Text

Vermont Department of Public Service Initial Discovery Disclosures Pursuant to 10 C.F.R. 2.336
	ML063170200
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	10/23/2006
From:	Hofmann S; State of VT, Dept of Public Service
To:	; Atomic Safety and Licensing Board Panel
	Byrdsong A T
References
	50-271-LR, ASLBP 06-849-03-LR, RAS 12430
	Download: ML063170200 (577)
	v • d • e

{{#Wiki_filter:-R/4 5 /9 q3O U~gM-ORRESPOM C)ctober 23, 2006 UNITED STATES OF AMERICA ,DOCKETED NUCLEAR REGULATORY COMMISSION USNRC October 23, 2006 (2:40pm) BEFORE THE ATOMIC SAFETY AND) LICENSING BOARD BEFOR THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRETARY RULEMAKINGS AND In the Matter of ) ADJUDICATIONS STAFF

ENTERGY NUCLEAR VERMONT ) YANKEE, LLC and ENTERGY ) Docket No. 50-271-LR NUCLEAR OPERATIONS, INC )

                                                            )       ASLBP No. 06-849-03-LR (Vermont Yankee Nuclear Power Station)                )

VERMONT DEPARTMENT OF PUBLIC SERVICE INITIAL DISCOVERY DISCLOSURES PURSUANT TO 10 C.F.R. § 2.336 Pursuant to 10 C.F.R. § 2.336, the Vermont Department of Public Service ("Vermont") hereby makes the following initial disclosures. In accordance with 10 C.F.R. § 2.336(d), Vermont will supplement these disclosures. (a)(1) Experts Vermont has not yet determined the person or persons it will rely upon as a witness with respect to the admitted contentions except for the state nuclear engineer, William K. Sherman. Mr. Sherman's address and telephone number are as follows: William K. Sherman State Nuclear Engineer Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, VT 05620-2601 802-828-3349 The basis for Mr. Sherman's opinion thus far is included in his affidavits filed with Vermont's Initial Contentions and its Reply as well as the information contained in these 1 mp p Icehe- sc 035-

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disclosures. (a)(2)(i) Documents and Data Compilations Documents provided in hard copy with this transmittal Related to NEC Contention 3

1. SIL No. 644, Rev. 1 dated November 9, 2004 - BWR steam dryer integrity.

2. DPS Responses to Discovery in PSB Docket 7195, Partial Production dated July 21, 2006.

3. DPS Responses to Discovery in PSB Docket 7195, Final Production dated July 21, 2006.

Background

A moisture'carryover greater than 0.1% at the licensed power level is an indication of potential steam dryer damage,, unless a higher threshold is established. A higher threshold may be warranted for a BWR with an unmodified square dryer hood (i.e., no addition of perforated plates) and/or operating with MELLLA+ at off-rated core flow. If plants are reporting measured moisture carryover values of "less than" a value because of inability to measure Na-24 in the condensed steam sample and the "less than" value is greater than 0.025%, then the moisture carryover measurement process should bb modified to reduce the minimum detectable threshold (preferably such that "less than" valueO are never reported). Without quantitative data, the plant staff will be unable to develop operational recommendations based on statistically valid moisture carryover and other plant data. BWR moisture carryover may be impacted by: (1) reactor power level, (2) core flow and power distributions, (3) core inlet subcooling (which is related to final Feedwater temperature), and (4) reactor water level. Moisture carryover is very sensitive to power level. Therefore, data should be collected during steady state operations at the highest possible power levels. Moisture carryover has increased in cases where steam flow is increased towards the center of the core. Moisture carryover has increasedin cases where core inlet sub-cooling is decreased (i.e., final Feedwater temperature is increased). Moisture carryover has increased in cases where reactor water level is increased (due to degraded separator performance). Note that the standard deviation of moisture carryover measurements is not expected to change significantly following power distribution changes. However, if a significant condenser tube leak occurs, then the standard deviation of moisture carryover measurements may change significantly due to the resulting increased Na-24 concentrations. Plants are recommended to accurately determine the flow distribution between individual steam lines. If significant steam dryer damage occurs, steam line flow distribution changes may result. It may be helpful to have pressure data at each main steam flow element (venturi) to better understand the pressure drops and possible pressure changes due to moisture content changes in the steam line flow. This pressure data would have been beneficial at Quad Cities to help identify the flow blockage

SIL No. 644 Revision 1 ° page 31 upstream of the flow element following significant steam dryer damage. Note that flow element performance calculations are based on the RPV steam dome pressure. An increased feed-to-steam mismatch (i.e., total Feedwater flow Rlus CRD flow minus total steam flow, with reactor water level constant) may validate an increase in moisture carryover. Plant application has confirmed this correlation exists when the initial moisture carryover value is low (-0.0 1%), however the correlptioni showed significant scatter at higher initial moisture carryover values (0.04% to 0.10%). Baseline Data NOTE Data should be collected during steady state operations at the highest possible power levels. Moisture Carryover Measure moisture carryover daily to obtain at least five (5) measurements. Statistically evaluate the moisture carrn'over data (e.g., determine the mean and standard deviation for the data) to determine if there is a significant increasing trend. Qualitatively review the data to ascertain if there is a significant increaMing trend. If there is an increasing trend. in moisture carryover, review the changes in plant operational parameters to determine if there is an operational basis for the trend. If an unexplained increasing trend is evident, then collect additional moisture carryover data with consideration for increasing the measurement frequency (e.g., from "once per day" to "once per 12 hours"). If an unexplained increasing trend is not evident, then begin collecting periodic data for moisture carryover. Plant Operational Parameters NOTE Most plant operational data is available from the process computer, which can normally be input into an Excel spread sheet for evaluation and storage. The following parameters should be measured under the same (or similar) plant conditions that existed during collection of moisture carryover baseline data: Reactor power (MWt) Core flow (Mlb/hr) Core inlet sub-cooling (deg F) Reactor water level, average of at least 1000 data points over a one to three hour time period. Individual main steam line flows (Mlb/hr), average of at least 1000 data points over a one to three hour time period. Include pressure data at each MSL flow element (venturi), if available.

SIL No. 644 Revision I

page 32 Total Feedwater flow (Mlb/hr), average of at least 1000 data points over a one to three hour time period.

CRD flow (Mlb/hr) Periodic Data and Operational Response NOTE Data should be collected during steady state'operations at the highest possible power levels. If a moisture carryover measurement is suspect (e.g., less than "mean minus 2-sigma"), then repeat the moisture carryover measurement to .verify sampling and analysis were performed correctly. Consider eliminating data shown to be incorrect/invalid. Moisture carryover should be monitored weekly. Statistically evaluate-the-moisture carryover data and qualitatively determine if there is a significant increasing trend that cannot be explained by changes in plant operational parameters. If an unexplained increasingtrend is evident, then collept additional moisture -carryover data with consideration for increasing the measurement frequency (e g., from "once per week" to "once per day"). If the latest moisture carryover measurement is greater than "mean plus 2-sigma" and this increase cannot be explained by changes in plant operational parameters, then obtain a complete set of data for the plant operational parameters (identified above). Compare the current plant operational data with the baseline data'to explain the increased moisture carryover (i.e., is there steam dryer damage or not). If an increase in moisture carryover occurs immediately following a rod swap, additional moisture carryover data should be obtained to assure that an increasing trend does not exist. Note that occurrence of steam dryer damage immediately following a rod swap would be highly unlikely. If the increasing trend of moisturecarryover cannot be explained by evaluation of the plant operational data, then initiate plant-specific contingency plans for potential steam dryer damage. If the evaluation of plant data confirms that significant steam dryer damage has most likely occurred, then initiate a plant shutdown. If there are no statistically significant changes in moisture carryover for an operating cycle, then decreasing the moisture carryover measurement frequency (e.g., from "once per week" to "once per month") may be considered, provided the highest operating power levelis not significantly increased.

112 STATE STREET FAX: (802) 828-2342 DRAWER 20 fTY (VT): 1-800-734-8390 MONTPELIER VT 05620-2601 e-mail: vtdps@psd.state.vtus TEL: (802) 828-2811 Internet: http://www.state.vLus/psd STATE OF VERMONT DEPARTMENT OF PUBLIC SERVICE July 21, 2006 John Marshall, Esq. Nancy Malmquist, Esq. Downs Rachlin Martin PLLC P.O. Box 99 St. Johnsbury, VT 05819-0099 Re: Docket 7195 - DPS Responses to Discovery- Partial Production

Dear John and Nancy:

I enclose herewith a partial production in response to the discovery requests served by Entergy in this docket on July 14, 2006. The response to question 8 indicates that a privilege log will be forthcoming. I plan to produce that to you on Monday, July 24. At that time, I will also either provide you with any supplemental responsive materials I have located or I will write to advise that the production is complete. Should you have any questions, please feel free to contact me upon my return to the office on Monday, July 24, 2006. ecial Counsel Enclosures

cc: Attached Service List NRC 50-271-LR

                                                                                    'ASLBP 0 6 - 8 49-03-LR
                                                                                  ,DPS-2

PSB Docket No. 7195 - SERVICE LIST Parties: Kenneth C. Picton, Esq. Central Vermont Public Service Corporation Sarah Hofmann, Esq. 77 Grove Street June E. Tierney, Esq. Rutland, VT 05701 Vermont Department of Public Service Chittenden Bank Building James Matteau, Executive Director 112 State Street - Drawer 20 Windham Regional Commission Montpelier VT 05620-2601 139 Main Street - Suite 505 Brattleboro, VT .05301 Donald J. Rendall, Jr., Esq. Green Mountain Power Corporation Raymond Shadis

.163 Acorn Lane                           New England Coalition Colchester, VT 05446                      PO Box 98 Edgecomb, ME 04556 Peter H. Zamore, Esq.

Sheehey, Furlong & Behm, P.C. Sandra Dragon, President Gateway Square Associated Industries of Vermont 30 Main Street PO Box 63'0 PO-Box 66 -----Montpelier, VT 05601 Burlington, VT 05402 John H. Marshall, Esq. Nancy S. Malmquist, Esq. Downs, Rachlin & Martin, PLLC. 90 Prospect Street - PO Box 99 St. Johnsbury, VT 05819-0099 Ted A. Sullivan David K. McElwee Entergy Nuclear Vermont Yankee, LLC. 185 Old Ferry Road PO Box 0500 Brattleboro, VT 05302-0500 Terence A. Burke, Esq. Entergy Nuclear Operations, Inc. 1340 Echelon Parkway PO Box 31995 Jackson, MS 39213 L. Jager Smith, Jr., Esq. Wise Carter, Child & Caraway, P.A. C/O Entergy Nuclear Operations, Inc. 1340 Echelon Parkway M-ECH-45 Jackson, MS 32913

STATE OF VERMONT PUBLIC SERVICE BOARD Docket No. 7195 Petition of Vermont Department of Public Service for an investigation into the reliability of the steam dryer and resulting performance of the Vermont Yankee Nuclear Power Station under uprate conditions DEPARTMENT OF PUBLIC SERVICE'S RESPONSES TO ENTERGY NUCLEAR VERMONT YANKEE, LLC. AND ENTERGY NUCLEAR OPERATIONS, INC.'S FIRST SET OF INFORMATION REQUESTS July 21, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests Please identify and produce all documents reviewed or relied upon for information relating to Quad Cities and Dresden steam dryer problems, repairs, or replacements in connection with Mr. Sherman's Direct Testimony dated June 21, 2006. ANSWER: The following attached documents in my possession are responsive to the request: Attachment 1-1 SECY-06-01361, Attachment 1-2 SECY-05-0098 Attachment 1-3 SECY-04-0104 Attachment 1-4 Quad Cities' new steam dryers project, Nuclear News, October 2005 Attachment 1-5 Snap, Crackel, & Pop: The BWR Power UprateExperiment, Union of Concerned Scientists, July 9, 2004 Attachment 1-6 Extended Power UprateLicensingChallenges, slides from Exelon presentation at the Regulatory Information Conference 2004 Attachment 1-7 NRC Preliminaiy Notification, PNO-lII-06-010, Cracking Identified in Unit 2 Steam Dryer, April 7, 2006 Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests

2. Please identify and produce all documents you reviewed relating to fatigue cracking of steam dryers other than those at Quad Cities, Dresden or Vermont Yankee.

ANSWER: Please see Attachment 1-2, provided in response to Request No.. 1 above. Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests

3. Reference Mr. Sherman's Direct Testimony dated June 21, 2006, beginning at page 6, line 4. Please identify and produce all documents you reviewed relating to cracks discovered in Vermont Yankee's steam dryer.

ANSWER: The following attached documents are responsive tothe request: Attachment 3-1 Vermont Yankee has m ore cracks;probe demanded, Rutland Herald, November 11, -2005. Attachment 3-2 62 cracksfound at Vt. Yankee, Brattleboro Reformer, November 11,2005. Attachment 3-3 More cracksfound in Vermont Yankee dryer, Vermont Guardian, November 10, 2005. Attachment 3-4 Congressional Letter (Jeffords, Leahy, Sanders, Olver) to NRC, November 10, 2005. Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests

4. Reference Mr.: Sherman's Direct Testimony dated June 21, 2006, beginning at page 6, line 16. Please identify and produce all documents relied upon for the assertion that

      "[t]he Quad Cities and Dresden experience is applicable to Vermont Yankee."

ANSWER: The following attached documents are responsive to the request: Attachment 4-1 NRC Summary 6f July 21 and 22, 2004 Meeting for Vermont Yankee steam drcer, September 2, 2004 Attachment 4-2 NRC Summary o0f July 25, 2003 meeting with GE regarding steam dryer failures, September 15, 2003 Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear. Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests

5. Reference Mr. Sherman's Direct Testimony dated June 21, 2006, at page 6, footnote 1.

Please identify and produce all documents relied upon for the assertion that "[i]t is even possible that Vermont Yankee's smaller size could exacerbate the problem." ANSWER: There are no documents responsive to this request.. Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests 6..

Reference:

Mr. Sherman's Direct Testimony dated June 21, 2006, beginning at page 9, line 5. Please identify and produce all documents relied upon for the assertion that the "only basis for NRC acceptance of the steam dryers in power uprate conditions was the added instrumentation and the power ascension tests." ANSWERk In my Direct Testimony dated June 21, 2006, I specifically rely on Exhibits DPS-WKS-2 and -3 for the statement that NRC acceptance of the steam dryers in power uprate conditions was based on the added instrumentation and the power ascension tests. The following additional attached documents are responsive to the request: Attachment 6-1 NRC letter to Entergy (Dyer to Kansler), Vermont Yankee Nuclear Power Station - Extended Power UprateReview.Schedule and License Conditions, October 12, 2005 Attachment 6-2 NRC letter to Entergy (Ennis to Kansler), Vermont Yankee Nuclear Power Station - Issuance ofAmendment Re; Extended Power Uprate, March 2, 2006 Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to (D Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests

7. Reference Mr. Sherman's Direct Testimony dated June 21, 2006, beginning at page 11, line 6. Please identify and produce all documents relied upon for the assertion that the

        'NRC was satisfied that catastrophic failure of the steam dryer would not occur."

ANSWER: The following 'attached documents are responsive to the request: Attachment 7-1 Staff Technical Basisfor Continued Power Ascension of Vermoni Yankee Nuclear Power Station up to 110% OriginaltLicensedThermal Power, April 5, 2006 Attachment 7-2 Staff Technical Basisfor ContinuedPower Ascension of Vermont Yankee NuclearPower Station up to 115% OriginalLicensed Thermal Power, April 28, 2006 Attachment 7-3 Staff TechnicalBasisfor Continued PowerAscension of Vermont Yankee NuclearPower Station to Full Extened Power Uprate Conditoins of 120% OriginalLicensed Thermal Power, June 20, 2006 Attachment 7-4 NRC Letter to the Vermont Public Service Board (Diaz to Dworkin), May 4, 2004 In addition, Attachment 8-4, provided in response to Request No. 8, is responsive to this request. Person Responsibl]e for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Yermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests

8. Reference Mr. Sherman's Direct Testimony dated June 21, 2006, beginning at page 11, line 13. Please identify and produce all notes taken by Mr. Sherman, or reports, memoranda or other documents drafted by Mr. Sherman, relating to Mr. Sherman's review of data Entergy provided to the NRC or relating to his participation in technical conference calls or his site visits during the Vermont Yankee Power Ascension Test.

OBJECTION (BY COUNSEL): The Department objects to this question tothe extent that it seeks disclosure and production of privileged information. A privilege log will be provided on or before July 24, 2006. Subject to this objection theDepartment responds as follows: The following are notes taken or reports; memoranda or other documents which I drafted, relating to my review of data Entergy provided to the NRC or relating to my participation in technical conference calls or site visits during the Vermont Yankee Power Ascension Test: Attachment 8-1 W. Sherman, handwritten notes from site, March 6, 2006 - May 5, 2006. Attachment 8-2 Email (Sherman to Ennis), Re: VY Power Ascension, March 31, 2006. Attachment 8-3 Email string, Steam dryer data-methodology (McElwee to Sherman; Nichols to McElwee; McElwee to Nichols; Sherman to McElwee; Sherman to Ennis), May 1, 2006. Attachment 8-4 Email (Sherman to Ennis), Steam dryer question, May 1, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests Attachment 8-5 Handwritten notes by, W. Sherman, Steam Dryer Meeting, 6-15-06 Attachment 8-6 Email (Sherman to McElwee), questions re: Rbettipresentation, June 19, 2006 Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests

9. Reference Mr. Sherman's Direct Testimony dated June 21, 2006, beginning at page 14, line 33. Please identify and produce all documents relied upon for assertion that the "original limit curves presented in the initial power ascension test plan (Exhibit DPS-WKS-4) carried the expectation that steam line/steam dryer phenomena were sufficiently understood analytically and that the limit curves were conservative." By way of clarification, Entergy VY is here requesting documents that demonstrate that the initial power ascension test plan "carried the expectation" indicated.

ANSWER: Please see Attachments 8-5 and 8-6, which are responsive to the request. In addition, the following document is responsive to the request: Attachment 9-1 Entergy News Release' Update: Vermont Yankee PowerIncrease Program Now at FirstPlateau,March 8, 2006 Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests

10. Reference Mr. Sherman's Direct Testimony dated June 21, 2006, beginning at page 16, line 17. Please identify and produce all documents relied upon for the assertion that

      "[p-art of NRC's conclusion of reasonable assurance that [the] steam dryer will meet safety requirements is that cracking can be detected by increases in moisture carryover, and the plant power can be reduced to a known, safe power level until the steam dryer can be evaluated and repaired."

ANSWER: The following document is responsive to the request: Attachment 10-1 NRC letter to BWR Owners Group (Wang to Putnam), Boiling Water Reactor Steam DryerIntegrity, September 26, 2003 In addition, Attachments 6-1 and 6-2 are responsive to this request. Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to En'tergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests

11. Reference Mr. Sherman's Direct Testimony dated June 21, 2006, beginning at page 17, line 1. Please identify and produce all documents relied upon for the assertion that "NRC relies upon the possibility of a derate in its safety determination."

ANSWER: There are no documents responsive to this request. Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Departmept of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Eniergy Nuclear Operations, Inc.'s First Set of Information Requests

12. Reference Mr. Sherman's Direct Testimony dated June 21, 2006, beginning at page 18, line 8, and Exhibit DPS-WKS-7. Please identify and produce the "current power price forecasts" source documents used for calculations in Exhibit DPS-WKS-7.

ANSWER: The following document is-responsive'.to this request: 2-1 NEPOOL Quote Sheet fir January 13, 2006 Person Responsible for Response: William Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests

13. To the extent not already provided in response to the requests above or already provided as Exhibits to Mr. Sherman's Direct Testimony, please identify and produce copies of any and all other documents relied upon by Mr. Sherman in drafting the opinions presented in' his Direct Testimony.

