uprate. As noted in the letter, the ACRS concluded that based on the results of the inspection that was performed and the performance of Vermont Yankee as determined by the NRC's reactor oversight process, a more extensive inspection is not warranted.

The NRC's approval of the Vermont Yankee EPU included a license condition that provides for monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of power uprate operation on structures, systems, and components (including verifying the continued structural integrity of the steam dryer). The license condition is implemented through the procedural steps, performance criteria, and required actions specified in the Vermont Yankee steam dryer monitoring plan and power ascension test procedure.

On March 4, 2006, Entergy began slowly increasing reactor power at Vermont Yankee following the NRC's approval of the EPU amendment on March 2, 2006. Since that time, the plant has suspended the power ascension twice (at 105% and 112.5% of original licensed thermal power) when administrative limits specified in the steam dryer monitoring plan were reached. When an administrative limit is reached, the monitoring plan requires that an engineering evaluation be performed prior to further increases in power. As documented in the NRC staff's Safety Evaluation for the EPU, Entergy formally committed to not increase power above the applicable hold point, if any safety concerns were identified during the NRC staff's review of the power ascension data. The NRC staff reviewed the evaluation and the power ascension data at 1O5%, 110%, 112.5% and 115% to determine if it had any safety concerns. On April 25, the NRC approved continued ascension to 120% power level.

Your letter also raised a concern regarding an unexpected plant shutdown at Vermont Yankee related to failure of a transformer. This event received significant scrutiny by the NRC. On June 18, 2004, an electrical fault on the 22 kilovolt (kV) electrical system forced the reactor to automatically shut down from 100% power. Arcing and heat generated during the fault caused a main transformer fire. The fire was extinguished through the combined efforts of the automatic fire suppression system, the site's fire brigade, and the local volunteer fire department. The NRC's resident inspectors immediately responded to the event, and the Region I Incident Response Center was staffed to support the residents and follow Entergy's response to the fire. The fire caused no damage to safety systems and Entergy restarted the plant on July 6, 2004, after making necessary repairs. In its November 8, 2004, quarterly inspection report, the NRC discussed Entergy's failure to incorporate operating experience into preventive maintenance of the 22 kV electrical system. Entergy is managing this issue through its corrective action program.

Your letter also referenced the views expressed by Commissioner Jaczko in a memorandum to his fellow Commissioners, concerning the Vermont Yankee EPU. The memorandum reflects the views of Commissioner Jaczko and not the entire Commission's view on any particular matter. On March 3, 2006, the Commission declined to stay the issuance of the requested EPU amendment, pending completion of the adjudicatory proceeding on this application; Commissioner Jaczko concurred in that decision.

! ne NRC's primary rnissior! is to ensure adequate protection of pub!i-c:health an6 safety. The

-8 NRC will not approve any proposed change to any plant license unless our technical staff can conclude that it has reasonable assurance that adequate protection of public health and safety

%ill be ensiired. We h m e taken great care iii c~i~citiciirig iiie ieciinicai reviews and inspections

regarding the Vermont Yankee power increase in order to ensure that these reviews and inspections will identify and address any potential safety concerns for operating the plant at uprated power conditions. We will continue to closely monitor the Vermont Yankee power ascension process and will take any actions deemed appropriate for continued protection of public health and safety. I trust that this letter addresses your concerns.

for o p e r a k i d

Enclosure:

As stated

Identical letters sent to:

The Honorable Stan Rosenberg Commonwealth of Massachusetts Senate Boston, MA 02133 The Honorable Andrea Nuciforo Commonwealth of Massachusetts Senate Boston, MA 02133 The Honorable Denis Guyer Commonwealth of Massachusetts House of Representatives Boston. MA 02133 The Honorable Stephen Kulik Commonwealth of Massachusetts House of Representatives Boston, MA 02133 The Honorable Daniel Bosley Commonwealth of Massachusetts House of Representatives Boston, MA 02133

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 CHAIRMAN May 4,2004 Mr. Michael H. Dworkin, Chairman Vermont Public Service Board 112 State Street, Drawer 20 Montpelier, Vermont 05620-2701

Dear Mr. Dworkin:

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I am responding on behalf qf~t..::,h e a ~~ . .= . ~ 6 < l & &-.is r ; ~ -<e ~ u l a tCommission T or~ (NRC) to your letters dated March 15 and ? !3 ?00&@gaiding the?equesLbf~ntergy Nuclear Vermont Yankee, LLC, and Entergy- ~ ~ i ? _ l & t b p e r a t i o nInc. s , ( ~ n t e r ~ ~ r q a the a ~Vermont nd Yankee Nuclear Power Station ~i&k$~to increase the power level of the faciFx In those letters, the Vermont Public ~ervice;gz%d requested that the NRC conduct its review of the proposed power uprate in a way.fhahp.pdd provide Vermont a level of assuran~G&bout piant reliability equivalent to an ind@@ndeiit&gipeering assessment. The i'jR~:f& +>.&-.- dC&dedto conduct a detailed e n g i n e e r i ~ i ~ s p e c t i-=--=-k3L $ ~ ~ $ ~xLi ' 7believe w e will be ape~dPF&t&or ad8?&ing our oversight responsibilities an=dTalso respi&3& --.~-=,., fo- the.B~w&-s z. % , .3tx-~ I co&,@~@~=ThisinspeeGTQnwill be performed as pad-of'a new engingeekg .. insp@ion ijrogra@$l$al -. _._ the NRC !as-been developing

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Vermont Yankee following:an- igcrease in powef level, e ~ ~ e c i a l l ~ . i @of%operational ~ht issues that have occurred at some .&er plants that have recently impl&$ented extended power uprates The NRC recognizes the~&po~rtance . *@-=

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of these isjges and is taking steps to ensure that they are satisfactorily addressed to mai$gyn s$@ty?Sgr &ample, in response to instances of steam dryer cracking at some boiling watei reac?ors: outside technical experts are assisting NRC staff in performing an audit of General Electric's analyses related to steam dryer performance and specific issues related to Vermont Yankee. We continue to engage the industry to ensure resolution of these issues and will consider additional regulatory action, if needed.

The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A description of the review process is enclosed. Engineering assessments have always been an integral part of the NRC's safety activities. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organization to determine whether engineering analyses adequately support safe operation. Over the past several months, the NRC has been developing a new engineering inspection program which we intend to pilot at selected plants. The NRC staff considered a number of factors, including the Board's request for an independent engineering assessment, and concluded it is appropriate to conduct this engineering inspection at Vermont Yankee. This new engineering assessment inspection incorporates the best practices of the existing and past engineering inspections. The NRC will use this inspection to verify that design bases have been correctly implemented for a sampling of components across multiple systems a 4 to jden@y A ,.a L - latent design issues. The inspection cry process uses operating experience,.riskass.ess~e~n~, .arid engineering analysis to select risk-significant components and o p e ~ a ~ ~ ~ - . ~ and c~io w-81 n sixi~ijrk , tliat adequate safety margins exist. Although the specific *-.~ $$$$ing U-z of components is still b%nggqeloped, it will include components from multiple~sysfemsthat are potentially affected by@%nwer uprate such as the emergency core cooling . sydems, the containment system, power conyersion systems, and

I 1; auxiliary systems. The'.ins,pectionwill be performed by a team of approkimately six inspectors, including some ~ ~ ~ ~ i t - @ ~ e ddo& not y uhave h o recent o ~ e r ~ ~ ~ t s ~ e ~with ~ e rVermont i&&e Yankee and at leastitgo con$~$1&~\41ith ~- --= -- design experieng&$T&$e 3 a.: +

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The NRC will not approve the Vermont-Yankee uprate, or any proposed change to a plant license, unless the NRC staff can conclude that the proposed change will be executed in a manner that assures the public's health and safety. In response to your request, the NRC staff has taken a close look at proposed inspections and technical reviews to ensure that they will identify and address potential safety concerns for operating at uprated power conditions. The staff has conclclded that the detailed technical review, prescribed in the Extended Power Uprate Review Standard, coupled with the normal associated program of power uprate and engineering inspections, will provide the information necessary for the NRC staff to make a

decision on the safety of operation of Vermont Yankee under uprated power conditions. The Commission believes that the results of NRC reviews and inspections, particularly the new engineering inspection, will assist in addressing the Board's concerns regarding the future reliability of Vermont Yankee. The NRC staff is prepared to meet with the Board to explain further our review process and scope, including the engineering assessment inspection.

