Text

Attachment 1, Vermont Yankee - Steam Dryer Monitoring Plan Rev. 4
	ML061870277
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	06/29/2006
From:	Callaghan J, Dreyfuss J, Nichols C; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	%dam200609, +sunsimjr=200607, BVY-06-056, TAC MC0761
	Download: ML061870277 (89)
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Docket 50-271 BVY 06-056 Attachment 1 Vermont Yankee Nuclear Power Station Steam Dryer Monitoring Plan Rev 4

Entergy Vermont Yankee Steam Dryer Monitoring Plan Revision 4 June 29, 2006 Prepared By

,. raig J. Nichols 6ate Reviewed By7-ý;

(_d'mes H. Callabjd "'Date Approved By_7*

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/ate

Rev. 4 Entergy Vermont Yankee Steam Dryer Monitoring Plan List of Revisions Revision Date Changes Original February 26, 2006 Original Issue 1 March 25, 2006 Incorporated new ACM. Incorporated revisions to FEM. Updated uncertainty evaluation and Limit Curves based on updated models and strain gage data evaluation at 1671 MWt.

2 April 20, 2006 Updated uncertainty evaluation and Limit Curves based on updated strain gage data evaluation at 1792 MWt.

3 May 4, 2006 Incorporated allowance for use of FEM/Strain Gage Evaluation (F-factor).

Provided allowance for up to 1Hz shift in limit curve peak frequencies.

Updated Limit Curves Based on 1872 MWt Data Clarified schedule for completion of final Full Power Steam Dryer Load Analysis 4 June 29, 2006 Document completion of Power Ascension and related testing. Provide final load definition, uncertainty assessment, and dryer stress evaluation.

Page 1 of 31 Rev. 4 VERMONT YANKEE NUCLEAR POWER STATION STEAM DRYER MONITORING PLAN Introduction and Purpose The Vermont Yankee Steam Dryer Monitoring Plan (SDMP) describes the course of action for monitoring and evaluating the performance of the Vermont Yankee Nuclear Power Station (VYNPS) steam dryer during power ascension testing and operation above 100% of the original licensed thermal power (OLTP), i.e., 1593 MWt, to the full 120% extended power uprate (EPU) condition of 1912 MWt to verify acceptable performance. The SDMP also addresses long-term actions necessary to implement proposed License Condition 3.M. Through operating limits, periodic surveillances, and required actions, the impact of potentially adverse flow effects on the structural integrity of the steam dryer will be minimized.

The SDMP also provides information about the equipment and computer analysis methodologies used to monitor Steam Dryer performance.

Unacceptable steam dryer performance is a condition that could challenge steam dryer structural integrity and result in the generation of loose parts, cracks or tears in the steam dryer that result in excessive moisture carryover. During reactor power operation, performance is demonstrated through the measurement of a combination of plant parameters.

Scope The SDMP is primarily an initial power ascension test plan designed to assess steam dryer performance from 100% OLTP (i.e., 1593 MWt) to 120% OLTP (i.e., 1912 MWt) and to perform confirmatory inspections for a period of time following initial and continued operation at uprated power levels. Power ascension to 120% OLTP will be achieved in a series of power step increases and holds at plateaus corresponding to 80 MWt increments above OLTP. Elements of this plan will be implemented before EPU power ascension testing, and others may continue after power ascension testing.

There are three main elements of the SDMP:

1. Slow and deliberate power ascension with defined hold points and durations, allowing time for monitoring and analysis;

2. A detailed power ascension monitoring and analysis program to trend steam dryer performance (primarily through the monitoring of steam dryer load signals and moisture carryover); and

3. A long term inspection program to verify steam dryer performance at EPU operating conditions.

Several elements of the SDMP also provide for completion of the necessary actions to satisfy the requirements of license conditions associated with the EPU license amendment. A complete tabulation of the provisions of the license condition and the implementing strategy to complete them is contained in Table 3.

Page 2 of 31 Rev. 4 Power Ascension VYNPS procedure ERSTI-04-VY1-1409-000, "Power Ascension Test Procedure for Extended Power Conditions 1593 to 1912 MWth," (PATP) will provide controls during power ascension testing and confirm acceptable plant performance. Other procedures may be entered to conduct specialized testing, such as condensate and feedwater testing. The VYNPS power ascension will occur over an extended period with gradual increases in power, hold periods, and engineering analyses of monitored data that must be approved by station management prior to subsequent power increases. Relevant data and evaluations will be transmitted to the NRC staff in accordance with the provisions of the license condition. The PATP includes:

1. Power ascension rate of 16 MWt/hr;

2. Hourly monitoring of steam dryer performance during power ascension (required by License Condition 3.M);

3. Four hour holds at each 40 MWt; and

4. Minimum 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months holds at each 80 MWt power plateau to perform steam dryer analysis allowing for NRC review, as appropriate (required by License Condition 3.M).

Monitoring Plans Table 1 outlines the steam dryer surveillance requirements during reactor power ascension testing for EPU. The monitoring of moisture carryover and main steam line (MSL) pressure data provide measures for ensuring acceptable performance of the steam dryer. Frequent monitoring of these parameters provides early detection capability of off-normal performance.

Proposed License Condition 3.M requires that steam dryer performance criteria are met and prompt action is taken if unacceptable performance is detected. Entergy has established two performance levels (Level 1 criteria and Level 2 criteria) as described in Table 2 for evaluating steam dryer performance during EPU power ascension testing. The Level 1 criteria correspond to the limits specified in the proposed license condition, while the Level 2 criteria are operating action levels that may indicate reductions in margin.

The comparison of measured plant data against defined criteria derived from the steam dryer analyses described below provides a means to assess continued steam dryer structural integrity under EPU conditions.

Main Steam FluctuatingPressure Monitoring System (Detailscontained in VYC-3001)

Main Steam Line Strain Gages Entergy has installed strain gages at two locations on each of the four MSLs in the primary containment and a data acquisition system (DAS) designed to reduce uncertainties in the evaluation of steam dryer loads. These strain gages and the associated data acquisition system have been selected and configured to maximize sensitivity and reliability while reducing data uncertainty.

Acoustic Circuit Model (ACM)

The CDI Acoustic Model has been improved based on results of the instrumented Steam Dryer at Exelon's Quad Cities Station. The revision has resulted in reduced uncertainty and a more conservative representation of the peak frequencies.

Page 3 of 31 Rev. 4 Finite Element Model (FEM)

In response to industry operating experience with steam dryer cover plate cracking, the ANSYS FEM has been updated to include more refined analysis of key dryer structural components such as the lower cover plate, the gussets, gusset shoes, and associated welds.

Since Entergy/GE started using the FEM to evaluate stresses on the VY dryer during power ascension, the contribution of the key in-plant forcing frequencies has been calculated. By understanding the impact on stress due to increases in each of the key in-plant forcing frequencies, the change in steam dryer stress with changes in strain gage signal can be determined directly. Use of these frequency contributions (known as

'F' factors) allows the relationship of the strain gages, ACM, and FEM to be more directly determined based on the plant-specific assessment of ACM/FEM results.

In addition, the Steam Dryer Strain Gage Monitoring and FEM frequency assessments have determined that in-plant acoustic signal frequencies have been shown to change slightly with increased stream flow. While the observed changes (<1 Hz) have negligible impact to the dryer structure, they can result in an unnecessary challenge to the limit curve. To address the shifts of in-plant acoustic frequencies, the limit curve may be shifted to the right or to the left less than or equal to 1Hz. The limit curve criteria is considered satisfied as long as the acoustic signal from the shifted peak falls under the shifted limit curve.

Acoustic Circuit Analysis (ACA) System Uncertainty Evaluation The VY Acoustic Circuit Model (ACM) has been updated. The revised ACM was developed to bound maximum pressure loads from three sets of test data from the instrumented QC2 dryer testing performed in 2005. This updated ACM uncertainty assessment is based on the enhanced VY strain gage and data acquisition system and the revised CDI Bounding Pressure model parameters. The Scale Model Test (SMT) benchmark evaluation and previous 790 MWe QC2 benchmark assessment that provided the uncertainty bases for the prior ACM have been accordingly deleted from this calculation.

The ACA uncertainty included both a non-conservative Bias and an Uncertainty. These are summarized below.

Summary of ACA Bias and Uncertainties Bias Uncertainty ACM ability to match response at the peak frequencies: -21% 15%

Difference in Sensor Locations from QC2 to VY 0% 7%

The application of a model tuned to QC2 applied to Vermont Yankee. 0% 0%

The selection of a 2 second analysis interval to produce peak stress -6% 0%

SG and DAS ability to measure pressure in Pipe 0% 11%

Uncertainty of Dryer Pressure data Measurements at QC2 0% 3%

Combined Bias -27%1

Page 4 of 31 Rev. 4 The Bias terms are added. The Uncertainty terms are independent and are therefore combined by the square root sum of the squares (SRSS) method. The frequency uncertainty value is not included in the summary above. Table 2 includes a summary of the time step summary stress results provided in Attachment J. In this table we also calculate the maximum increase in stress for the frequency sensitivity runs; -10%, -5%, -

2.5%, +2.5%, +5%, +10% for each of the dryer subcomponents. These maximum values are then combined by the SRSS method with the ACA load uncertainties summarized above to provide a specific uncertainty for each dryer component. Finally, the -27% bias is subtracted from the resulting uncertainty to provide the combined uncertainty for each dryer component.

Entergy also performed an additional bounding assessment of FIV fatigue stress. This sensitivity study determined that a worst case combination of the bias and uncertainties would result in a bias of 75% and an ACA uncertainty of 17%. Even with these extremely conservative values the total dryer stress of 9169 psi would have 33% margin to the ASME Curve C endurance limit.

CFD Load Uncertainty (Remains unchanged from Revision 0 of VYC 3001)

The CFD predictions using the Large Eddy Simulation runs for VY are on average 118%

above the RMS values of in-plant data with a standard deviation of 82%. Therefore a conservative estimate of uncertainty is 118% - 82% = +36%. This would support 0%

uncertainty for the CFD load. Conservatively, VY has maintained a 15% CFD load uncertainty in the Limit Curve Factor assessment.

The CFD analysis with the +/-10% change in load step had an impact on the limiting stress by 4%. Therefore the CFD frequency uncertainty is determined to be 4%. The total CFD uncertainty; uncCFD= sqrt(15A2 + 4A2) = 16%.

System Monitoring Requirements (During Power Ascension) o During power ascension, steam dryer performance will be monitored hourly through the evaluation of pressure fluctuation data collected from strain gages installed on the MSLs.

o The strain gage data collected hourly during power ascension will be compared against the stress limit curve that is provided as Figures 1 - 8 of the SDMP and is based on Entergy Calculation VYC-3001. If any frequency peak from the MSL strain gage data exceeds the stress limit curve (Level 1), Entergy will reduce the reactor power to a level at which the stress limit curve is not exceeded.

o Additionally, Entergy will monitor data collected from accelerometers mounted to the main steam piping inside the drywell to provide additional insights into the strain gage signals.

o During hold points at each 80 MWt power level above current licensed thermal power, the collected data, along with a comparison to the steam dryer limit curve, will be transmitted to the NRC staff.

o For any circumstance requiring a revision to the steam dryer limit curve, Entergy will resolve uncertainties in the steam dryer analysis and provide the results of that evaluation to the NRC staff prior to further increases in reactor power.

o Entergy will resolve uncertainties in the steam dryer analysis with the NRC staff within 90 days of issuance of the EPU license amendment. If resolution is not made within this time interval, reactor operation will not exceed 1593 MWt. These planned actions are in compliance with proposed License Condition 3.M.

Page 5 of 31 Rev. 4 Moisture Carryover

Moisture carryover trending provides an indicator of steam dryer integrity. At each 40 MWt step, moisture carryover data will be taken and compared to the predetermined acceptance criteria (Table 2).

Level 1 criterion (0.35%) is based on the maximum analyzed value.

The data taken at each 80 MWt plateau will be evaluated and documented in the assessment sent to the NRC for information.

Other Monitoring Plant data that may be indicative of off-normal steam dryer performance will be monitored during power ascension (e.g., reactor water level, steam flow, feed flow, steam flow distribution between the individual steam lines). Plant data can provide an early indication of unacceptable steam dryer performance. The enhanced monitoring of selected plant parameters will be controlled by the PATP and other plant procedures.

NRC Notifications

" In accordance with proposed License Condition 3.M., at discrete power levels, and if the steam dryer stress limit curve (i.e., Level 1 criterion) is exceeded, Entergy will provide notifications to the NRC staff consisting of data and evaluations performed during EPU power ascension testing above 1593 MWt. Detailed discussions regarding new plant data, inspections, and evaluations will be held with NRC staff upon request. The designated NRC point of contact for such information is the NRC Project Manager for the VYNPS EPU.

" The results of the SDMP will be submitted to the NRC staff in a report within 60 days following the completion of all EPU power ascension testing. This will include the final full EPU power performance criteria spectra (i.e., steam dryer stress limit curve). In accordance with License Condition 3.M the uncertainty questions associated with the ACM will be resolved and submitted to the NRC staff within 90 days of license amendment issuance.

Contemporary data and results from steam dryer monitoring will be available on-site for review by NRC inspectors as it becomes available. The written report on steam dryer performance during EPU power ascension testing will include evaluations or corrective actions that were required to obtain satisfactory steam dryer performance. The report will include relevant data collected at each power step, comparisons to performance criteria (design predictions), and evaluations performed in conjunction with steam dryer structural integrity monitoring.

Long Term Monitorinq The long-term monitoring of plant parameters potentially indicative of steam dryer failure will be conducted, as recommended by General Electric Service Information Letter 644, Rev. 1 and consistent with License Condition 3.M.