ANSWER: The following documents are responsive to the request: Attachment 13- 1 Entergy letter to 64RC, Information Regarding Steam Dryer Monitoringand FIV Effects, February 26, 2006 Attachment 13-2 Entergy letter to NRC, Revision 1 to Steam Dryer MonitoringPlan, March 26, 2006 Attachment 13-3 Entergy letter to NRC, Revision 2 to Steam Dryer Monitoring Plan, April 20, 2006 Attachment 13-4 Entergy letter to NRC, Revision 3 to Steam DryerMonitoring Plan, May 4, 2006 Attachment 13-5 Entergy letter to Department of Public Service (McElwee to Sherman), May 17, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests In addition, I viewed various documents at the Vermont Yankee site related to the results of the power ascension tests. I do not have access to copies of these documents to produce in response to this request as I have not removed these documents for copying from the site in accordance with the Memorandum of Understandingon Cooperation,Notification and Access Between Entergy Nuclear Vermont Yankee LLC and Vermont Department of Public Servicefor the Vermont Yankee Nuclear Power Station (the "Inspection MOU"), dated July 30, 2002. Person Responsible for Response: William K. Sherman, Department of Public Service Date: July 20, 2006

Docket No. 7195 Department of Public Service's Responses to Entergy Nuclear Vermont Yankee, LLC. And Entergy Nuclear Operations, Inc.'s First Set of Information Requests VERMONT DEPARTMENT OF PUBLIC SERVICE By William Shermar Subscribed and sworn before me this 2 4th day of July, 2006. Notary Public My commission expires February 10, 2007 As to cc: Attached Service List

(9 POLICY ISSUE INFORMATION June 9. 2006 SECY-06-0136 FOR: The Commissioners FROM: Luis A. Reyes' Executive Director for Operatipns

SUBJECT:

STATUS REPORT ON POWER UPRATES PURPOSE: This paper summarizes the power uprate program accomplishments and challenges since the last update in SECY-05-0098, dated June 2, 2005. This paper does not address any new commitments or resources. BACKGROUND: The staff provides the Commission an annual update of significant power uprate activities in accordance with a staff requirements memorandum dated February 81 2002 (SRM-M020129). DISCUSSION: Since the last update, the staff has approved 4 plant-specific power uprates. The staff is currently reviewing 9 power uprates. Over the next 5 years, licensees are expected to submit an additional 23 power uprate applications. The enclosed status report provides detailed information on the power uprates approved since June 2, 2005, applications under review, applications expected in the future, accomplishments, operating experience, program performance and interactions with stakeholders. CONTACT: Thomas W. Alexion (301) 415-1326 Docket No. 7195 Attachment 1-1 9 Pages

The Commissioners The staff is continuing to develop process improvements based on lessons learned from completed reviews and operating experience reviews. The process improvements include more detailed reviews of certain technical issues and some efficiency improvements. The technical issues include power uprate testing programs, flow-induced vibration issues, and reactor in an systems calculative techniques and methods. These more detailed reviews have resulted extended power uprate (EPU) review from 3,900 hours increase in the planned resources for an to 5,000 hours. These resources are budgeted through Fiscal Year 2008. Regarding efficiency improvements, the staff has implemented more rigorous acceptance reviews for power uprate applications and the staff will, on a pilot basis, conduct more extensive audits to improve the in review efficiency. Details of the program accomplishments and improvements are described the enclosure. With the exception of the Vermont Yankee review, the 4 plant-specific power uprate reviews were completed within the established resource and timeliness goals. The Vermont Yankee issues review required additionaltime and resources to allow a thorough r~eview of key technical associated with safe operation at the new power level. The review of the key technical issues on discussed above took longer than expected for the staff and licensee to come to resolution these issues. The review involved several rounds of RAIs and over 40 supplemental submittals issues. by the licensee. Ultimately, license conditions, were used to resolve the remaining key involvement in the To correct this in. the future, the staff will utilize more and earlier management key issues decision-making process; including consideration of license conditions to resolve earlier in the review process. . The staff formed a Special Inspection Team to evaluate the licensee's response to significant degradation of the electromatic relief valves at the Quad Cities units from EPU operation, and of reviewed modifications at Quad Cities Unit 2in spring 2006 to eliminate the source in the main steam lines during EPU flow-induced vibration and acoustic pressure pulses operation. Additionally, the staff monitored the power ascension at Vermont Yankee following issuance of the EPU license amendment on March 2, 2006, and met with the vendors of ultrasonic flow meters used for measurement uncertainty recapture power uprates to discuss issues related to small differences in power level indications at some plants. The staff is evaluating the need to modify guidance to address the operating experience. COORDINATION: The Office of the General Counsel reviewed this report and has no legal objection. IRAI Luis A, Reyes Executive Director for Operations

Enclosure:

Power Uprate Program Status Report

Power Uprate Program Status Report June 2006 Power uprates are categorized based on the magnitude of the power increase and the methods used to achieve the increase. Measurement uncertainty recapture (MUR) power uprates result in power level increases that are less than 2 percent and are achieved by implementing enhanced techniques for calculating reactor power. Stretch power uprates (SPUs) typically result in power level increases that are up to 7 percent and generally do not involve major plant modifications. Extended power uprates (EPUs) result in power level increases that are greater than SPUs and usually require significant modifications to major plant equipment. The Nuclear Regulatory Commission has approved EPUs for increases as high as 20 percent. Power Uprates Approved Since June 2005 Power uprates approved since June 2, 2005, have added an additional 608 megawatts thermal (MWt) or approximately 203 megawatts electric (MWe) to the Nation's electric generating capacity. This brings the total number of power uprates approved since 1977 to 109, resulting in a combined increase of about 13,858 MWt or 4,619 MWe to the Nation's electric generating capacity.

   *1     Palo Verde 1        2.9             114          07/09/2004      11/16/2005     SPU 2      Palo Verde 3        2.9             114          07/09/2004      11/16/2005     SPU 3   Vermont Yankee          20             319          09/10/2003      03/02/2006      EPU 4       Seabrook           1.7              61          09/22/2005      05/22/2006     MUR On March 2, 2006, the staff completed its review of the Vermont Yankee EPU application and approved the 20 percent power uprate. The licensee reached 120 percent of original licensed thermal power (the full EPU) on May 5, 2006, and successfully conducted a planned condensate pump trip test on May 8, 2006. Details on program performance versus established goals for these approved power uprates are presented later in this enclosure.

Power UDrate Applications Currently Under Staff Review Power uprates currently under review could add an additional 2420 MWt or 807 MWe to the Nation's electric generating capacity if approved. 1 Browns Ferry 2 1 15 I. 494 I 06/25/2004 I Spring 2007 I EPU I 2 Browns Ferry 3 1 15 I 494 I 06/25/2004 1 Spring 2007 I EPU I

                                               -I1-                                     Enclosure

3 Browns Ferry 1 20 659 06/28/2004 Spring 2007 EPU 4 Beaver Valley 1 8 211 10/04/2004 07/18/2006 EPU 5 Beaver Valley 2 8 211- 10/04/2004 07/18/2006 EPU 6 Calvert Cliffs 1 1.3 37 01/31/2005 12/31/2006 MUR 7 Calvert Cliffs 2 1.3 37 01'/31/2005 12/31/2006 MUR 8 Fort Calhoun 1.5 22 03/31/2005 12/31/2006 MUR 9 Ginna 17 255 07/07/2005 08/23/2006 EPU Expected Power Uprate Applications The following table describing intended future license amendment applications is the result of a survey of all licensees conducted in March 2006 and information obtained since the survey. Fiscal ~Po~wer Uprates MUR SPUs EP~js, MWt MWe Year Expected Power

                                 <   Uprates _________              _____
 .2006               4                  1        \0          3           1470         490 2007               6                  5            1       0            431         144 2008               0                 0            0        0              0           0 2009              10                 2.           3        5           1792         597 2010               2                 2            0        0             76          25 2011               1                 1            0        0             26           9 Accomplishments Since June 2, 2005

Approved four plant-specific power uprates: one MUR power uprate (Seabrook), two SPUs (Palo Verde Units 1 and 3) and an EPU (Vermont Yankee). An adjudicatory proceeding is currently in progress on the Vermont Yankee EPU; hearings are expected to be held in September-October 2006.

0 Issued an acceptance review letter for the Ginna power uprate application.

Monitored the installation of new steam dryers with an improved design at Quad Cities Units 1 and 2 in May 2005 and the return of those units to EPU operation.
Performed additional reviews of, and conducted public meetings on, the Exelon Generating Company, LLC (Exelon) evaluations of the plant data obtained during EPU operation at Quad Cities to determine the causes of flow-induced vibration (FIV) issues.

0 Reviewed Exelon's evaluation of the steam dryer cracking iderntified at Dresden Units 2 and 3 in November 2005 and subsequent repair of the steam dryers.

Formed a Special Inspection Team led by Region III with NRR assistance in January 2006 to evaluate Exelon's response to significant degradation of the electromatic relief valves (ERVs) at Quad Cities Units 1 and 2 from EPU operation.
Reviewed Exelon's response to the significant cracking identified in the steam dryer in Quad Cities Unit 2 during its spring 2006 refueling outage, which the licensee determined was caused by installation difficulties with the new dryer in May 2005.

"        Reviewed the modifications performed by Exelon at Quad Cities Unit 2 in spring 2006 to eliminate the source of FIV and acoustic pressure pulses in the main steam lines to reduce vibration of main steam line components and pressure loading on the steam dryer during EPU operation.

Monitored the power ascension at Vermont Yankee following issuance of the EPU license amendment on March 2, 2006, and reviewed plant data to evaluate pressure loading on the modified steam dryer and vibration of plant components during the power

       .ascension process.

Continued to hold discussions regarding FIV issues with General Electric Nuclear Energy and the Boiling Water Reactor Owners Group.
Met with Westinghouse and Caldon, the vendors of ultrasonic flow meters used for MUR power uprates, to discuss issues related to small differences in power level indications at some plants.

"       Presented information on the Vermont Yankee, Ginna, and Beaver Valley Units 1 and 2 EPU applications to the Advisory Committee on Reactor Safeguards (ACRS) and the ACRS Subcommittee on Power Uprates.

0 Performed acceptance reviews of the EPU applications for Hope Creek and Susquehanna Units 1 and 2 and determined that the information provided was insufficient to demonstrate that the structural integrity of the steam dryers would be maintained during EPU operation.

Briefed the Mexican regulator,*the Japanese regulator, and a group of Young Swedish Nuclear Professionals on the Nuclear Regulator Commission's (NRC's) power uprate program.
Presented information on NRC's power uprate program at regulatory information exchange meetings in Taiwan and Korea.
Supported interviews by World Watch and the Chicago Tribune that included questions on NRC's power uprate program.
Provided comprehensive power uprate review guidance in all aspects of power uprate reviews to NRC's plant project managers.

" Briefed the ACRS on the staffs proposed final version of Standard Review Plan Section 14.2.1, "Generic Guidelines for Extended Power Uprate Testing Programs."

Responded to Congressional questions on power uprates.

Operating Experience Related to Power Uprates There have been several FIV issues warranting staff attention. In May 2005, the licensee installed new steam dryers in Quad Cities Units 1 and 2 with an improved design to increase their structural capability for EPU operation. The steam dryer in Quad Cities Unit 2 was instrumented with pressure, strain, and acceleration sensors to collect data during the power ascension and EPU operation to determine actual steam dryer loading and to validate an acoustic analysis method that uses main steam line strain gage data as input in calculating stress in the steam dryer during plant operation. The staff monitored the return to EPU operation of the Quad Cities units following replacement of the steam dryers. The staff has been reviewing the data collected at the Quad Cities units and the startup test reports prepared by the licensee and has conducted several public meetings with the licensee to discuss the steam dryer loads at EPU conditions. The staff is currently rpviewing the licensee's response to several remaining issues regarding the steam dryer stress analysis and its uncertainty assumptions.submitted on December 22, 2005. During EPU operation at Quad Cities Units 1 and 2, the licensee discovered significant degradation of the ERVs at those units in late December 2005 and early January 2006. The licensee shut down the Quad Cities units to repair the ERVs and restarted the units with operation up to pre-EPU power levels. In response to the discovery of the ERV degradation, NRC sent a Special InspectionTeam to Quad Cities in January 2006 where the staff found several weaknesses in the licensee's actions to ensure the capability of the ERVs for EPU conditions. The licensee's evaluation of the ERV degradation under EPU conditions determined that the degradation was due to the failure to address the source"of the vibrations at the Quad Cities units over the last several years. During the spring 2006 refueling outage at Quad Cities Unit 2, the licensee discovered a significant crack in the skirt region of the steam dryer. The licensee determined that the cracking was the result of fatigue failure during EPU operation due to overstressing of the skirt during installation difficulties in May 2005. The licensee also conducted modifications to the safety and relief valves branch lines from the main steam lines at Quad Cities Unit 2 to reduce 'the acoustic pressure fluctuations that are causing significant steam dryer loading and main steam line component vibration. Upon restart of Quad Cities Unit 2 in April 2006, the licensee found that the main steam line strain gage instrumentation indicated acoustic pressure fluctuations during a brief test period at EPU conditions to be below the levels measured at EPU conditions. The licensee shut down Quad Cities Unit 1 in May 2006 to install similar modifications in its steam lines and to inspect the steam dryer. The licensee found minimal indications on the Quad Cities Unit 1 steam dryer which confirmed the analysis of the steam dryer cracking found at Quad Cities Unit 2 earlier this year. As a result, the licensee returned Quad Cities Unit 2 to EPU operation. Following the steam line modifications in Quad Cities Unit 1, the licensee restarted that unit and returned it to EPU operation. The NRC staff will evaluate the Quad Cities plant data, analysis, and inspection results to determine whether any safety concerns exist with the long-term EPU operation of those units. In previous years, the steam dryers at Dresden Units 2 and 3 were modified to increase their structural capability for EPU operation. These plants had operated for several years at the EPU levels with the modified steam dryers without significant damage. However, cracking was found in November 2005 in Unit 2 and later in Unit 3. The licensee r'epaired the cracks and installed additional modifications to the steam dryers in the Dresden units. The licensee plans to replace the dryers during the fall 2006 (Unit 3) and the fall 2007 (Unit 2). In preparing a safety evaluation for the EPU license amendment request for Vermont Yankee, the staff reviewed the licensee's modifications and analysis of the Vermont Yankee steam dryer and the plans for monitoring plant instrumentation to assess steam dryer loads and FIV during powerascension and EPU operation. The staff accepted the licensee's analysis of potential adverse flow effects for EPU operation with specific license conditions and a regulatory commitment for monitoring plant instrumentation during power ascension. In March 2006 following issuance of the EPU license amendment, the licensee initiated a slow and d6liberat.e power ascension at Vermont Yankee. The plant reached administrative limits on main steam line strain gage measurements at 105 percent, 112.5 percent, and 117.5 percent of original licensed thermal power (OLTP). The licensee also reached an administrative limit at 117.5 percent of OLTP for moisture carryover efficiency of the steam dryer. The staff reviewed the plant data for each power ascension step and the licensee's analysis of the stress on the steam dryer and specific reassessments of the administrative limits. The staff also reviewed the plant data for vibration and the results from walkdown inspections conducted by the licensee during the power ascension hold points. The staff will continue to monitor steam dryer loads and FIV of plant components at Vermont Yankee. The staff is applying the lessons learned from the review of the power uprate flow effects at Quad Cities and Dresden to other power uprate applications. For example, the staff determined that the initial EPU applications submitted by the Hope Creek and Susquehanna Units 1 and 2 licensees were insufficient to demonstrate that the steam dryers at those plants were capable of maintaining their structural integrity at the uprated power levels. The Hope Creek and Susquehanna Units 1 and.2 licensees are modifying their applicatigns. Another operating experience issue relates to'abnormalities in ultrasonic flow meter (UFM) instrumentation. The staff is currently following industry evaluations of a problem at plants using a UFM of the type used for MUR power yiprates. This problem has led to *unexpected but small differences in power level indications at ýome plants. The staff is currently completing its evaluations of pending applications using the Westinghouse Crossflow system with the benefit of this operating experience. Program Performance vs. Established Goals. The established performance goals are: 6 months and 960 staff-hours for reviewing MUR power uprate applications, 9 months and 1800 staff-hours for reviewing SPU applications, and 12 months and 3900 staff-hours for reviewing EPU applications.' The staff will continue to ensure that the goal of protection of public health and safety is not compromised in order to meet these timeliness and resource expenditure goals. To that end, the staff believes it now needs to increase the resource goal for EPU applications to 5,000 hours to adequately review EPU applications in several areas, including power uprate testing programs, FIV issues, and reactor systems calculative techniques and methods. These resources are budgeted through Fiscal Year 2008. It should be noted that individual applications may require more or less review time depending on the nature of the technical issues; for example, the staffs review of the Vermont Yankee EPU involved about 1.1,000 hours of review (about 10 percent of the 11,000 hours was used in the staffs acceptance review), and. 900 hours for a pilot engineering inspection that touched on several EPU issues. These goals do not include the duration of and staff-hours for the staffs acceptance review, which the staff conducts upon receipt of the initial application. The timeliness and resource expenditure goals assume that licensees' submittals are consistent with established guiddlines, do not incl~de other non-power-uprate related requests, do not involve new or unanticipated significant technical issues, and that licensees respond to requests for additional information (RAIs) within established schedules. When establishing the above goals for the Office of Nuclear Reactor Regulation (NRR) Operating Plan, the staff recognized that in some cases, licensees' plans for implementing power uprates exceed the timeliness goals described above. As a result,.for the NRR Operating Plan, the staff can meet its timeliness goals by either completing the reviews according to the numerical goals or by completing the reviews in time to support licensees' proposed implementation schedules (also known as licensees' need dates), whichever is longer. This flexibility-allows the.staff to utilize its resources to better support other high-priority activities. The staff met its timeliness and resource goals for its review of the Seabrook MUR power uprate as'well as the Palo Verde Units 1 and 3 SPUs. The Seabrook MUR power uprate was approved on May 22, 2006 (which was the licensee's need date), and the staff charged about 900 hours for its review. The Palo Verde Units 1 and 3 SPU was approved on November 16, 2005 (which was prior to the' licensee's need date of November 1,8, 2005), and the staff charged about 1200 hours for its review. Fqr the Vermont Yankee EPU review, the staff took about 25 months and charged about 10,000 hours from the completion of NRC's acceptance review. The timeliness and resource goals were not met. The scheduled review of the Vermont Yankee EPU was extended largely due to incomplete submissions by the licensee, which required greater effort to allow a thorough review of key technical issues associated with safe operation at the new power level. The review involved several rounds of RAIs ahd over 40 supplemental submittals bty the licensee. Ultimately, license conditions were used to resolvethe remaining key issues. To correct this in the future, the staff will utilizemore and earlier management involvement in the decision-making process, including consideration of license conditions to resolve key issues earlier in the review process. In addition, the staff will conduct, on a pilot basis, more extensive audits at the plant and/or vendor sites to expedite resolution of RAIs. For the ongoing EPU reviews of Browns Ferry Unit 1, Browns Ferry Units 2 and 3, and Beaver Valley Units 1 and 2, the staff expects to meet the timeliness goals of 12 months after the staffs acceptance review or the licensee's need date; however, these applications needed substantial supplementation to. pass their acceptance reviews, which took over 9 months in each case. To correct this situation, the staff is now conducting more thorough and rigorous acceptance reviews of power uprate applications. Any significant area not addressed with sufficient completeness to allow the staff to proceed with its detailed technical review, may be treated as a basis for not accepting the application. This staff position was illustrated with the Hope Creek and Susquehanna Units 1 and 2 applications that were withdrawn by the licensees on February 10 and May 18, 2006, respectively, after the staff determined that the applications were insufficient to demonstrate that the structural integrity of the steam dryers would be maintained during EPU operation. In addition, the Susquehanna application did not adequately address several plant systems areas. For the Ft. Calhoun and Calvert Cliffs Units 1 and 2 MUR power uprate reviews, the NRC staff issued acceptance letters on May 12 and March 18, 2005, respectively. However, these reviews did not meet the 6-month timeliness goal because subsequent to the issuance of the acceptance letters, the staff determined that the NRC-approved methodologies for feedwater flow measurement were not being used by the licensees. (The staff based the 6-month timeliness goal for MUR power uprates on the use of NRC-approved methodologies.) The staff may also need to revisit the generic topical report associated with these reviews (i.e., the Westinghouse Crossflow system). Interactions with Internal and External Stakeholders The staff briefed the ACRS Subcommittee on Power Uprates and the ACRS Full Committee in November and December of 2005 for the Vermont Yankee EP.U, and in March, April and May of 2006 for the Ginna and Beaver Valley Units 1 and 2 EPUs. Regarding the Vermont Yankee EPU, the ACRS had particular interest in the areas of containment overpressure credit, large transient tests, times available to perform critical operator actions, margin added to the safety limit minimum critical power ratio, and the steam dryer monitoring plan during power ascension. By letter dated January 4, 2006, the ACRS recommended approval of the Vermont Yankee EPU. Regarding the Ginna and Beaver Valley Units 1 and 2 EPUs, the ACRS had particular interest in the areas of non-loss-of-coolant accident (non-LOCA) events, LOCAs, boron precipitation during, long-term cooling following a LOCA, flow-induced vibration, flow accelerated corrosion, and probabilistic risk assessment. By letters dated May 22, 2006, the ACRS recommended approval of the Ginna and Beaver Valley Units 1 and 2 EPUs. For EPU applications, a proposed No Significant Hazards Consideration (NSHC) determination will be issued as soon as the staff is able to make this proposed determination. This determination would most likely be made right after the staff determines that the application passes the acceptance review. The reason for noticing future EPU applications with proposed NSHC determinations is that there has now been enough experience with EPUs (thestaff has approved 14 EPUs to date), such that the staff can now issue a proposed NSHC determination when noticing the application. The staff briefed the Mexican regulator (April 2006), the Japanese regulator (October 2005), and a group of Young Swedish Nuclear Professionals (October 2005) on NRC's power uprate program. This briefing focused on the staffs process for reviewing power uprate applications. The staff presented information on NRC's power uprate program at regulatory information exchange meetings in Taiwan and Korea in April 2006. These presentations focused on the staffs process for reviewing power uprate applications and some of the current technical issues with power uprates. The Commissioners POLICY ISSUE (Information) June 2. 2005 SECY-05-0098 FOR: The Commissioners FROM: Luis A. Reyes

                 *Executive Director for Operations /RA/

SUBJECT:

STATUS REPORT ON POWER UPRATES PURPOSE: To provide the Commission an update on the status of power uprate activities. This Commission paper summarizes the staff's accomplishments and qhallenges since the last update in SECY-04-0104, dated June .24, 2004. The staff will continue to keep the Commission informed of the status of power uprate activities by providing annual status reports and by other means as appropriate. Status reports on the power uprate program are generated in response to a staff requirements memorandum dated Fgbruary 8, 2002.