Sincerely, Nils J. Diaz

Enclosure:

Established

Established NRC Power Uprate Review Process The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A team of engineers with specialties in a minimum of 17 different technical areas will review the Vermont Yankee power uprate application. The NRC plans to expend about 4000 hours0.0463 days 1.111 hours 0.00661 weeks 0.00152 months to perform a comprehensive assessment of the engineering, design, and safety analyses related to the uprate. The NRC's "Review Standard for Extended Power Uprates" guides the staff in its review of the application. The Review Standard also provides guidance for determining when and what type of audits should be performed at the plant or vendor sites, as well as for performing our own confirmatory analyses and independent calculations to supplement the review.

The NRC's review of the power uprate application also includes on-site inspections. NRC inspections will review selected activities and modifications made to allow operation at higher power levels to verify that changes to plant,sys~,eps~~will support safe plant operation and are in accordance with Vermont ~ankee:s.licensfi ++z>. : - a$$desig$- i .I. .- .. b:ases. .- ie The NRC will use Inspection Procedure 71004, "Power ~prat&Zas %3 - = well as a numb~e?6L6g.r baseline inspection procedures to inspect issues s p e c i f i c a l l y @ to power uprate. These ?fis$$ct&ns will assess changes that could impact the inteaFfgf barriers (e.g., higher flow rates $ h i ~ ~ ~ o increase uld vibration at specific support poin-&),%afety evaluations, plant modifications, postImaintenance and surveillance testing, h&t exchanger performance, and integrated p(Gt:operation. Additionally, our other baseline i&@pctic$a~$y(ties, while not specifically dire:~t$dat pc@eruprate activities, will provide additio&al-~nform~~&@~~O_ut power level.

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~wks low-steam flow areas of the dryer*an$mot in the areas-kft-ierecracks ~h%reobser-v&dat other plants that implemented extended pow&uprates. NRC rn'spectors monitored~ntergy'ssteam dryer inspection activities, and we'-&ill thoroughly review Entergy's fol18$?up actions as part of our evaluation of Vermont Yankee's reagest-@operate - &

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.;$+g Assessment of engineering has always been an integral part of the NRC's safety mission. In the 1990s, the NRC performed extensive reviews at plants across the country to determine if licensees were operating plants in accordance with their design bases. As part of this review, two team inspections were conducted at Vermont Yankee in 1997. One of these inspections was led by staff from NRC headquarters and included six contractors. In 1998, the NRC conducted an engineering inspection, as well as a team inspection to address operability issues resulting from Vermont Yankee's configuration improvement program. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organizaiion to determine whether the engineering analyses adequately supports safe operation. Our inspectors conduct both routine engineering inspections, as well as an in-depth team inspection every two years. Since the Reactor Oversight Process was implemented in 2000, the NRC has conducted two such safety system design team inspections.

Enclosure

IIMK NUCLEAR REGU WASHINGTON, D.C. 205554001 A p r i l 27, 2006 The Honorable Andrea Nuciforo State Senator The Commonwealth of Massachusetts Senate State House Boston, MA 02133

Dear Senator Nuciforo:

On behalf of the Nuclear Regulatory Commission (NRC), I am writing in response to your letter to NRC Chairman Nils J. Diaz, of March 22, 2006, in which you expressed concerns about the implementation of the extended power uprate (EPU) at the Vermont Yankee Nuclear Power Station (Vermont Yankee). Specifically, your letter requested that the NRC conduct a comprehensive independent safety assessment of Vermont Yankee.

I am enclosing a copy of a letter that Chairman Diaz sent to the Vermont Public Service Board (PSB), dated May 4, 2004, explaining the NRC's approach in response to the PSB's request for an independent engineering assessment of Vermont Yankee. As noted in the letter, the NRC staff concluded that its detailed technical review of the proposed amendment, combined with the inspections prescribed by the reactor oversight process, as enhanced by an improved engineering inspection, was determined to be the most effective method of informing the staff decision on whether Vermont Yankee could operate safely under uprated power conditions.

On March 2, 2006, the NRC staff issued its safety evaluation documenting the results of the technical review for the power uprate. A copy of this 335 page report is available on the NRC's Web site at http://adamswebsearch.nrc.qov/doloain.htm by searching for accession number ML060050028. Section 1.6 of the safety evaluation discusses the engineering inspection that was completed in September 2004. The NRC staff spent over 11,000 hours0 days 0 hours 0 weeks 0 months on the technical review of the proposed power uprate. In addition, over 900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months were spent on the engineering inspection effort. We believe that the Vermont Yankee engineering inspection responds appropriately to requests to conduct an independent assessment of Vermont Yankee.

The NRC Advisory Committee on Reactor Safeguards (ACRS) reviewed the engineering inspection results in the context of its evaluation of the Vermont Yankee power uprate request.

The ACRS is a statutory committee that reports directly to the Commission and is structured to provide a forum where experts representing many technical perspectives can provide advice that is factored into the NRC's decision-making process. The ACRS Subcommittee on Power Uprates held a meeting on November 15 and 16, 2005, in Brattleboro, Vermont to receive input from the public, Entergy, and the NRC staff regarding the proposed power uprate. During this meeting the NRC staff provided the results of the engineering inspection, including a discussion of a!! re!evant inspectinr! findings. Many members of the pub!ic asked for 2 more e u t e t ? s k inspection, similar to that performed at the Maine Yankee plant. In a letter to NRC Chairman

Diaz dated January 4,2006, the ACRS recommended approval of the Vermont Yankee power uprate. As noted in the letter, the ACRS concluded that based on the results of the inspection that was performed and the performance of Vermont Yankee as determined by the NRC's reactor oversight process, a more extensive inspection is not warranted.

The NRC's approval of the Vermont Yankee EPU included a license condition that provides for monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of power uprate operation on structures, systems, and components (including verifying the continued structural integrity of the steam dryer). The license condition is implemented through the procedural steps, performance criteria, and required actions specified in the Vermont Yankee steam dryer monitoring plan and power ascension test procedure.

On March 4, 2006, Entergy began slowly increasing reactor power at Vermont Yankee following the NRC's approval of the EPU amendment on March 2, 2006. Since that time, the plant has suspended the power ascension twice (at 105% and 112.5% of original licensed thermal power) when administrative limits specified in the steam dryer monitoring plan were reached. When an administrative limit is reached, the monitoring plan requires that an engineering evaluation be performed prior to further increases in power. As documented in the NRC staff's Safety Evaluation for the EPU, Entergy formally committed to not increase power above the applicable hold point, if any safety concerns were identified during the NRC staff's review of the power ascension data. The NRC staff reviewed the evaluation and the power ascension data at 105%, 110%, 112.5%, and 115% to determine if it had any safety concerns. On April 25, the NRC approved continued ascension to 120% power level.

Your letter also raised a concern regarding an unexpected plant shutdown at Vermont Yankee related to failure of a transformer. This event received significant scrutiny by the NRC. On June 18, 2004, an electrical fault on the 22 kilovolt (kV) electrical system forced the reactor to automatically shut down from 100% power. Arcing and heat generated during the fault caused a main transformer fire. The fire was extinguished through the combined efforts of the automatic fire suppression system, the site's fire brigade, and the local volunteer fire department. The NRC's resident inspectors immediately responded to the event, and the Region I Incident Response Center was staffed to support the residents and follow Entergy's response to the fire. The fire caused no damage to safety systems and Entergy restarted the plant on July 6, 2004, after making necessary repairs. In its November 8, 2004, quarterly inspection report, the NRC discussed Entergy's failure to incorporate operating experience into preventive maintenance of the 22 kV electrical system. Entergy is managing this issue through its corrective action program.

Your letter also referenced the views expressed by Commissioner Jaczko in a memorandum to his fellow Commissioners, concerning the Vermont Yankee EPU. The memorandum reflects the views of Commissioner Jaczko and not the entire Commission's view on any particular matter. On March 3, 2006, the Commission declined to stay the issuance of the requested EPU amendment, pending completion of the adjudicatory proceeding on this application; Commissioner Jaczko concurred in that decision.