Moisture Carryover Per VYNPS station operating procedure OP-0631, "Radiochemistry," moisture carryover is periodically monitored for moisture carryover during normal plant operations. VYNPS off-normal procedure ON-3178, "Increased Moisture Carryover," provides guidance to evaluate any

Page 6 of 31 Rev. 4 elevated moisture carryover results including that resulting from potential vessel internals damage. This monitoring will also provide insight into changes in moisture carryover values during changing reactor core configurations (control rod patterns)

Strain Gage Monitoring As the strain gages will remain operational and can provide for future data collection, additional strain gage monitoring will be performed as determined appropriate during the remainder of the operating cycle following EPU implementation.

Inspections The VYNPS steam dryer will be inspected during the refueling outages scheduled for the Spring 2007, Fall 2008, and Spring 2010. The inspections conducted after power uprate implementation will be comparable in scope to the inspection conducted during the Spring 2004 refueling outage and will be in accordance with the guidance in SIL 644, Rev. 1.

Reporting to NRC Steam Dryer Visual Inspections: The results of the visual inspections of the steam dryer conducted during the next three refueling outages shall be reported to the NRC staff within 60 days following startup from the respective refueling outage.

Results of Steam Dryer Monitoring Plan Power Ascension Power was raised in small (16 MWt and 8 MWt) increments to achieve each plateau.

Monitoring in accordance with the Power Ascension Test Plan (PATP) was completed with no significant monitoring equipment issues. As expected signals on the Main Steam Line Strain Gages detected increased strain signals and the predicted frequencies associated with the branch lines from the Main Steam Lines. In accordance with the SDMP and the PATP, when the signal at any frequency reached predetermined administrative limits (Level 2) the power ascension was put on hold, additional, preestablished analyses were completed and the results provided to the NRC for review. These holds occurred at 105, 112.5 and 117.5 percent power and in each case the reanalysis demonstrated that the actual load on the dryer remained very low.

Steam Dryer Stress Analysis

Peak ACA Steam Dryer Load at 1593 MWt (100% Power) 1857 psi

Peak ACA Steam Dryer Load at 1912 MWt (120% Power) 4762 psi (Note: This value includes use of Rayleigh damping anchored at 20 and 150Hz for additionalconservatism)

Page 7 of 31 Rev. 4 o Load Limit Factors Peak Stress Limit 13,600 psi 0.8 x 13,600 ASME C Limit LCF1 80% of ASME C Limit LCF2 Minimum Load Factor 2.85 2.28 Uncertainty of Load Factor 0.92 0.73 Load Factor Minus Uncertainty 1.93 1.55

Peak CFD Stress 599 psi (Note: Most limiting of 100% and 120% CFD Cases)

Trending of acoustic signals A detailed review of the plots from 90% OLTP to 120% OLTP indicates that there has been an increasing trend at 143 Hz. It is likely the sources of these acoustic signals are the Dresser safety valve branch lines. It was calculated that that the onset of resonance was 150 ft/sec and resonance was calculated to occur at 170 ft/sec. In addition, small shifts (<1 Hz) in the frequency peak were also noted as power increased and allowance was made to shift the limit curve up to 1 Hz up or down to account for these changes.

A technique was developed to determine directly, based on experiential data, the impact on dryer stress of a change in strain gage signal at existing peak frequencies. This technique is applicable for the assessment of signal changes, not for the assessment of new signals that are outside the frequency bands evaluated in the previous acoustic circuit and stress analysis.

VYStaem Dryer Stres Vaue (p13) 14o 120000 10000 6WOOOD 01 100 105 112.5 117.5 12D F43rýnt l*m*r L~mOW4 S--a-- Peak Stress Lekel 2 Urnit -- (- Laud 1 Urrit1 Notes:

1) Stress Calculated with 1% Rayleigh damping Anchored at 20 and 80 Hz.

2) Power Level expressed as percent of original licensed thermal power, 1593 MWt.

Page 8 of 31 Rev. 4 Final Uncertainty Evaluation Based on refinements made to the strain gage monitoring system, the ACA, and the FEM an updated uncertainty assessment was completed. The revised assessment includes both biases and uncertainties to best characterize the performance of the models. The ACA uncertainty included both a non-conservative Bias and an Uncertainty. These are summarized below.

Summary of ACA Bias and Uncertainties Bias Uncertainty ACM ability to match response at the peak frequencies: -21% 15%

Difference in Sensor Locations from QC2 to VY 0% 7%

The application of a model tuned to QC2 applied to Vermont Yankee. 0% 0%

The selection of a 2 second analysis interval to produce peak stress -6% 0%

SG and DAS ability to measure pressure in Pipe 0% 11%

Uncertainty of Dryer Pressure data Measurements at QC2 0% 3%

Combined Bias -27%

Moisture Carryover During Power Ascension Moisture Carryover was monitored per the PATP and results reported to the NRC. The original Level 2 Criteria (0.1%) was reached at 1872 MWt (117.5% Power). Evaluations in accordance with plant procedures determined the final 1912 MWt Level 2 Criteria to be 0.16%. At 1912 MWt all data remains below 0.15%.

Significant Margin remains to the Level 1 Criteria (0.35%).

Conclusion As shown above, after reduction for uncertainties, the VY dryer maintains a 93% margin to the 13.6 ksi endurance limit under FIV loads.

License Condition Criteria (3.M.2.c, 3.M.2.f)

Obtain measurements from the main steam line strain gauges - On May 5, 2006 VY reached 1912 MWt (120% Power) and obtained the full power main steam line strain gage signature from all eight main steam line strain gage locations. The averaged signals from the array of strain gages at each location are shown on Figures 1 through 8 of the SDMP (Figures 9 through 12 are expanded versions of certain frequency signatures).

" Establish the steam dryer flow-induced vibration load fatigue margin - Bas6d on the results of the steam dryer stress analysis using the 120% load definition the limit factors specified above were calculated. These limit factors are shown graphically in Figures 1 though 8 of the SDMP.

Update the steam dryer stress report - The Steam Dryer stress report has been updated based on the 120% load definition and is included in Entergy calculation VYC-3001. This report, GE-NE-0000-0054-1378P-RO, Vermont Yankee Nuclear Power station Steam Dryer Stress Analysis at Extended Power Uprate Conditions, Revision 0, Class III (GE Proprietary Information), dated June 2006 will be provided separately to the NRC.

Page 9 of 31 Rev. 4 Reestablish the SDMP limit curve with the updated acoustic circuit model load definition and revised instrument uncertainty values - The updated SDMP limit curves are shown on Figures 1 through 8 of the SDMP (Figures 9 through 12 are expanded versions of certain frequency signatures).

Develop the final steam dryer load definition - The final Steam Dryer Load definition is represented by the eight main steam line strain gage signatures shown in Figures 1 through 8 of the SDMP (Figures 9 through 12 are expanded versions of certain frequency signatures). A conservative 2 second sample from these signatures was used in the Acoustic Circuit Analysis.

Page 10 of 31 Rev. 4 Table 1 Steam Dryer Surveillance Requirements During Reactor Power Operation Above a Previously Attained Power Level Parameter Surveillance Frequency

1. Moisture Carryover Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Notes 1 and 2)

2. Main steam line pressure data Hourly when initially increasing power above a from strain gages previously attained power level AND At least once at every 40 MWt (nominal) power step above 100% OLTP (Note 3)

3. Main steam line data from At least once at every 40 MWt (nominal) power step accelerometers above 100% OLTP (Note 3)

AND Within one hour after achieving every 40 MWt

_(nominal) power step above 100% OLTP Notes to Table 1:

1. If a determination of moisture carryover cannot be made within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of achieving an 80 MWt power plateau, an orderly power reduction shall be made within the subsequent 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to a power level at which moisture carryover was previously determined to be acceptable. For testing purposes, a power ascension step is defined as each power increment of .40 MWt, i.e., at thermal power levels of approximately 102.5%, 105%, 107.5%,

110%, 112.5%, 115%, 117.5%,- and 120% OLTP. Power level plateaus are nominally every 80 MWt.

2. Provided that the Level 2 performance criteria in Table 2 are not exceeded, when steady state operation at a given power exceeds 168 consecutive hours, moisture carryover monitoring frequency may be reduced to once per week.

3. The strain gage surveillance shall be performed hourly when increasing power above a level at which data was previously obtained. The surveillance of both the strain gage data and MSL pressure data is also required to be performed once at each 40 MWt power step above 1593 MWt and within one hour of achieving each 40 MWt step in power, i.e., at thermal power levels of approximately 102.5%, 105%, 107.5%, 110%, 112.5%, 115%, 117.5%, and 120% OLTP (i.e., 1593 MWt). If the surveillance is met at a given power level, additional surveillances do not need to be performed at a power level where data had previously been obtained.

If valid strain gage data cannot be recorded hourly or within one hour of initially reaching a 40 MWt power step from at least three of the four MSLs, an orderly power reduction shall be made to a lower power level at which data had previously been obtained. Any such power level reduction shall be completed within two hours of determining that valid data was not recorded.

Page 11 of 31 Rev. 4 Table 2 Steam Dryer Performance Criteria and Required Actions Performance Criteria Not to be Required Actions if Performance Criteria Exceeded and Required Exceeded Completion Times Level 2: 1. Promptly suspend reactor power ascension until an engineering evaluation concludes that further power ascension is justified.

Moisture carryover exceeds 0.1% 2. Before resuming reactor power ascension, the steam dryer OR performance data shall be reviewed as part of an engineering evaluation to assess whether further power ascension can be made Moisture carryover exceeds without exceeding the Level 1 criteria.

0.1% and increases by

> 50% over the average of the three previous measurements taken at

> 1593 MWt OR

Pressure data exceed Level 2 Spectra 1 Level 1: 1. Promptly initiate a reactor power reduction and achieve a previously acceptable power level (i.e., reduce power to a previous step level)

Moisture carryover exceeds within two hours, unless an engineering evaluation concludes that 0.35% continued power operation or power ascension is acceptable.

OR

2. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , re-measure moisture carryover and perform an Pressure data exceed Level engineering evaluation of steam dryer structural integrity. If the 1 Spectral results of the evaluation of steam dryer structural integrity do not support continued plant operation, the reactor shall be placed in a hot shutdown condition within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If the results of the engineering evaluation support continued power operation, implement steps 3 and 4 below.

3. If the results of the engineering evaluation support continued power operation, reduce further power ascension step and plateau levels to nominal increases of 20 MWt and 40 MWt, respectively, for any additional power ascension.

4. Within 30 days, the transient pressure data shall be used to calculate the steam dryer fatigue usage to demonstrate that continued power operation is acceptable.

1 The EPU spectra shall be determined and documented in an engineering calculation or report.

Acceptable Level 2 spectra shall be based on maintaining < 80% of the ASME allowable alternating stress (Sa) value at 1011 cycles (i.e., 10.88 ksi). Acceptable Level 1 Spectra shall be based on maintaining the ASME Sa at 10" cycles (i.e., 13.6 ksi).

Page 12 of 31 Rev. 4 Table 3 Steam Dryer License Conditions License Condition Requirement Implementing Actions 3.M.l.a Entergy shall monitor hourly the 32 COMPLETE - During initial power ascension above main steam line (MSL) strain gages 1593 MWt, data from at least 32 strain gages will be during power ascension above 1593 collected and evaluated by Entergy's power MWt for increasing pressure ascension test team to verify that acoustic signals fluctuations in the steam lines, indicative of increasing pressure fluctuations in the steam lines are not challenging the steam dryer stress limit curve. Monitoring will be conducted hourly during any power ascension above a previously attained power level.

(Reference ERSTI-04-VY1-1409-000)

(Reference PCRS tracking item WT-VTY-2005-00000-01803) 3.M.l.b Entergy shall hold the facility for 24 COMPLETE - The PATP has established test hours at 105%, 110%, and 115% of plateau increments of approximately 80 MWt OLTP (i.e., 1593 MWt) to collect (corresponding to 105%, 110%, and 115% of 1593 data from the 32 MSL strain gages MWt). Reactor power will not be increased above required by License Condition the plateau for a minimum of 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months . During the 3.M.l.a, conduct plant inspections first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of steady state operation at each and walkdowns, and evaluate steam plateau, strain gage data will be collected from all dryer performance based on these available strain gages (minimum of 32) and data; shall provide the evaluation to evaluated to demonstrate acceptable steam dryer the NRC staff by facsimile or performance. Additionally, moisture carryover electronic transmission to the NRC measurements will be made at each plateau and project manager upon completion of every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during power ascension testing. At the evaluation; and shall not the 80 MWt plateau hold points, Entergy will increase power above each hold conduct plant walkdowns and inspections of plant point until 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months after the NRC equipment, including piping and components project manager confirms receipt of identified as potentially vulnerable to flow-induced the transmission. vibration (FIV) in accordance with the PATP and other plant procedures. Steam dryer performance will be evaluated based on these data.

The 24-hour period and the 96-hour period may overlap once the transmittal is provided to the NRC staff.

The evaluations of steam dryer performance, based on the data collected during each of the 80 MWt plateaus, as well as the results of walkdowns and other measurements of FIV for various piping and plant components, will be provided to the NRC staff.

Arrangements have been made for electronic transmission through email and/or uploading to a designated website. Upon the NRC Project

Page 13 of 31 Rev. 4 License Condition Requirement Implementing Actions Manager confirming receipt of the steam dryer data and performance evaluation, the 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months of hold time will commence. Power will not be increased above each of the 80 MWt hold points until the expiration of the 96-hour hold.

If during the hold periods, or at any other time, the NRC staff requests a discussion or requires clarification of the engineering evaluations provided in fulfillment of this requirement, Entergy will promptly arrange for such discussions. Entergy will maintain a power ascension control center, including management oversight, available 24/7 on-site during power increases to previously unattained power levels.

(Reference ERSTI-04-VY1 -1409-000)

(Reference PCRS tracking item WT-VTY-2005-00000-01803) 3.M.1.c If any frequency peak from the MSL COMPLETE - The steam dryer stress limit curve strain gage data exceeds the limit provided herewith contains Level 1 and Level 2 curve established by Entergy criteria. If frequency peaks from MSL strain gage Nuclear Operations, Inc. and data exceed either Level 1 or Level 2 criteria, submitted to the NRC staff prior to prompt action will be taken in response to the operation above OLTP, Entergy potential adverse flow effects that might result.