SUMMARY

Since the last status update, the staff has made progress in reviewing plant-specific power uprates, stayed abreast of operating experience with potential effects on power uprate reviews, continued to monitor performance related'to the effectiveness and efficiency measures established for power uprate reviews, and continued to look for ways to improve the power uprate process. Details of the staff's progress are provided in this Commission paper and the attachments. CONTACT: John F. Stang, NRR/DLPM (301) 415-1345 BACKGROUND: Power uprates are categorized according to power increases and the methods used to achieve the increase. A MUR power uprate results in a power level increase that is less than 2 percent and is achieved by implementing advanced techniques for calculating reactor power. SPUs usually result in power level increases that are up to 7 percent and generally do not involve major plant modifications. EPUs result in larger power level increases than SPUs and usually Docket No. 7195 Attachment 1-2 16 Pages

The Commissioners require significant modifications to major plant equipment. The NRC has approved EPUs for increases as high as 20 percent. This status report is written in response to a staff requirements memorandum dated February 8, 2002. The staff provided its last update in SECY-04-0104, dated June 24, 2004. This update summarizes the staffs accomplishments and challenges since the last update. To date, the staff has completed the following actions:

approved five plant-specific power uprates (one extended power uprate (EPU), three stretch power uprates (SPUs), and one-measurement uncertainty recapture (MUR) power uprate);
issued acceptance review letters for the Indian PointUnit 3, Beaver Valley Units 1 and 2, Browns Ferry Units 1, 2, and 3, Calvert Cliffs Units 1 and 2, and Fort Calhoun power uprate applications;
continued to use Review Standard (RS)-001, "Review Standard for Extended Power Uprates " for EPU reviews;
conducted additional reviews of Exelon Generating Company, LLC's (Exelon's) evaluations of the causes of flow-induced vibration (FIV) issues at Dresden and Quad Cities;
continued to hold discussions regarding FIV issues with General Electric Nuclear Energy (GENE) and the Boiling Water Reactor Owners Group (BWROG)

.. met with industry on September 17, 2004, to discuss ongoing ultrasonic flow meters (UFMs) issues;

performed a pilot engineering inspection at Vermont Yankee with focus on the power uprate application;
discussed the approval of the Indian Point Units 2 and 3, and Seabrook SPUs with external stakeholders, including Congressional delegates and their staff, through public meetings and correspondence;
presented information on the Waterford EPU application to the Advisory Committee on Reactor Safeguards (ACRS), and the ACRS Subcommittee on Thermal-Hydraulic Phenomena;
discussed the power uprate program at a panel session during the 2005 NRC Regulatory Information Conference (RIC);
met with the State of New Jersey to discuss EPU reviews;
visited Switzerland and Sweden in June 2004 to discuss the NRC's Power Uprate Program and gathered information on lessons learned with international power uprate programs;
briefed a Japanese delegation on NRC's Power Uprate Program; and
provided input on power uprates for the 2005 U.S. National Report for the Convention on Nuclear Safety.

The staff will continue to keep the Commission informed of the status of power uprate activities by providing annual status reports and by other means as appropriate. DISCUSSION: Power UDrate Applications Approved Power Uprates

The Commissioners This status update covers power updates approved since June 24, 2004 (Attachment 1). During this period, the staff approved power uprates for five nuclear power plant units, resulting in a combined increase of 735 megawatts thermal (MWt) or approximately 245 megawatts electric (MWe). This brings the total number of power uprates approved since*1977 to 105, resulting in a combined increase of approximately 13250 MWt or 4417 MWe to the Nation's electric generating capacity. Ongoing Reviews of Power Uprates The staff is currently reviewing power uprates for 11 nuclear power plant units (three MUR power uprates, two SPUs, and six EPUs (Attachment 2)). If approved, these power uprates will result in 2714 MWt or 905 MWe added to the Nation's electric generating capacity. The staff has given the review of power uprates a high priority, as previously directed by the Commission. Expected Power Uprates In January 2*005, the staff surveyed all licensees to obtain informatibn on whether they planned to submit power uprate applications over the next 5 years (Attachment 3). Based on this survey and information obtained since the survey, licensees plan to request power uprates for result 28 nuclear power plant units over the next 5 years. If approved, these power uprates will in an increase of about 4139 MWt or approximbtely 1379 MWe. Based on the results of the January 2005 survey and the staffs models for\reviewing power uprates, approximately 24 full-time equivalent staff will be used to review power uprate applications expected over the next 5 years. These resources are budgeted a~d the staff does not anticipate needing additional resources for power uprate reviews. Vermont Yankee EPU Review On September 10, 2003, Entergy Nuclear Northeast (Entergy) submitted an EPU application for Vermont Yankee. Entergy requested a 20-percent (310 MWt) EPU. Some of the technical issues associated with the power uprate include: (1) steam dryer cracking, (2) FIV issues, (3) flow-accelerated corrosion, and (4) use of containment overpressure for calculating net positive suction head for emergency core cooling system pumps. The NRC has received numerous stakeholder comments, questions, and concerns regarding this proposed EPU (from members of the public, intervener groups, the State and Congress).

The Commissioners Based on the public's interest and the amount of correspondence associated with the Vermont Yankee EPU review, the staff established a communications team and developed a communication plan for Vermont Yankee. On August 30, 2004, the Vermont Department of Public Service (DPS) and the New England Coalition (NEC) filed requests for hearings in connection with the proposed EPU. The NRC established an Atomic Safety Licensing Board (ASLB) panel of three NRC administrative judges to review the requests. The ASLB found that each of the petitioners has standing to intervene. Currently, the only contentions 'that have been admitted by the ASLB and that will be argued during the hearing are two contentions from DPS related to the use of containment overpressure and two contentions from NEC related to large transient testing and the structural integrity of the cooling towers. The ASLB has not yet set a date for the hearing. The date will be set after the NRC staff provides a revised EPU schedule to the ASLB. As discussed in the NRC's letter to Entergy dated October 15, 2004, the Vermont Yankee EPU review schedule is being' impacted primarily due to concerns abobt the steam dryer analysis. On April 5, 2005, Entergy submitted a supplement to the EPU application. This submittal is the last in a series of supplements to address the concerns in the October 15, 2004, letter. The NRC staff is currently reviewing these submittals and is reassessing the review schedule. Once the reassessment is complete, the informatioh will be provided to the ACRS so that the subcommittee and full committee meeting cai be scheduled. The schedule information will also be provided to the ASLB so that a-date for thý hearing on the proposed EPU can be set as noted above. The staff will not approve the EPU license amendment until all outstanding technical issues have been resolved to the staffs satisfaction, to ensure that after approval and implementation of the EPU an adequate safety margin is maintained. The staffs timeliness goal of completing the review within one year or by the licensee's need date of the fall of 2005 likely will not be met. The staff is making every effort to meet the goal, however the staff will not sacrifice safety to meet the goal. Operating Experience Related to Power Uprates to this memorandum provides details about power uprate operating experience issues over the last year. Staff Performance vs. Established Goals Established Goals Maintaining safety remains the staffs highest priority in reviewing power uprate applications and the staff intends to ensure that safety is maintained. The staff has established performance goals of 6 months and 960'staff-hours for reviewing MUR power uprate applications, 9 months and 1800 staff-hours for reviewing SPU applications, and 12 months and 3900 staff-hours for reviewing EPU applications. The staff will continue to ensure that the goal of maintaining safety is not compromised in order to meet these timeliness and resource expenditure goals. The timeliness and resource expenditure goals assume that licensees' submittals are consistent with established guidelines; that licensees' submittals do not include other non-power

The Commissioners uprate related requests; that licensees' submittals do not result in substantive requests for additional information (RAIs); and that licensees respond to RAIs within established schedules. In establishing the above goals, the staff recognized that in some cases, licensees' plans for implementing power uprates are more flexible than the timeliness goals described above. As a result, the staff can meet its timeliness goals by either completing the reviews according to the numerical goals or by completing the reviews in time to support licensees' proposed implementation schedules, whichever is longer. This flexibility allows the staff to utilize its resources to better support other high-priority activities. Staff Performance Since the staff, at the direction of the Commission, established timeliness and resource expenditure goals for power uprate reviews, the staff has met the timeliness goals for all power uprate reviews. Specifically, for the five power uprate applications approved since June 2004, the Indian Point Units 2 and 3 SPUs were issued within the 9 months goal. The Waterford EPU, Seabrook SPU and Palisades MUR power uprate were all approved before the licensees' need dates. However, the staff only met the hourly goal for completing power uprate reviews for 2 of the 5 power uprate applications approved since June 2004. The goal hours were met for the power uprate reviews of the Palisades MUR (948 hours) and Indian Point Unit 3 SPU (1660 hours). For the Seabrook (2883 hours) and Indian Point Unit 2 (2800 hours) SPU reviews, and the Vermont Yankee (5995 hours) currently under review, and Waterford (7344 hours) EPU reviews, the staff has exceeded the hourly goals for the reviews. Attachments 4, 5, and 6 summarize the hours charged by the staff for the power uprate reviews recently completed, and for the power uprate applications currently under review. The key reason the staff exceeded the hourly goals is the quality of the power uprate applications. The applications lacked sufficient technical information to allow the staff to decide that safe plant operation will continue after the proposed power uprate. The staff had to request additional information from the licensees resulting in several supplements to the original applications. The original Waterford EPU application lacked so much technical information that 32 supplements were needed to provide the information required by the staff. To address the hourly-goal issue, the staff is using the Office of Nuclear Reactor Regulation (NRR) Work Planning Center (WPC) to control and monitor all power uprate applications. The WPC monitors the timeliness and hourly goals for power uprates. The staff is also developing additional guidance for power uprate reviews. The guidance is intended to provide project managers with a comprehensive set of directions on how to process a power uprate license amendment. The guidance will .emphasize a pre-application review of each power uprate starting approximately 1 year before the power uprate application is submitted. This will initiate a dialogue between the staff and the licensee to ensure that sufficient technical information is included in each application. The guidance will also focus on a timely and thorough acceptance review of each power uprate application. The guidance is scheduled to be issued by the end of 2005.

The Commissioners The staff' will continue to closely monitor power uprate reviews and keep the Commission informed when the performance goals are not met. Review Standard for EPUs RS-001 was issued in December 2003. RS-001 is a first-of-a.kind document that provides a comprehensive process and technical guidance for NRC EPU reviews. The document also was provides useful information to licensees for EPU applications. The development of RS-001 a significant process improvement effort and involved all divisions within NRR. The final RS fully addressed the public comments received on.the draft RS and was endorsed by the ACRS as an "excellent review standard." In previous memoranda to the Commission, the staff stated that it would ask the Committee To Review Generic Requirements (CRGR) to endorse the final version of RS-001. After discussing the matter with the staff, the CRGR chairman determined that a CRGR formal review was not required. The staff is currently using RS-001 for reviewing EPUs. The staff used RS-001 for the first time to review the Waterford EPU application, which was approved on April 15, 2005. RS-001 was developed to improve the effectiveness and efficiency of EPU reviews. The staff exceeded the review hours goals in the Waterford and Vermont Yankee reviews. The staff is performing lessons learned reviews to determine why the hourly goals were exceeded. The staff is also reviewing operating experience at plants which have implemented EPUs. The staff will make changes to RS-001 based on these reviews and operating experience insights. Interactions With Internal and External Stakeholders ACRS Briefings on the Waterford EPU The staff briefed the ACRS Subcommittee on Thermal-Hydraulic Phenomena on January 26, 2005, and the ACRS Full Committee on February 10-11, 2005, on the Waterford 8-percent EPU. The-ACRS questionedthe staff about boron precipitation during long-term cooling after a loss-of-coolant accident, large transient testing, and the effects of FIV on components as a result of the EPU. The ACRS complimented the staff on the review of the Waterford EPU as being comprehensive. In addition, the ACRS indicated that the rationale for the staffs decisions in the safety .evaluation was clear. The ACRS attributed the high quality of the staff s review to RS-001. Power Uprate Presentation at the 2005 NRC Regulatory Information Conference The NRC chaired a power uprate panel at the 2005 RIC. The panel included several distinguished industry representatives and external and internal stakeholders. The discussion focused on the challenges and operating experience of plants with approved power uprates. The session was a great success and was well attended by over 250 people. There was a frank and open exchange of information between the panel and audience.

The Commissioners States Activities In February 2005, NRR management met with representatives of the State of New Jersey, and made a presentation on the NRC's Power Uprate Program. The presentation focused on how the staff reviews and approves an EPU. The presentation included details on RS-001 and the interface between States and the NRC during an EPU review. International Activities The staff is continuing its dialogue with international regulatory counterparts on power uprates and technical challenges. The staff visited Switzerland and Sweden in June 2004 to discuss the NRC's Power Uprate Program and gathered information on lessons learned from international power uprate programs. The staff provided input on power uprates for the 2005 U.S. National Report for the Convention on Nuclear Safety. The input included a description of the NRC's Power Uprate Program and details of staff activities related to operating experience issues in plants that have implemented power uprates. In September 2005, NRR management briefed a Japanese delegation on the status of the NRC's Power Uprate Program, and the operating experience of plants which have implemented power uprates. Challenaes The staff continues to be challenged by various FIV issues at Quad Cities and Dresden, and by issues associated with EPUs currently under review. Based on these challenges, the staff is evaluating the need to modify guidance for future power uprate reviews, and the need to revisit previous reviews of power upr~tes. The staff is monitoring operating experience issues related to.power uprates to ensure that review guidance is updated and is focused on reactor safety. The staff also continues to monitor its performance related to power uprate reviews, especially the hourly goals for completing power uprate reviews. Due to extensive public interest and correspondence from stakeholders, the staff continues to be challenged with activities related to the Vermont Yankee EPU review. The staff has dedicated resources to deal with these issues. COMMITMENTS: Listed below are the actions or activities committed to by the staff in the paper:

1. Perform lessons learned reviews concerning the use of RS-001;

2. Update power uprate guidance documents as necessary;

3. Continue to monitor operating experience at plants that are operating at uprate power levels;

4. Continue to interface with owners groups;

5. Continue international exchange of information and operating experiencescontinue to monitor effectiveness and efficiency goals; and

(. The Commissioners 6. Review the inspection activities related to the power uprate program and incorporate the Vermont Yankee inspection lessons learned as appropriate. This issue will be reported to the Commission in a separate Commission paper as required in staff requirements memorandum dated December 23, 2004. IRAI Luis A. Reyes Executive Director for Operations Attachments: 1. Table 1 - Power Uprates Approved Since June 2004

2. Table 2 - Power Uprate Applications Currently Under Staff Review

3. Table 3 - Expected Power Uprate Applications

4. MUR Hourly Charges Through April 2005

5. SPU Hourly Charges Through April 2005

6. EPU Hourly Charges Through April 2005

7. Operating Experience Related to Power Uprates

TABLE I - Power Uprates Approved Since June 2004 1 Palisades 1.4 34 06/18/2003 06/23/2004 MUR 2 Indian Point 2 3,.26 101.6 01/29/2004 10/27/2004 SPU 3 Seabrook 5.2 176 03/17/2004 02/28/2005 SPU 4 Indian Point 3 4.85 148.6. 06/03/2004 03/24/2005 SPU 5 Waterford 8 275 11/13/2003 04/15/2005 EPU TOTAL 735.2 _ Power'uprates approved since June 2004 have added an additional 735.2 MWt or approximately 245 MWe to the Nation's electric generating capacity. ATTACHMENT 1

TABLE 2 - Power Uprate Applications Currently Under StaffiReview Boiling Water Reactor (BWR) Pressurized Water Reactor (PWR) 1 Vermont Yankee I BWR 20 319 09/10/2003 TBD* EPU I .I " I1I SBWR 15 494 06/25/2004 TBD*, EPU 2 Browns Ferry 2 3 Browns Ferry 3 BWR 15 494 06/25/2004 TBD* EPU 4 Browns Ferry 1 BWR 20 659 '06/28/2004 TBD* EPU 5 Palo Verde 1 PWR 2.9 114 07/09/2004 06/30/2005 SPU 6 Palo Verde 3 PWR 2.9 114 07/09/2004 06/30/2005 SPU 7 BeaIver Valley 1 PWR 8 211 10/04/2004 TBD* EPU 8 Beaver Valley 2 PWR 8 211 10/04/2004 TBD* EPU 9 Calvert Cliffs 1 PWR 1.3 37- 01/31/2005 08/01/2005 MUR 10 Calvert Cliffs 2 PWR 1.3 37 01/31/2005 08/01/2005 MUR 11 Fort Calhoun PWR 1.6 24 03/31/2005 10/01/2005 MUR TOTAL 2714 _ Power uprates currently under review could add an additional 2714 MWt or approximately 905 MWe to the Nation's electric generating capacity if approved.

The projected completion date is uncertain.