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I ne ~ n cs, primary mission is i o ensure aciequaie protection o i pubiic neaiin and safety. I hg NRC will not approve any proposed change to any plant license unless our technical staff can conclude that it has reasonable assurance that adequate protection of public health and safety

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vvlll ~ t c1 : ,aUred. Vie have takeii great iii coiiducting the technical reviews and iiispeciion

regarding the Vermont Yankee power increase in order to ensure that these reviews and inspections will identify and address any potential safety concerns for operating the plant at uprated power conditions. VVe will continue to closely monitor the Vermont Yankee power ascension process and will take any actions deemed appropriate for continued protection of public health and safety. I trust that this letter addresses your concerns.

Sincerelv.

Executive Dire for Operations

Enclosure:

As stated

Identical letters sent to:

The Honorable Stan Rosenberg Commonwealth of Massachusetts Senate Boston, MA 02133 The Honorable Andrea Nuciforo Commonwealth of Massachusetts Senate Boston, MA 02133 The Honorable Denis Guyer Commonwealth of Massachusetts House of Representatives Boston, MA 02133 The Honorable Stephen Kulik Commonwealth of Massachusetts House of Representatives Boston, MA 02133 The Honorable Daniel Bosley Commonwealth of Massachusetts House of Representatives Boston, MA 02133

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 CHAIRMAN May 4,2004 Mr. Michael H. Dworkin, Chairman Vermont Public Service Board 112 State Street, Drawer 20 Montpelier, Vermont 05620-2701

Dear Mr. Dworkin:

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I am responding on behalf of the..~.;~.Nu<l$arl-_RggulatoryCommission (NRC) to your letters dated March 15 and 31-,20d&:~ke~a-rd~in~ the re@fest,b$-~ntergyNuclear Vermont Yankee, LLC, and Entergya-~~(&&bperations, Inc. ( ~ n t e r ~ ~ the ~ W Vermont

~ ~ ~Yankeen d Nuclear Power Station li~gii.sTtoincrease the power level of the 6 c i f ~In those letters, the Vermont Public ~ e r v i c ~ l ~ 8requested ard that the NRC conduct its e &

r;v! of the proposed power uprate in a waytt&ysuld provide Vermont a level of assurance:abgut plant reliability equivalent to an ind6jbenderifs~~glneering assessment. The-&k- N~RG%~S d&$ed to conduct a detailed e n g i n e e r i @ i ~ ~ +

&-: s P e~x KF z t believe ie will be appy@&g@for ad&&ing our oversight responsibilities an$salso resp4psqe . 2 - : ~ ~ x h 9 fq theBq_dls c o n & ~ ~ ~ ~insp@Qn

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,: - cohEErned @$%tthe reliability of Vermont Yankee f o ~ ~ o w i n ~ ~ d n , . i ~ cin r epower a s e level, especially.inlight of operational issues that have occurred at some dtbbr plants that have recently implefnl&nted extended power uprates. The NRC recognizes t h e ' ~ o o r t j n c eof these_is$l&gs and is taking steps to ensure that they are satisfactorily addressed t6?&ai$@i $@t~%@r e%ample, in response to instances of steam dryer cracking at some boiling water reactors, outside technical experts are assisting NRC staff in performing an audit of General Electric's analyses related to steam dryer performance and specific issues related to Vermont Yankee. We continue to engage the industry to ensure resolution of these issues and will consider additional regulatory action, if needed.

The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A description of the review process is enclosed. Engineering assessments have always been an integral part of the NRC's safety activities. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organization to determine whether engineering analyses adequately support safe operation. Over the past several months, the NRC has been developing a new engineering inspection program which we intend to pilot at selected plants. The NRC staff considered a number of factors, including the Board's request for an independent engineering assessment, and concluded it is appropriate to conduct this engineering inspection at Vermont Yankee. This new engineering assessment inspection incorporates the best practices of the existing and past engineering inspections. The NRC will use this inspection to verify that design bases have been correctly implemented for a sampling of components across multiple systems and to i d g ~ t j f ylatent design issues. The inspection I.L" process uses operating experience,.ri~k.assessmee~~, ,&5dengineering analysis to select risk-significant components and opeLaf&~&tiohs, and G'll 3n'skd h a t adequate safety margins exist. Although the specific ga&lrng of components is still b % n ~ ~ e ~ e l o pitewill d , include 2.". -,* :-

components from multiplgsyXerns that are potentially affected bqa?&er uprate such as the emergency core c o o l i n ~ , ~ s ~ ~the e mcontainment s, system, power conv&sion systems, and auxiliary systems. The i6spection :-.r, will be performed by a team o i approximately six inspectors, including some ~ ~ G $ t y p e & ~ r s : : ~doh onot have recent o v e..plll- r ~ i ~ h . ~ ~ e x ~with e r iVermont

~~ee Yankee and at leas&two con$&%&with -. %-.* design experienge~~&$e -rT.*.~ -.*- weeEs%f on-site inspection and over 700 hourgTf direct i&$@@fi$f~!ime %=*:?-<<.

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The NRC will not approve the ~ e r i o n F F a n k k e u ~ r a tor e , any proposed change to a plant license, unless the NRC staff can conclude that the proposed change will be executed in a manner that assures the public's health and safety. In response to your request, the NRC staff has taken a close look at proposed inspections and technical reviews to ensure that they will identify and address potential safety concerns for operating at uprated power conditions. The staff has concluded that the detailed technical review, prescribed in the Extended Power Uprate Review Standard, coupled with the normal associated program of power uprate and engineering inspections, will provide the information necessary for the NRC staff to make a

decision on the safety of operation of Vermont Yankee under uprated power conditions. The Commission believes that the results of NRC reviews and inspections, particularly the new engineering inspection, will assist in addressing the Board's concerns regarding the future reliability of Vermont Yankee. The NRC staff is prepared to meet with the Board to explain further our review process and scope, including the engineering assessment inspection.

Sincerely, Nils J. Diaz

Enclosure:

Established

Established NRC Power Uprate Review Process The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A team of engineers with specialties in a minimum of 17 different technical areas will review the Vermont Yankee power uprate application. The NRC plans to expend about 4000 hours0.0463 days 1.111 hours 0.00661 weeks 0.00152 months to perform a comprehensive assessment of the engineering, design, and safety analyses related to the uprate. The NRC's "Review Standard for Extended Power Uprates" guides the staff in its review of the application. The Review Standard also provides guidance for determining when and what type of audits should be performed at the plant or vendor sites, as well as for performing our own confirmatory analyses and independent calculations to supplement the review.

Assessment of engineering has always been an integral part of the NRC's safety mission. In the 1990s, the NRC performed extensive reviews at plants across the country to determine if licensees were operating plants in accordance with their design bases. As part of this review, two team inspections were conducted at Vermont Yankee in 1997. One of these inspections was led by staff from NRC headquarters and included six contractors. In 1998, the NRC conducted an engineering inspection, as well as a team inspection to address operability issues resulting from Vermont Yankee's configuration improvement program. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licerisee's engineering organization to determine whether the engineering analyses adequately supports safe operation. Our inspectors conduct both routine engineer~nginspections, as well as an in-depth team inspection every two years. Since the Reactor Oversight Process was implemented in 2000, the NRC has conducted two such safety system design team inspections.

Enclosure

UNZTED STATES NUCLEAR REGU WASHINGTBt.8, D.C. 205556081 April 27, 2006 The Honorable Denis Guyer State Representative The Commonwealth of Massachusetts House of Representatives State House Boston, MA 021 33

Dear Representative Guyer:

On behalf of the Nuclear Regulatory Commission (NRC), I am writing in response to your letter to NRC Chairman Nils J. Diaz, of March 22, 2006, in which you expressed concerns about the implementation of the extended power uprate (EPU) at the Vermont Yankee Nuclear Power Station (Vermont Yankee). Specifically, your letter requested that the NRC conduct a comprehensive independent safety assessment of Vermont Yankee.