Nuclear Operations, Inc. shall return Similar actions will occur if moisture carryover is the facility to a power level at which excessive and previously established Level 1 or the limit curve is not exceeded. Level 2 criteria are exceeded. The Level 2 criteria Entergy Nuclear Operations, Inc. represent a conservative action level for evaluation shall resolve the uncertainties in the and close monitoring of steam dryer performance-steam dryer analysis, document the not a limit. The Level 1 criteria represent analytical continued structural integrity of the limits and additional actions may be warranted.

steam dryer, and provide that documentation to the NRC staff by If any frequency peak from the MSL strain gage facsimile or electronic transmission data exceeds the Level 1 steam dryer stress limit to the NRC project manager prior to curve, Entergy will reduce reactor power to a power further increases in reactor power. level at which the limit curve is not exceeded.

(Reference ERSTI-04-VY1-1409-000)

Prior to any further increase in power above the reduced power level, Entergy will (1) resolve the uncertainties in the steam dryer analysis, (2) evaluate and document the adequate structural integrity of the steam dryer, and (3) provide that documentation to the NRC staff. Any revision to the limit curve based on this evaluation will be provided to the NRC staff.

(Reference PCRS tracking item WT-VTY-2005-00000-01803)

Page 14 of 31 Rev. 4 License Condition Requirement Implementing Actions 3.M.1.d In addition to evaluating the MSL COMPLETE - Accelerometers mounted on MSL strain gage data, Entergy Nuclear piping will be monitored on an hourly basis during Operations, Inc. shall monitor power ascension testing to identify if resonances reactor pressure vessel water level are increasing above nominal levels in proportion to instrumentation or MSL piping MSL strain gage data. If abnormally increasing accelerometers on an hourly basis resonant frequencies are detected, power during power ascension above ascension will be halted. Prior to any further OLTP. If resonance frequencies are increase in power, Entergy will (1) evaluate and identified as increasing above document the adequate structural integrity of the nominal levels in proportion to strain steam dryer, and (2) provide that documentation to gage instrumentation data, Entergy the NRC staff.

Nuclear Operations, Inc. shall stop (Reference ERSTI-04-VY1-1409-000) power ascension, document the (Reference PCRS tracking item WT-VTY-2005-continued structural integrity of the 00000-01803) steam dryer, and provide that documentation to the NRC staff by facsimile or electronic transmission to the NRC project manager prior to further increases in reactor power.

3.M.1.e Following start-up testing, Entergy COMPLETE - After collecting strain gage data at Nuclear Operations, Inc. shall approximately the EPU full power level, Entergy will resolve the uncertainties in ,the resolve the uncertainties in the steam dryer analysis steam dryer analysis and. provide and provide documentation of the resolution to the that resolution to the NRC staff by NRC staff. If these actions cannot be achieved facsimile or electronic transmission within 90 days of issuance of the license to the NRC project manager. If the amendment, reactor power will be limited to 1593 uncertainties are not resolved within MWt. This uncertainty evaluation may be prepared 90 days of issuance of the license and provided to the NRC prior to reaching EPU full amendment authorizing operation at power levels associated with any proposed revision 1912 MWt, Entergy Nuclear to the steam dryer limit curve.

Operations, Inc. shall return the (Reference PCRS tracking item WT-V'Y-2005-facility to OLTP. 00000-01803) 3.M.2.a Prior to operation above OLTP, COMPLETE To enhance performance and Entergy Nuclear Operations, Inc. improve the accuracy of the steam dryer shall install 32 additional strain measurement system, Entergy has installed 48 gages on the main steam piping and! strain gages on MSL piping and will maintain a shall enhance the data acquisition i minimum of 32 operable strain gages during power system in order to reduce the ascension testing. The data acquisition system measurement uncertainty (DAS) was upgraded to reduce the uncertainty associated with the acoustic circuiti associated with the ACM.

model (ACM). (Reference Entergy VYNPS Temporary Alteration TA-2005-15 R1) 3.M.2.b In the event that acoustic signals: COMPLETE - As part of the evaluation performed are identified that challenge the limit at 1673MWt Entergy Vermont Yankee employed a

Page 15 of 31 Rev. 4 License Condition Requirement Implementing Actions curve during power ascension new revision of the Acoustic Circuit Model. In above OLTP, Entergy Nuclear association with the benchmarking of the new ACM Operations, Inc. shall evaluate a frequency specific assessment of the ACM steam dryer loads and re-establish uncertainty was performed and is contained in the limit curve based on the new Calculation VYC-3001, Rev.1.

strain gage data, and shall perform (Reference ERSTI-04-VY1-1409-000) a frequency-specific assessment of (Reference VYC-3001 Rev. 1)

ACM uncertainty at the acoustic sighal frequency.

3.M.2.c After reaching 120% of OLTP, COMPLETE - After collecting strain gage data at Entergy Nuclear Operations, Inc. approximately the EPU full power level, Entergy will shall obtain measurements from the establish the steam dryer flow-induced vibration MSL strain gages and establish the load fatigue margin for the facility, update the steam steam dryer flow-induced vibration dryer stress report, and re-establish the stress limit load fatigue margin for the facility, curve with the updated ACM load definition and update the steam dryer stress revised instrument uncertainty. This information will report, and re-establish the steam be included in the report to the NRC staff being dryer monitoring plan (SDMP) limit made in accordance with License Condition curve with the updated ACM load 3.M.l.e. (Reference PCRS tracking item WT-VTY-definition and revised instrument 2006-00000-00249) uncertainty, which will be provided to the NRC staff.

3.M.2.d During power ascension above COMPLETE - As part of the evaluation performed OLTP, if an engineering evaluation at 1673MWt Entergy Vermont Yankee completed is required in accordance with the revisions to the VY Steam Dryer model used in the SDMP, Entergy Nuclear Operations, Finite Element Model (FEM). Additional analysis of Inc. shall perform the structural the FEM output was performed to assess the analysis to address frequency frequency uncertainties. The results of this uncertainties up to +/-10% and assessment are contained in Calculation VYC-assure that peak responses that fall 3001, Rev. 1.

within this uncertainty band are (Reference ERSTI-04-VY1-1409-000) addressed.

3.M.2.e Entergy Nuclear Operations, Inc. COMPLETE - The revised SDMP provides long-shall revise the SDMP to reflect: term monitoring of steam dryer performance in long-term monitoring of plant accordance with GE SIL 644 Rev. 1.

parameters potentially indicative of (Reference PCRS tracking item WT-VTY-2006-steam dryer failure; to reflect' 00000-00250) consistency of the facility's steami dryer inspection program with COMPLETE - The SDMP and the PATP identify the General Electric Services NRC Project Manager for the VYNPS EPU as the Information Letter 644, Revision 1;i point of contact for providing SDMP information and to identify the NRC Project' during power ascension.

Manager for the facility as the point' (Reference ERSTI-04-VYl-1409-000) of contact for providing SDMP!

information during power ascension.' COMPLETE - For moisture carryover, procedures OP-0631 and ON-3178 provide for long-term monitoring and controls.

Page 16 of 31 Rev. 4 License Condition Requirement Implementing Actions 3.M.2.f Entergy Nuclear Operations, Inc. COMPLETE - The final EPU steam dryer load shall submit the final extended definition will be included in the report provided to power uprate (EPU) steam dryer the NRC, staff in accordance with License load definition for the facility to the Conditions 3.M.l.e. and 3.M.2.c.

NRC upon completion of the power (Reference PCRS tracking item WT-VTY-2006-ascension test program. 00000-00251) 3.M.2.g Entergy Nuclear Operations, Inc. COMPLETE - Entergy letter BVY 06-019 forwards shall submit the flow-induced the FIV-related portions of the EPU power vibration related portions of the EPU ascension test procedure to the NRC. (Reference startup test procedure to the NRC, ERSTI-04-VY1-1409-000) including methodology for updating the limit curve, prior to initial power The methodology for updating the steam dryer ascension above OLTP. stress limit curve is as follows:

Prerequisite: Generate report resolving uncertainties in the steam dryer analysis.

1. Collect representative data from 32 strain gages at eight MSL locations.

2. Using a plant-specific ACM, analyze strain gage data to determine steam dryer loads.

3. Input ACM loads into a finite element model to determine dryer stresses.

4. Perform an updated uncertainty evaluation.

5.. Generate revised steam dryer stress limit curve(s).

(Reference PCRS tracking item WT-VTY-2006-00000-00252) 3.M.3(a) Entergy shall prepare the EPU COMPLETE - The steam dryer stress limit curve to startup test procedure to include the I be applied for evaluating steam dryer performance stress limit curve to be applied for during power ascension is provided herewith. The evaluating steam dryer limit curve was developed on the basis of performance. calculation VYC-3001, which is incorporated by reference into the EPU PATP.

(Reference ERSTI-04-VY1-1409-000) 3.M.3(b) Entergy shall prepare the EPU COMPLETE - Specific hold points and durations are startup test procedure to include specified in the PATP.

specific hold points and their (Reference ERSTI-04-VY1-1409-000) duration during EPU powert ascension.

3.M.3(c) Entergy shall prepare the EPUV COMPLETE - Activities to be accomplished during startup test procedure to include' hold points are specified in the PATP.

activities to be accomplished during (Reference ERSTI-04-VY1-1409-000)

Page 17 of 31 Rev. 4 License Condition Requirement Implementing Actions hold points.

3.M.3(d) Entergy shall prepare the EPU COMPLETE - Plant parameters to be monitored are startup test procedure to include specified in Attachment 9 to the PATP.

plant parameters to be monitored. (Reference ERSTI-04-VY1-1409-000) 3.M.3(e) Entergy shall prepare the EPU COMPLETE - Inspections and walkdowns to be startup test procedure to include conducted for steam, feedwater, and condensate inspections and walkdowns to be systems and components during hold points are conducted for steam, feedwater, specified in Attachment 9 to the PATP.

and condensate systems and (Reference ERSTI-04-VY1-1409-000) components during the hold points.

3.M.3(f) Entergy shall prepare the EPU COMPLETE - Methods to be used to trend plant startup test procedure to include parameters are specified in Attachment 9 to the methods to be used to trend plant PATP.

parameters. (Reference ERSTI-04-VY1 -1409-000) 3.M.3(g) Entergy shall prepare the EPU COMPLETE - Acceptance criteria for monitoring startup test procedure to include and trending plant parameters, and conducting the acceptance criteria for monitoring walkdowns and inspections are specified in and trending plant parameters, and Attachment 9 to the PATP. (Reference ERSTI conducting the walkdowns and VY1-1409-000) inspections.

3.M.3(h) Entergy. shall prepare the EPU COMPLETE - Actions to be taken if acceptance startup test procedure to include criteria are not satisfied are specified in the PATP.

actions to be taken if acceptance (Reference ERSTI-04-VY1-1409-000) criteria are not satisfied.

3.M.3(i) Entergy shall prepare the EPU COMPLETE - Verification of the completion of startup test procedure to include commitments and planned actions specified in the verification of the completion of license amendment application and all supplements commitments and planned actions, to the application in support of the EPU license specified in the license amendmentJ amendment request pertaining to the steam dryer is application and all supplements to specified in the PATP.

the application in support of the! (Reference ERSTI-04-VYl-1409-000)

EPU license amendment request, pertaining to the steam dryer.

Page 18 of 31 Rev. 4 3.M.4 When operating above OLTP, the These restrictions are provided in the PATP and/or operating limits, required actions, the SDMP.

and surveillances specified in the (Reference ERSTI-04-VY1-1409-000)

SDMP shall be met. The following key attributes of the SDMP shall not be made less restrictive without prior NRC approval:

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

b. Level 1 performance criteria; and

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

Changes to other aspects of the SDMP may be made in accordance f

with the quidance of NEI 99-04. f 3.M.5 During each of the three scheduled The VYNPS steam dryer will be inspected during refueling outages (beginning with the refueling outages scheduled for the Spring the spring 2007 refueling outage), 2007, Fall 2008, and Spring 2010. The inspections a visual inspection shall be conducted after power uprate implementation will conducted of all accessible, be comparable to the inspections conducted during susceptible locations of the steam the Spring 2004 and Fall 2005 refueling outages dryer, including flaws left "as is" and will be in accordance with the guidance in SIL and modifications. 644, Rev. 1.

(Reference PCRS tracking item WT-VTY-2006-00000-00253)

(Reference PCRS tracking item WT-VTY-2006-00000-00254)

(Reference PCRS tracking item WT-VTY-2006-00000-00255)

Page 19 of 31 Rev. 4 3.M.6 The results of the visual The VYNPS steam dryer will be inspected during inspections of the steam dryer the refueling outages scheduled for the Spring conducted during the three 2007, Fall 2008, and Spring 2010. The inspections scheduled refueling outages conducted after power uprate implementation will (beginning with the spring 2007 be comparable to the inspections conducted during refueling outage) shall be reported the Spring 2004 and Fall 2005 refueling outages to the NRC staff within 60 days and will be in accordance with the guidance in SIL following startup from the 644, Rev. 1. The results will be documented in a respective refueling outage. The report and submitted to the NRC within 60 days results of the SDMP shall be following completion of all EPU power ascension submitted to the NRC staff in a testing.

report within 60 days following the (Reference PCRS tracking item WT-VTY-2006-completion of all EPU power 00000-00256) ascension testing. (Reference PCRS tracking item WT-VTY-2006-00000-00257)

(Reference PCRS tracking item WT-VTY-2006-00000-00258) 3.M.7 The requirements of paragraph When operating above 1593 MWt, the operating 3.M.4 above for meeting the SDMP limits, required actions, and surveillances specified shall be implemented upon in the SDMP will be met. Those key attributes of issuance of the EPU license the SDMP specified in License Condition 3.M.4 will amendment and shall continue not be made less restrictive without prior NRC until the completion of one full approval.

operating cycle at EPU. If an (Reference PCRS tracking item WT-VTY-2006-unacceptable structural flaw (due 00000-00259) to fatigue) is detected during the subsequent visual inspection of the steam dryer, the requirements of paragraph 4 shall extend another full operating cycle until the visual inspection standard of no new flaws/flaw growth based on visual inspection is satisfied.