ATTACHMENT 2

TABLE 3 - Expected Power Uprate Applications 2005 I 7 1 5 01 2 959 320 2006 9 7 0 2 11177 392 2007 3 0 1 2 386 129 2008 5 0 0 .5 1309 436 2009 2 0 2 0 232 77 2010 2 2 0 0 76 25

   .TOTAL    28        14    (   3         11       4139     j  1379

"'t ATTACHMENT 3

Measurement Uncertainty Power Uprate Hourly Charges Through April 2005 1800 1600 1400 1200 1000 800 600 400 200 0 0 0 0V c00Irv Cy C, 0 M Opn R w i oI k M IOpen Reviews IClosed Reviews i~Target ATT-ACHMENT 4

Stretch Power Uprate Hourly Charges Through April 2005 ý Open Reviews n Rosed Reviews . -Target ATTACHMENT 5

(~9 Extended Power Uprates Hourly Charges Throuah ADril 2005 8000 - 7000 - 6000 - 5000 =4000 3000 - 2000* 1000 0 1998 2001 '002 2005

                                                                                  ~rp 0<<

iOpen Reviews ao eiws -Target ATT-ACH ME NT 6 OPERATING EXPERIENCE RELATED TO POWER UPRATES Flow-Induced Vibration Issues The commercial nuclear industry has experienced several incidents of steam dryer cracking and FIV issues at nuclear power plants operating at EPU conditions. The NRC staff continues to closely monitor plant-specific actions and the industry's generic response to this issue. Based on its review, the staff will consider the need for additional regulatory actions. In June 2002 and again in June 2003, Quad Cities Unit 2 experienced failures of its ATTACHMENT 7

steam dryer during 17 percent EPU operation. Similarly, the steam dryer in Quad Cities Unit 1 failed during 17 percent EPU operation in November 2003. During a March 2004 refueling outage, Exelon discovered additional cracks in the steam dryer in Quad Cities Unit 2. Exelon identified less significant cracks in the steam dryers in Dresden Units 2 and 3 during their outage inspections. Exelon repaired the damaged steam dryers at Quad Cities and Dresden to improve their structural capability following each instance of steam dryer degradation. In addition to steam dryer cracking, FIV contributed to failures of feedwater sampling probes at-Dresden Units 2 and 3, the inoperability of an electromatic relief valve, and degradation of other main steam components and pipe supports at Quad Cities Unit 1. In response to the adverse flow effects at Quad Cities Units 1 and 2 and subsequent analyses, Exelon committed to maintain those units at pre-EPU power levels, except for limited EPU testing, until the NRC staff is satisfied that the FIV issue is resolved. During the Quad Cities Unit I refueling outage in March 2005, Exelon identified cracks in its steam dryer similar to those found in other BWRs operating at uprated power conditions (as well as non-uprated power conditions). The licensee evaluated the structural 'capability of the modified steam dryers in Dresden Units 2 and 3, and has returned those units to EPU operation. The staff does not consider the FIV issue to pose safety concerns. However, steam dryers and other internal main steam and feedwater components must maintain structural integrity to avoid generating loose parts. Exelon is planning to install new steam dryers with-an improved design in Quad Cities Units 1 and 2 in 2005. The enhanced features of the new steam dryers include thicker outer hoods and cover plates, curved edges to reduce FIV, and slanted outer hood plates. In addition, the new steam dryer in Quad Cities Unit 2 will be instrumented to obtain direct data about the FIV loads acting on the dryer during EPU operation. Over the past 6 months, the staff has conducted numerous public meetings with Exelon to discuss the licensee's FIV analyses for the Dresden and Quad Cities steam dryers and other components, and its extent of condition review of EPU FIV issues. The staff also observed the fabrication of the Quad Cities replacement steam dryers, and installation of the instrumentation on the Quad Cities Unit 2 replacement steam dryer. The staff is currently reviewing the licensee's design and analysis of the replacement steam dryers for Quad Cities Units 1 and 2 to demonstrate its structural capability for EPU conditions, and the startup test procedure for Quad Cities Unit 2 following the steam dryer replacement. The staff expects Exelon to request NRC approval to return Quad Cities Units 1 and 2 to EPU power following replacement of their steam dryers. Entergy has modified the steam dryer at Vermont Yankee to increase its structural capability in support of its request to operate the plant at EPU conditions. The licensee recently submitted an analysis of the structural capability of the modified steam dryer at Vermont Yankee. The staff is currently reviewing the licensee's analysis. The staff monitors the inspection results of steam dryers in BWR plants during refueling outages for potential adverse flow effects. For example, licensee inspections of the slanted hood steam dryer at LaSalle Unit 2 in the spring of 2005 found only indications on the lug support bracket only after several years of operation at 5 percent power uprate conditions. Further, licensee inspections of the slanted hood steam dryer at Brunswick Units 1 and 2 in the spring of 2005 following several years of EPU operation found several fatigue and stress corrosion cracks that the licensee has resolved by

I. repair or analysis. The BWROG is leading the industry's efforts in assessing the generic implications of potential adverse flow effects of power uprate operation, and has several initiatives underway to address this issue. The BWROG issued a lessons learned report in November 2004 to help licensees avoid adverse flow effects of EPU operation. General. Electric also revised its steam dryer inspection guidelines in November 2004 in response to industry experience with adverse flow effects under EPU conditions. The staff has provided comments to the BWROG on its EPU lessons learned report and the revised. General Electric steam dryer inspection guidelines. The staff will continue to hold public meetings with the BWROG to discuss industry activities to resolve this issue. The Office of Nuclear Reactor Regulation (NRR) is working with the Office of Nuclear Regulatory Research (RES) on the long-term resolution of potential adverse flow effects of power dprate. operation. RES has.assisted NRR during reviews of steam dryer analyses presented by licensees at public meetings. NRR is assisting RES in compiling "an operating experience report on adverse flow effects of EPU operation at BWR plants. The BWROG has several initiatives to assess industry-wide operating experience with post-EPU FIV issues. NRR is also working with RES in assessing the industry's resolution of the issues. - Abnormalities in Ultrasonic'Flow Meter Instrumentation The staff is following the industry's evaluations of a problem at plants that use an ultrasonic flow meter of the type used for MUR power uprates. This problem has led to unexpected but small differences in power level indications at some plants. The staff is closely monitoring this issue to identify information relevant to the use of feedwater measurement techniques in power uprate applications. The staff is also clarifying the safety evaluation basis for feedwater measurement techniques in power uprate applications, based on the operating experience. After completing the evaluation of pending MUR power uprate applications, the staff will determine whether a generic communication or updating staff review guidance is needed.

O POLICY ISSUE (Information) June 24, 2004 SECY-04-0104 FOR: The Commissioners FROM: Luis A. Reyes Executive Director for Operations IRA/

SUBJECT:

STATUS REPORT ONPOWER UPRATES PURPOSE: To provide the Commission an update on the ýtatus of power uprate activities. This memorandum summariZes the staff's accomplishments and challenges since the last update in SECY-03-0190, dated November 3, 2003. The staff will continue to keep the Commission informed of the status of power uprate activities by providing annual status reports and by other means as appropriate. This status report is generated in response to a staff requirements memorandum dated February 8, 2002.

SUMMARY

Since the last status update, the staff has made progress in reviews of plant-specific power uprates, stayed abreast of operating experience with potential effects on power uprate reviews, continued to monitor performance related to the effectiveness and efficiency measures established for power uprate reviews, and continued to look for ways to improve the power uprate process. Details of the staff's progress are provided in this Commission paper and the attachments. In summary, the staff has: CONTACT: Anthony C. McMurtray, NRR (301) 415-4106 Docket No. 7195 Attachment 1-3 15 Pages

1 " approved two plant-specific power uprates " issued final Review Standard (RS)-001, "Review Standard for Extended Power Uprates" on December 24, 2003 " conducted additional inspections of Exelon Generating Company, LLC's (Exelon's), evaluations of the causes and subsequent repairs of the steam dryer damage at Quad Cities Unit 2 - issued a commitment acknowledgment letter on April 20, 2004, regarding Exelon's commitments for long-term extended power uprate (EPU) operation at the Dresden and Quad Cities units " continued to engage General Electric Nuclear Energy (GENE) and the Boiling Water Reactor Owners Group regarding steam dryer damage and flow-induced vibration issues " issued Supplement 2 to Information Notice 2002-026, "Additional Flow-Induced Vibration Failures after a Recent Power Uprate" " met with Westinghouse on April 22, 2004, to discuss ongoing issues related to the Advanced Measurement and Analysis Group (AMAG) ultrasonic flow meters " issued an acceptance review letter for the Vermont Yankee Nuclear Power Station (Vermont Yankee) EPU application on February 20, 2004 " issued a letter to the Vermont Public Service Board on May 4, 2004, noting that the Nuclear at Regulatory Commission (NRC) would perform a pilot engineering assessment inspection Vermont Yankee " engaged external stakeholders, including Congressional delegates and their staff, through and the ,,,public meetings and correspondence regarding the Vermont Yankee EPU application need for an independent safety assessment (ISA) at Vermont Yankee

presented information to the full committee of the Advisory Committee on Reactor Safeguards (ACRS) on unanticipated effects of power uprates, and the ACRS Subcommittee on Thermal-Hydraulic Phenomena on potential adverse flow effects from power uprates the
presented power uprate reports at the 2004 NRC Regulatory Information Conference, International Conference of Nuclear Engineering (ICONE), and at an American Nuclear Society (ANS) meeting BACKGROUND:

Power uprates are categorized based on the magnitude of the power increase and the methods result used to achieve the increase. Measurement uncertainty recapture (MUR) power uprates in power level increases that are less than 2 percent and are achieved by implementing enhanced techniques for calculating reactor power., Stretch power uprates typically result in power level increases that are up to 7 percent and generally do not involve major plant modifications. EPUs result in power level increases that are greater than stretch power uprates 1 Subsequent to the staff's approval of one of the power uprates which was an MUR power uprate for Fort Calhoun, the staff approved an exigent license amendment request to return Fort Calhoun's maximum licensed operating power level back to the pire-MUR power level.

and usually require significant modifications to major plant, equipment. The NRC has approved EPUs for increases as high as 20 percent. The staff provided its last update in SECY-03-0190, dated November 3, 2003. This memorandum summarizes the staff's accomplishments and challenges since the last update. The staff will continue to keep the Commission informed of the status of power uprate activities by providing annual status reports and by other means as appropriate. This status report is generated in response to a staff requirements memorandum dated February 8, 2002. DISCUSSION: Power, Uprate Applications Approved Power Uprates This status update covers power uprates approved since November 3, 2003 (Attachment 1). During this period, the staff approved power yprates for two nuclear power plant units, resulting in a combined increase of 99 megawatts thermal (MWt) or about 35 megawatts electric (MWe). This brings the total number of power uprates approved since 1977 to 101, resulting in a combined increase of approximately 12513 MYVt or 4173 MWe to the Nation's electric generating capacity. The staff approved an MUR power uprate for Fort Calhoun on January 16, 2004., which authorized an increase in the licensed thermal power limit to 1524 MWt. The Omaha Public Power District wvas subsequently informed by Westinghouse that potential instrument inaccuracies in the AMAG ultrasonic flow meter would not allow implementation of the MUR power uprate at Fort Calhoun. Asa result, on May 7, 2004, prior to implementation of the MUR power uprate,'the Omaha Public Power District submitted an exigent license amendment request to return Fort Calhoun's licensed thermal power limit to 1500 MWt, the pre-MUR level. On May 14, 2004, the staff approved this license amendment request, returning the licensed maximum power level at Fort Calhoun to 1500 MWt. Ongoing Reviews of Power Uprates The staff is currently reviewing power uprates for five nuclear power plant units. These include one MUR power uprate, two stretch power uprates, and two EPUs (Attachment 2). If approved, these power uprates would result in a combined increase of an additional 907 MWt or 325 MWe to the Nation's electric generating capacity. As in the past, the staff has given the review of these power uprates a high priority. Expected Power Uprates In January 2004, the staff conducted a survey of all licensees to obtain information regarding their plans for submitting power uprates over the next 5 years (Attachment 3). Based on this survey and information obtained since the survey, licensees plan to request power uprates for

24 nuclear power plant units over the next 5 years. If approved, these power uprates would result in an increase of about 5018 MWt or about 1692 MWe. Based on the results of the January 2004 survey and the models the staff developed for reviewing power uprates, approximately 29 full-time equivalent staff will be used for reviewing the power uprates expected over the next 5 years. These resources are budgeted and the staff does not anticipate any need for additional resources for power uprate reviews. Vermont Yankee Extended Power Uprate Review In a letter dated December 15, 2003, the NRC notified Entergy Nuclear Operations, Inc. (Entergy), that its EPU application for Vermont Yankee lacked sufficient information in several areas needed to allow the NRC staff to complete a detailed review of the application. These areas included: (1) applicability of analyses in GENE's Constant Pressure Power Uprate (CPPU) Licensing Topical Report to Vermont Yankee, (2) insufficient information for the NRC staff to arrive at an adequate safety conclusion based on the template safety evaluation in RS-001, and (3) steam dryer integrity analysis. Entergy submitted additional information to the NRC on January 31, 2004. The staff evaluated the additional information and responded to Entergy on February 20, 2004, noting that Entergy had provided the necessary information to allow the staff to proceed with the detailed technical review. The staff's review of this amendment request is expected to be completed by January 31, 2005. Operating Experience Related to Power Uprat~s to this memorandum provides details regarding power uprate operating experience issues. Review Standard for EPUs Issuance of RS-001 RS-001 was issued in December 2003. RS-001 is a first-of-a-kind document that provides a comprehensive process and technical guidance for EPU reviews by the NRC staff and. provides useful information to licensees for EPU applications. The development of RS-001 was a significant process improvement effort and involved all divisions within the Office of Nuclear Reactor Regulation (NRR). The final RS fully addressed the public comments received on the draft RS and was endorsed by the ACRS as an "excellent review standard." In previous memoranda to the Commission, the staff stated that it would seek endorsement from the Co'mmittee to Review Generic Requirements (CRGR) of the final version of RS-001. Following dialogue with the staff, the CRGR Chairman determined that formal review by the CRGR was not required. The staff is currently using RS-001 for the review of the proposed 20-percent EPU for Vermont Yankee and the proposed 8-percent EPU for the Waterford Steam Electric Station.

The staff will closely monitor these ongoing EPU reviews to identify any issues with the use of RS-001. Assessment of Past Requests for Additional Information During the development of draft RS-001, the staff reviewed requests for additional information (RAIs) issued during the reviews of recently approved EPUs to ensure that RS-001 addressed the issues identified as a result of the staff's reviews of those 'EPUs. The staff is preparing a summary of this review and plans to make it available to internal and external stakeholders. The staff believes that making the results of this summary available to licensees could aid them in preparing high quality applications. In SECY-03-0190, the staff committed to complete the assessment of past RAIs by the end of 2003. Due to ongoing activities related to the Vermont Yankee EPU and steam dryer cracking and flow-induced vibration issues, this assessment has not been completed. The staff plans to complete this task by the end of 2004. Staff Performance vs. Established Goals Established Goals Maintaining safety remains the staff's highest priority when conducting power uprate reviews and the staff intends to take the time necessary to ensure that safety is maintained. The staff has established performance goals of 6 months and 960 staff hours for completing the review of a MUR power uprate application, 9 months and 1800 staff hours for completing the review of a'stretch power uprate application, and 12 months and 3900 staff hours for completing the review of an EPU application. The staff will ensure that the goal to maintain safety is not compromised in order to meet these timeliness and resource expenditure goals. The timeliness and resource expenditure goals are predicated on licensees' submittals being consistent with established guidelines; licensees not including other non-power uprate related requests in their submittals; licensees' submittals not resulting in substantive RAIs; and licensees responding to RAls within established schedules. In establishing the above goals, the staff recognized that in some cases, licensees' plans for implementing power uprates are more flexible than the numerical timeliness goals described above. As a result, the staff may meet its timeliness goals by either completing the reviews according to the numerical goals or by completing the reviews in time to support licensees' implementation schedules, whichever is longer. This flexibility allows the staff to better utilize its resources in a way to support other high priority activities. Staff Performance One of the two power uprates the staff approved during the period covered by this status report was for a MUR power uprate. It was completed within the staff's established timeliness goal of 6 months and the established goal of 960 staff review hours. The staff also approved a

6-percent power uprate for Kewaunee during this period. The review was completed within the staff's established timeliness goal of 9 months. However, the review required over 2600 staff review hours to complete due to the following reasons: (1) some necessary technical analyses were not provided in the original application, (2) some technical information lacked sufficient detail to support the requested changes and resulted in the staff issuing multiple RAIs, and (3) late in the review of this application, the staff identified areas where additional information was needed resulting in further delays and a reduction in efficiency. The staff will continue to closely monitor power uprate reviews and keep the Commission informed of instances where the performance goals are not met. Interaction With Internal and External Stakeholders ACRS Briefings on Potential Adverse Flow Effects from Power Uprates NRR management briefed the full committee of the ACRS on March 5, 2004, regarding unanticipated effects of power uprates. The staff. briefed the ACRS Subcommittee on Thermal-Hydraulic Phenomena on May 7, 2004, on potential adverse flow effects from power uprates and the Office of Nuclear Regulatory Research's (RES's) plan to assess potential adverse flow effects during boiling-water reactor power uprates. RES is developing computational fluid dynamics and finite element analysis models to perform thermal hydraulic and structural analyses of the steam dryer cracking issue. The ACRS challenged the staff regarding the staff's understanding of the causes and the adequacy of repairs of steam dryer cracking at plants that have implemented EPUs. The ACRS also expressed concern about the lack of risk analyses regarding the dryer cracking at these plants. The staff is evaluating the ACRS comments. Vermont Yankee Power Uprate Stakeholder Issues Based on the substantial amount of public interest and correspondence associated with the Vermont Yankee EPU review from various public officials, public interest groups, and other stakeholders, the staff established a communications team and developed a communication plan for Vermont Yankee. Additionally, NRR has temporarily established a new project section that is developing and coordinating communications for all of the various Vermont Yankee issues. On January 15, 2004, the NRC .staff held a conference call with senior staff members for Vermont Senators Jeffords and Leahy in response to their constituents' requests for an ISA inspection of Vermont Yankee (similar to the Maine Yankee inspection). The NRC staff also discussed the EPU review process and the status of the NRC's review of the Vermont Yankee EPU application. Following this call, the NRC received a letter from Senator Leahy's office requesting an overview of the NRC's review process for the Vermont Yankee EPU application.

The staff sent a response describing its EPU review process in a letter dated February 20, 2004. The Vermont State Senate passed a resolution in March 2004 requesting that the NRC perform an independent engineering assessment at Vermont Yankee. The NRC also received a letter from the Vermont Public Service Board on March 15, 2004,. requesting that the NRC perform an independent engineering inspection at Vermont Yankee to support the ongoing NRC review of the Vermont Yankee EPU application. The NRC issued its response on May 4, 2004, noting that the NRC would perform a pilot engineering inspection at the site and was willing to meet with the Vermont Public Service Board. On March 29, 2004, in response to a February 27, 2004, letter from Senators Jeffords and Leahy, the NRC stated that it will hold a public meeting in Vernon, Vermont, near Vermont Yankee, to discuss the status of the agency's review of Entergy's EPU request for Vermont Yankee. Additionally, certain stakeholders have raised a concern regarding the adequacy of Entergy's analyses supporting its EPU amendment request. The staff is preparing responses to stakeholder letters and evaluating the'concern during the EPU review. Vermont Yankee Power Uprate Public Meeting On March 31, 2004, the NRC held a public m6eting in Vernon, Vermont, near Vermont Yankee, to discuss the status of the agency's review oý Entergy's EPU request for Vermont Yankee. More than 500 people attended this meeting, i~cluding several State and local public officials from Vermont, Massachusetts, and New Hampshire, as well as representatives of Senators Leahy and Jeffords. Many people at this meeting voiced concerns about the power uprate process and expressed their desire for an' independent engineering inspection at Vermont Yankee to support the proposed EPU. Power Uprate Presentation at the 2004 NRC Regulatory Information Conference NRC management presented a report on power uprates and other licensing actions during a panel session of the 2004 Regulatory Information Conference. The presentation included details about RS-001 and information on several technical challenges that the staff has been addressing related to power uprates. These challenges include steam dryer cracking and flow-induced vibration issues at plants that have implemented EPUs, interpretations of GENE EPU topical reports, and issues with the AMAG ultrasonic feedwater flow meter measurement systems. International Activities The staff is continuing dialogue with international regulatory counterparts related to power uprates and technical challenges. The staff is scheduled to visit Switzerland and Sweden in June 2004 to discuss the NRC's Power Uprate Program and gather information regarding developments and lessons learned with international power uprate programs. The staff provided input on power uprates for the 2004 U.S. National Report for the Convention on Nuclear Safety. This input included a description of the NRC's Power Uprate Program and details of staff activities related to operating experience issues from plants that have implemented power uprates.