I am enclosing a copy of a letter that Chairman Diaz sent to the Vermont Public Service Board (PSB), dated May 4, 2004, explaining the NRC's approach in response to the PSB's request for an independent engineering assessment of Vermont Yankee. As noted in the letter, the NRC staff concluded that its detailed technical review of the proposed amendment, combined with the inspections prescribed by the reactor oversight process, as enhanced by an improved engineering inspection, was determined to be the most effective method of informing the staff decision on whether Vermont Yankee could operate safely under uprated power conditions.

On March 2, 2006, the NRC staff issued its safety evaluation documenting the results of the technical review for the power uprate. A copy of this 335 page report is available on the NRC's Web site at http://adamswebsearch.nrc.qov/doloqin.htm by searching for accession number ML060050028. Section 1.6 of the safety evaluation discusses the engineering inspection that was completed in September 2004. The NRC staff spent over 11,000 hours0 days 0 hours 0 weeks 0 months on the technical review of the proposed power uprate. In addition, over 900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months were spent on the engineering inspection effort. We believe that the Vermont Yankee engineering inspection responds appropriately to requests to conduct an independent assessment of Vermont Yankee.

The NRC Advisory Committee on Reactor Safeguards (ACRS) reviewed the engineering inspection results in the context of its evaluation of the Vermont Yankee power uprate request.

The ACRS is a statutory committee that reports directly to the Commission and is structured to provide a forum where experts representing many technical perspectives can provide advice that is factored into the NRC's decision-making process. The ACRS Subcommittee on Power Uprates held a meeting on November 15 and 16, 2005, in Brattleboro, Vermont to receive input from the public, Entergy, and the NRC staff regarding the proposed power uprate. During this meeting the NRC staff provided the results of the engineering inspection, including a discussion of a!! relevant inspection findings. F?rlar,y rnernbers of the public asked for a more extensive inspection, similar to that performed at the Maine Yankee plant. In a letter to NRC Chairman

Diaz dated January 4,2006, the ACRS recommended approval of the Vermont Yankee power uprate. As noted in the letter, the ACRS concluded that based on the results of the inspection that was performed and the performance of Vermont Yankee as determined by the NRC's reactor oversight process, a more extensive inspection is not warranted.

The NRC's approval of the Vermont Yankee EPU included a license condition that provides for monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of power uprate operation on structures, systems, and components (including verifying the continued structural integrity of the steam dryer). The license condition is implemented through the procedural steps, performance criteria, and required actions specified in the Vermont Yankee steam dryer monitoring plan and power ascension test procedure.

On March 4, 2006, Entergy began slowly increasing reactor power at Vermont Yankee following the NRC's approval of the EPU amendment on March 2, 2006. Since that time, the plant has suspended the power ascension twice (at 105O/0 and 112.5% of original licensed thermal power) when administrative limits specified in the steam dryer monitoring plan were reached. When an administrative limit is reached, the monitoring plan requires that an engineering evaluation be performed prior to further increases in power. As documented in the NRC staff's Safety Evaluation for the EPU, Entergy formally committed to not increase power above the applicable hold point, if any safety concerns were identified during the NRC staff's review of the power ascension data. The NRC staff reviewed the evaluation and the power ascension data at 105%, 110%, 112.5%, and 115% to determine if it had any safety concerns. On April 25, the NRC approved continued ascension to 120% power level.

Your letter also raised a concern regarding an unexpected plant shutdown at Vermont Yankee related to failure of a transformer. This event received significant scrutiny by the NRC. On June 18, 2004, an electrical fault on the 22 kilovolt (kV) electrical system forced the reactor to automatically shut down from 100% power. Arcing and heat generated during the fault caused a main transformer fire. The fire was extinguished through the combined efforts of the automatic fire suppression system, the site's fire brigade, and the local volunteer fire department. The NRC's resident inspectors immediately responded to the event, and the Region I Incident Response Center was staffed to support the residents and follow Entergy's response to the fire. The fire caused no damage to safety systems and Entergy restarted the plant on July 6, 2004, after making necessary repairs. In its November 8, 2004, quarterly inspection report, the NRC discussed Entergy's failure to incorporate operating experience into preventive maintenance of the 22 kV electrical system. Entergy is managing this issue through its corrective action program.

Your letter also referenced the views expressed by Commissioner Jaczko in a memorandum to his fellow Commissioners, concerning the Vermont Yankee EPU. The memorandum reflects the views of Commissioner Jaczko and not the entire Commission's view on any particular matter. On March 3, 2006, the Commission declined to stay the issuance of the requested EPU amendment, pending completion of the adjudicatory proceedjng on this application; Commissioner Jaczko concurred in that decision.

The NRC's primary mission is to ensure adequate protection of pubiic: health and safety. !-he NRC will not approve any proposed change to any plant license unless our technical staff can conclude that it has reasonable assurance that adequate protection of public health and safety v v l l l be ensuiecl.

.:!I LA4ehzve taken great care in c ~ i i d u c t i i ~the g ieciiiiicai reviews arid inspections

regarding the Vermont Yankee power increase in order to ensure that these reviews and inspections will identify and address any potential safety concerns for operating the plant at uprated power conditions. W e will continue to closely monitor the Vermont Yankee power ascension process and will take any actions deemed appropriate for continued protection of public health and safety. I trust that this letter addresses your concerns.

Sincerely, Executive Dire for Operations

Enclosure:

As stated

Identical letters sent to:

The Honorable Stan Rosenberg Commonwealth of Massachusetts Senate Boston, MA 021 33 The Honorable Andrea Nuciforo Commonwealth of Massachusetts Senate Boston, MA 021 33 The Honorable Denis Guyer Commonwealth of Massachusetts House of Representatives Boston, MA 021 33 The Honorable Stephen Kulik Commonwealth of Massachusetts House of Representatives Boston, MA 02133 The Honorable Daniel Bosley Commonwealth of Massachusetts House of Representatives Boston, MA 02133

UNITED STATES NUCLEAR REGULATORY COIVlMISSION WASHINGTON, D.C. 20555-0001 CHAIRMAN May 4,2004 Mr. Michael H. Dworkin, Chairman Vermont Public Service Board 112 State Street, Drawer 20 Montpelier, Vermont 05620-2701

Dear Mr. Dworkin:

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I am responding on behalf gf the U S . ~ u $ l e a degulatory r Commission (NRC) to your letters dated March 15 and 31, 200% iegardng the 'iee~eestbyEntergy Nuclear Vermont Yankee, LLC, and E n t e r g y - ~ ~ c l &Operations, ai Inc. ( ~ n t e r ~ ~ ~ " ; ~ t o ~the rn_ Vermont e n d Yankee Nuclear Power Station l i c e k r t o increase the power level of the f a c i f k In those letters, the Vermont Public Service ~ o & drequested that the NRC conduct its rev-@iv of the proposed

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power uprate in a way that would provide Vermont a level of assura_nce,about plant reliability equivalent to an independentcengineering assessment. The NRC has dgcided to conduct a detailed engineerin&i&pecti~6_'t$cj-\N_,e believe will be apQ~o@&tefor w *- a d d B s i n g our oversight responsib~litiesand7salso resp~7l5IGeto.- the B ~ d con~c@ii~'

a s ---ze- This inspeetion will be performed as partrota new engi@ee>f&g inspe3ion program~thqt . --- - the NRC pas been developing to enhance the ~ e ~ c t Overs~gti~P,r~cess.

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FY The ~ommissi&$derstands thaiibe Bbtyd'is c&ni%rned ab&t<he reliability of Vermont Yankee following,an increase in powef level, especially in3light of operational issues that have occurred at some other plants that have recently imple$ented extended power uprates. The NRC recognizes the?&odance they are satisfactorily addressed to maid=

-- -- of these issues and IS taking steps to ensure that

.&@ty??or e'xample, in response to instances of steam dryer crackrng at some boiling water readiorsj outside technical experts are assisting NRC staff in performing an audit of General Electric's analyses related to steam dryer performance and specific issues related to Vermont Yankee. We continue to engage the industry to ensure resolution of these issues and will consider additional regulatory action, if needed.