3.M.8 This license condition shall expire (Reference PCRS tracking item WT-VTY-2006-upon satisfaction of the 00000-00260) requirements in paragraphs 5, 6, and 7 provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw or unacceptable flaw growth that is due to fatigue.

Page 20 of 31 Rev. 4 1.OE+00 1.OE-01 1.OE-02 1.OE-03

1' 1.OE-04 1.OE-05 1.OE-06 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200 Frequency, Hz LC2_AveMSL_&AUpper -L~lAveMSLAUpper - 1912MWt BaselineMSLA Upper I:-

Figure 1: Steam Dryer Stress Limit Curve - MSL A' Upper

Page 21 of 31 Rev. 4 1.QE+O0 1.OE-01 1.OE-02 1.OE-03 I,

1.OE-04 1.OE-05 1.OE-06 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200 Frequency, Hz Figure 2: Steam Dryer Stress Limit Curve - MSL 'A' Lower

Page 22 of 31 Rev. 4 1.OE+O0 1.OE-01 1.OE-02 1.OE-03 1.0E-04 1.OE-05 1.oE-06 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200 Frequency, Hz

-LC2_AveMSLB_Upper -L01_AveMSLBUpper - 1 912MWt BaselineMSLB Upper Figure 3: Steam Dryer Stress Limit Curve - MSL 'B' Upper

Page 23 of 31 Rev. 4 1.OE+O0 1.OE-01 1.0E-02 ......

1.0E-03 1.0E-04-W 1.OE-05 1.OE-06 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200 Frequency, Hz

- 1912MWt BaselineMSLBLower Fiqure 4: Steam Dryer Stress Limit Curve - MSL 'B' Lower

Page 24 of 31 Rev. 4 1.OE+OO 1.OE-O1 1 .OE-02 1.OE-03 1.OE-04 1 .OE-05 1.OE-06 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 2( 0 0

- LC2_AveMSL_C_Upper -LCAveMSL-CUpper - 1912MWt BaselineMSL C Upper Figure 5: Steam Dryer Stress Limit Curve - MSL 'C' Upper

Page 25 of 31 Rev. 4 1.0E+O0 1.0E-O1 1.OE-02 4

' 1.OE-03 1.OE-04 1.OE-05 1.OE-06 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200 Frequency, Hz Fiaure 6: Steam Dryer Stress Limit Curve - MSL 'C' Lower

Page 26 of 31 Rev. 4 1.OE+O0 1.OE-01 1.OE-02

1.OE-03 1.0E-04 1.OE-05 1.OE-06 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 20'0 Frequency, Hz Fiqure 7: Steam Dryer Stress Limit Curve - MSL 'D' Upper

Page 27 of 31 Rev. 4 1.OE+00 1.OE-01 1.OE-02 1.OE-03 I-1.OE-04 1.OE-05 1.OE-06 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200 Frequency, Hz LC2_AveMSL D Lower -LCIAveMSLDLower 1912MWt BaselineMSLD0Lower Figure 8: Steam Dryer Stress Limit Curve - MSL 'D' Lower

Page 28 of 31 Rev. 4 1.OE+00 1.0E-01 1.OE-02 N

1.OE-03 1.OE-04 1.OE-05 1.OE-06 4-130 140 150 Frequency, Hz

-LC2_AveMSLAUpper -LC1_AveMSL-AUpper - 1912MWt BaselineMSLA Upper Figure 9: Steam Dryer Stress Limit Curve - MSL 'A' Upper Expanded

Page 29 of 31 Rev. 4 1.OE+00 1.OE-01 1.0E-02 w 1.0E-03 1.0E-04 1.OE-05 1.0E-06 130 140 150 Frequency, Hz

-LC2_AveMSLALower -LClAveMSL A Lower 1912MWt Fi-gure 10: Steam Dryer Stress Limit Curve - MSL 'A' Lower Expanded

Page 30 of 31 Rev. 4 1.OE+00 1.OE-01 1.OE-02 1.OE-03

'I, 1.0E-04 1.OE-05 1.0E-06 130 140 150 Frequency, Hz

- LC2_AveMSLDUpper - LCIAveMSL D-Upper - 1912MWt BaselineMSL_D_Upper Figure 11: Steam Dryer Stress Limit Curve - MSL 'D' Upper Expanded

Page 31 of 31 Rev. 4 1.OE+00 1.OE-01 1.OE-02 1.OE-03 1.OE-04 1.OE-05 1.OE-06 4-130 140 150 Frequency, Hz

-LC2_AveMSLDLower -LCIAveMSLD0Lower -- 1912MWt BaselineMSLD0Lower Figure 12: Steam Dryer Stress Limit Curve - MSL 'D' Lower Expanded

Docket 50-271 BVY 06-056 Attachment 3 Vermont Yankee Nuclear Power Station Affidavit for Withholding GE-NE-0000-0054-1378P-RO from Public Disclosure

General Electric Company AFFIDAVIT 1, Louis M. Quintana, state as follows:

(1) I am Manager, Licensing, General Electric Company ("GE"), have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in GE proprietary report, GE-NE-0000-0054-1378P-RO, Vermont Yankee Nuclear Power Station Steam Dryer Stress Analysis at Extended Power Uprate Conditions, Revision 0, Class III (GE Proprietary Information),

dated June 2006. The proprietary information is delineated by a double underline inside double square brackets. Figures and large equation objects are identified with double square brackets before and after the object. In each case, the superscript notation 31 refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d 1280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, resulting in potential products to General Electric;

d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

AfVY Dryer Stress Rpt.doc Affidavit Page I of 3

The information sought to be withheld is considered to be proprietary for the reasons set forth in.paragraphs (4)a and (4)b above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it documents the dynamic, stress and fatigue analyses that demonstrate the adequacy of the BWR steam dryer using GE-developed structural analysis techniques and methodology.

Development of the test methods, the methodology for analysis of this information and the steam dryer performance, and its application for the analyses methodologies and processes for the determination of the acceptability of the steam dryer at Extended Power Uprate

.conditions was achieved at a significant cost to GE, on the order of approximately two million dollars.

The development of the dryer performance evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR satety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

AfVY Dryer Stress Rpt.doc Affidavit Page 2 of 3

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GE would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this 23rd day of June 2006. WK Louis M. Quintana General Electric Company AfVY Dryer Stress Rpt.doc Affidavit Pa-e 3 of 3

Docket 50-271 BVY 06-056 Attachment 4 Vermont Yankee Nuclear Power Station GE-N E-0000-0054-1378NP-RO (Non-Proprietary Information)

GE Energy, Nuclear 3901 Castle Hayne Rd Wilmington, NC 28401 GE-NE-0000-0054-1378NP-RO DRF 0000-0050-8392 Revision 0 Class I June 2006 Non-Proprietary Version Entergy Nuclear Operations Incorporated Vermont Yankee Nuclear Power Station Steam Dryer Stress Analysis at Extended Power Uprate Conditions Principal Contributors:

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GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION NON PROPRIETARY NOTICE This is a non-proprietary version of the document GE-NE-0000-0054-1378P, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here (( fl.

IMPORTANT NOTICE REGARDING THE CONTENTS OF THIS REPORT Please Read Carefullu The only undertakings of the General Electric Company (GE) respecting information in this document are contained in the contract between Entergy Nuclear Operations Incorporated and GE, Order 4500528282, Schedule A-2, as amended to the date of transmittal of this document, and nothing contained in this document shall be construed as changing the contract. The use of this information by anyone other than Entergy Nuclear Operations Incorporated, for any purpose other than that for which it is furnished by GE, is not authorized; and with respect to any unauthorized use, GE makes no representation or warranty, express or implied, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document, or that its use may not infringe upon privately owned rights.

GE-N E-0000-0054-1378N P-R0 GE PROPRIETARY INFORMATION Table of Contents Acronym s and Abbreviations ................................................................................................. iv 1.0 Executive Sum m ary ...................................................................................................... 1 2.0 Background and Introduction ...................................................................................... 2 3.0 Acceptance Criteria ..................................................................................................... 7 4.0 Inputs ................................................................................................................................ 11 5.0 Steam Dryer Model and Analysis .............................................................................. 12 6.0 Modified Dryer Analysis Results ................................................................................. 24 7.0 Conclusion ........................................................................................................................ 38 8.0 References ........................................................................................................................ 39 Appendix A Vermont Yankee Steam Dryer Differential Pressures ................................ A-1 List of Figures Figure 2-1 Modified Dryer .................................................................................................... 4 Figure 2-2 Modification Details ........................................................................................... 5 Figure 5-1 Modified Full Dryer Analysis Model ................................................................. 16 Figure 5-2 Details of Analysis Model Showing Front Hood, Support Ring and Skirt ....... 17 Figure 5-3 Details of Analysis Model Showing Front Hood Gussets .............................. 18 Figure 5-4 FEA Model Mode Shapes for Outer Dryer Hood ............................................ 19 Figure 5-5 Rayleigh Dam ping ........................................................................................... 23 Figure 6-1 Power Spectral Density Comparison of Nominal Case Damping ................ 36 Figure 6-2 Stress Spectrum Comparison of Nominal Case Damping ............................ 37 Figure A-1 Typical TSV Load Time Histories ....................................................................... A-3 List of Tables Table 2.1 Properties of SS304L and SS316L ................................................................... 6 Table 3.2-1 Primary Stress Limits ...................................................................................... 10 Table 3.2-2 ASME Code Section III Load Combinations .................................................... 10 Table 6-1 Damping Ratio Effect on Nominal FIV Stress Intensities .............................. 27 Table 6-2 FIV Stress Intensities with Time Step Variation .............................................. 28 ii

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION Table 6-3 FIV Stress Intensities with Time Step Variation and Uncertainty .................. 30 Table 6-4 ASME Load Combination Results ................................................................... 32 Table A-1 Steam Dryer Pressure Differentials for Normal Conditions at EPU ............ A-1 Table A-2 Dryer Delta-P for EPU (( 1]Upset Conditions .......................... A-2 Table A-3 Maximum TSV (( )) Load on the Dryer Face at EPU ...................... A-2 Table A-4 Maximum MSL Break (( 1]Load on the Dryer Face at EPU ........... A-4 iii

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION Acronyms and Abbreviations

,itemlfý::4 4th Decpto H.' t 1 ACM Acoustic Circuit Model 2 ACA Acoustic Circuit Analysis 3 ASME American Society of Mechanical Engineers 4 BWR Boiling Water Reactor 5 CDI Continuum Dgnamics, Inc.

6 EPU Extended Power Uprate 7 CFD Computational Fluid Dynamics 8 FEA Finite Element Analysis 9 FEM Finite Element Model 10 FFT Fast Fourier Transform 11 FIV Flow Induced Vibration 12 GE General Electric 13 GENE General Electric Nuclear Energy 14 Hz Hertz 15 ksi Thousand pounds per square inch 16 LES Large Eddy Simulation 17 Mlbm/hr Million pounds mass per hour 18 MS Main Steam 19 MSL Main Steam Line 20 MWth Megawatt Thermal 21 NA Not Applicable 22 NRC Nuclear Regulatory Commission 23 OBE Operational Basis Earthquake 24 OLTP Original Licensed Thermal Power 25 Pb Primary Bending Stress 26 Pm Primary Membrane Stress 27 PSD Power Spectral Density 28 psi Pounds per square inch 29 RAI Request for Additional Information 30 Ref. Reference 31 RMS Root-Mean-Squared 32 RPV Reactor Pressure Vessel 33 Salt Alternating Stress Intensity 34 SCF Stress Concentration Factor iv

GE-N E-0000-0054-13 78N P-RO GE PROPRIETARY INFORMATION Itemn short Form,:` .Description

....- r 35 SDMP Steam Dryer Monitoring Plan 36 S.I. Stress Intensity 37 SIL Service Information Letter 38 SRSS Square RootSum of Squares 39 SRV Safety Relief Valve 40 SS Stainless Steel 41 SSE Safe Shutdown Earthquake 42 Su Ultimate Strength 43 TSV Turbine Stop Valve 44 WNPS Vermont Yankee Nuclear Power Station 45 UF Undersize Factor v

GE-N E-0000-0054-1378 NP-RO GE PROPRIETARY INFORMATION 1.0 Executive Summary This report provides the results of Finite Element Analysis (FEA) of the modified Vermont Yankee Nuclear Power Station (VYNPS) steam dryer. The analyses consisted of dynamic time-history analyses that used two sources for the fluctuating loads that impact the steam dryer at 120% Extended Power Uprate (EPU) operating conditions.

These fluctuating load definitions are from an Acoustic Circuit Analysis (ACA) that used in-plant measurements from the VYNPS steam lines and from a Computation Fluid Dynamics (CFD) Large Eddy Simulation (LES) model for vortex shedding. In addition, ASME-based load cases were also applied to the finite element model.

The VYNPS acoustic circuit model was developed based on plant design/operation configuration and used VYNPS-specific measured pressure fluctuation data as input.

The LES model characterizes the nature and magnitude of unsteady flow effects across the face of the dryer at the entrance to the main steam line nozzles. Each model generated time history pressure profiles that were input to the ANSYS finite element program to determine associated FIV stress intensities.

Maximum acoustic pressure stresses and vortex shedding stress intensities were extracted from separate finite element analyses. The stress intensities were conservatively combined and, where appropriate, multiplied by stress concentration factors that account for weld shape and size. The time history analyses were done with varying time step changes to conservatively account for uncertainty in the frequency content of the FIV loads.

The resulting maximum FIV stress intensities calculated for EPU conditions, including uncertainties and biases, were about 54% of the 13,600 psi ASME endurance limit. In addition, normal, upset and faulted stresses were calculated and compared to ASME Code allowable, with all conditions showing acceptable stresses.