Power Uprate Presentation at the American Nuclear Society International Winter Meeting The staff made a presentation on the NRC's Power Uprate Program during a 2-day workshop at the 2003 ANS International Winter Meeting in November 2003. The workshop covered several power uprate topics, including an NRC staff presentation on the regulatory aspects of power uprates. The audience at the workshop included domestic and foreign representatives of utilities interested in power uprates. Presentation at the 12t International Conference on Nuclear Engineering On April 28, 2004, the staff presented a report on power uprates during a panel session at the 120' ICONE. The staff's presentation included information regarding final RS-001, methods that licensees can follow for improving NRC reviews of power uprates, and technical challenges resulting from power uprates.. Challenqes The staff continues to face challenges with technical issues including the Quad Cities steam dryer failures, various flow-induced vibration issues at Quad Cities and Dresden, and ultrasonic flow meter reading abnormalities at Byron, Briidwood, and Fort Calhoun. Based on these challenges, the staff is evaluating the need for modifying its guidance for future reviews of power uprates, and the potential need to revisit prior reviews of power uprates. The staff is monitoring operating experience related to power uprates to ensure that review guidance is updated and focused on reactor safety. The staff also continues to monitor its performance related to power uprate reviews to identify areas for further improvement. Due to extensive public interest and correspondence from various public officials, public interest groups, and other stakeholders, the staff continues to be challenged with activities related to the Vermont Yankee EPU review. As noted above, to meet these challenges, the staff has dedicated resources for these issues. IRA Martin Virgilio Acting For! Luis A. Reyes Executive Director for Operations Attachments: 1. Table 1 - Power Uprates Approved Since November 3, 2003

2. Table 2 - Power Uprate.Applications Currently Under Staff Review

3. Table 3 - Expected Power Uprate Applications

4. Operating Experience Related to Power Uprates

TABLE 1 - Power Uprates Approved Since November 3, 2003 1 Fort Calhoun* 1.6 24 7/18/2003 1/16/2004 MUR 2 Kewaunee 6.0 99 5/22/2003 2/27/2004 S Power uprates approved since November 3, 2003, have added an additional 99 megawatts thermal or approximately 35 megawatts electric to the Nation's electric generating capacity.

Due to an exigent license amendment approved by the staff on May 14, 2004, Fort Calhoun's authorized licensed power level was returned to the pre-MUR level.

      'TYPE  -- S Stretch; MUR = Measurement Uncertainty Recapture ATTACHMENT 1

TABLE 2 - Power Uprate Applications Currently Under Staff Review 1 Palisades 1.4 35 6/3/2003 June 2004 MUR

  .2 Vermont Yankee             20              319          9/10/2003   1 January 2,005          EPU 3 Waterford 3                8              275          11/13/2003. January 2005           EPU 4 Indian Point 2            3.3              102          1/29/2004     October 2004            S 5 Seabrook                  5.2              176          3/17/2004          TBD*               S Power uprates currently under review could add an additional 907 ,megawatts thermal or 325 megawatts electric to the Nation's. electric generating capacity if approved.

Seabrook's projected completion date is still being determined.

1 TYPE -- EPU = Extended Power Uprate; S = Stretch; MUR = Measurement Uncertainty Recapture ATTACHMENT 2

TABLE 3 - Expected Power Uprate Applications Megawats Fiscal. Total Power, U6'rates Stretch, 'EPU~s Megawatts

             ~; Expected&            Power        Pow~er                 IThermal Megawatts4' Yea                                                                             Electric '

Uprates UJprate's 2004 12 2 3 7 3538 1196 2005 4 3 0 1' 362 121 2006 5 3 0 2 426 142 2007 2 0 1 1 333 111 2008 1 0 0 1 365 122 ITOTAL 24 8' 4:44 12~ 5018 <1 692 MUR = Measurement Uncertainty Recapture; EPU = Extended Power Uprate ATTACHMENT 3

I .. OPERATING EXPERIENCE RELATED TO POWER UPRATES Damage of Steam Dryers and Other Plant Components at Quad Cities and Dresden Exelon Generating Company, LLC (Exelon), has discovered cracks in the steam dryer on three separate occasions at Quad Cities Unit 2 since the unit has operated at EPU power levels. Exelon also found cracks in the steam dryers at Dresden Units 2 and 3 and Quad Cities Unit 1. Flow-induced vibration contributed to failures of feedwater sampling probes at Dresden Units 2 and 3 and inoperability of an electromatic relief valve at Quad Cities Unit 1. Loose parts in the reactor coolant system have been generated from pieces of cracked steam dryers and flow-induced vibration damaged feedwater probes. The staff has determined that these issues do not pose an immediate safety concern given the current operating conditions at Quad Cities and Dresden. However, steam dryers and other internal main steam and feedwater components must maintain structural integrity to avoid generating loose parts that could impact safety system or reactor plant operation. Since 2002, steam dryer cracking and flow-induced vibration damage on components and supports for the main steam and feedwater lines have been observed at Dresden and Quad.Cities following implementation of extended power uprates (EPUs). In June 2002, approximately 3 months following implementation of a 17.8-percent EPU, Quad Cities Unit 2 experienced an increase in the moisture content of the steam flowing to the turbine. In July 2002, the licensee shut down Quad Cities, Unit 2, for inspection and identified cracks in the steam dryer. The licensee repaired the steam dryer, and returned the unit to power operation at the EPU power level. The steam dryer is not a safety-related component, but is required to mnaintain its structural integrity. Approximately 10 months following restart of Quad Cities, Unit 2 from the.outage to repair the steam dryer, the plant experienced a similar increase in the moisture content of the steam. The licensee shut down the plant for inspection of the steam dryer and identified cracks in several locations of the steam dryer. On November 12, 2003, Quad Cities Unit 1 was shut down to perform inspections and repairs of the steam dryer. The unit had been operating at a reduced power level since November 3, 2003, due to indications of higher-than-normal moisture carryover in the reactor steam. On November 13, 2003, the steam dryer was found damaged during inspections following reactor disassembly. The damage occurred in the /2 inch-thick upper dryer hood cover plate. The cover plate had cracks approximately 51 inches in total length and a 6 inch by 9 inch portion of the plate broke off from the steam dryer. Exelon conducted extensive inspections in an effort to locate the lost steam dryer piece(s). The piece(s) were not recovered; however, Exelon has found indications on a recirculation pump impeller. Based on these indications, the material is most likely in the bottom of the reactor vessel. The licensee conducted.a loose part analysis to determine potential effects on plant systems and concluded that it was safe to operate the plant with the loose part in the vessel. The staff reviewed the licensee's loose partanalysis and agreed with the licensee. Repairs and modifications, similar to those completed on the Quad Cities Unit 2 steam dryer earlier in 2003, were also completed on Unit 1. ATTACHMENT 4

Also during the November 2003 Quad Cities Unit 1 outage, Exelon discovered that the pilot vent line on a main steam line electromatic relief valve was sheared off from the pilot assembly and the solenoid actuator for the valve was significantly damaged. Flow-induced vibration on the main steam line during EPU operating conditions contributed to this damage. Exelon replaced the damaged solenoid actuator and rewelded the pilot vent line to the pilot assembly on the relief valve prior to restarting the unit. During the fall 2003 refueling outage at Dresden Unit 2, Exelon found cracking on the steam dryer, but it was not through-wall. There were no indications of higher-than-expected moisture carryover in the reactor steam at Dresden Unit 2 during the previous operating cycle. Repairs and modifications, similar to those performed on the dryers at Quad Cities Units I and 2, were completed on the steam dryer at Dresden Unit 2 during this recent refueling outage. Additionally, Exelon found three holes in a feedwater sparger and an isokinetic feedwater sampling probe in the sparger at Dresden Unit 2. Exelon believed that the probe apparently caused the damage to the sparger. Exelon determined that the probe failed due to mechanical, high-cycle fatigue induced by flow vibrations during the previous operating cycle. A feedwater sampling probe also failed at Dresden Unit 3 following EPU operation. This probe was never found. The staff issued Information Notice (IN) 2004-06, "Loss of Feedwater Isokinetic Sampling Probes at Dresden Units.2 and 3, on March 26, 2004, to inform licensees about this issue. On February 24, 2004, Quad Cities Unit 2 waý shut down for a scheduled refueling outage and for inspections of the steam dryer. After approximately 6 months of operation at EPU conditions, Exelon identified several new cracks on the steam dryer at Quad Cities Unit 2, including cracking on areas of the steam dryer that were modified to address previous problems identified with the steam dryer,. Exelon repaired the steam dryer and developed a plan to attempt to identify the mechanism that has been causing unacceptable steam dryer loads and steam dryer cracking. On March 28, 2004, Exelon returned Quad Cities Unit 2 to operation at the pre-EPU power level and will hold the unit at this power level except to conduct testing at EPU conditions, for brief periods of time, to establish the steam dryer loads with respect to flow rates and to identify any operating limitations. Exelon has held Quad Cities 1 to pre-EPU power to levels since returning the unit to operation following the November 2003 outage and plans continue to operate the unit at pre-EPU levels until the results of the tests at Quad Cities 2 are evaluated. Based on longer EPU operation and less observed steam dryer damage at the Dresden units, in comparison to the Quad Cities units, Exelon believes that sufficient basis exists to continue to operate Dresden Units 2 and 3 at EPU power levels. Exelon plans to inspect the steam dryers at the Quad Cities and Dresden units at the next applicable refueling outages. On April 2, 2004, Exelon committed to the Nuclear Regulatory Commission (NRC) to maintain both Quad Cities units at pre-EPU power levels, except for testing of the flow effects on the Quad Cities units. The NRC sent Exelon a commitment acknowledgment letter on April 20, 2004, documenting Exelon's commitments and the NRC's assessment of those commitments. In the April 20, 2004, letter, the NRC staff noted ,concerns with Exelon's plans to justify long-term EPU operation of the Quad Cities units and Exelon's summary basis for continued long-term EPU operation of the Dresden units. On May 12, 2004, Exelon provided an update to its commitments regarding EPU operation of the Quad Cities and Dresden units. In particular, Exelon will not exceed pre-EPU levels at the Quad Cities units until demonstrating

(9 to the NRC staff that EPU operation is justified. Exelon also provided additional information for support of the continued EPU operation of the Dresden units. The staff is closely monitoring industry's generic response to the failures. General Electric Nuclear Energy (GENE) issued Services Information Letter (SIL) No. 644, "BWR/3 Steam Dryer Failure," on August 21, 2002, to inform its customers of the first steam dryer failure and SIL No. 644, Supplement 1, "BWR Steam Dryer Integrity," on September 5, 2003, to inform its customers of the second steam dryer failure. Both of these documents provided recommendations for monitoring steam dryer performance to ensure that steam dryer degradation is promptly identified. The staff issued IN 2002-026, "Failure of Steam Dryer Cover Plate after a Recent Power Uprate," on September 11, 2002, to inform licensees of the first failure and Supplement 1 to IN 2002-026, "Additional Failure of Steam Dryer after'a Recent Power Uprate," on July 21, 2003, to inform licensees of the second failure. On January 9, 2004, the staff issued Supplement 2 to IN 2002-026, "Additional Flow-Induced Vibration Failures after a Recent Power Uprate," to inform licensees of the failure of the steam dryer and other plant components at Quad Cities, Unit 1. In addition, the staff has provided comments to the Boiling Water Reactor Owners Group (BWROG) on the technical evaluation and recommendations contained in SIL No. 644. The staff held meetings with the BWROG and GENE on February 3 and March 4, 2004, to discuss industry's actions related to resolution/of BWR steam dryer integrity and other EPU concerns. On May 7, 2004, the BWROG provided the results from its EPU survey'and the Institute of Nuclear Power Operations databas6 review. The staff is considering its regulatory options based on the industry's response, including the ongoing activities noted above. Abnormalities in Ultrasonic Flow Meter Instrumentation Readings On August 28, 2003, Exelon informedthe staff that it was reducing the operating power of Byron Units 1 and 2 by 32 megawatts thermal (MWe) and 22 MWe, respectively. The decision was made following analysis of feedwater flow data derived from the Westinghouse/AMAG "CROSSFLOW" ultrasonic flow meters (AMAG UFMs) used at Byron and Braidwood. The AMAG UFMs were used to adjust the feedwater flow rate indications from the venturi meters to compensate for possible venturi fouling during an operating cycle. Exelon reported that there were unexpected, small differences in power level indications while using the AMAG UFMs. On September 1, 2003, the power at Braidwood Unit 2 was reduced due to problems with the AMAG UFM. Westinghouse issued Technical Bulletin (TB) 03-6 on September 5, 2003, to inform its customers of the abnormalities experienced at the Byron and Braidwood plants. TB 03-6 also provided recommendations for plants to monitor their instrumentation to promptly identify any such abnormalities at their plants. Westinghouse issued a Nuclear Safety Advisory Letter (NSAL)-03-12 on December 5, 2003, describing this issue and providing recommendations to licensees using the AMAG system. On February 6, 2004, a tracer test of the feedwater flow rates was conducted at Byron to obtain an accurate measure of the feedwater flow and compare this measurement with the AMAG UFM. The test results indicated that there were differences in flow measurements between the AMAG UFM reading and the tracer test results. On February 12, 2004, Westinghouse issued TB-04-4, which provided information regarding recent AMAG UFM system performance issues

including the results of the tracer test. Braidwood and Byron are no longer using the AMAG UFM system to measure feedwater flow. The NRC staff met with Westinghouse on April 22, 2004, to discuss ongoing activities related to' the AMAG UFMs. Westinghouse has implemented an action plan to perform scale model testing and obtain industry performance data. Additionally, the Westinghouse Owners Group (WOG) has notified the NRC that it is adopting the AMAG issue as an industry initiative. The WOG is soliciting industry support and will take over the Westinghouse action plan. The staff continues to follow this issue for any implications for plants that have implemented MUR power uprates. There are 12 nuclear reactor units in the United States that have received staff approval for MUR power uprates based on the use of the AMAG UFM system. An MUR power uprate for Fort Calhoun was authorized on January 16, 2004, which allowed an increase in the licensed thermal power limit to 1524 MWt. The licensee was subsequently informed by Westinghouse that potential instrument inaccuracies in the AMAG UFM would not allow implementation of the MUR power uprate at Fort Calhoun. As a result, on May 7, 2004, prior to implementation of the MUR power uprate, the licensee submitted an exigent license amendment request to return Fort Calhoun's licensed thermal power limit to 1500 MWt, the pre-MUR level. On May 14, 2004, the staff appr6ved this license amendment request, returning the licensed maximum power level at Fort Calhoun to 1500 MWt. Currently, the issues identified with the AMAG UFMs at Byron, Braidwood, and Fort Calhoun have not been shown to be a problem at nuclear units that have implemented MUR power uprates using the AMAG UFM system.

Docket No. 7195 Attachment 1-4 5 Pages Quad Cities',new steam dryers project For the first time ever, Exelon performed the replacement of a pair of steam dryers. E XELON GrENERATION'S Q 1 AD Cities nuclear power plant installed new steam dryers in the site's boiling water reactors earlier this year. Quad Cities, in Cordova, Ill., has two General Electric BWRs, each rated at 867-MWe (net design electric rating). Unit I started commercial operation in February 1973 and Unit 2 in March 1973. The installation project, which took place during outages at Unit I in April and Unit 2 in May, was a first for Exelon and its con-tractor, Barnhart Crane and Rigging..The utility-contractor team worked together on the off-site assembly of the steam dryers, transporting thern to the site, removing and replacing siding from the reactor building, and designing, fabricating, and building a temporary platform and slide rail system that were used to get the dryers inside the reactor building. Once inside, the dryers were moved from a temporary containment airlock to the refueling floor for their even-tualoinstallation in the reactors. The steam dryers, manufactured in Penn-sylvania by GE, weigh 55 tons each. The width of each dryer is 20 ft 7 in., and the height is 17 ft 10 in. After manufacture, the dryers were transported in March in pieces to an assembly plant in Illinois. Once as-sembled, the dryers traveled 15 miles down the road aboard a hydraulic platform trailer to the Quad Cities plant.

                                   *The utility-contractor team focused on minimizing the project's impact on plant activities. Seismic and tornado loads were
                                -important considerations for the team in the design and fabrication of the tempo-rary platform, which had to be capable of supporting more than 110 000 pounds.

Once on the plaiform, the dryers were seated on a slide rail system that used hy-draulics to transport each one into the air-lock through a series of small moves, 30 inches at a time. The distance covered along the slide rail system was about 30 feet, almost an hour's worth of work. Clearances were as tight as a couple of inches for moving the dryers through the airlock doors. Tolerances were less than that for other parts of the job. 40 4NUCLEAR NEWS October 2005

                                                                               ýfO41i5!Lerr- /A temporary piattornl was 411f.assembled                on the exterior of the Quad Cities reactor building      J in anticipation of accepting a pair of new steam dryersthaIt ultim.tMen weould be installed in the piesboplantbing water 3                          Z                          reactors. After the platform was assembled, a hole was cut and a:

doorway placed inthe buildings side. (Photos. pp.41-44: Barnhart Crane and Rigginj), BlW: olowing the assembly ransorted IS miles aboardpa hydraulic platformitallerto, the Quad Cities: plant.One dryer arrivd n Apind the other in y. Stof tde steamrdrye.s atna local arnue thropugh PbowWR. ihrou 4 Steamd(Ivers are uasd 1i3tiona h3WnRs-not in prdssttri/ trbine. i er When wet stearn i reptaors' K formed in aoWR ii leaves: theK ' core and poer through a r*al si

 .separator, ju' like in 'a MWR But unlike a PWl-, the: ,1ean in a BWR. abso gpe' through atj'~K steam, dryer. :where aidd itionalK nmoisture, i,; removed. 11e stamtn thieni procceds to the itirbine.

This~ wa.Aic h rsl time. Ex-§ elon had ever replaced S.team tv drvers.in inv ol its BW~R~s and it was, one ol 7thje first replace- KKK ment jobs of it, kind in tlhe in-dlustry. according tozipi-jetc IOctober 200-5 N U C L. E A R N U W'S S1 41

Abq.ve: On the same day.that each dryer arrived:at Quad Cities, it-was connected to a crane liftito be hoisted to thE Left::The project'S contractor, Barnhart Crane and Riggin used a lattice boom crane to, lift each of the dryers. -Each dry .erweighs 55 tons and has a width of 20 ft 7 in. and a Sheig o7.f ift 10 in.

Below: Workers.:stand ready.to accept.the dryer onto th reactor building's temporary platform. A.slide.rail -system used four shoes and hydraulic pump assemblies to inch eat. dryer into the airlock. Inset: One of the four shoes: upon whic*h te dryer was placed. In photo, the shoe is the flat red piece on the slide rail, located Jin front of the two hydraulic pumps used to push the shoe-as-the other:sho. andpumps..work in unison. 42 42 1. C L~~N EA R N E WS Oertober c0r2(5 2005

Tboý The dryer edges closer to the :emporary platform. Middle: Nearing setdown the dryer hovers over the slide raiI system:used to move it inside the airlock, 6ottO The dryer is transported through.a series of small moves.:30 inches at a time, into the airlock, with. clearances th.edoorway.as tight as:a couplesof inches. ohrough Octo~berJ 200.5 20U,5 N,,oe C L ,.A R N EW5 43 4S

Top: The dryer nears the end of its journey, from, its start at Quad Cities outside.the reactor building, to inside the temporary. airlock. Once tie doors were sealed, the top.of the airlock was remioved; and the plant's.overhead crahe hoisted the dryer out, moving it.to the refueling floor. where it: waited.instatlati*on into a reactor.. " A-D, 3he"o~verhead crane (A~eioW:.A moves. the .dryer.to .a location above a reactor cavity. (BýD) Inside: the'reator, the..I dryer~is: ns* ed;,::Pho6t s.AýD:' Exelon. . ,! .Generati'on . .. : A.. 7"'

                                                        ý,7:

44

Union of Conceined Scientists Citizens and Scientists for Environmental SolutionssZ* k'* SNAP, CRACKLE, & POP: THE BWR POWER UPRATE EXPERIMENT EPU. The Nuclear Regulatory Commission believes it stands for Extended Power Uprate where the agency relicenses a nuclear power reactor to operate at a significantly higher power level.' But trials and tribulations at nuclear power reactors over the past two years strongly suggest that EPU really stands for Experimental Power Uprate. The Experiment underway in Illinois may soon move to Vermont. The Quad Cities Nuclear Power Station is located on the Mississippi River about 20 miles northeast of Moline, IL. The NRC licensed its two. boiling water reactors (BWRs) on December 14, 1972.2 Twenty-nine years later - almost to the day - the NRC amended the licenses to permit the reactors to operate at--nearly-20 . percent higher output. L As illustrated in the color schematic, . energy released from the reactor core I ........ of a BWR boils water. The steam spins ' 4 7 i7* "' .......... a turbine connected to a generator to Boil,*ngWater React,*r** . make electricity. The outline drawing shows the components inside the reactor vessel above the reactor core that process the steam before it flows to the turbine. The steam S "-- leaving the reactor core carries little droplets of water. The steam passes through vertical tubes called 'steam i' -, oseparators' that remove many of the droplets. The

                                                       !drier                steam then weaves its way back and forth through a metal maze called the 'steam dryer.' When all is working right, water droplets form less than one-tenth of one percent of the steam leaving the J                                                                reactor vessel.