The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A description of the review process is enclosed. Engineering assessments have always been an integral part of the NRC's safety activities. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organization to determine whether engineering analyses adequately support safe operation. Over the past several months, the NRC has been developing a new engineering inspection program which we intend to pilot at selected plants. The NRC staff considered a number of factors, including the Board's request for an independent engineering assessment, and concluded it is appropriate to conduct this engineering inspection at Vermont Yankee. This new engineering assessment inspection incorporates the best practices of the existing and past engineering inspections. The NRC will use this inspection to verify that design bases have been correctly implemented for a sampling of components across multiple systems an-d to @en.tjfy . ~3 F~-. latent design issues. The inspection process uses operating experience,.riskass.essment, a _-.. ;a$d .engineering analysis to select risk-significant components and opela~fi,a'6tio'n~, and will 6ns&eil4at adequate safety margins exist. Although the specific $&@ng of components is still be7naeyeloped, it will include e_ -- -

components from muItipIe_sysTemsthat are potentially affected byapower - &

. =L. uprate such as the emergency core cooling$$~tems, the containment system, power conv~rsionsystems, and auxiliary systems. ~h&i&p-ection will be performed by a team o i appro%mately six inspectors, including some ~ ~ C $ ~ m p e c t ~ ~ do k ~not y d have h o recent oversi:c&t . .e%i- Peri6nce with Vermont Yankee and at lea$$& -.-.

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The NRC will not approve the ~ e r m o n t - ~ a n k uprate, ee or any proposed change to a plant license, unless the NRC staff can conclude that the proposed change will be executed in a manner that assures the public's health and safety. In response to your request, the NRC staff has taken a close look at proposed inspections and technical reviews to ensure that they will identify and address potential safety concerns for operating at uprated power conditions. The staff has concluded that the detailed technical review, prescribed in the Extended Power Uprate Review Standard, coupled with the normal associated program of power uprate and engineering inspections, will provide the information necessary for the NRC staff to make a

decision on the safety of operation of Vermont Yankee under uprated power conditions. The Commission believes that the results of NRC reviews and inspections, particularly the new engineering inspection, will assist in addressing the Board's concerns regarding the future reliability of Vermont Yankee. The NRC staff is prepared to meet with the Board to explain further our review process and scope, including the engineering assessment inspection.

Sincerely, Nils J. Diaz

Enclosure:

Established

Established NRC Power Uprate Review Process The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A team of engineers with specialties in a minimum of 17 different technical areas will review the Vermont Yankee power uprate application. The NRC plans to expend about 4000 hours0.0463 days 1.111 hours 0.00661 weeks 0.00152 months to perform a comprehensive assessment of the engineering, design, and safety analyses related to the uprate. The NRC's "Review Standard for Extended Power Uprates" guides the staff in its review of the application. The Review Standard also provides guidance for determining when and what type of audits should be performed at the plant or vendor sites, as well as for performing our own confirmatory analyses and independent calculations to supplement the review.

The NRC's review of the power uprate application also includes on-site inspections. NRC inspections will review selected activities and modifications made to allow operation at higher power levels to verify that changes to plant7sys~ems,willsupport safe plant operation and are in accordance with Vermont Yankee'slicenshg = &,&:. 5 -- a$i$dgsigi: bases. The NRC will use Inspection Procedure 71004, "Power Upratgs:cas --= e- well as a numbg? df&j? bqseline inspection procedures to inspect issues specificakly-~~g@d to power uprate. These %'s@ctions will assess changes that could impact the integ8ky-bf barriers (e.g., higher flow rates whi&could increase vibration at specific support points),?'&fety evaluations, plant modifications, post-haintenance and surveillance testing, h e a ~ t l e ~ h a n performance, ~er and integrated plant;operation. Additionally, our other baseline irT+fgctiod:~cti&ies, while not specifically d&edtid'at p'Gwer uprate activities,

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Assessment of engineering has always been an integral part of the NRC's safety mission. In the 1990s, the NRC performed extensive reviews at plants across the country to determine if licensees were operating plants in accordance with their design bases. As part of this review, two team inspections were conducted at Vermont Yankee in 1997. One of these inspections was led by staff from NRC headquarters and included six contractors. In 1998, the NRC conducted an engineeri~ginspection, as well as a tezm inspection to address operability issues resulting from Vermont Yankee's configuration improvement program. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organization to determine whether the engineering analyses adequately supports safe operation. Our inspectors conduct both routine engineering inspections, as well as an in-depth team inspection every two years. Since the Reactor Oversight Process was implemented In 2000, the NRC has conducted two such safety system design team inspections.

Enclosure

UNITED STATES REGUMTORY C0MMISSlai.i WASHINGTON, B.C. 20555-0004 A p r i l 2 7 , 2006 The Honorable Daniel Bosley State Representative The Commonwealth of Massachusetts House of Representatives State House Boston, MA 02133

Dear Representative Bosley:

On behalf of the Nuclear Regulatory Commission (NRC), I am writing in response to your letter to NRC Chairman Nils J. Diaz, of March 22, 2006, in which you expressed concerns about the implementation of the extended power uprate (EPU) at the Vermont Yankee Nuclear Power Station (Vermont Yankee). Specifically, your letter requested that the NRC conduct a comprehensive independent safety assessment of Vermont Yankee.

I am enclosing a copy of a letter that Chairman Diaz sent to the Vermont Public Service Board (PSB), dated May 4, 2004, explaining the NRC's approach in response to the PSB's request for an independent engineering assessment of Vermont Yankee. As noted in the letter, the NRC staff concluded that its detailed technical review of the proposed amendment, combined with the inspections prescribed by the reactor oversight process, as enhanced by an improved engineering inspection, was determined to be the most effective method of informing the staff decision on whether Vermont Yankee could operate safely under uprated power conditions.

On March 2, 2006, the NRC staff issued its safety evaluation documenting the results of the technical review for the power uprate. A copy of this 335 page report is available on the NRC's Web site at http://adamswebsearch.nrc.aov/doloqin.htm by searching for accession number ML060050028. Section 1.6 of the safety evaluation discusses the engineering inspection that was completed in September 2004. The NRC staff spent over 11,000 hours0 days 0 hours 0 weeks 0 months on the technical review of the proposed power uprate. In addition, over 900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months were spent on the engineering inspection effort. We believe that the Vermont Yankee engineering inspection responds appropriately to requests to conduct an independent assessment of Vermont Yankee.

The NRC Advisory Committee on Reactor Safeguards (ACRS) reviewed the engineering inspection results in the context of its evaluation of the Vermont Yankee power uprate request.

The ACRS is a statutory committee that reports directly to the Commission and is structured to provide a forum where experts representing many technical perspectives can provide advice that is factored into the NRC's decision-making process. The ACRS Subcommittee on Power Uprates held a meeting on November 15 and 16, 2005, in Brattleboro, Vermont to receive input from the public, Entergy, and the NRC staff regarding the proposed power uprate. During this meeting the NRC staff provided the results of the engineering inspection, including a discussion of a!! re!evant inspection findings. !'Aany members cf the p~lh!icasked for a rngre extensive inspection, similar to that performed at the Maine Yankee plant. In a letter to NRC Chairman

Diaz dated January 4,2006, the ACRS recommended approval of the Vermont Yankee power uprate. As noted in the letter, the ACRS concluded that based on the results of the inspection that was performed and the performance of Vermont Yankee as determined by the NRC's reactor oversight process, a more extensive inspection is not warranted.

The NRC's approval of the Vermont Yankee EPU included a license condition that provides for monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of power uprate operation on structures, systems, and components (including verifying the continued structural integrity of the steam dryer). The license condition is implemented through the procedural steps, performance criteria, and required actions specified in the Vermont Yankee steam dryer monitoring plan and power ascension test procedure.

On March 4, 2006, Entergy began slowly increasing reactor power at Vermont Yankee following the NRC's approval of the EPU amendment on March 2, 2006. Since that time, the plant has suspended the power ascension twice (at 105% and 112.5% of original licensed thermal power) when administrative limits specified in the steam dryer monitoring plan were reached. When an administrative limit is reached, the monitoring plan requires that an engineering evaluation be performed prior to further increases in power. As documented in the NRC staff's Safety Evaluation for the EPU, Entergy formally committed to not increase power above the applicable hold point, if any safety concerns were identified during the NRC staff's review of the power ascension data. The NRC staff reviewed the evaluation and the power ascension data at 1O5%, 1 1O0/0, 1 l2.5%, and 1 15% to determine if it had any safety concerns. On April 25, the NRC approved continued ascension to 120% power level.