1 of 40

GE-N E-0000-0054-1378N P-R0 GE PROPRIETARY INFORMATION 2.0 Background and Introduction As a result of significant steam dryer cover plate fatigue cracking at Quad Cities Unit

2. GE issued SIL 644 in August of 2002 to provide information to all BWR utilities on cover plate related failures. In September of 2003, GE added Supplement 1 to SIL No.

644 in order to describe additional steam dryer fatigue cracking at Quad Cities 2, and to explain that the root cause of the second event was different than the first. SIL 644 applied to BWR/3-style steam dryer design plants. Supplement 1 to SIL No. 644 provided recommendations applicable to plants with BWR/4 and later design steam dryers. The objective of this report is to detail the latest analyses of the Vermont Yankee Nuclear Power Station (VYNPS) steam dryer that were performed for the modified dryer configuration. The purpose of these analyses is to confirm that the modified dryer meets ASME criteria for fatigue initiation and other ASME-based acceptance criteria concerning the ability of the steam dryer to maintain structural integrity under steady-state normal, transient upset, and design basis accident loading conditions.

The VYNPS steam dryer modifications were installed in early 2004 and included replacing the 1/2 inch outer vertical plates and portions of the top hood plates with 1-inch plates, removing internal brackets that attached the internal braces to the outer hood plates, replacing the 1/4 inch thick cover plate with 5/8 inch thick material, and adding three long gussets at the outer vertical hood plate and cover plate junction.

Each gusset is triangular in shape, 53 inches high, with no more than 1.0-inch width at the top. The top of each gusset is welded around and has a smooth transition to the modified front hood. Each gusset extends to within 5.5 inches of the top of the modified front hood. Transition between each gusset and the modified lower cover plate is accomplished via the use of a U-shaped "gusset extension", also called a "shoe", that is welded to both the lower cover plate and to each gusset. The replacement lower cover plate is attached with 1/2-inch welds all around except for the corner intersection with the dryer support ring where 5/8-inch welds are used for a distance of four inches. The existing tie-bars are replaced with a modified tie bar design. Figures 2-1 and 2-2 show the modified dryer configuration.

The original VYNPS dryer assembly was manufactured from solution heat-treated SS304 conforming to applicable ASTM standards at the time of manufacture. The modification plate is made from SS316L. Minimum of SS304L and 316L properties from [71 are used for steam dryer structural analysis to conservatively envelop the properties of the unmodified components and the modification plate. In actuality the 2 of 40

GE-N E-0000-0054-13 78N P-RO GE PROPRIETARY INFORMATION stress intensity limit, Sm. of SS304 is slightly greater than SS304L1 . Therefore the use of SS304L material properties for unmodified dryer components is conservative. The applicable properties are shown in Table 2-1.

The Nuclear Regulatory Commission (NRC) safety evaluation report [12] for approval of the WNPS EPU licensing amendment request included licensing commitments by Entergy for EPU power ascension data gathering in order to determine the increase in acoustic fluctuating loading on the steam dryer. Specifically, the VYNPS EPU safety evaluation commitment is as follows: "After reaching 120% of OLTP, Entergy Nuclear Operations, Inc. shall obtain measurements from the MSL strain gages and establish the steam dryer flow-induced vibration load fatigue margin for the facility, update the dryer stress report, and re-establish the steam dryer monitoring plan (SDMP) limit curve with the updated ACM load definition and revised instrument uncertainty, which will be provided to the NRC staff."

This report updates the Reference [1] steam dryer structural evaluation that was supplemented by additional Entergy submittals to the NRC [2][3] in response to requests for additional information (RAls) during the NRC review of the VYNPS EPU licensing amendment request.

'The ASME code 1971 and 1989 editions have the following material properties for SS304:

ASME 1971 - Sm = 17.4 ksi at 500'F, Sm = 16.4 ksi at 600°F ASME 1989 - Sm = 17.5 ksi at 500'F, Sm = 16.4 ksi at 600'F 3 of 40

GE-N E-0000-0054-13 78N P-RO GE PROPRIETARY INFORMATION Figure 2-1 Modified Dryer 4 of 40

GE-NE-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION

(( ))

Figure 2-2 Modification Details 5 of 40

GE-N E-0000-0054-13 78N P-RO GE PROPRIETARY INFORMATION Table 2.1 Properties of SS304L and SS316L tem perature 0...

MaterialtP- 70F ~ ~ 4?

SS304L Sm, Stress intensity limit, psi 16.700 14,400 S., Yield strength, psi 25,000 15,940 S., Ultimate strength, psi 70,000 57,200 Soat, Endurance limit, psi 13,600 E,Elastic modulus, psi 28,300,000 25,575,000 SS316L Sm. Stress intensity limit, psi 16.700 13,995 S., Yield strength, psi 25,000 15,495 Su, Ultimate strength, psi 70,000 61,600 Salt, Endurance limit, psi 13,600 E, Elastic modulus, psi 28,300,000 25,575,000 6 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION 3.0 Acceptance Criteria 3.1 Original Steam Dryer Design Acceptance Criteria The VYNPS steam dryer was originally procured and supplied as a non-safety related, non-seismic category I, non-ASME component. There was no design specification for the dryer and, as such, the service conditions for the steam dryer were not specifically defined. However, as late as 1969, an internal GE design report, 257HA760, was prepared for BWR-3 style steam dryers. In the 257HA760 report the following service condition and acceptance criterion were stated:

" The principal design loads considered in the analysis of the steam dryer assembly are the weight loads and the pressure loads, which are present during accident conditions.

" In the event of a guillotine steam line break outside the drywell, dryer design must preclude the possibility of dryer debris entering the steam line and interfering with isolation valve closure.

" The structural elements, which hold the dryer in place, are designed to accommodate the pressure loading due to a break outside the isolation valves within the ASME Code,Section III stress criteria. The flat panels, which form partitions in the dryer, are designed so that the elastic collapse loading on these panels is not exceeded under these same pressure loadings.

3.2 Acceptance Criteria for Modified Steam Dryer at EPU Conditions The original steam dryer acceptance criteria continue as design bases for the modified VYNPS steam dryer at EPU conditions. The VYNPS steam dryer design basis continues to be structural integrity after a steam line break outside of containment.

However, due to the operating experience related to steam dryer structural integrity associated with normal operation, specific emphasis has been placed in the analysis for EPU conditions to ensure that fatigue failure does not occur that could cause a loss of steam dryer structural integrity. In addition, this analysis includes Normal and Upset case loading combinations, using ASME Code,Section III stress criteria.

Analysis of Normal and Upset cases addresses the concern that frequent and moderately frequent events which do not require an immediate inspection of the dryer should not degrade the dryer condition to the point that it might not meet its faulted condition design criteria.

7 of 40

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION 3.2.1 Fatigue Criteria The fatigue evaluation consists of calculating the alternating stress intensity from flow induced vibration (Fly) loading in the steam dryer structure and comparing it to the allowable fatigue design threshold stress intensity. The fatigue threshold stress intensity from ASME Code Curve C is. 13,600 psi. The fatigue design criteria for the dryer is based on Figure 1-9.2.2 of ASME Section III [7], which provides the fatigue threshold values for use in the evaluation of stainless steels. ASME Code fatigue Curve C assumes a mean stress equal to the material yield strength. The shell finite element model of the full dryer is not refined enough to predict the full stress concentrations in the welds. Therefore, additional weld factors are applied to the maximum stress intensities obtained from the shell finite element time history analyses at weld locations [13]. A key component of the fatigue alternating stress calculation at a location is the appropriate value of the stress concentration factor (SCFR. The stress intensities with the applied weld factors are then compared to the fatigue criteria given above.

3.2.2 Acceptance Criteria for Normal, Upset and Faulted Conditions The analysis uses the ASME Code [8] as a design guide although the dryer is not an ASME Code component. Specifically, structural adequacy for Service Level A and B loads is investigated using the corresponding stress limits of [8] with the exception of application of the weld quality factors. Weld quality factors are described in the ASME code Table NG-3352-1 for safety components, such as the reactor pressure vessel, that contain radioactive fluid. Because the steam dryer is not a safety-related pressure retaining component ((

1] In addition, inspection of the VYNPS steam dryer modification after 18-months of in-service operation showed no degradation of the modification welds. The requirement of 'no loose parts' during Service Level D events is investigated using stress limits of Subsection NG and Appendix F of the ASME Code

[9]. The stress limits are summarized in Table 3.2-1. (Note that for completeness, application of the seismic loading in the (( 1]direction is considered).

Table 3.2-2 shows the ASME Code Section III load combinations used in the VYNPS steam dryer primary stress evaluation. The ((

i term 8 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION in load cases 4 and 5 (Levels B3 and B4). The ((

)) load cases 6 and 7 (Levels B5 and B6). The faulted condition [R

)) term in load cases 8 and 9 (Levels D1 and D2). ((

))term in load cases 10 and 11 (Levels D3 and D4). ((

1]

9 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION Table 3.2-1 Primary Stress Limits

i,.k Service level cator iStress . Stress lmt .

Service levels A & B Pm Sm Pm + Pb 1.5 Sm Service level D Pm min (2.4Sm, 0.7Su)

Pm + Pb min (3.6Sm, 1.05Su)

Pm: Primary membrane stress intensity Pb: Primary bending stress intensity Sm: Stress intensity limit Su: Ultimate strength Table 3.2-2 ASME Code Section III Load Combinations Case Service Level Load Combination 1 Level A [R 2 Level B 1 3 Level B 2 4 Level B 3 5 Level B 4 6 Level B 5 7 Level B 6 8 Level D 1 9 Level D 2 10 Level D 3 11 Level D 4

)))

10 of 40

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION 4.0 Inputs This section describes the key inputs that are used for the steam dryer structural analysis.

4.1 Operation Pressure Loading The flow-induced vibration (FIV) loading as a result of the passage of steam through the steam dryer vane banks is a significant cyclic loading that has the potential to initiate and grow fatigue cracking. This FIV loading in the form of distributed fluctuating pressures is highly complex in that it varies as a function of the location and phasing, and has complex frequency content. The FIV pressure loading was calculated from two sources: (1) Acoustic Circuit Modeling, and (2) Large Eddy Simulation (LES).

4.1.1 Acoustic Pressures The acoustic circuit based pressure fluctuations were developed by Continuum Dynamics Inc. (CDI) [4] and supplied by Entergy as input to GE. The acoustic circuit model for the VYNPS steam path (i.e., steam dome, dryer and the steam lines) was developed by CDI and used VYNPS-specific measured pressure fluctuation data as input. The acoustic circuit based pressure fluctuations, used in this analysis, were determined by the measurement of VYNPS main steam line piping strains at the steam flow associated with the EPU power level of 1912 megawatt thermal (MWth).

Evaluation of the in-plant acoustic pressure data by Entergy showed important acoustic loading frequency content at 77, 82, 137, and 143.5 Hz. The ACA model conservatively produces additional loads at 102, 115, and 155 Hz. These loads are at frequencies where there is little or no acoustic signal in the steam lines. Entergy and CDI have indicated that loads at these frequencies are conservative and could be reduced. However, the load definition used in this analysis [41 conservatively did not perform any filtering or reduction of the loading at 102, 115, and 155 Hz.

4.1.2 Vortex Shedding Pressures and Stress Intensities The large eddy simulation (LES) model and determination of unsteady vortex shedding pressures using computational fluid dynamics (CFD) on the VYNPS modified steam dryer at EPU operating conditions are documented in [51. Determination of the stress intensities with the application of the vortex shedding pressures was performed by Entergy and was documented in [2]. This stress calculation was performed using an ANSYS finite element model of the VYNPS modified steam dryer upper structure without inclusion of the steam dryer skirt. As stated in (3], inclusion of the dryer skirt in the ANSYS model would reduce the governing outer hood stress intensities since including the dryer skirt in the FEA model raises the dryer model fundamental frequency away from alignment with the CFD load frequency of 62 Hz.

11 of 40

GE-NE-0000-0054-1378NP-R0 GE PROPRIETARY INFORMATION Therefore, for this analysis, the conservative CFD load stress intensities from [21 are used in combination with the FIV stresses calculated in this analysis using the VYNPS EPU operating condition acoustic loads.

4.1.3 Seismic Loading The seismic loads for the Operational Basis Earthquake (OBE) and the Safe Shutdown Earthquake (SSE) on the VYNPS dryer are documented in [10]. These seismic loads are unchanged with EPU. The accelerations are listed below.

1]

4.1.4 Steady State, Upset Transient, and Faulted Condition Loads The other normal operating (steady state), transient and faulted pressure loadings on the dryer components for the ASME Code Section III Load Combination evaluations are described for EPU conditions in Appendix A.

4.1.5 Uncertainty and Bias for FIV Loads The uncertainties and Biases associated with the acoustic circuit analysis (ACA) and CFD (vortex shedding pressures) analysis as applied to the VYNPS EPU steam dryer structural analysis were provided by Entergy [6]. They are listed below:

ACA Bias - Twenty-Seven Percent (27%)

ACA Uncertainty - Twenty Percent (20%)

CFD Uncertainty - Sixteen Percent (16%)

5.0 Steam Dryer Model and Analgsis 5.1 Steam Dryer Finite Element Model The ANSYS finite element model is a full dryer model, as shown in Figures 5-1 through 5-3, which incorporates the modifications made to the VYNPS dryer in 2004. The model is primarily composed of shell elements since the physical dryer construction is mostly plate. The dryer support ring and dryer crossbeams are modeled as solid elements. The dryer modification gusset shoes, part of the front hood gusset and the gusset to cover plate weld and gusset shoe to gusset weld are also modeled as solid elements. Since the lower third of the dryer skirt is submerged under water, the 12 of 40

GE-N E-0000-0054-1378N P-R0 GE PROPRIETARY INFORMATION water mass in this region is modeled as a super-element using ANSYS Fluid-80 elements.