On began March at Quad Cities the 5, 2002, whenExperimental Power Uprate workers reconnected Unit 2 to the electrical grid following a refueling outage. After operating nearly 30 years up to the original licensed power level, the plant literally began shaking itself apart at the, higher power level. Workers manually shut down Unit 2 on March 29t after high vibrations caused leaks in the control system for the. main turbine.4 www.ucsusa.org Two Brattle Square Cambridge, MA 02238-9105

TEL: 617.547.5552
FAX: 617.864.9405 1707 H Street, NW
Suite 6oo - Washington, DC20006-3962
TEL: 202.223.6133
FAX: 202.223.616: Docket No. 7195 2397 Shattuck Avenue
Suite 203
Berkeley, CA 94704-1567
TEL: 510.843.1872 -FAX: 51o.843.378 Attachment 1-5 6 Pages

SNAP, CRACKLE,'& POP: THE BWR POWER UPRATE EXPERIMENT During the subsequent restart of Unit 2 on April 2, 2002, vibrations broke a drain line on one of the four main steam pipes. Workers knew the main steam pipes were vibrating abnormally at the Experimental

PowerUprate conditions because insulation and - of all things - vibration monitors had shaken loose and fallen from the pipes.5 Workers fixed the broken line - not its cause - and restarted Unit 2 to resume the Experiment.

The main steam pipes signaled trouble again on June 7, 2002. With Unit 2 steadily operating at Experimental Power Uprate conditions, the indicated flow in main steam line 'A' suddenly increased from 2.95 to. 3.05 million pounds per hour while the indicated flows in the remaining three lines decreased. The plant's owner, the reactor's manufacturer, and the site's regulator huddled about the problem.6 The head-scratching intensified on June 18, 2002, when the measured amount of water droplets being carried away by the steam was about four or five times the values recorded over the past three decades. When the high amount doubled over the next two days, operators suspended the Experimental Power Uprate by reducing Unit 2's output below the original licensed level. But the damage had already been done. Operators shut down Unit 2 on July 11, 2002, for repairs. Workers soon spotted a

                                                         -           --        gaping hole in the steam dryer. Metal fragments from the hole were later found in a flow instrument for one of the main steam lines and on the inlet
                                                             -"Iscreen                 for a main turbine stop valve. Thus, at least one fragment from the cracked, broken        steam dryer   sitting  above    the
                                                                              -reactor core was carred by
                                                                        *"     steam out of the reactor vessel, past both of the main      steam     isolation valves, out of the primary containment, out of the secondary containment, to the stop valve in the turbine building.

According to Exelon, the owner of the Quad Cities reactors: The root cause of the steam dryerfailure was determined to be a lack of industry experience and knowledge offlow-induced vibration dryerfailures. The dryerfailed as a result offatigue caused by flow-induced vibrations created by higher steam flows due to Extended Power Update conditions!8 Hence, the Experiment fills in gaps in the nuclear industry's knowledge. The nuclear industry did not know what to expect or what might happen, so Exelon cranked up Quad Cities Unit 2 to find out. But the resulting steam dryer snap, crackle, and pop in 2002 only schooled the industry on how to band-aid that problem, not how to prevent it. July 9, 2004 Page 2 of 6

SNAP, CRACKLE, &.POP: THE BWR POWER UPRATE EXPERIMENT After repairing the steam dryer by replacing the damaged plate and adding braces, workers restarted Unit 2 on July 21, 2002, and resumed the Experiment. water droplets inI next phase of the Experiment began on May 6, 2003, when the measured amount of The the steam again significantly exceeded the normal value. On May 28, 2003, operators suspended the Experiment by reducing Unit 2's power output below the original licensed level. Two weeks later, Unit 2 was shut down for another round of steam dryer repairs.9 It was again child's play to spot the damage - a crack in the steam dryer 3/4 inch wide and merely 9 feet long. The damage was not in the exact same location as in 2002, but Exelon recycled the same excuse nonetheless: The root cause of the steam dryerfailure was determined to be a lack of industry experience and knowledge offlow-induced vibration dryerfailures. The dryerfailed as a result offatigue caused byflow-induced vibrations createdby highersteam flows due to EPU conditions.' July 9, 2004 Page 3 of 6

SýNAP, CRACKLE, & POP: THE BWR POWER UPRATE EXPERIMENT In other words, not enough knowledge was gained from the steam dryer shaking itself apart in 2000 to prevent it from happening again in 2003. Not enough data? No problem, there are more BWRs to include in the Experiment. Enter Quad Cities Unit L.' On October 26, 2003, the indicated flow in main steam line 'D' suddenly increased by 0.5 million pounds per hour while the indicated flows in the remaining three lines decreased.* Within days, the amount of water droplets in the steam was measured at significantly higher than the usual value. Operators suspended the Experiment on November 3, 2003, by reducing Unit l's power output below the original licensed level. Unit I was shut down on November 12, 2003, for repairs to' the steam dryer. That same month, workers discovered cracks in the Dresden Unit 2 (another Exelon BWR) steam dryer following a 1 single operating cycle at the Experimental Power Update conditions." When workers entered the Quad Cities Unit I containment for the now well-rehearsed repairs to the steam dryer, they found a new problem. The vent line broke off the pilot valve for one of the electromatic relief valves. Technicians later concluded that vibrations broke the vent line, which prevented the relief valve* from opening as required in event of an accident. Although its operatitrg license only allowed Unit 1 to operate for 14 days with a broken relief valves the reactor had operated for nearly 110 days in that degraded condition. 12 General Electric Reactor Pressure Vessel The Unit I steam dryer had a half-inch thick piece of the outer hood bank STEA measuring about 6 /2 inches by 9 inches A---?.:h... ) missing. Workers could' not locate thed A Atyf missing piece(s), but they did find evidence of its journey. One of the two large pumps that recirculates. cooling Cli SP*AY water through the. reactor core had scratch COREPRAY. A. marks on its impeller. The pump's CO°ANI i°itcy---! impeller had been replaced in 2002 so the ACR CORE ! 7 "3: damage was recent. Workers restarted Unit I after repairing RICIACULATIDN PM the steam dryer and abandoning the search .r* ASmn.y for its missing pieces. Exelon guessed the steam dryer piece, or a fragment thereof, £.ATRL RaD . passed through the recirculation pump and

                                                                                                                   -ROD now resides inside the lower curved dome                           C?0"°Ot of the reactor vessel.

On March 18, 2004, the NRC teleconferenced with Exelon about recent inspections of the steam dryer during the spring refueling outage on Unit 2. The Experiment continues to add to the nuclear industry's knowledge of how steam dryers break while remaining coy about how to stop the damage: o Cracks formed in some of the plates added during the 2003 repairs o Cracks formed in a weld where a stiffener plate was added o A one-inch crack formed in a steam dryer seam This steam flow redistribution occurs'because the hole(s) in the broken steam dryer allows a "short cut" for steam to the nearest steam pipe. July 9, 2004 Page 4 of 6

SNAP, CRACKLE, & POP: THE BWR POWER UPRATE EXPERIMENT Exelon may have tired of the Experiment. They plan to replace the steam dryers at Quad Cities as soon as practical. For Unit 1, that means the refueling outage scheduled for March 2005. For Unit 2, that means the refueling outage scheduled for spring 2006."3 In Exelon's own words: The dryer is a non-safety related component whose only safety function is to remain intact such that no loose part will prevent a safety related componentfrom performing itsfunction.'4 The steam dryer has no moving parts. It is a bunch of metal plates, some with holes drilled through them, welded together. The only thing one has to do is keep it intact. The Experimental Power Uprate failed three times against this fairly simple success criterion at Quad Cities in less than two years. The NRC informed Exelon that: the NRC staff noted that the licensee's resolution of the potential adverse flow effects from EPU operationat Quad Cities and Dresden continues to rely primarily on questionable analyses.15 Lack of knowledge caused the problems. Questionable analyses hinder their resolution. Yet the NRC allows BWRs in Illinois, Iowa, and North Carolina to operate at Experimental Power Uprate conditions justified by the ill-informed, questionable analyses. The NRC's mission is to protect public health and safety. The BWR Power Uprate Experiment conflicts with that mission. For the NRC.to allow BWRs to continue operating atExperimental Power Update conditions is to naively assume that the only adverse consequences from the incomplete knowledge and questionable analyses have - very politely - revealed themselves in the form of Swiss-cheese steam dryers and vibration monitors lying on the floor. What about emergency systems also incapacitated at the Experimental Power Uprate conditions but still undetected? We won't know until someday when these standby emergency systems are called upon during an accident and fail to respond. That lesson will come with a very high, and totally unnecessary, price tag. Repeatedly told that the nuclear industry doesn't have enough knowledge about Experimental Power Update conditions, the NRC is shirking its responsibility to protect the public by allowing clueless plant owners to crank up BWRs to see what happens. Prepared by: David Lochbaum, Nuclear Safety Engineer Sources: United States Nuclear Regulatory Commission, "Fact Sheet on Power Uprates for Nuclear Plants," March 2004. Available online at htp://wvww.nrcgzov/reading-rmi/doc-collections/fact-sheets/power-uprates.html 2 United States Nuclear Regulatory Commission, NUREG/CR-5640, "Overview and Comparison of U.S. Commerical Nuclear Power Plants: Nuclear Power Plant System Sourcebook," September 1990. 3 Technical Training Center, United States Nuclear Regulatory Commission, "G.E. Technology Systems Manual," Chapter 2.1, "Reactor Vessel System," January 1997. 4 Letter from David E. Hills, Chief- Mechanical Engineering Branch, Nuclear Regulatory Commission, to John L Skolds, President - Exelon Nuclear, "Quad Cities Nuclear Power Station NRC Integrated Inspection Report 50-254/03-02; 50-265/03-02," January 31, 2003. 5 Letter from David E. Hills, Chief- Mechanical Engineering Branch, Nuclear Regulatory Commission, to John L Skolds, President - Exelon Nuclear, "Quad Cities Nuclear Power Station NRC Integrated Inspection Report 50-254/03-02; 50-265/03-02," January 31, 2003. July 9, 2004 Page 5 of 6

SNAP, CRACKLE, & POP: THE BWR POWER UPRATE EXPERIMENT 6 Letter from Mark A. Ring, Chief - Branch 1, Nuclear Regulatory Commission, to John L. Skolds, President - Report 50-254/02-05; 50-265/02-Exelon Nuclear, "Quad Cities Nuclear Power Station, NRC Integrated Inspection 05," July 30, 2002. .7 Letter from Geoffrey E. Grant, Director - Division of Reactor Projects, Nuclear Regulatory Commission, to John Unit 2 NRC Special Inspection Report L. Skolds, President - Exelon Nuclear, "Quad Cities Nuclear Power Station, 50-265/03-11," August 7, 2003. to Nuclear Regulatory Letter from Timothy J. Tulon, Site Vice President, Exelon Generation Corporation, due to Failure of Reactor Steam Dryer from Commission, "Licensee Event Report 265/02-003, "Reactor Shutdown Power Update,'"" September 9, 2002. Flow-Induced Vibrations as a Result of Extended Regulatory Commission, to John 9 Letter from Geoffrey E. Grant, Director - Division of Reactor Projects, Nuclear Unit 2 NRC Special Inspection Report. L. Skolds, President - Exelon Nuclear, "Quad Cities Nuclear Power Station, 50-265/03-11," August 7, 2003. to.Nuclear Regulatory to Letter from Timothy J. Tulon, Site Vice President, Exelon Generation Corporation, Report 265/03-004, "Reactor Shutdown due to Degraded Reactor Steam Dryer as a. Commission, "Licensee Event August 22, 2003. Result of Increased Steam Velocities from Extended Power Update,'"" to Nuclear Regulatory Commission, 11Letter from Patrick R. Simpson, Manager - Licensing, Exelon Nuclear, for Extended Power Update NRC Safety Evaluation," April 9, 2004. "Additional Information Regarding Request to Christopher M. Crane, 12 Letter from Mark A. Ring, Chief- Branch 1, Nuclear Regulatory Commission, Nuclear Power Station, Units 1 and 2 NRC President and Chief Nuclear Officer - Exelon Nuclear, "Quad Cities 05000265/2004002," April 19, 2004. Integrated Inspection Report 05000254/2004002; 13Letter from Keith R, Jury, Director - Licensing and Regulatory Affairs, Exelon Nuclear, to Nuclear Regulatory Operation," May 12, 2004. Commission, "Commitments and Plans Related to Extended Power Uprate President, Exelon Generation Corporation, to Nuclear Regulatory

'a Letter from Timothy J. Tulon, Site Vice Report  265/03-004,  "Reactor  Shutdown   due   to Degraded     Reactor Steam Dryer as a Commission, "Licensee Event August    22,  2003.

Result of Increased Steam Velocities from Extended Power Update,'"" Commission, "Quad

" Memorandum to File from Lawrence W. Rossbach, Project Manager, Nuclear Regulatory of Conference   Call  with  Exelon    on March  18, 2004, to Cities Nuclear Power Station, Unit 2 - Documentation Plan and Comparison       with Dresden Discuss Steam Dryer Indications, Causes, Repairs, Modeling, Dryer Test Nuclear Power Station," March 25, 2004.

July 9, 2004 Page 6 of 6

I Exel n. Nuclear Extended Power Uprate Licensing Challenges Exelon Nuclear Keith Jury, Director -. Licensing and Regulatory Affairs Regulatory Information Conference 2004 Session W6 March 11, 2004 Background Exel:r:n. NucleaT

NRC approved 17% extended power uprate (EPU) for Dresden and Quad Cities in 2001, and modifications were implemented in 2001-2002 9 Two major categories of EPU issues since implementation

     - Vibration effects

Steam dryer failures
Main steam relief valve degradation
One example ol small bore piping iailure
Feedwater sample probe failures

     - Reduced operating or safety margin 2

Docket No. 7195 Attachment 1-6 3 Pages

Licensing Process Issues Exel A-Nuclear

   " Approved EPU topical reports donot provide sufficient guidance on the depth or focus of analyses required, especially concerning vibration
  *. Effects of core design and fuel transitions, combined with EPU, may result in unanticipated cycle-specific analysis results Example is requirement fnr Additional safety valve at Dresden
  " Review of previous generic communications and operating experience (0E) information for EPU needs to be more thorough
        - EPU oxacerbated condition rApnnred in GE Service Information Letter (SIL) on main steam line low pressure isolation setpoint margin
        - SIL regarding sample probe failures was thought to be unaffected by EPUI BWRVIP documents, regarding steam dryers and effects of loose parts S

require re-evaluation/revision 3. Regulatory Implications ExeNcIn. NUCdear, ., NRC confidence in the EPU licensing process has eroded

      - Extensive high level interactions with NRC management
      - Additional NRC information and review requests
      - Letters of expectatiorn and commitment confirmation
      - Recognized need.to revise satety evaluation for previous E U amendment

NRC has shown increased sensitivity toward potential EPU impact on licensing actions and plant issues

"   Licensing process is still robust
     - Safety analysis acceptance criteria are verilied to be met
     - Issues to date have not been safety significant
"   Issues show there is some uncertainty when moving into previously uncharted territory Uncertainty is mitigated through sharing of CE, similar to experience gained during early stages of nuclear industry

Emphasizes need for continued focus on effective use of industry OE 4

2

Exelon and Industry Response- Exel... n. NuClear

Exelon and industry EPU evaluation

       - Exelon has undertaken several in-depth reviews to prevent additional unexpected outcomes
      -  BWR Owners' Group committee on EPU effects
      -  BWR Owners' Group subcommittee and BWRVIP working group on steam dryers 5

. Conclusion Exeil. n.. Nucdeay

  ° EPUs have produced significant benefit to the industry by increasing generation at acceptable costs

Unexpected issues clearly demonstrate the need.

to make adjustments in the analyses and reviews

NRC sensitivity toward potential EPU impacts has increased significantly
Implications'are manageable through a combination of more detailed up-front analyses and continued effective use of OE 6

April 7, 2006 PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE -- PNO-III-06-01,0. This preliminary notification constitutes EARLY notice of events of POSSIBLE safety or public interest significance. The information is as initially received without verification or evaluation, and is basically all that is known by the Region III staff on this date. Facility Licensee Emergency Classification Exelon Generation Co. Notification of Unusual Event Quad Cities 2 __ Alert Cordova, IL - Site Area Emergency Docket: 50-265 __ General Emergency License:. .DPR-30 X Not Applicable

SUBJECT:

CRACKING IDENTIFIED IN UNIT 2 STEAM DRYER DESCRIPTION: The' licensee has identified cracking in the Unit 2 steam dryer during the unit's ongoing refueling outage. The steam dryer is an internal reactor structure designed to remove moisture from steam before it enters the main steam lines to the turbine. The steam dryer was installed in May 2005 as the first steam dryer replacement in a U. S. reactor. The steam dryers for both Quad Cities units were replaced because of cracking concerns caused by acoustic loading and vibration from operation at Extended Power Uprate power levels. The replacement dryers were designed and constructed to be more robust and resistant to cracking than the previous steam dryers. The Unit 2 steam dryer was also instrumented with several strain gauges, pressure transducers, and accelerometers. The initial inspection by the licensee revealed one large crack, approximately 5 feet in length, with multiple branches, in the skirt region of the dryer. This crack is currently believed to have been caused by binding difficulties experienced during the initial installation last year, but the root cause evaluation is still in process. The Unit 2 dryer installation lessons learned were incorporated into the Unit 1 steam dryer installation, and no difficulties were experienced with its installation. The licensee has also identified several smaller cracks of lesser significance on various internal bracing within the dryer. The steam dryer inspection is expected to be completed on April 9. Evaluations of all of the cracks and indications also are continuing, and the licensee is developing plans to repair the steam dryer. Region III (Chicago) and the NRC Resident Inspectors are monitoring the licensee's activities. The State of Illinois will be notified. The information in this preliminary notification has been discussed with licensee management. Docket No. 7195 Attachment 1-7 2 Pages

Region III received initial notification of the steam drye'r inspection findings on March 29, 2006, and additional information was provided as the inspection has continued. This information is current as of 1:45 p.m. CDT on April 7, 2006. CONTACTS: Allan Barker Mark Ring 630/829-9679 630/829-9703 1

Page 1 of3 Docket No. 7195 Sherman, William Attachment 3-1 From: Raymond Shadis [shadis@prexar.com] Pages Sent: Friday, November 11, 2005 7:54 AM To: c-10@c-10.org; can@nukebusters.org; Nuclear Policy Research Institute; NECNP; nuclearfreevermont@yahoogroups.com; NucNews; vce@vermontel.net

Subject:

Vermont Yankee has more cracks; probe demanded Importance: Low http://www.rutlandherald.com/apps/pbcs.dll/arti( AID=/2005111//NEWS/511110380/1003/NEWS02 Article published Nov 11, 2005 Vermont Yankee has more cracks; probe. demanded BRATTLEBORO A key component at Vermont Yankee nuclear power plant has developed dozens of additional cracks, the plant's owner announced late Thursday. Entergy Nuclear said that sophisticated technology discovered a total of 62 cracks in the steam dryer during a special inspection during the power plant's ongoing shutdown and refueling. The company had reported last year that there were 16 cracks in the 17-foot-wide steel steam dryer. The Nuclear Regulatory Commission said that despite the cracks, the reactor was safe to resume operation, but it said the new cracks raised unanswered questions about the plant's ability to withstand the additional pressures that would come with its plans to generate more power. The large number of cracks quickly caught the attention of the state's congressional delegation. Led by Sen. James Jeffords, I-Vt., the ranking member of the Senate committee that oversees nuclear power plants, the delegation called for federal regulators to do their own investigation into the cause of the cracks in the steam dryer. "We request that the condition of the steam dryer be fully evaluated, using the techniques of the most recent'inspection and any other appropriate means, as the NRC considers Entergy Nuclear's request to produce an additional 100 megawatts of power from Vermont Yankee," said the statement from Jeffords, Sen. Patrick Leahy, D-Vt., and Rep. Bernard Sanders, I-Vt., to NRC Chairman Nils Diaz. "We believe it is essential that our constituents receive needed information about whether the plant's steam dryer will be able to withstand boosted power conditions 7/17/1006