Your letter also raised a concern regarding an unexpected plant shutdown at Vermont Yankee related to failure of a transformer. This event received significant scrutiny by the NRC. On June 18, 2004, an electrical fault on the 22 kilovolt (kV) electrical system forced the reactor to automatically shut down from 100% power. Arcing and heat generated during the fault caused a main transformer fire. The fire was extinguished through the combined efforts of the automatic fire suppression system, the site's fire brigade, and the local volunteer fire department. The NRC's resident inspectors immediately responded to the event, and the Region I Incident Response Center was staffed to support the residents and follow Entergy's response to the fire. The fire caused no damage to safety systems and Entergy restarted the plant on July 6, 2004, after making necessary repairs. In its November 8, 2004, quarterly inspection report, the NRC discussed Entergy's failure to incorporate operating experience into preventive maintenance of the 22 kV electrical system. Entergy is managing this issue through its corrective action program.

Your letter also referenced the views expressed by Commissioner Jaczko in a memorandum to his fellow Commissioners, concerning the Vermont Yankee EPU. The memorandum reflects the views of Commissioner Jaczko and not the entire Commission's view on any particular matter. On March 3, 2006, the Commission declined to stay the issuance of the requested EPU amendment, pending completion of the adjudicatory proceeding on this application; Commissioner Jaczko concurred in that decision.

7 , -

! ne i\jRC3sprimar)~mission is tc! e n s x e adequate protection of pubiic heaith anti safety. I he NRC will not approve any proposed change to any plant license unless our technical staff can conclude that it has reasonable assurance that adequate protection of public health and safety will be ensured. Vv'e have taken great care iii cmdilciiiig the technical reviews and irsspeciions

regarding the Vermont Yankee power increase in order to ensure that these reviews and inspections will identify and address any potential safety concerns for operating the plant at uprated power conditions. W e will continue to closely monitor the Vermont Yankee power ascension process and will take any actions deemed appropriate for continued protection of public health and safety. I trust that this letter addresses your concerns.

for operationsV

Enclosure:

As stated

Identical letters sent to:

The Honorable Stan Rosenberg Commonwealth of Massachusetts Senate Boston, MA 02133 The Honorable Andrea Nuciforo Commonwealth of Massachusetts Senate Boston, MA 02133 The Honorable Denis Guyer Commonwealth of Massachusetts House of Representatives Boston, MA 02133 The Honorable Stephen Kulik Commonwealth of Massachusetts House of Representatives Boston, MA 02133 The Honorable Daniel Bosley Commonwealth of Massachusetts House of Representatives Boston, MA 02133

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001

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CHAIRMAN May 4,2004 Mr. Michael H. Dworkin, Chairman Vermont Public Service Board 112 State Street, Drawer 20 Montpelier, Vermont 05620-2701

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I am responding on behalf of t h e u. s+. ~ ~ u2F~. l e ,T. --.~v a r ~ f i e ~ uCommission lator~ (NRC) to your letters dated March 15 and 31-, g06$,ii5?jaiding the reqnes~f$~ntergyNuclear Vermont Yankee, LLC, and Entergy_@=@$ Operations, lnc. ( ~ n t e r g ~ ~ ~ ~the ~ tVermont q e n d Yankee Nuclear Power Station lic$kzto increase the power level of the ficifiy, In those letters, the Vermont Public service:~Ei%rd requested that the NRC conduct its re$$ of the proposed power uprate in a way-'that7-, would provide Vermont a level of assuranc~a$iput plant reliability equivalent to an inde$$nde6t@gi_neering assessment. The ~ ~ ~ d6cjgied 6 a to sconduct a detailed e n g i n e e r i m ~ ~ i ~ ~ s p e c tbelieve i ~ ~ ~ ~will ~ ~be v ua_p_~ e @ & $ f o r ad&2&ing our oversight

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The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A description of the review process is enclosed. Engineering assessments have always been an integral part of the NRC's safety activities. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organization to determine whether engineering analyses adequately support safe operation. Over the past several months, the NRC has been developing a new engineering inspection program which we intend to pilot at selected plants. The NRC staff considered a number of factors, including the Board's request for an independent engineering assessment, and concluded it is appropriate to conduct this engineering inspection at Vermont Yankee. This new engineering assessment inspection incorporates the best practices of the existing and past engineering inspections. The NRC will use this inspection to verify that design bases have been correctly implemented for a sampling of components across multiple systems a@ to identify ?$ jrA latent design issues. The inspection process uses operating experience,,~iskass.essrn~~nf~ .and engineering analysis to select risk-significant components and opeyat~&&%ons, and will ~ f i s d r d m aadequate t safety margins exist. Although the specific Gm'@ltng of components is still b~lng:geyeloped, it will include components from multiplef~y~~6ms that are potentially affected bf&%per uprate such as the emergency core ~ o o l i n g : : ~ ~ 8 e the m s ,containment system, power co$version systems, and auxiliary systems. ~ h e - i 6 s , ~ ~ cwill including some ~ ~ G l @ p e c t* =-

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directly to the Comm~@sion anaLisg~bcr~i.e_d;f@:~~$<d&f~~&iij7iwhere - = ~ 7 r -.= =, - .*.- e@rts representing many technical perspectives cah pro&e ad%ggfmt;&fg;gi@d into t , h @ g ~ ~decision-making

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's process. The NRC st&.gi;ill provide the r ~ ~ ~ l ~ revi&~~fforts,.i$luding ~ ; q f ) ~ 3 relevant inspection findings, to the ACRS for review. ~ f t ' ethe r ACRS com3etes its review, it will make an independent recommendation regarding -. .. whether the p r ~ ~ o s e ~ ~ p uprate o w e r amendment

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%cw3 The NRC will not approve the ~ e r G o n t ~ ~ ~ n k k e u ~ orr any a t eproposed , change to a plant license, unless the NRC staff can conclude that the proposed change will be executed in a manner that assures the public's health and safety. In response to your request, the NRC staff has taken a close look at proposed inspections and technical reviews to ensure that they will identify and address potential safety concerns for operating at uprated power conditions. The staff has concluded that the detailed technical review, prescribed in the Extended Power Uprate Review Standard, coupled with the normal associated program of power uprate and engineering inspections, will provide the information necessary for the NRC staff to make a

decision on the safety of operation of Vermont Yankee under uprated power conditions. The Commission believes that the results of NRC reviews and inspections, particularly the new engineering inspection, will assist in addressing the Board's concerns regarding the future reliability of Vermont Yankee. The NRC staff is prepared to meet with the Board to explain further our review process and scope, including the engineering assessment inspection.

Sincerely, Nils J. Diaz

Established NRC Power Uprate Review Process The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A team of engineers with specialties in a minimum of 17 different technical areas will review the Vermont Yankee power uprate application. The NRC plans to expend about 4000 hours0.0463 days 1.111 hours 0.00661 weeks 0.00152 months to perform a comprehensive assessment of the engineering, design, and safety analyses related to the uprate. The NRC's "Review Standard for Extended Power Uprates" guides the staff in its review of the application. The Review Standard also provides guidance for determining when and what type of audits should be performed at the plant or vendor sites, as well as for performing our own confirmatory analyses and independent calculations to supplement the review.

Assessment of engineering has always been anintegral part of the NRC's safety mission. In the 1990s, the NRC performed extensive reviews at plants across the country to determine if licensees were operating plants in accordance with their design bases. As part of this review, two team inspections were conducted at Vermont Yankee in 1997. One of these inspections was led by staff from NRC headquarters and included six contractors. In 1998, the NRC conducted an engineerifig inspection, as well as a team inspection to address operability issues resulting from Vermont Yankee's configuration improvement program. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organization to datermine whether the engineering analyses adequately supports safe operation. Our inspectors conduct both routine engineering inspections, as well as an in-depth team inspection every two years. Since the Reactor Oversight Process was implemented in 2000, the NRC has conducted two such safety system design team inspections.