5.2 Mode Shapes of FEA Model Frequency calculations were performed using the ANSYS 8.1 finite element analysis program in order to determine the significant mode shapes of the steam dryer model. The steam dryer has 390 modes between zero and 200 Hertz. However, the majority of these 390 modes are either due to dryer skirt modes, or modes associated with the steam dryer baffle plates. The first skirt mode occurs at approximately 5 Hz with subsequent modes about every 1 Hertz. The baffle plate first mode occurs at 19.5 Hz. The dryer front (outer) hood first frequency occurs at approximately 83 Hz. Other mode significant mode shapes between 0-200 Hz for the dryer front hoods are shown in Figure 5-4 5.3 Structural Damping for Finite Element Analysis Due to the use of super-elements in the VYNPS steam dryer model, the direct integration solution method in ANSYS must be used. Previous time-history analyses of the VYNPS steam dryer without the super-elements were performed under modal superposition using a constant one-percent of critical damping.

Previous time-history analyses using direct integration [2][3] used Rayleigh damping constants of: Alpha = 2.0106, Beta = 0.00003183. These constants provide 1%

damping at 20 and 80 Hertz. At 150 Hertz, the damping is 1.5%.

In order to provide an additional degree of conservatism in the dryer structural analysis with the ACM loads at EPU conditions, Rayleigh damping constants of: Alpha

= 2.2176, Beta = 0.00001872 are used in the direct integration solution. These constants provide 1% damping at 20 and 150 Hertz. Figure 5-5 shows the effect of damping constants on the damping ratio.

5.4 Application of Acoustic Pressure Loading to FEA Model The ACM data set for the EPU transient analysis consists of 2.5 seconds of data at a sampling frequency of 4096 hertz. This quantity of data would make the finite element analysis run times on the order of several weeks using super-computing resources and would produce result files on the order of several terabytes. Therefore, a resompling routine was developed to remove the last 0.5 seconds of data and downsample the resultant data to 1200 hertz. This results in 2400 load steps of data applied to the finite element analysis. Verification of this process confirmed that all frequency content of the loading was preserved and that there was no aliasing of the 13 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION data. A GE developed ANSYS macro is used to translate the resampled ACM pressures into input pressures for the GE ANSYS finite element model.

5.5 Time History FIV Analysis The stress analysis is performed using the direct integration routine of the ANSYS finite element code Version 8.1 (11]. The nominal time step value used in the analysis is 0.000833 second. Two sets of analyses are performed using this nominal time step, one with Rayleigh damping of 1% at 20 and 80 Hz and a second analysis with Rayleigh damping of 1% at 20 and 150 Hz. The purpose of these comparative runs is to determine the effect of using more conservative damping parameters on the stress analysis.

It is an accepted engineering practice to assess the sensitivity of the calculated stresses to such factors as differences in modal frequency due to geometric and material variations, random variations in pressure time history, etc. A sensitivity assessment is conducted by varying the time interval between the pressure time steps by +/- 10%. This is equivalent to peak broadening in the response spectrum analysis method. The 10% variation is judged to be a reasonable value to capture instances where a structural mode that contributes significant response may have its frequency very close to any one of the frequencies present in the fluctuating pressure time history. To further study the sensitivity of the stress analysis due to a shift in the time step, additional analyses are performed using time shifts of +/- 2.5%

and +/- 5%. All of the sensitivity analyses are performed with conservative Rayleigh damping constants of Alpha = 2.2176, Beta = 0.00001872 (damping of 1% at 20 and 150 Hz.)

5.6 FIV Stress Determination The FIV stress intensities are taken as a combination of the acoustic and vortex shedding contributions. The acoustic pressure FEA results for each dryer component of interest are screened for the maximum stress intensity throughout the 2400 time steps. The search routine finds the maximum surface stress intensity of the component top and bottom surface. The larger of the top or bottom surface stress intensity is conservatively used as the acoustic contribution to the FIV stress amplitude.

The stress intensity from the acoustic pressure analysis is multiplied by the bias term of the ACA (Section 4.1.5) and then combined with the maximum stress range from 14 of 40

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION the vortex shedding pressure analysis via the square root of the sum of the squares (SRSS) method.

5.7 Weld Stress Concentration Factors and Weld Undersized Factors The following stress concentration factors (SCFs) are used in this evaluation: fillet weld, 1.8; butt weld, 1.4. These SCFs were applied to the calculated peak stresses from the finite element analyses. The use of peak stress to multiply with SCFs provides alternating stresses at welds consistent with recommended SCFs in the ASME Code. The technical basis for these values is provided in [13].

The calculation of the stress concentration factor to account for undersized welds is the square of the ratio of plate thickness to the weld size. For example, in the modified dryer stress analysis, a 1/2--inch fillet weld is used for the 5/8- inch thick lower cover plate; the stress factor to convert the plate stress to the fillet weld stress is (0.625/0.500)2 = 1.56.

5.8 Calculation of FIV Stress Intensity The equation for the calculation of the FIV stress intensity, that includes the ACA bias term, but does not include the uncertainty terms of either the ACA or the CFD analysis is as follows:

FIV Stress Intensity = V((1 + ACA Bias) x ACA S.I.)2 + (CFD S.I.)2 x Weld SCF x Weld UF Where ACA Bias = ACA Bias Term ACA S.I. = Stress Intensity for component from FEA analysis using ACA Loads CFD S. I.= Stress Intensity for component from FEA analysis using CFD Loads Weld SCF = Weld Stress Concentration Factor Weld UF = Weld Undersize Factor 15 of 40

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION I Hood Top Plates i Steam Dam Front Hood with Gusset Modification Dryer Support Ring SDryer Skirt Water Super-element Figure 5-1 Modified Full Dryer Analysis Model 16 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION I'

Figure 5-2 Details of Analysis Model Showing Front Hood, Support Ring and Skirt 17 of 40

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION Figure 5-3 Details of Analysis Model Showing Front Hood Gussets 18 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION

.1 Mode7 ý 120fir w t-U.XTLý Hz, - Mode14-.D145To9 tt- Hz 45, - 114JVi1iU Mode 120 - 82.9 Hz Mode 145 - 94.9 Hz all Xt=t YWr. Myer. 1g.rr~ii Abi - 05.4=16)3 M 154rode t 134.

Hz 11%7ifl Model128 -85.4 Hz Mode 154 - 97.7 Hz Figure 5-4 FEA Model Mode Shapes for Outer Dryer Hood 19 of 40

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION Ing Am Mode 1lf- D-Mye. 113. Hzfrwry - 17.147774 Mode 167 - 102.2 Hz Mode 193 - 117.7 Hz k

7-V:wrt Ywyne cryer,f tie T n m, -]o!.'*

Mode 226 - 135.1 Hz Mode 175 - 107.7 Hz Figure 5-4 FEA Model Mode Shapes for Outer Dryer Hood 20 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION Mode 240 rye. - 240, 1 Twj 5 - 42.74M3 'M'od eZ -1553.2.

e,ty k5o tr,.Wj -265 3 Mode 240 - 142.7 Hz Mode 265 - 153.2 Hz r

%61trrxt Y.al rmr SI. yr. - JAU4 Mode 261 -151 Hz Mode 286 - 166.4 Hz Figure 5-4 FEA Model Mode Shapes for Outer Dryer Hood 21 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION

-m-U 162 M e-zalYwrae Dryer. I fr w~zy -

-M. Hzi' vModteYvY opr, ma rn,

- 87.Hz -

Mode 291 - 168.4 Hz Mode 351 - 187.8 Hz hg6l ý11ý§L Mjod 32r - 17ý WV, f.5rwy- -Hz Mode 322 - 178.5 Hz Mode 355 - 189.1 Hz Figure 5-4 FEA Model Mode Shapes for Outer Dryer Hood 22 of 40

GE-N E-OO0O-0054-1378N P-RO GE PROPRIETARY INFORMATION 5.0% -

4.5%

4.0%

F , _ _ I _ _I_

3.5% - _ _ _ i I 0 3.0%

ES2.5%-

E

" 2.0% II 1.5%

1.0%

0,0% ,

0 20 40 60 80 I00 120 140 160 180 200 frequency (Hz)

I- Damping Ratio VYAnalysis - 1% (20 to 80 Hz) - Damping Ratio VYAnalysis - 1% (20 to 150 Hz) I Figure 5-5 Rayleigh Damping 23 of 40

GE-N E-0000-0054-1378N P-R0 GE PROPRIETARY INFORMATION 6.0 Modified Dryer Analysis Results 6.1 Evaluation of Flow Induced Vibration Stress Intensities Table 6-1 shows the comparison of the nominal time step analysis with a variation in the Rayleigh damping constants. As expected, the use of the more conservative damping constants results in an increase in the stress intensity for each component.

Observation of Table 6-1 shows that the average stress intensity increase is 16% with the largest increase of approximately 30% in the skirt region. In order to more fully study the effect of the Rayleigh damping constants, time-history data was extracted from the nominal FEA stress result analysis files, nominal case with 1% damping at 20-80 Hz and 1%damping at 20-150 Hz, for the modification gusset shoe (Group 27).

Figures 6-1 and 6-2 provide a comparison of the stress result power spectral density (PSD) and the stress result spectrum. As seen in Figures 6-1 and Figures 6-2, the key frequency contributors to the increase in stress intensity with the more conservative damping constants are at 74.5 Hz and 135 Hz. Other frequencies show smaller stress intensity changes in this comparison.

Table 6-2 shows the results of the nominal and time-step variation cases with all analyses performed with conservative Rayleigh damping constants of 1% damping at 20 and 150 Hz. The stress intensity tabulations in Table 6-2 include the ACA bias term but do not include ACA or CFD uncertainties. The results of these studies show that the maximum percentage variation for ACA load input, maximum stress intensity for all time steps versus nominal time step stress intensity, is 44% and occurs for the hood partition plates, Group 16. The hood partition plates are lightly stressed components and have a FIV stress intensity at EPU condition of approximately 10%

of the allowable endurance limit. -For the components that experience the highest stress intensities at EPU conditions, the percentage variation between the nominal and time step variation maximum stress intensities for the ACA load input is as follows:

Gusset Shoes 4% -10% time shift Lower Cover plate 25% -10% time shift Outer hood plates 7% +5%time shift Skirt Components 20% +5%time shift The dryer component with the highest stress intensity for all time-step variations is the modified top hood with a peak FIV stress intensity of 6,668 psi. This stress 24 of 40

GE-N E-0000-0054-13 78N P-R0 GE PROPRIETARY INFORMATION intensity is approximately 50% of the FIV stress intensity acceptance criterion of 13,600 psi. Due to the large margins remaining to the acceptance criterion for FIV, it is concluded that the time step variations applied to the WNPS dryer analysis are acceptable to show that no resonance peaks are expected that would result in further large increases in FIV stresses.

6.1.1 FIV stress results with Uncertainties The equation for the calculation of the FIV stress intensity, that includes the ACA bias term and the uncertainty terms of the ACA and the CFD analysis is as follows:

FIV Stress Intensity = V((l + ACA Bias + ACAU) x ACA S.I.)2 + (CFDU x CFD S.I.)2 x Weld SCF x Weld UF Where ACA Bias = ACA Bias Term ACAU = ACA Uncertainty ACA S.I. = Stress Intensity for component from FEA analysis using ACA Loads CFDU = CFD Uncertainty CFD S. I. = Stress Intensity for component from FEA analysis using CFD Loads Weld SCF = Weld Stress Concentration Factor Weld UF = Weld Undersize Factor Table 6.4 shows the stress intensities for all components with ACA Bias, ACA uncertainty and CFD uncertainty included. The components with the highest peak stress intensity at EPU conditions is the modified top hood (Group 5) with a peak stress intensity of 7406 psi for the case run with a plus 10% time shift. This peak stress intensity is approximately 54% of the ASME design allowable endurance limit of 13,600 psi. The modification gusset shoe (Group 27) has a peak stress intensity of 7282 psi for the case run with a minus 10% time shift. This peak stress intensity is also approximately 54% of the ASME design allowable endurance limit of 13,600 psi.

6.2 Evaluation of Primary Stresses under ASME Code Section III Loads Each of the load combination tabulated in Table 3.2-2 has been analyzed for the modified dryer in (1]. The nominal surface stress intensity at EPU conditions with the inclusion of ACA bias, ACA uncertainty and CFD uncertainty is conservatively used as 25 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION the flow-induced vibration contribution for each load combination even though the FIV surface stress intensity includes secondary stresses. Inthe ASME Code Section III load analysis, the dynamic loads, such as OBE, SSE and TSV loads should be combined by square root of the sum of the square (SRSS). This analysis combined the dynamic loads by algebraic sum. Because the OBE and SSE have been input in both the positive and negative directions and both results are compared with the allowable limits, the results are equivalent to absolute sum results. Therefore, the load combinations are conservative. The TSV and MSL Break pressure ((

)) in the input for ANSYS analyses.

Table 6.4 tabulates the stresses for each weld with the undersize weld factor included. For Service Levels A and B, the maximum stress ratio is 0.827, at the modification gusset, due to the Service Level B-3 load combination. For Service D the maximum stress ratio is 1.003, at the modification gusset due to the Service Level D-4 load combination. ((

)) Therefore, the component is considered acceptable.

26 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION I..............

S, fI 1%R.I.igh 11itR.I.sgh R..h.dRing edSolidModolhn- 1912 :MWthLo.d. 1201%OLTp Damping (20 -[Dlspang I g (20.

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fpto....ing io..ntity ottonoity SheddmngM o Weld Plot. Intonoity. Intensity.

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Otp inta st. tnt.n.ity P.0-Factor S.. *it* p5606 ector 20-80H.20-10H. ...Tome Stop .... Tm Step itort-.talaI.Sei Macotto 6.225 6-623 I

~ Inn., hood base plot.

16635 1973 624 1 ito 0.500 0.5m 1000 3.962 4.6 Modfdld owt.r so.et pito.31*9.