Page 2 of 3 and operate safely and reliably," the letter added. Cracking in steam dryers has been a critical issue in Entergy's ambition to boost power production by 20 percent, or 110 megawatts, because other General Electric-designed reactors have developed cracks-in their steam dryers, resulting in failure. Entergy's long-stalled application for a power boost has been largely delayed over the NRC's concerns about the steam dryer. According to NRC information, only six reactors out of the 100 commercial reactors in the country have developed such cracks. The steam dryers are not a safety component by themselves, but their failure, which could result in pieces of steel falling back into large steam valves, which lead back to the reactor, could create serious safety problems. NRC spokesman Neil Sheehan said Thursday the NRC was sure that the plant was safe to continue to operate and the plant had clearance to resume operation. The plant has been shut down for its regular refueling and maintenance outage since Oct. 24. But Sheehan said the NRC had asked Entergy for additional information about the cracking issue, a report that is expected \by the end of the month. Sheehan said 16 cracks had been discovered in April 2004, the last time the plant was shut down for its regular refueling and maintenance. He said a testing with increased magnification revealed the additional cracks. "Our evaluation is these cracks don't pose any sort of a problem," Sheehan said. He said the NRC and Entergy had concluded that the cracks had been there "a long time," probably "early in the power history of Vermont Yankee." The reactor started operation in November 1972. Sheehan said he didn't know how big the cracks were, but said they were "very minor." "We don't believe these pose any problem for restarting," he said. The uprate or power boost is another matter, he said. Robert Williams, spokesman for Entergy, said the cracks were "insignificant and didn't pose a safety hazard." Last year, the plant originally announced finding only four cracks, with one as long as 14 inches and another 3 inches long. They were cleaned and welded. Months later, the company later increased the number to, 16. - /I" Iýnfl I,

Page 3 of 3 Williams said a "high-resolution inspection" had revealed 62 "shallow hairline surface cracks that Entergy, General Electric and the Nuclear Regulatory Commission staff have determired are acceptable because they are not structurally significant." Williams said the cracks are "similar to those found at other boiling-water reactors." He said the cracks occurred in metal less than a quarter-inch thick, while the "hairline" ones were 1 to 5 inches long. Unlike the cracks discovered last year, these cracks didn't have to be welded or reinforced, Williams said. Raymond Shadis, senior technical advisor for the anti-nuclear group New England Coalition, said it was "insulting to the public" that the information was released so late in the day, on the eve of a federal three-day weekend holiday, and leading up to important NRC hearings in Brattleboro on the technical problems of the so-called uprate. "These (surface) failures are indicators of future structural failures," Shadis said, saying that anyone with commonsense qxperience in welding, metal fabrication or metalurgy knew that cracking was a precursor to failure. He said Entergy, having now identified defects which probably existed since plant construction, "should have undertaken an analysis to determine whether or not they would have an effect on future safety." Contact Susan Smallheer at susan.smallheer@rutlandherald.com. 7/11 "71')A04q

Page 1 of 3 Sherman, William From: Raymond Shadis [shadis@prexar.com] Sent: Friday, November 11, 2005 8:07 AM To: c-10@c-1O.org; can@nukebusters.org; Nuclear Policy Research Institute; NECNP; nuclearfreevermont@ya.hoogroups.com; NucNews; vce@ver~montel.net

Subject:

62 cracks found at Vt. Yankee http://www.reformer-com/Stories/O, 1413,102-8860-3126276,00.html 62 cracks found at Vt. Yankee By KRISTI CECCAROSSI Reformer Staff BRATTLEBORO -- There are 62 cracks in an important piece of equipment at Vermont Yankee, but plant officials and federal regulators say that's not a problem. The hairline, surface cracks in the plant's steam dryer were found this month during a routine shutdown. Entergy Nuclear, ovwners of the plant, and the Nuclear Regulatory Commission said the cracks pose no safety threat. The cracks are not structurally significant and they are probably from the plant's early years of operation, according to Neil Sheehan, spokesman for the NRC. They "appear to be old," he said. However, nuclear watchdogs say the cracks are one more reason why the NRC should put the brakes on Entergy's plans to boost power at the plant to 120 percent. A so-called "uprate" at Vermont Yankee is pending final review by the NRC. In other nuclear plants that have been uprated, cracks in the steam dryer have been a persistent concern. Vermont's congressional delegation has identified the cracks as a problem, too. The state's senators and sole representative wrote to the NRC on Thursday, urging the agency to evaluate the steam dryer issue before approving the uprate. The Vernon reactor has been off line for re-fueling since Oct. 22. During the outage, plant engineers looked at the reactor and the steam dryer, located at the top of the reactor. They found 42 cracks, ranging. from 1 inch to 5 inches in length, said Rob Williams, spokesman for the plant. The other 16 cracks were discovered in March 2004, during the last refueling outage. The cracks could have been on the steam dryer more than 20 years, but they've only been discovered now because engineers are using cameras with higher resolutions than ever before. The images show the cracks have been reviewed by Entergy officials, as well as the NRC and General Electric. Vermont Yankee is a boiling water reactor that started running in 1972. Docket No. 7195 Attachment 3-2 3 Pages

Page 2 of 3 When the reactor heats up, it produces steam which, eventually, produces power. Before the steam hits the plant's turbines, it passes through the steam dryer, where any traces of water are removed. The Quad Cities Generating Station in Illinois, also a boiling water reactor that went on line in 1972, was granted a 17.5 percent uprate by the NRC in 2002. Since then,-the steam dryer has failed twice because of cracking. In one instance, a piece of the dryer broke off and damaged other components of the reactor. The plant has been shut down a number of times to try to fix the problem.. The NRC is scrutinizing the steam dryer issue at Vermont Yankee as a result. This fall, it told plant officials that in order to~have their uprate approved, they'd have to adhere to more stringent maintenance of the steam dryer. Entergy agreed to the condition. Ray Shadis, technical advisor for the nuclear watchdog New England Coalition, said the added oversight amounts to "an experiment on the banks of the Connecticut River." "They are now making the assertion that because these are surface cracks, they will go no further." And particularly in light of a 20 percent boost in power output at the plant, Shadis said, "that's preposterous." Entergy officials have until the end of the month to prove that the cracks won't be exacerbated by an uprate, said Sheehan, of the NRC. Plant engineers will evaluate the steam dryer and submit a report to the NRC for review. The NRC will not investigate the issue itself. However, in a letter to the NRC chairman, Sens. Patrick Leahy, D-Vt., and Jim Jeffords, I-Vt., and Rep. Bernard Sanders, I-Vt., indicated that's what they'd like the agency to do. "We request that the condition of the steam dryer be fully evaluated, using the techniques of the most recent inspection and any other appropriate means," the letter states. "... it is essential that our constituents receive needed information about whether the plant's steam dryer will be able to withstand boosted power conditions and operate safely and reliably." While Vermont Yankee was shut down, plant officials refueled the reactor with a fuel specifically designed for the plant's. "uprated" production, according to Williams, plant spokesman. During last year's outage, plant officials installed the same fuel. Entergy has reportedly done other work at the plant in preparation for the power boost, but Williams could not say how much officials have spent in anticipation of an uprate. The uprate has been approved by the state's Public Service Board, a quasi-judicial panel that handles all matters related to utilities. The board's approval is not final, however; members are still deliberating whether they want an independent safety assessment of the plant done first. The NRC is the last, major agency that must endorse the uprate. This month, it all but granted tentative approval. It's "draft" evaluation will bear public review on Nov. 15 and 16, when an agency panel hosts hearings at the Quality Inn in Brattleboro. I /1 '7 11MA

Page 3 of 3 NRC officials have said they will issue a final evaluation of the uprate early next year. Kristi Ceccarossi can be reached at kceccarossi(reformer.com. "71/1 " /") 0 [)

Page 1 of 2 Sherman, William From: Raymond Shadis [shadis@prexar.com]. - , Sent: Friday, November 11, 2005 7:45 AM To: c-10 @c-1 o.org; can@nukebusters.org; Nuclear Policy Research Institute; NECNP; nuclearfreevermont@yahoogroups.com; NucNews; .vce@vermontel.net

Subject:

More cracks found in Vermont Yankee dryer http://www.vermontguardian.com/loc al//12005/V More cracks found in Vermont Yankee dryer By Kathryn Casa I Vermont Guardian Posted Nov. 10, 2005 BRATTLEBORO Inspectors at the Vermont Yankee Nuclear Power plant discovered another 46 hairline cracks in the reactor's problematic steam dryer during a regular refueling outage, prompting a call by Vermont's congressional delegation for closer review of the component. The fissures were found with specialized remote-Lontrolled underwater cameras that were being 'used to check the welds on some 40 Steam dryer cracks discovered in 2004, according to a press release from VY spokesman Rob Williams. They'are in addition to 16 cracks found during the last refueling outage, according to federal regulators. "The high resolution inspection of the steam dryer in this outage and the previous outage have identified a total of 62 shallow hairline surface cracks that Entergy, General Electric and the Nuclear Regulatory Commission staff have determined are acceptable because they are not structurally significant and are likely to have occurred in the early years of plant operation," according to Williams. He said further operation of the reactor "will not affect their condition." Entergy is the Mississippi-based corporation that owns Vermont Yankee, and is seeking to increase power there by 20 percent. General Electric is the company that built the. 33-year-old boiling water reactor. The development prompted Vermont's three-member congressional delegation to call for more testing of the steam dryer. "We believe it is essential that our constituents receive needed information about whether the plant's steam dryer will be able to withstand boosted power conditions and operate safely and reliably," wrote Sens. James Jeffords, I-VT, and Patrick Leahy, D-VT, and Rep. Bernie Sanders, I-VT, in a letter Thursday to NRC Chairman Nils Diaz. "We request that the condition of the steam dryer be fully evaluated, using the techniques of the most recent inspection and any other appropriate means, as the NRC considers Entergy Nuclear's request to produce an additional 100 megawatts of power from Vermont Yankee," they wrote. Jeffords is ranking member of the Senate Environment and Public Works Committee. Williams said operators were preparing Thursday to restart the reactor, which has been shut down in Docket No. 7195 Attachment 3-3 '7/ 7/9Onn 2 Pages

Page 2. of 2 refueling mode since Oct. 22.

"The outage ... was based on 18 months of planning and involved more than 5,000 separate tasks including refueling the reactor, as well as testing and inspection of virtually every component and system in the plant," Williams said in a press release. "In addition, several equipment upgrades were completed to support a proposed increase in power output."

It is unclear what effect the increased vibrations of a power uprate wouldhave on the steam dryer. Although it is not considered a safety component, breakage could lead to complications within the plant's safety systems. NRC Region I spokesman Neil Sheehan said a special inspector was sent to Vernon to review Vermont Yankee's steam dryer work during the outage. "We have not identified any problems with the company's evaluation and determination that the steam dryer will be safe to operate following the outage, at current power conditions," Sheehan said in an e-mail Thursday. However, Entergy will be required to "Conduct an evaluation of the new cracks for uprate conditions by the end of this month," Sheehan said. The VY uprate application is believed to be in its final stages. In a draft safety report issued late last month, NRC staff said the plant. could be uprated safely. A two-day meeting and public hearings on the uprate are set for Nov. 15-16 in Brattleboro. Nuclear watchdog Ray Shadis, technical advisor to the New England Coalition, a citizens' group fighting the uprate, said the cracking is far more serious than either the NRC or Entergy -have indicated. "Anybody who understands how metal is stressed understands that surface indications are very, very serious because they reflect what is beneath the metal," Shadis said. "Therefore, the uprate should not proceed until a thorough analysis is done." Shadis rejected the contention by Entergy and the NRC that the cracks were not recent. "Why didn't they find them sooner?" he asked. "The more they look, the more they find." The NRC last month informed Entergy that it would require a broad set of conditions before an uprate would be permitted, including hourly monitoring of plant conditions as power is increased and an ongoing assessment of the steam dryer. David Lochbaum, a nuclear engineer with the Union of Concerned Scientists in Washington, said such conditions indicate that neither Entergy nor the NRC are confident the plant can withstand an uprate. Lochbaum pointed to serious steam dryer breakage at two sister boiling water reactors in Illinois, which vibrated apart when those plants implemented a power uprate. Both of those reactors were also made by General Electric, and both had to temporarily shut down due to serious steam dryer breakage. Raymond Shadis Staff Technical Advisor New England Coalition Post Office Box 98 Edgecomb, Maine 04556 207-882-7801 shadis@prexar.com '"7/11 `, /") A A*l

Congr5q of the Unitd I&tatC

                                        *iastjington,

20515 November 10, 2005 The Honorable Nils J. Diaz Chairman U.S. Nuclear Regulatory Commission Washington, DC. 20555-0001

Dear Mr. Chairmnan:

We write in response to the announcement today of the discovery, during a recent scheduled outage, of more than 40 additional cracks in the steam dryer at Vermont Yankee. We. understand that a Region I Nuclear Regulatory Commission (NRC) inspector was dispatched to assist the resident inspector in the determining whether these cracks pose safety and operational concerns for the plant's current power production. We request that the condition of the steam dryer be fully evaluated, using the techniques of the most recent inspection and any other appropriate means, as the NRC considers Entergy Nuclear's request to produce an additional 100 megawatts ofpower from Vermont Yankee. We understand. that these cracks were discovered through the use of enhanced visual inspection techniques. As you know, these cracks are in a4dition to some 18 cracks, both hairline and larger, that were discovered through visual inspectidns of the plant's steam dryer in April and May of 2004. Steam dryer cracking is of concern at many boiling water reactor facilities. We know that cracking problems have persisted at the Quad Cities facilities' steam dryers, despite. repeated fixes, and that uprated power conditions at those facilities place additional stresses on dryer performance. While the steam dryer itself is not a safety-related piece of equipment, i.ts proper functioning is important to the plant's safe and reliable operation. Steam dryer cracking could result in pieces breaking off, and falling back into the steam lines that lead out of the reactor. In the case of the Quad Cities reactors, these plants have been forced to shut down because of cracking, making their operation less reliable. As the NRC reviews the Vermont Yankee power uprate request, we believe it is essential that our constituents receive needed information about whether the plant's steam dryer will be able to withstand boosted power conditions and operate safely and reliably. The functioning of this piece of equipment should receive the Commission's full and thorough attention during the review of the uprate application. -We look forward to a pronmpt reply. Sincerely, Docket No. 7195

                                           , R 7,
                                               . 9 ON,-, ,,.*PAPE.R*,

. A ttac h m e n t 3 -4 2 Pages

Diaz, pg. 2 November 10, 2005

          .. L

0 UNITED STATES NUCLEAR REGULATORY COMMISSION 0 WASHINGTON, D.C. 20555-0001

                                     *,September 2, 2004 LICENSEE:         Entergy Nuclear Operations, Inc.

FACILITY: Vermont Yankee Nuclear Power Station

SUBJECT:

SUMMARY

OF JULY 21 and 22, 2004, MEETINGS WITH ENTERGY, NUCLEAR OPERATIONS, INC. ON STEAM DRYER ANALYSIS FOR-VERMONT YANKEE NUCLEAR POWER STATION (TAC NO. MC0761) On July 21 and 22, 2004, Category. 1 meetings were held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Entergy Nuclear Operations, Inc. (Entergy) at NRC Headquarters in Rockville, Maryland. The purpose of the July 21, 2004, meeting was to discuss the methodology being used by Entergy's contractor, General Electric Nuclear Energy (GENE), for the structural analysis of the Vermont Yankee Nuclear Power Station (VYNPS) steam dryer. This analysis is being used to support Entergy's license amendment request for a 20% power uprate at VYNPS. The power uprate request was submitted by Entergy to the NRC on September 10, 2003. The purpose of the July 22, 2004, meeting was to discuss some of the specific issues related to the VYNPS steam dryer analysis, including the steam dryer inspection and modifications performed during the Spring 2004 outage, and testing and monitoring planned for the steam dryer. A portion of each meeting was closed to the public in order to discuss proprietary information associated with GENE's analysis. The lists of attendees for the July 21 and 22, 2004, meetings are provided as Attachments 1 and 2, respectively. Open Portion of Meeting on July 21, 2004 Mr. Richard Ennis, Project Manager for VYNPS in the NRC's Office of Nuclear Reactor Regulation (NRR) Division of Licensing Project Management (DLPM), provided introductory remarks. Mr. Ennis explained that although the steam dryer is a non safety-related component, industry experience with steam dryer cracking has raised concerns because of the potential for loose dryer parts to impact the performance of safety-related components. Mr. Ennis emphasized that the NRC needs to fully understand the analysis, design, and monitoring that Entergy plans for the VYNPS steam dryer as part of the staff's evaluation of the request to operate at a higher power level. Mr. Craig Nichols, Entergy's VYNPS power uprate Project Manager, provided an overview of the information to be discussed during both meetings. Mr. Dan Pappone, of GENE, presented information regarding the steam dryer structural analysis methodology as shown in slides 1 through 14 of Attachment 3. Mr. Pappone* emphasized that industry experience with steam dryer failures is that steam line velocity is a good indicator of the pressure loads on the dryer. He noted that the VYNPS steam line velocities after the proposed power uprate would be about the same as the steam line velocities before power uprate at the Quad Cities and Dresden plants. Docket No. '71.95 Attachment 4-1 45 Patges

questions from the Members of the public were in attendance. There were no comments or staff. There were no public and no Public Meeting Feedback forms were received by the NRC action items resulting from this meeting. Open Portion of Meeting on July 22, 2004 during the Mr. Ennis provided introductory remarks similar in nature to his introductory remarks meeting on July 21, 2004. activities related to the Mr. Nichols presented information regarding the VYNPS steam dryer following major topics were proposed power uprate as shown in the Attachment 4 slides. The discussed during the presentation: e Mr. Nichols discussed the VYNPS steam dryer inspection and steam dryer modifications same type inspection that were performed during the Spring 2004 refueling outage. The next (i.e., consistent with GENE SIL-644 recommendations) will be performed during the tostrengthen the dryer refueling outage. The modifications that were performed lessons-learned from Quad incorporated the latest GENE modifications consistent with the Cities. e Mr. Nichols stated that VYNPS steam dryer monitoring would take measurements consistent with GENE SIL-644 recommelcdations. to get VYNPS a Mr. Nichols discussed an acoustical moni toring program that will be used by the VYNPS specific data. specific data in order to show the GENE analysis is bounded was installed Entergy is using the same vendors as Exelon for this effort. Instrumentation Data was collected for the acoustic monitoring program during the recent forced outage. 100% power. during the subsequent plant startup for power levels between 80% and power levels Additional data would be collected following the proposed power uprate at above the current 100% level during a controlled power ascension program. questions and Following the presentation by Mr. Nichols, the NRC staff provided the following comments: regarding Mr. Tad Marsh, Director of DLPM in the NRC's Office of NRR, raised concerns main steam lines) in the acoustic monitoring program use of data external to the dryer (e.g., predicting the effects on the steam dryer. He asked if Entergy had considered the acoustic instrumenting the steam dryer. Mr. Nichols stated that Entergy believes that going back to the dryer. He stated that instrumenting model can predict the pressure wave to ALARA concerns. He said that during.the the existing dryer would be difficult due outage, underwater modifications performed to strengthen the dryer during the Spring 2004 15 rem. In addition, he welding was performed and the dose to workers was approximately due to a lack of stated it would be difficult to route new wiring out of the reactor vessel electrical penetrations.

Mr. Gene Imbro, Chief of the Mechanical and Civil Engineering Branch (EMEB) in. the Division of Engineering (DE) in the NRC's Office of NRR, stated that the staff still needs more information to have, reasonable assurance that the steam dryer analysis is acceptable.

Some of the specific concerns relate to the extrapolation of data from 100% power to 120% power, the adequacy of the GENE steam dryer scale model testing, and-the lack of existing plant data on the face of the steam dryer hood. Mr. Imbro also stated that the NRC was considering whether, if the VYNPS power uprate was approved, the NRC may require a mid-cycle inspection of the dryer. Mr. Marsh discussed that the NRC was also considering if hold points, with interaction between the NRC and the licensee, may be required during a controlled power ascension.

"   Mr. Tom Scarbrough, NRC Senior Mechanical Engineer in NRR/DE/EMEB,, asked what work still needs to be done to support the VYNPS power uprate evaluation of the steam dryer. Mr. Nichols stated that the GENE analysis is done and Entergy will continue to evaluate any industry experience for applicability to VYNPS. .Plant testing and monitoring of the steam dryer would be done during power ascension at uprated power conditions.

" Mr. John McCann, Entergy Director of Licensing, stated that Entergy would supplement the power uprate application with information' regarding the acoustic monitoring program and power ascension program.. They will not Wvait for an.NRC request for additional information to provide this information.