Enclosure

REGUMTORY CO WASHINGTON, D.C.2Q5554001 A p r i l 27, 2006 The Honorable Stephen Kulik State Representative The Commonwealth of Massachusetts House of Representatives State House Boston, MA 02133

Dear Representative Kulik:

On behalf of the Nuclear Regulatory Commission (NRC), I am writing in response to your letter to NRC Chairman Nils J. Diaz, of March 22, 2006, in which you expressed concerns about the implementation of the extended power uprate (EPU) at the Vermont Yankee Nuclear Power Station (Vermont Yankee). Specifically, your letter requested that the NRC conduct a comprehensive independent safety assessment of Vermont Yankee.

I am enclosing a copy of a letter that Chairman Diaz sent to the Vermont Public Service Board (PSB), dated May 4, 2004, explaining the NRC's approach in response to the PSB's request for an independent engineering assessment of Vermont Yankee. As noted in the letter, the NRC staff concluded that its detailed technical review of the proposed amendment, combined with the inspections prescribed by the reactor oversight process, as enhanced by an improved engineering inspection, was determined to be the most effective method of informing the staff decision on whether Vermont Yankee could operate safely under uprated power conditions.

On March 2, 2006, the NRC staff issued its safety evaluation documenting the results of the technical review for the power uprate. A copy of this 335 page report is available on the NRC's Web site at http://adamswebsearch.nrc.qov/doloqin.htm by searching for accession number ML060050028. Section 1.6 of the safety evaluation discusses the engineering inspection that was completed in September 2004. The NRC staff spent over 11,000 hours0 days 0 hours 0 weeks 0 months on the technical review of the proposed power uprate. In addition, over 900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months were spent on the engineering inspection effort. We believe that the Vermont Yankee engineering inspection responds appropriately to requests to conduct an independent assessment of Vermont Yankee.

The NRC Advisory Committee on Reactor Safeguards (ACRS) reviewed the engineering inspection results in the context of its evaluation of the Vermont Yankee power uprate request.

The ACRS is a statutory committee that reports directly to the Commission and is structured to provide a forum where experts representing many technical perspectives can provide advice that is factored into the NRC's decision-making process. The ACRS Subcommittee on Power Uprates held a meeting on November 15 and 16, 2005, in Brattleboro, Vermont to receive input from the public, Entergy, and the NRC staff regarding the proposed power uprate. During this meeting the NRC staff provided the results of the engineering inspection, including a discussion of a!! re!evant inspection findinnc ,,

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-, tho w asked fey 2 mere extensi\/a inspection, similar to that performed at the Maine Yankee plant. In a letter to NRC Chairman

Diaz dated January 4,2006, the ACRS recommended approval of the Vermont Yankee power uprate. As noted in the letter, the ACRS concluded that based on the results of the inspection that was performed and the performance of Vermont Yankee as determined by the NRC's reactor oversight process, a more extensive inspection is not warranted.

The NRC's approval of the Vermont Yankee EPU included a license condition that provides for monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of power uprate operation on structures, systems, and components (including verifying the continued structural integrity of the steam dryer). The license condition is implemented through the procedural steps, performance criteria, and required actions specified in the Vermont Yankee steam dryer monitoring plan and power ascension test procedure.

On March 4, 2006, Entergy began slowly increasing reactor power at Vermont Yankee following the NRC's approval of the EPU amendment on March 2, 2006. Since that time, the plant has suspended the power ascension twice (at 105% and 112.5% of original licensed thermal power) when administrative limits specified in the steam dryer monitoring plan were reached. When an administrative limit is reached, the monitoring plan requires that an engineering evaluation be performed prior to further increases in power. As documented in the NRC staff's Safety Evaluation for the EPU, Entergy formally committed to not increase power above the applicable hold point, if any safety concerns were identified during the NRC staff's review of the power ascension data. The NRC staff reviewed the evaluation and the power ascension data at 105%, 1lo%, 112.5%, and 115% to determine if it had any safety concerns. On April 25, the NRC approved continued ascension to 120°/0 power level.

Your letter also raised a concern regarding an unexpected plant shutdown at Vermont Yankee related to failure of a transformer. This event received significant scrutiny by the NRC. On June 18, 2004, an electrical fault on the 22 kilovolt (kV) electrical system forced the reactor to automatically shut down from 100% power. Arcing and heat generated during the fault caused a main transformer fire. The fire was extinguished through the combined efforts of the automatic fire suppression system, the site's fire brigade, and the local volunteer fire department. The NRC's resident inspectors immediately responded to the event, and the Region I Incident Response Center was staffed to support the residents and follow Entergy's response to the fire. The fire caused no damage to safety systems and Entergy restarted the plant on July 6, 2004, after making necessary repairs. In its November 8, 2004, quarterly inspection report, the NRC discussed Entergy's failure to incorporate operating experience into preventive maintenance of the 22 kV electrical system. Entergy is managing this issue through its corrective action program.

Your letter also referenced the views expressed by Commissioner Jaczko in a memorandum to his fellow Commissioners, concerning the Vermont Yankee EPU. The memorandum reflects the views of Commissioner Jaczko and not the entire Commission's view on any particular matter. On March 3, 2006, the Commission declined to stay the issuance of the requested EPU amendment, pending completion of the adjudicatory proceeding on this application; Commissioner Jaczko concurred in that decision.

I ne NHLS primary missior! is to ensure adequate prni~ctionof p u b k nnaith and safety. ! he NRC will not approve any proposed change to any plant license unless our technical staff can conclude that it has reasonable assurance that adequate protection of public health and safety

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regarding the Vermont Yankee power increase in order to ensure that these reviews and inspections will identify and address any potential safety concerns for operating the plant at uprated power conditions. We will continue to closely monitor the Vermont Yankee power ascension process and will take any actions deemed appropriate for continued protection of public health and safety. I trust that this letter addresses your concerns.

Sincerelv.

for Operation

Enclosure:

As stated

Identical letters sent to:

The Honorable Stan Rosenberg Commonwealth of Massachusetts Senate Boston, MA 02133 The Honorable Andrea Nuciforo Commonwealth of Massachusetts Senate Boston. MA 02133 The Honorable Denis Guyer Commonwealth of Massachusetts House of Representatives Boston, MA 02133 The Honorable Stephen Kulik Commonwealth of Massachusetts House of Representatives Boston, MA 02133 The Honorable Daniel Bosley Commonwealth of Massachusetts House of Representatives Boston, MA 02133

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 CHAIRMAN May 4, 2004 Mr. Michael H. Dworkin, Chairman Vermont Public Service Board 112 State Street, Drawer 20 Montpelier, Vermont 05620-2701

Dear Mr. Dworkin:

I am responding on behalf of the U.S. ~ G c l & r Regulatory Commission (NRC) to your letters dated March 15 and 31, 200$.regar$ng theieq%est by Entergy Nuclear Vermont Yankee, LLC, and Entergy ~\pu&GrOperations, Inc. (~ntergyg-tcf&rgendthe Vermont Yankee Nuclear Power Station license to increase the power level of the facimy. In those letters, the Vermont Publlc ~ervic~.,~o"a'rd requested that the NRC conduct its r e v i c ~ of the proposed power uprate in a way thatLyould provide Vermont a level of assurance,a$ut plant reliability equivalent to an independenhgineering assessment. The N R C - ~ d&!ded ~S to conduct a detalled engineerim&~i~specti<a&af-~e - &=->&

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. - E<>7p-The ~ommissi6n~&derstands that th6 &at&is conFerned aboutthe reliability of Vermont Yankee followin5 %* increase in p o i e i l'&el, especially i d i g h t of operational issues that have occurred at some <$er plants that have recently implemented extended power uprates. The NRC recognizes the EBporLance of these i ~ x e and s IS taking steps to ensure that they are satisfactorily addressed to-main%%. ~- @ t ~ ? e5ample, ? ~ r in response to instances of steam dryer cracking at some boiling water reactors: outside technical experts are assisting NRC staff in performing an audit of General Electric's analyses related to steam dryer performance and specific issues related to Vermont Yankee. We continue to engage the industry to ensure resolution of these issues and will consider additional regulatory action, if needed.