6 2 othtip.4" 1413 1810 437 180 0625 0625 I.000 3.325 4,212 Modified otr., -o-a plit.,

3 -bd .tltttip. 2095 2482 439 00 0 625 0 625_ 100 2.697 3.183 S W*eld lIt. outr co.0- plot.

32 .... ,*xclude tip. to Suppowt rinsg 1114 1297 439 1.80 0 623 0 50 I 543 k166 C794 Ongutnal top hood (o11 hood) 4 722 rm70 943 ISO o'". 0 50 1 100 2,368 2.615

.5

.. ~Moddted Lop hood (out.r hood) 604 717 Ir112 ISO IW 0623 2.360 d.223 6.623 S Hood top plat..(loter hood) 6 1328 1536 1-064 . 0 0300 &500 I.0.0 3.624 3,f 0ýý.l out- Hood. tp.

7 1 1300 U10 10 050 0500 V000 2,M 2.978 Moddil.d ovt., hood¢ top wold 8 612 703 301 180 100 0623 2360 3.841 4.342 0lt Moddlod outer hood. bottouaweld 9 608 699 7235 180 100 I.00O 1 0ow 1.9M 2..3 Hood andco plato. (ootor hood) 10 ______812 1018 761 164 05 0 0 300 I~O* 174 r till lIIl Hoodsndplat...(hrsos*ohoo¢d)

I1 646 752 336 1.8 050 03 00 100 IS 1.764 1971 I Cl S Hood and plate. (outer hood) 12 1241 1498 322 ISO 020 0,500 1000 2,9" 3.473 13 *

od314 122 537 10 0 050 0500 10 20R8 2.427 14 487 578 807 180 050 0300 1000 18m0 1.964 135 to.- ae gu .. i. t54 791 941 IS0 050 0a500 1.000 2 259 2478 Other Ploto.

Hood poctition plate-16 294 363 94 18 030 0.300 1000 693 847 17 M -g S.MS. plot.. 1183 1432 1.144 1.80 050 0.5w 3.00 1 23" 38S67 is o____702 864 . I..7Ml8 180 020 0300 1000 w 3763 3"3*

Ro*m. Ber. AG-..4.

19 y47p 397 673 1.80 300 3000 1000 1,630 1,10 20 363 407 135 1.80 300 3 000 I 8DD S65 962 ute.To. Cro.. bea- g ... t.

21 1546 1743 414 1SO 050 000 I 000 3_612 4,054 Gets fr *ter C-rplaht.a.

fi O.r.od h..

22 2234 2662 W2 100 0300 0.500 1 000 2.953 3479 C .o.tsolid to guso.tlabel 23 lsition 1333 1593 I 00 000 0300 I 1.762 2.084

% Solid Ou...t h.o..

27 4018 4762 490 1o0 0500 0.

0 _I 000 5.126 6.068

% Ostet shoe0 weld to cover plate 28 ___.._th..____to _.1_lot 1930 2312 490 It0 0.00 0300 10 C5404 5,332

% Shoo weld to solid gu..o 29

2026 2400 490 ISO 0500 0300 100 A.715 5.557 30 S,,olid p.4t ocyu ... 1783 2119 490 I 00 0300 0 300 I 000 2.319 2.735 III Outr Hood Cus.. ot. wld line to 31 &ont hood 925 1076 82C I 8o 0 3W 07*0 I O 2 79 28-69 Skit A-24 1051 1345 0 1 40 030 0500 1,000 1,869 2.91 l I Dr.in B* a.(. Ch.1-,l.)

23 __6 876 0 I 40 0500 0500 1 000 I 1 1,.58 26 j hd. Rod andi 0-I" upper.Lug 2h6ete. 695 "64 0 140 0 5M 0373 1778 2,1-"

Table 6-1 Damping Ratio Effect on Nominal FIV Stress Intensities 27 of 40

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION 88m,,W Ri.# 088,, or.8 i 1n4.1%&*11q8 18 ~(~12 1080(

Q.- I..d ip lo, 88748, Ikst A ~ l"l

%61188'871888889 1-4R8.Y8d8

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8.efl8 4 lk.89,,6 ,0818.I 1C188(6 *.44lJsly bUn.U ,, lcIi.h I - y- tlýg "" n~h 0on 'onp. 8i8 804,88..'8 8(n8'6tPy6'0. 78 .o. '. 88

,88 - 184 S,'i886 7888 '1n, 6

7N8068 rim88. 7tw808 flacp Th'.p Th~kr,8 Tim slo'8k

'8*,nn 7 6.1,62 6.627 6.568l &.11, 6.4871 6.421

______(71 8S4.4 I8I8g 1918 7 W$ 141% 811! 64 1.880 1 6.5(0) 0.9.08 80881 4.1,1 17(7l 2.1(6 48.64 4_183 1950 .6177 2N ,8hi.4* 18911 166! 8116 88(72 18(61 198(7 !214 3;7 888(8 00625 g;624 888880 8.282 3.911(l .6 1.141399 8 8.W78 :.WM84 kf_____f_

________________t."___ !498?2 7288 2571 2%69 72(771 2288 :.%m 4198 1700 182 6629 888047 1 7M.8:7 2118 J.218 .806 il.919 111182 1.07"9 22 (((8iI 97v, 88 829A5

'7 1427 81622 14708 8477 83184 11.6 419 10 0.65 .50 1.563 1 4.Q 9.lt 5924 !--.94 $.419. f4.8 0 4.142 4 1..

irigi81878I"I88 (18188 N8684, 518 71(9 882 -42 78.6 2(78 728 9873 8881 88.8 (8.50 81,00 1 U14 2.477 2. W, 2,464 !.419 1841 2866" 5 %WifldbVh___ "

__. 787 7"28 718 7(8l 661 6886 667 8812 18 1.0114 0623 21.60 6621Z 68(1,4 6112? 6.484 68107 6.424 6__________ _ 81576 88112 1872 My4 8278 8276 946 1 .1864 8-.40 0.5m9 0.9887 8081 1.117(7 1.81.1 115(7 y1889 7.589 ;2964 3.261 7____________ INA84 8772 6888 8111 962 87881 88-49 868 0 8 0 _480 6._500 8108(1 2.9's 7.8812 2.267 21(78 2.1.!3 3.87 r 2.6371 woo -k,8

__________ Vkd (3

'64ifwi fo ?7487 787 621( 774 624 v1(7 8.0 86011 0.625 2-560 8.142 48.084 4.3!8 4,144 k!.26 8.511 1*)86 98.d' 0. 6W0 656 624- 74 611f 71M 8 725 860 6*

101 0114)71 .01.0 2661 8.'87 I.81 2.01.8 2111 131 81.986 to841(888 togs88888.8d0819 888 is8 9(97 8488 907 182? 884 L68 0 047

.5" 8884 286*0 8.80 L.66. 2.0611 88162 81(93.4 8(708

_ _ _ __ _ _ _ _ 78'. 671 '2N -go 626 6.78 7008 $718 888 8878 6884 8800 18,1008 .97( 8.AM8 8.9(28 !72 8.72b 8?6J18 1.1164 Q___ 491 1__________ 8M4 1 888. 84418 88(72 7M8 875 4in 8018a 0_ .90 8 .9008118 .47, -1.57f8 2388I )-I.1 2.'8 3.672 2..72 I____

It ____ 8288 (818

['Jill;_________ 13288 819 487(7 8891 (26 571 8440 085* wl.888 801, 2.8In 2.0189 2,11084 11 2.818 r87 2264 231M 14 ______ 71 (77 W18 6809 4'1 A"4 5849 8(7 8.110 18.90 03W88 1. 1, 1.9711 .ll!

880)(188 2,082 8.1116 1.878 1.93 1.1

8,8.,,W4077 8 .7 W'8 87 6818 608 988 88W0 0."0 2.873g !.40i ? 18182 646 0180 8.88887H 2.81" 2.48 -- m0 Table 6-2 FIV Stress Intensities with Time Step Variation 28 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION 0

R.-OWI-F WWWill*1* .*.ki.** Mfo.-i %***o*

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11) 4117 431 '112 0Ih16 11 4'(* A7M 1*1 LA *01

" 1.0 140 30 *1.14 *329 8.750 0.72* '11? 1*02

,11 172 40Z.00610*8~~7 30! 197 42* 3140 1411 *10 80 1.F 30 1, Ism 10111 962 lo3 062 040o 1 01A 810 830!

21 1743 *1150 *00t It"0 I"7 *241 *067 411 8.1 0.5031 054101 1*Jos 4.0*54 4204 2640 .8.2M! 4.217 i0*1 12*13 hood 226112 2.297 260 641 21,10 :270* 2415 JIM0 Lost *0.50*1 0.001 L"4 1.474 2.921 .001 *.451 1.014 194'. 31*0 23 I 1418 *541 *575 14-1*1 *41, 1151 4"* 1010 0.4410* Aux *.* *0101 *1.1 1.040 201 2000~ 0150116* 1.9s 20

411*41 1-.lid G6sc* Oho.

Z7 11k_________ 471*2 4*92 401* 47 11 42 10 4*0415 050 00 60 608 04 6,244 00* 0'* .f80(*t 20 G___a-__o___w ____ 21*7 20%65 210K 220* N2*7 10631 z*0 4')011 1.1" 040*1 0*1 9 1*9IM *34 -4773? S412 5.11; 1491*1 47'0 4.003 29 40 21*6 NW____________ 2475 21*4 M2*7 2*7.4 2`94 140f 1.0*1 0.50 0.511,1 J10t0 $.557 4902 0722 51031 0*144 *0057 501

.1 IWWIsms r("~_______ 2*14 1370 i*0 2003 19N 101)1 *047 490 t*0. 0.5*0* 000* 010 7* 2.41* 1,11 *5 2*2 24s. 1571*

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24 Skid __________ 1144 111M 121-1 13V2 144.1 *0*2 *5*2 0 1.4*) 0.5401 0,91* 1*001 !.19* 2.061 116 '147 2 27%2*0 25 1W. ____- ____________ 76 744 3*7 91t2 (** *4* 70 1.30 6.04*1 0.5W0 I.** 80'8t 0.21 1.506 18710

00

08

0

464 (0*55*01**172 Zo.4 -1 Table 6-2 FIV Stress Intensities with Time Step Variation 29 of 40

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION R,4344.hp 44d941.

Asd1 t- 14 11iM 41 I

________49I 44 111 44I43 144 34 I'd,4 45()* 46IIO. 314 4.6 .26 .. 4 .64 4.4 .442 44-

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It ld 4414.41444((4 44 I."40 112 624 Ill4 kA4 7111 1114 JON I 441 a." 44.-A 44(IM 2126 1,2. 10 1.6 1.4164 .4 .(4 .4

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i' I I U.1 1.9111.169 Y% 2.41 Ir 43p 24 4 I44m34 444 44s 441 424. 17vi4 0.54 0-M6 1444 2.734 2-44442.841 2."(124' 2.4 .441. 2.74' 21%

441~34 %97 i4.4 944' 464 446 34 '44 I 4 "44 " Od6. L.11 1111 2.4 2"i3 2,1462 2.214 -2.,444 J -,or! 2.431 47 43! I ýV It 4443 I"4 614 W47 647 4.44_I .4.6 2.1:(4

".(1.. 1.4 0.3" 4416M 2.7%6 70410 1 2 ý4 142.411 .3",7 ' 12Y27 Table 6-3 FIV Stress Intensities with Time Step Variation and Uncertainty 30 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION 6

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11. ~ ~ '.ddie1.

________,g;2 212 a

Table 6-3 FIV Stress Intensities with Time Step Variation and Uncertainty 31 of 40

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION Modified dryer stresses at the outer cover 120 %OLTP plate Service Level (A) Modified Fillet (C) (E) FIV+ ASME (D)

Pm+Pb cover weld size weld FIV iPm+Pb), (Pm+Pb) Primary stress plate stress without (A+E)xlC) Allowable stress intensity thickness factor weld at weld stress ratio stress factor Level A 1 818 0.625 0.500 1.56 1973 4362 20993 0.208 Level B 1 1721 0.625 0.500 1.56 1973 5773 20993 0.275 Level B 2 1842 0.625 0.500 1.56 1973 5962 20993 0.284 Level B 3 3072 0.625 0.500 1.56 1973 7883 20993 0.376 Level B 4 2988 0.625 0.500 1.56 1973 7752 20993 0.369 Level B 5 1216 0.625 0.500 1.56 1973 4983 20993 0.237 Level B 6 878 0.625 0.500 1.56 1973 4455 20993 0.212 Level D 1 2841 0.625 0.500 1.56 0 4439 50382 0.088 Level D 2 3036 0.625 0.500 1.56 0 4744 50382 0.094 Level D 3 10279 0.625 0.500 1.56 1973 19144 50382 0.380 Level D 4 10411 0.625 0.500 1.56 1973 19351 50382 0.384 Modified dryer stress at the original front hood both side strips 120 %OLTP Service Level (A) Modified Fillet (C) (E) FIV+ ASME (D)

Pm+Pb cover weld size weld FIV (Pm+Pb). (Pm+Pb) Primary stress plate stress without (A+E)x(C) Allowable stress intensity thickness factor weld at weld stress ratio stress factor Level A 1 1831 0.500 0.500 1.00 1915 3746 20993 0.178 Level B 1 3776 0.500 0.500 1.00 1915 5691 20993 0.271 Level B 2 4069 0.500 0.500 1.00 1915 5984 20993 0.285 Level B 3 4847 0.500 0.500 1.00 1915 6762 20993 0.322 Level B 4 4544, 0.500 0.500 1.00 1915 6459 20993 0.308 Level B 5 1700 0.500 0.500 1.00 1915 3615 20993 0.172 Level B 6 1973 0.500 0.500 1.00 1915 3888 20993 0.185 Level D 1 5111 0.500 0.500 1.00 0 5111 50382 0.101 Level D 21 5588 0.500 0.500 1.00 0 5588 50382 0.111 Level D 3 172311 0.500 0.500 1.00 1915 19146 50382 0.380 Level D 4 176971 0.500 0.500 1.00 1915 19612 50382 0.389 Table 6-4 ASME Load Combination Results 32 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION Modified dryer stress at the front hood lower weld 120 %OLTP Service Level (A) Modified Fillet (C) (E) FIV+ ASME (D)

Pm+Pb cover weld size weld FIV (Pm+Pb), (Pm+Pb) Primary stress plate stress without (A+E)x(C) Allowable stress intensity thickness factor weld at weld stress ratio stress factor Level A 1 903 1.000 0.500 1.00 1328 2231 20993 0.106 Level B 1 1082 1.000 0.500 1.00 1328 2410 20993 0.115 Level B 2 1925 1.000 0.500 1.00 1328 3253 20993 0.155 Level B 3 2787 1.000 0.500 1.00 1328 4115 20993 0.196 Level B 4 2686 1.000 0.500 1.00 1328 4014 20993 0.191 Level B 5 1213 1.000 0.500 1.00 1328 2541 20993 0.121 Level B 6 964 1.000 0.500 1.00 1328 2292 20993 0.109 Level D 1 2586 1.000 0.500 1.00 0 2586 50382 0.051 Level D 2 2783 1.000 0.500 1.00 0 2783 50382 0.055 Level D 3 9024 1.000 0.500 1.00 1328 10352 50382 0.205 Level D 4 9219 1.000 0.500 1.00 1328 10547 50382 0.209 Modified dryer stress at the un-modified top hood 120 %OLTP Service Level (A) Modified Fillet (C) (E) FIV+ ASME (D)

Pm+Pb cover weld size weld FIV (Pm+Pb). (Pm+Pb) Primary stress plate stress without (A+E)x(C) Allowable stress intensity thickness factor weld at weld stress ratio stress factor Level A 1 463 0.500 0.500 1.00 1683 2146 20993 0.102 Level B 1 1041 0.500 0.500 1.00 1683 2724 20993 0.130 Level 8 2 1060 0.500 0.500 1.00 1683 2743 20993 0.131 Level B 3 1006 0.500 0.500 1.00 1683 2689 20993 0.128 Level B 4 1013 0.500 0.500 1.00 1683 2696 20993 0.128 Level B 5 640 0.500 0.500 1.00 1683 2323 20993 0.111 Level B 6 495 0.500 0.500 1.00 1683 2178 20993 0.104 Level D 1 1591 0.500 0.500 1.00 0 1591 50382 0.032 Level D 2 1624 0.500 0.500 1.00 0 1624 50382 0.032 Level D 3 2044 0.500 0.500 1.00 1683 3727 50382 0.074 Level D 4 2070 0.500 0.500 1.00 1683 3753 50382 0.074 Table 6-4 ASME Load Combination Results 33 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION Modified dryer stress at the modified top 120 %OLTP hood Service Level (A) Modified Fillet (C) (E) FIV+ ASME (D)

Pm+Pb cover weld size weld FIV (Pm+Pb). (Pm+Pb) Primary stress plate stress without (A+E)x(C) Allowable stress intensity thickness factor weld at weld stress ratio stress factor Level A 1 270 1.000 0.625 2.56 1666 4956 20993 0.236 Level B 1 584 1.000 0.625 2.56 1666 5759 20993 0.274 Level B 2 600 1.000 0.625 2.56 1666 5800 20993 0.276 Level B 3 504 1.000 0.625 2.56 1666 5555 20993 0.265 Level B 4 506 1.000 0.625 2.56 1666 5560 20993 0.265 Level B 5 307 1.000 0.625 2.56 1666 5050 20993 0.241 Level B 6 282 1.000 0.625 2.56 1666 4986 20993 0.238 Level D 1 800 1.000 0.625 2.56 0 2048 50382 0.041 Level D 2 833 1.000 0.625 2.56 0 2132 50382 0.042 Level D 3 1411 1.000 0.625 2.56 1666 7877 50382 0.156 Level D 4 1430 1.000 0.625 2.56 1666 7925 50382 0.157 Modified dryer stress at the front hood gussets shoe weld to cover plate 120 %OLTP Service Level (A) Modified Fillet (C) (E) FIV+ ASME (D)

Pm+Pb cover weld size weld FIV (Pm+Pb), (Pm+Pb) Primary stress plate stress without (A+E)x(C) Allowable stress intensity thickness factor weld at weld stress ratio stress factor Level A 1 4509 0.500 2x0.375 1.00 3446 7955 20993 0.379 Level B 1 9040 0.500 2x0.375 1.00 3446 12486 20993 0.595 Level 8 2 9505 0.500 2x0.375 1.00 3446 12951 20993 0.617 Level B 3 13921 0.500 2x0.375 1.00 3446 17367 20993 0.827 Level B 4 13455 0.500 2x0.375 1.00 3446 16901 20993 0.805 Level B 5 5146 0.500 2x0.375 1.00 3446 8592 20993 0.409 Level B 6 4711 0.500 2x0.375 1.00 3446 8157 20993 0.389 Level D 1 11598 0.500 2x0.375 1.00 0 11598 50382 0.230 Level D 2 12336 0.500 2x0.375 1.00 0 12336 50382 0.245 Level D 3 46367 0.500 2x0.375 1.00 3446 49813 50382 0.989 Level D 4 47077 0.500 2x0.375 1.00 3446 50523 50382 1.003 Table 6-4 ASME Load Combination Results 34 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION Modified dryer stress at the vertical side hood 120 %OLTP Service Level (A) Modified Fillet (C) (E) FIV+ ASME (D)

Pm+Pb cover weld size weld FIV (Pm+Pb), (Pm+Pb) Primary stress plate stress without (A+E)x( C) Allowable stress intensity thickness factor weld at weld stress ratio stress factor Level A 1 1796 0.500 0.500 1.00 2234 4030 20993 0.192 Level B 1 3577 0,500 0.500 1.00 2234 5811 20993 0.277 Level B 2 3746 0.500 0.500 1.00 2234 5980 20993 0.285 Level B 3 3499 0.500 0.500 1.00 2234 5733 20993 0.273 Level B 4 3307 0.500 0.500 1.00 2234 5541 20993 0.264 Level B 5 1497 0.500 0.500 1.00 2234 3731 20993 0.178 Level B 6 1890 0.500 0.500 1.00 2234 4124 20993 0.196 Level D 1 4247 0.500 0.500 1.00 0 4247 50382 0.084 Level D 2 4488 0.500 0.500 1.00 0 4488 50382 0.089 Level D 3 13797 0.500 0.500 1.00 2234 16031 50382 0.318 Level D 4 14106 0.500 0.500 1.00 2234 16340 50382 0.324 Table 6-4 ASME Load Combination Results 35 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION 20 40 83 100 120 143 160 160 230 300 00 . , I I 3 o00 00 Red: 1% Damping 20-80Hz 250000- -- Blue: 1% Damping 20-150Hz ii _ _

&-v- 4al-1; PSD PSIA 2/Hz innnnnOi - Il~fl~fl(~

II

,I I 0 0 20 40 60 8o 100R 120 14o 160 1;0 2;0 Frequency Hz Figure 6-1 Power Spectral Density Comparison of Nominal Case Damping 36 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION 20 40 80J 80 100 120 140 160 180 200 iI Red: 1% Damping 20-80Hz Blue: 1% Dampinq 20-150Hz Stress Intensity PSI Frequency Hz Figure 6-2 Stress Spectrum Comparison of Nominal Case Damping 37 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION 7.0 Conclusion 7.1 Fatigue Alternating Stresses The FIV alternating stresses for the modified dryer at EPU conditions are well below the endurance limit. The FlY alternating stress for the limiting dryer components with consideration of biases and uncertainties are approximately 54% of the endurance limit of 13,600 psi.

7.2 ASME Primary Stresses Evaluation The modified dryer is acceptable for meeting the ASME Code Section III, Service Level A, B, and D, primary stress criteria for all the load combinations tabulated in Table 3.2-2 using conservative methods of analysis.

The WNPS modified steam dryer is acceptable for continuous operation at Extended Power Uprate conditions.

38 of 40

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION 8.0 References

[1] GE-NE 0000-0038-0963P, Class III, DRF Section 0000-0038-0936, Vermont Yankee Nuclear Power Station Steam Dryer Stress Analysis, March 2005.

[2] Entergy letter (BVY 05-084) to NRC dated September 14, 2005, "Vermont Yankee Nuclear Power Station, Technical Specification Proposed Change No.

263, Supplement No. 33, Extended Power Uprate - Response to Request for Additional Information." - Attachment 5 - Revised Exhibit EMEB-B-143-1 (31 Entergy letter (BVY 05-084) to NRC dated September 14, 2005, "Vermont Yankee Nuclear Power Station, Technical Specification Proposed Change No.

263, Supplement No. 33, Extended Power Uprate - Response to Request for Additional Information." - Attachment 2 - Revised response to RAI EMEB-B-39, consideration of steam dryer skirt in the structural finite element analysis

[41 C.D.I. letter F445/0136, M.Teske (CDI) to E. Betti (Entergy), dated 17 May 2006, "Dryer Loads for Vermont Yankee at 120% Power"

[51 Entergy letter (BVY 05-061) to NRC dated June 2, 2005, "Vermont Yankee Nuclear Power Station, Technical Specification Proposed Change No. 263, Supplement No. 29, Extended Power Uprate - Computational Fluid Dynamics."

(61 Letter from Craig J. Nichols (Entergy) to Michael J. Dick (GE), "VY Load Definition Input and Uncertainty Values for use in GE Steam Dryer Analysis Report",

PUPVY-06-470, June 15, 2006.

[71 American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section II1, Appendix I, 1989 Edition with no Addenda.

[8] American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III, Subsection NG, 1989 Edition with no Addenda.

(9] American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III, Appendix F, 1989 Edition with no Addenda.

(10] MPR Calculation Number 319-002-01, transmitted by MPR letter H. William McCurdy to JR Hoffman, "Vermont Yankee Seismic Data for Increased Core Flow Evaluatioh," May 29, 1997.

[111 ANSYS, Release 8.1, ANSYS, Incorporated, 2005.

39 of 40

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION

[12) Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 229 to Facility Operating License No. DPR-28 Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station Docket No. 50-271, March 2006 (13] "Recommended Weld Quality and Stress Concentration Factors for Use in the Structural Analysis of Exelon Replacement Steam Dryer," GENE Report, e-DRF#0000-0034-6079, February 2005.

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GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION Appendix A Vermont Yankee Steam Drger Differential Pressures The pressure differentials across the steam dryer are calculated for three categories of events; normal, upset, and faulted conditions. Normal conditions are the steady-state operating conditions. Upset conditions are the anticipated transient events. ((

)) Faulted conditions are the design basis accident events (e.g. main steam line break). The ((

1]

The pressure differentials across the steam dryer for the normal conditions at EPU power level are summarized in Table A-I.

Table A-1 Steam Dryer Pressure Differentials for Normal Conditions at EPU Descri[ton

[

__ _ K Psid I 4 11 A-1 of 4

GE-N E-0000-0054-1378N P-RO GE PROPRIETARY INFORMATION The pressure differentials across the steam dryer due to (( )) for upset conditions at EPU power level are summarized in Table A-2.

Table A-2 Dryer Delta-P for EPU (( 1]Upset Conditions

'uscrnton

____________________________________ (sdi The maximum [R J] loads on the dryer face at EPU power level for the Turbine Stop Valve (TSV) fast closure event are summarized in Table A-3. Typical pressure time history is shown in Figure A-1.

Table A-3 Maximum TSV [( )) Load on the Dryer Face at EPU

_________________________________ ]

))

A-2 of 4

GE-NE-0000-0054-1378NP-RO GE PROPRIETARY INFORMATION 11 3)

Figure A-1 Typical TSV Load Time Histories 11 1]

A-3 of 4

GE-N E-OOOO-0054-1378N P-RO GE PROPRIETARY INFORMATION The maximum (( )) loads on the dryer face at EPU power level due to the ((

)) for the Main Steam Line Break event are summarized in Table A-4.

Table A-4 Maximum MSL Break (( )) Load on the Dryer Face at EPU A-4 of 4

v t e Letter Sequence Other
TAC:MC0761, (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request Acceptance, Acceptance, Acceptance, Acceptance Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement Administration Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting Questions 30 December 2003 19 March 2004 28 May 2004 6 July 2004 1 September 2004 21 December 2004 28 March 2005 14 April 2005 27 July 2005 7 September 2005 28 October 2005 25 November 2005 Answers 1 April 2005 Results Approval, Approval, Approval Other: BVY 06-014, E-mail, Meyer, Entergy, to Ennis, NRR, VY EPU, BVY 06-019, Vermont Yankee, Extended Power Uprate - Regulatory Commitment Information Regarding Steam Dryer Monitoring and Fiv Effects, BVY 06-031, Revision 1 to Steam Dryer Monitoring Plan, BVY 06-039, Vermont Yankee Nuclear Power Station Revision 2 to Steam Dryer Monitoring Plan, BVY 06-051, Vermont Yankee - Summary of Reactor Feedwater Pump Trip Analysis, BVY 06-056, Submittal of Vermont Yankee Report on the Results of Steam Dryer Monitoring, BVY 06-080, Vermont Yankee, Extended Power Uprate - License Amendment No. 229 Clarifications to Nrc'S Final Safety Evaluation, BVY 06-087, Update to Information Related to 10CFR50.63 Licensing Basis, ML033140025, ML033160187, ML040080573, ML040090411, ML041810022, ML041810433, ML042180463, ML042650265, ML042680087, ML043020494, ML050060086, ML050280310, ML050450423, ML050940230, ML050940242, ML052080154, ML053490030, ML053530148, ML060330490, ML060410119, ML061290566, ML061870277
MONTHYEAR2004-12-09 [Table View]

ML061870277

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