The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A description of the review process is enclosed. Engineering assessments have always been an integral part of the NRC's safety activities. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organization to determine whether engineering analyses adequately support safe operation. Over the past several months, the NRC has been developing a new engineering inspection program which we intend to pilot at selected plants. The NRC staff considered a number of factors, including the Board's request for an independent engineering assessment, and concluded it is appropriate to conduct this engineering inspection at Vermont Yankee. This new engineering assessment inspection incorporates the best practices of the existing and past engineering inspections. The NRC will use this inspection to verify that design bases have been correctly implemented for a sampling of components across multiple systems and to i@t$y,,!atent design issues. The inspection process uses operating experienc~~,~~risk,assess~ent, a$d en,gineering analysis to select risk-significant components and opera<&$&%oh~, and w,'ll &ds6rdi!fiat adequate safety margins exist. Although the specific ~-Gm2$h'ngof components is still beh&3eyeloped, it will include components from multiple,%Y~~.ms that are potentially affected b y *$ewer uprate such as the emergency core cooling~sysiems,the containment system, power corffersion systems, and auxiliary systems. The ihspection will be performed by a team o i apiroximately six inspectors, including some ~ ~ ~ & t s ~ e cdot not o i have $ ~ recent ~ ~ oversighiexperien@e &*=~--- with Vermont Yankee and at --. <- con~~$C~eyith -.>z>.T----.-F.-e

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I revievf%fforts,:i@luding relevant inspection findings, to t h e . 4 for ~ ~ review. ~ Aftei the ACRS co.mplet& its review, it will make an independent recommendatkn regaarding -~ whether the propose~~~power uprate amendment

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p-~.~;~ .zs -t-:-E The NRC will not approve the ~ ~ r r 6 o n t ~ i m uprate, k e e or any proposed change to a plant license, unless the NRC staff can conclude that the proposed change will be executed in a manner that assures the public's health and safety. In response to your request, the NRC staff has taken a close look at proposed inspections and technical reviews to ensure that they will identify and address potential safety concerns for operating at uprated power conditions. The staff has concluded that the detai!ed technical review, prescribed in the Extended Power Uprate Review Standard, coupled with the normal associated program of power uprate and engineering inspections, will provide the information necessary for the NRC staff to make a

decision on the safety of operation of Vermont Yankee under uprated power conditions. The Commission believes that the results of NRC reviews and inspections, particularly the new engineering inspection, will assist in addressing the Board's concerns regarding the future reliability of Vermont Yankee. The NRC staff is prepared to meet with the Board to explain further our review process and scope, including the engineering assessment inspection.

Sincerely, Nils J. Diaz

Enclosure:

Established

Established NRC Power Uprate Review Process The NRC's established review process for power uprate applications is independent, thorough, and comprehensive. A team of engineers with specialties in a minimum of 17 different technical areas will review the Vermont Yankee power uprate application. The NRC plans to expend about 4000 hours0.0463 days 1.111 hours 0.00661 weeks 0.00152 months to perform a comprehensive assessment of the engineering, design, and safety analyses related to the uprate. The NRC's "Review Standard for Extended Power Uprates" guides the staff in its review of the application. The Review Standard also provides guidance for determining when and what type of audits should be performed at the plant or vendor sites, as well as for performing our own confirmatory analyses and independent calculations to supplement the review.

The NRC's review of the power uprate application also includes on-site inspections. NRC inspections will review selected activities and modifications made to allow operation at higher power levels to verify that changes to plant sysLems.,will support safe plant operation and are in Procedure 71 004, "Power U p ~ ~ s ~ ~ a Eas--

accordance with Vermont Yankee:~.licens.i;~ a$,desi$fi-.-.- bases. The NRC will use Inspection qm to inspect issues specifically:felat~d to power uprate. ~hese?ns$ctipns will assess changes

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low-steam flow areas of the dryer"ai@:not in the area3%h&$.@hcks wwe'reo b ~ r F e d at other plants that implemented extended p6&&uprates. NRC ikpectors monitored%ntergy9ssteam dryer inspection activities, and we%yill thoroughly review Entergy's fo16gup actions as part of our evaluation of Vermont Yankee's re&@+sttg ope~ate at a hf&fier -- power level.

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Assessment of engineering has always been anintegral part of the NRC's safety mission. In the l99Os, the NRC performed extensive reviews at plants across the country to determine if licensees were operating plants in accordance with their design bases. As part of this review, two team inspections were conducted at Vermont Yankee in 1997. One of these inspections was led by staff from NRC headquarters and included six contractors. In 1998, the NRC conducted an engineering inspection, as well as a team inspection to address operability issues resulting from Vermont Yankee's configuration improvement program. Under our current Reactor Oversight Process, NRC resident inspectors and regional specialists routinely evaluate the work performed by the licensee's engineering organization to determine whether the engineering analyses adequately supports safe operation. Our inspectors conduct both routine engineering inspections, as well as an in-depth team inspection every two years. Since the Reactor Oversight Process was implemented in 2000, the NRC has conducted two such safety system design team inspections.
Enclosure
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
ENTERGY NUCLEAR VERMONT YANKEE L.L.C. ) Docket No. 50-271-0LA and ENTERGY NUCLEAR OPERATIONS, INC. )
)
)
)
(Vermont Yankee Nuclear Power Station) )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing LETTERS FROM LUIS A. REYES TO SIX MASSACHUSETTS STATE OFFICIALS RESPONDING TO THEIR MARCH 22,2006 LETTER RE SAFETY ASSESSMENT OF VERMONT YANKEE have been served upon the following persons by U.S. mail, first class, or through NRC internal distribution.
Office of Commission Appellate Administrative Judge Adjudication Alex S. Karlin, Chair U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, DC 20555-0001 Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Administrative Judge Administrative Judge Anthony J. Baratta Lester S. Rubenstein Atomic Safety and Licensing Board Panel 4270 E Country Villa Drive Mail Stop - T-3 F23 Tucson, AZ 8571 8 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Sherwin E. Turk, Esq. Raymond Shadis Steven C. Hamrick, Esq. New England Coalition Office of the General Counsel P.O. Box 98 Mail Stop 15 D21 Edgecomb, ME 04556 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Docket No. 50-271-0LA LETTERS FROM LUIS A. REYES TO SIX MASSACHUSETTS STATE OFFICIALS RESPONDING TO THEIR MARCH 22,2006 LETTER RE SAFETY ASSESSMENT OF VERMONT YANKEE John M. Fulton, Esq. Sarah Hofmann, Esq.
Assistant General Counsel Special Counsel Entergy Nuclear Operations, Inc. Department of Public Service 440 Hamilton Avenue 112 State Street - Drawer 20 White Plains, NY 10601 Montpelier, VT 05620-2601 Anthony Z. Roisman, Esq. Jay E. Silberg, Esq.
National Legal Scholars Law Firm Matias F. Travieso-Diaz, Esq.
84 East Thetford Rd. Pillsbury Winthrop Shaw Pittman LLP Lyme, NH 03768 2300 N Street, NW Washington, DC 20037-1 128 Jonathan M. Rund, Esq. Terence A. Burke, Esq.
Law Clerk Associate General Counsel Atomic Safety and Licensing Board Panel Entergy Services, Inc.
Mail Stop - T-3 F23 1340 Echelon Parkway U.S. Nuclear Regulatory Commission Jackson, MS 3921 3 Washington, DC 20555-0001 Office of t h d ~ e c r e t a r ~
Dated at Rockville, Maryland, this 1othday of May 2006

ML061300389

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Dear Representative Guyer:

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ML061300389

Text

Dear Representative Donelan:

Enclosure:

Dear Mr. Dworkin:

Enclosure:

Dear Senator Rosenberg:

Enclosure:

Dear Mr. Dworkin:

Enclosure:

Dear Senator Nuciforo:

Enclosure:

Dear Mr. Dworkin:

Enclosure:

Dear Representative Guyer:

Enclosure:

Dear Mr. Dworkin:

e

..-

Enclosure:

Dear Representative Bosley:

Enclosure:

Dear Mr. Dworkin:

Dear Representative Kulik:

Enclosure:

Dear Mr. Dworkin:

Enclosure:

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