Mr. Gene Imbro stated that the NRC's con~tractor, Argonne National Labs, was reviewing the recent Entergy submittals related to the steam dryer analysis and that the staff and the contractors were still planning a trip to San Jose to audit the GENE analysis for VYNPS.
Mr. Billi Ruland, the NRC's Program Manager for power uprates in NRR/DLPM, stated that Entergy should consider defining the specific acceptance criteria for what is acceptable in terms of steam dryer cracking. The criteria should be developed to provide clear justification of why certain type of cracking may be acceptable to be left in service following a steam dryer inspection. The criteria should define what is considered an unacceptable failure of the dryer.

Members of the public were in. attendance. There were no comments or questions from the public. Public Meeting Feedback forms were not received. The following are the action items resulting from this meeting:

1. Entergy noted that they are currently developing a plant specific acoustic analysis model for use in validating that the load definition for the steam dryer in the analysis of recod is sufficiently conservative. This effort is scheduled for completion by the end of August, 2004. Entergy agreed to provide the results to the NRC and schedule a meeting to discuss with the NRC.

2. Entergy agreed to provide additional details on the power ascension test plan including plans for monitoring the steam dryer, as ,well as other plant systems and components, for flow induced vibration (FIV). This would include the acceptance criteria that will be used.

3. Entergy agreed to supply computational fluid dynamic output plots showing velocity profiles and streamlines.

steam

4. Energy agreed to provide a discussion of the effects of potential bi-stable flow on the dryer dynamics.

2 drain

5. Entergy agreed to supply the basis for the stress intensity limit of 5 ksi-in" limit for the channel cracks.

6. Entergy agreed to supply a discussion of the FIV and extended power uprate operating condition effect on crack growth.

dryer

7. Entergy agreed to provide, a commitment to perform detailed inspections of the steam during the next two refueling outages, in accordance with SIL-644, Supplement 1.

8. Entergy agreed to provide the results of the inspections scheduled for the next two outages to the NRC and discuss any changes to the long term monitoring plan once these inslbctions are completed.

9. Entergy agreed to, supply the acceptance criteria that will be used in evaluating the structural integrity of the dryer.

10. A number of technical questions associated with the GENE analysis (e.g. damping values) were discussed and it was agreed that additional discussions would occur during the NRC's audit in San Jose.

Please direct any inquires concerning this meeting to me. I can be reached at (301) 415-1420, or rxe @nrc.gov.. Richard B. Ennis,.Senior Project Manager, VY Section Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271 Attachments:

1. List of Attendees for July 21, 2004

2. List of Attendees for July 22, 2004

3. GENE Slides for July 21, 2004

4. Entergy Slides for July 22, 2004 cc w/atts: See next page

Vermont Yankee Nuclear Power Station cc: Regional Administrator, Region I Ms. Carla A. White, RRPT, CHP U. S. Nuclear RegulatoryCommission Radiological Health 475 Allendale Road Vermont Department of Health P.O. Box-70, Drawer #43 King of Prussia, PA 19406-1415 108 Cherry Street Mr. David R. Lewis Burlington, VT 05402-0070 Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W. Mr. James M. DeVincentis Washington, DC 20037-1128 Manager, Licensing Vermont Yankee Nuclear Power Station P.O. Box 0500 Ms. Christine S. Salembier, Commissioner Vermont Department of Public Service 185 Old Ferry Road 112 State Street '\ Brattleboro, VT 05302-0500 Montpelier, VT 05620-2601 Resident Inspector Mr. Michael H. Dworkin, Chairman Vermont Yankee Nuclear Power Station Public Service Board U. S. Nuclear Regulatory Commission State of Vermont P.O. Box 176 112 State Street Vernon, VT 05354 Montpelier, VT 05620-2701 Director, Massachusetts Emergency Chairman, Board of Selectmen Management Agency Town of Vernon ATTN: James Muckerheide P.O. Box 116 400 Worcester Rd. Vernon, VT 05354-0116 Framingham, MA 01702-5399 Operating Experience Coordinator Jonathan M. Block, Esq. Main Street Vermont Yankee Nuclear Power Station 320 Governor Hunt Road P.O. Box 566 Vernon, VT 05354 Putney, VT 05346-0566 G. Dana Bisbee, Esq. Mr. John F. McCann Deputy Attorney General Director, Nuclear Safety Assurance 33 Capitol Street Entergy Nuclear Operations, Inc. 440 Hamilton Avenue Concord, NH 03301-6937 White Plains, NY 10601 Chief, Safety Unit Mr. Gary J. Taylor Office of the Attorney General Chief Executive Officer One Ashburton Place, 19th Floor Entergy Operations Boston, MA 02108 1340 Echelon Parkway Ms. Deborah B. Katz Jackson, MS 39213 Box 83 Shelburne Falls, MA 01370

Vermont Yankee Nuclear Power Station cc: Mr. John T. Herron Mr. Ronald Toole 1282 Valley of Lakes Sr. VP and Chief Operating Officer Box R-10 Entergy Nuclear Operations, Inc. HC'zelton, PA 18202 440 Hamilton Avenue White Plains, NY 10601 Ms. Stacey M. Lousteau Mr. Danny L. Pace Treasury Department Vice President, Engineering Entergy Services, Inc, 639 Loyola Avenue Entergy Nuclear Operations, Inc. New Orleans, LA 70113 440 Hamilton Avenue White Plains, NY 10601 Mr. Raymond Shadis Mr. Brian O'Grady New England Coalition Post Office Box 98 Vice President, Operations Support Edgecomb, ME 04556 Entergy Nuclear Operations, Inc. 440 Hamilton Avenue Mr. James P. Matteau White Plains, NY 10601 Executive Director Mr. Michael j. Colomb Windham Regional Commission Director of Oversight 139 Main Street, Suite 505 Brattleboro, VT 05301 Entergy Nuclear Operations, Inc. 440 Hamilton Avenue Mr. William K. Sherman White Plains, NY. 10601 Vermont Department of Public Service 112 State Street Mr. John M. Fulton Drawer 20 Assistant General Counsel Montpelier, VT 05620-2601 Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601 Mr. Jay K. Thayer Site Vice President Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. Kenneth L. Graesser 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801

MEETING ATTENDANCE LIST Licensee: Ent.Der Plant: Vermont.Yankee Nuclear Power Station

Subject:

General Electric Steam Dryer Analysis Methodology Date: July 21. 2004 Time: 8:00 a.m. Location: NRC Headauarters, TWFN Room 8A1 Name Title Organization w/e/ ,..g,-, 27- biCt-1t IP Di

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MEETING ATTENDANCE LIST Licensee: Enta! Plant: Vermont Yankee Nuclear Power Station

Subject:

Steam Dryer Analysis Associated with Extended Power Uprate Reouest Date: J Time: 8:00 a.m. Location: NRC -ieadduarters, OWFN Room 1G16 Title Organization Name 9 ra iL___ N --l, _Pt_,,_,

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U BWR Steam Dryer Structural Analysis Methodology July 21, 2004 rC2 Agenda " Meeting Goals " Meeting Structure " EPU Operating Experience

Fluctuating Load Definition
Structural Analysis Techniques

" Finite Element Model " Fatigue Structural Analysis " Load Combinations

Transient and Accident Load Definitions
Primary Stress Structural Analysis tDryer ctrJCturaI Analyýi 'Methooocooy Meeting 7/2112004 ...- .,Slide.2 ,. o . .. .:

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Meeting Goals

"  Update NRC technical staff on BWR steam dryer structural analysis methodology
       - Load definition
       - Structural analysis

Provide generic basis and background information supporting EPU dryer analyses
Provide information supporting VY dryer analysis review Significant improvements in methodology have been made over the last year, Meeting Structure Informal question/answer format

     - Similar to technical audit
     - Not a structured presentation

Review

    - Detailed analysis results
    - Design record files
    - Spreadsheets, etc

" Review of generic methodology

    - Vermont-Yankee EPU analysis used as example

Copies of materials requested by the staff will be formally provided after the review

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GENE Technical Discussion Leaders 0 Fluctuating Load Definition -Dan Pappone a Structural Analysis Richard Wu Techniques 0 Finite Element Model Alex. Pinsker 0 Fatigue Structural Analysis Henry Hwang 0 Load Combinations Henry Hwang 0 Transient and Accident Dan Pappone Load Definitions Primary Stress Structural Henry Hwang Analysis ethodolo i Steam Dryer Design Basis

Original Design Requirements

       - Not ASME-coded component
       - Fatigue from flow-induced vibration not explicitly considered
       - Maintain structural integrity for outside steamline break accident
            " No loose parts

Deformation acceptable Current Dryer Analyses

      -    Finite Element Model of dryer Fluctuating pressure loads defined Fatioue from flow-induced vibration analyzed Normal, upset, faulted conditions analyzed ASME code criteria used as ouidance for modifications
. Dver structural Anaiysis Methodology Meetind 7/2/12004 . lde6 .. -

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EPU Operating Experience 120

                                                                     ~I M

f 100 9- R 90 i I N4< W-1 Nerrly 50 Reactor

                        .  -  -    Operating Years of EPU Experience Steamline Flow Velocities 220,0 .

0 000 00,0 C3 ) stqc~~~bi~~i tnli M eic. 112G EtoJlg imagination at work 4

Relative Hood Stresses Ipsi Fist Hood With Struts Slanted Road With P12te~s

                                                            , 2294 psi VYNPS PI    Modified f-1l Spsi       Dryer Fist Hood Without Struts Curved Hood With Plat"es Drrrut         ral Aulsi- Methodol~oi Mieetnb 711207iSie9~4 "0

Overall Dryer Screening 120 100 110 Go g1

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BWR/3 Dryer Failure History (QC2) June 2002 Dislodged 114' High cycle fatigue Replaced cover plate with *" Developed dryer component lower cover plate at due to high plate structural analysis QC2 frequency fluctuating Used more robust attachment pressure (120-230 welds. Hz), thiN cover plate. small welds, potential resonance May 2003 Cracks in outer High cyde fatigue Removed diagonal braces Modified dryer structural hood, broken due to low frequency from outer hoods analysis to account for braces and atrutn in fluctuating pressure Rfluctuating pressure load the outer hood loading pressHr) Replaced outer hood plates definition over full frequency with 1*plate range, for all dryer types Operation with Added external gussets darnaged cover plate contributing factor March Cracks in plate at Local stress Full height V vertical hood Solid submodels for high 2004 gusset tips, broken concentrations not plate stress locations used to tie bar welds modeled in sufficient supplement 3D shell Finite detail Full height external gussets Element model Full penetration shop welds on Analysis includes gusset tip external gussets design and weld design

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J,- ,'. Hood Failure Locations Top of Outer Hood (2003 Failure Location) Drye4 i* M Locafion). Fao SCover lt S(2002Faur

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Review Topics Load Definition Structural Analysis Plant Application

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Conclusions

Significant progress in structural analysis methodology
Overall methodology is conservative
Dryer modifications assure structural integrity at EPU conditions

           -Increased              design margin at critical locations Stuiu

_.-7Dryer Analsiy Methodology.Meietflo 7zi/2004 -- S:lde14 ,- imagination at work 7

Closed Session Y,.

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Fluctuating Load Definition

Generic load definition

       - Assumptions
       -     In-plant test data
       -     Scale model test data
       -     Reference load definition

Plant-specific application

      -      Load scaling

Load definition confirmation

       .Strcurl An y.i
... *..Dryer                     Methodolory Meetin . I/zlkO04     -. S6ide- 1          .E       * .

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Structural Analysis Techniques Equivalent static method

            - Frequency analysis using reference load
            -   Load scaling
            - Dynamic amplification, stress concentration factors

Response spectrum method

           -    Pressure load to response spectrum transform

Acceptance Criteria

, Dryer Structural An~lysi. Methodo

                                     .ogy.Meeting,7/21/2OO4-'.***, *... Sld 17 .* *...,u*=-*

Finite Element Model

Model Assumptions
Dryer components modeled
Shell model Solid submodels

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Fatigue Structural Analysis Analyze current power, EPU power conditions Benchmark current power results against acceptance criteria Evaluate EPU results against acceptance criteria

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Load Combinations

Operating conditions

     - Normal
     - Upset
     - Faulted

" Loads considered

     -   Deadweight
     -  Static differential pressure
     -  Seismic
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10

Transient and Accident Load Definitions

Differential pressure loads

     -   Forward flow transients (e.g., SORV)
     - Reverse flow transients (e.g., TSV)
    -Steamline break accident

Seismic loads

    -OBE
    -SSE tir~!      Ih~

S.rdu.aA-: i Methodology'M t

                       .ryer       Est   7/1IO4~'-:L 0       ie2
                                                               -b-12 Primary Stress Structural Analysis

Analyze individual load components for each operating condition
Combine stress results for individual components
Assess overall stress results against acceptance criteria

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L"*'- ntergy Entergy VY Power Uprate Project Steam Dryer RAI Review July 22,_2004 p, TPA 1

-Mi-teDEnrtergyy

    * .. *--*.  -Main Steam Dryer 2

What we know " Significant improvement in methodology

Dryer Finite Element Model adequately reflects dryer performance under defined load

" VY Modified Dryer relative stresses are less than other dryer types under the same load , Dryer Loads are adequately defined , VY Steam Line velocity at EPU is less than QC/Dresden original steam, velocity , Reasonable Assurance that Dryer will perform per current design requirements at Extended Power Uprate Conditions at Vermont Yankee 3

Future Activities

Obtain and evaluate VY Plant Specific data m Comprehensive, deliberate, well monitored power ascension 4

Quad Cities Experience , Methodologies developed after QC2 failures accurately predict high stress locations

Confirmed by actual high- stress failure locations 5

SIndustr Steam Dryer Experi I x r..' e Nearly 50 Reactor Operating Years of EPU Experience 120 . 2;/,0 4/04 S 8/00 110-0 /3 118 1/8 11/98 2/12/ 2/01 3/02 5/ ,602 262 8/96 1/2 12/02 103 6/02 100

                                'I.*":' :! :'            . .. . ..      T PR ,; _                     ¢        -         -

polit*o, 80 .. -0* ICY a 0 6

- En tergy Main Steam Line Flow Velocities 220.0 200.0 ' 160.0 SLi

   .E ci 140.0.-                                            ,,~,
                                                                                                        "!ig
                                                                               ~rol 120.0 100.0 4  1                                                            -.

(f!f41 ( f 10 - 0 0

                                                               -       -5  ---       --      --

LL m~m U) (1)i a),c)ajN( t- n t , CjC e-t 0MM-tý I t 00 i 00 07 MM 7

Overall Dryer Screening 120 100-80- .. , 'P60 40 20 H iPJ

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--*-'-Entergy _VY Steam Dryer Analysis

      , GE developed Finite Element Model of VY Dryer

Loads defined based on similar plant instrumented dryer data
Results: identified increased stress areas at uprate conditions
Developed robust modification -. industry experience incorporated
Re-ran the Model incorporating the modification and validated stresses were below Code limits at uprate conditions Significantly increased structural margin 9

   .*,, i*'*,'::*

fVY Steam Dryer Inspection

                  - * . . . ... .............v*** * ................

Internal & external visual inspection of steam dryer accessible areas
No outer bank or lower cover plate cracking found 10

-**-EntergW VY Steam Dryer Inspection Some visual indications were found: consistent with BWR industry-experience

Two 3" cracks in dryer steam dam were repaired & strengthened
Caused by fabrication residual stresses
Several intergranular stress corrosion cracks (IGSCC) were found (dryer end bank and drain channel)
Caused by sensitization -and weld residual stresses from original welding

          , Not structurally significant 11

En tergy Steam Dryer - Strengthening Design Modifications Lower cover plate - Increase -from 1/4" to 5/8" Upper vertical and horizontal cover plates in outer hood - Increase from 1/2" to 1"

Remove internal diagonal shippinrg braces

    , Eliminate stress concentrators which were the crack initiators for the Quad Cities Failures

Replace dryer bank tie bars and improve weld attachment
Add six, full-length external gussets to hood plates

     , Full penetration versus fillet welds

Gusset shoe provides enhanced weld strength
Employed low carbon stainless steel - IGSCC resistant 12

Admllhý pqp%_ .M. En tergy VY Dryer Before & After Strengthening Performed Repair of V-02m90 and Cut Original Tie Ba rs V-02-270 Welds a.nd Installed 8 New rie Bars 270°0 lug Installed new cover plate, front p-tateio, 270 o sides Before After 13

AdMIL PTO P-M E ntergý I__VY Steam Dryer Strengthening-Tie Bars 14

-SerSEnterr t n H ,* *.*..VY Steam Dryer Strengthenhing -Hood 15

Entergy VY Steam Dryer Monitoring

Measurements consistent with SIL 644

    . -Moisture carryover levels N System parameters (flow and level)

Inspection in planned refuel outage (-8 months of <115% uprate operation) 16

-ýý En.tergy VY Acoustic Circuit Model a Collect VY Main Steam Data

Develop Acoustic Circuit Model a Reconcile Test Results with GE Analysis 17

-L--"nte-rgy VY Main Steam System Data Collection Measurement locations more extensive than other stations

Pressure data taken with high speed recorder at:

MSL venturis (one on each steamline) N Vessel instrument reference legs (2)

Main steam header
Strain Gauges located on each steam line close to vessel
Data taken at 80%, 85%, 90%, 92%, 95%, 97%/and 100% power 18

Entergy VY Steam System Data Collection Map RPV Level Instrument Reference Leg High Speed Pressure Sensors (10) 19

tergy VY Steam Dryer Timeline Feb 2004 Mar 2004 Apr 2004 May 2004 Jun 2004 Jul 2004 Aug 2004 Sep 2004 VY Review/ I I aI I° , n°° I I Oversight A Tech Review RAT Set I. *'*'1?.*',*-. ;*: .*:'" :,:.,.*;.*?,*:*,,.*.*J.*:*

                                                         *.; r) . **m,, l*.. #** *, **,,:* *.*f,** *,. ,*;;,*,*,.:** *:'i;." 'i$*.<* , ;"JS*\" 'f***L-*,** * *,Ar-* L*f' Submittal GE Audit RAT Set 2 Submittal Design Inspection Modification Piping Vibs Data A

MS System Data AIqs Acoustic Ckt ACM Complete A 20

VY Uprate Testing and __ __ _ __ _Inspection Plan

Two Step Uprate
Gradual Power Ascension Test Plan with predefined hold points
Pre-uprate testing provides baseline data
Measurement program
Main Steam and Feedwater FIV Accelerometers
Steam System Pressure Transmitters
Main Steam Line Strain Gauges
Installed Plant Equipment
Inspection in planned refuel-outage (8 months of <115% uprate operation)

       , Detailed inspection consistent with SIL 644 21

a Q&,A. 22

September 15, 2003 MEMORANDUM TO: Stephen Dembek, Chief, Section ý2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM: Alan Wang, Project Manager, Section 2 IRA/ Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF MEETING HELD ON JULY 25, 2003, WITH GE NUCLEAR ENERGY (GENE) REGARDING STEAM DRYER FAILURES On July 25, 2003, representatives of GENE Met with the NRC staff to discuss the generic implications of the Quad Cities steam dryer fallures. The staff had invited GENE to share some of their preliminary analyses and insights to date with regard to the generic implications of the Quad Cities steam dryer failures. GENE state1 that the steam dryer does not perform any safety function. The staff did not disagree, but noted that the concern is not the failure of the steam dryer itself but the potential to damage or interfere with the ability of the plant to shut down the reactor. In addition, the staff was concerned that the failures could be a result of the increased steam flow due to the power uprate. GENE provided their root cause analyses for the two failures. GENE stated that the first failure was due to high cycle fatigue due to high frequency acoustic resonance and the second failure was due to high cycle fatigue due to low frequency pressure loading. GENE agreed that the increased flow contributed to both failures. GENE stated that a failure modes and effects analysis (FMEA) was performed to evaluate the likelihood and consequences for loose parts. This analysis determined that no loose part from a dryer failure would affect plant safety. In addition, GENE performed additional analyses to determine if the increased flow could potentially impact any other components in the reactor coolant system. This analyses determined for the identified components that they are acceptable at extended power uprate conditions. GENE's root cause determined that there are three basic hood types: square hoods used in BWR/3 designs, slanted hoods in early BWR/4 designs and curved hoods in BWR/4 and later designs., GENE stated that they have determined that this is the critical factor in determining the failure susceptibility of the steam dryers. GENE is developing a service information letter (SIL) to incorporate the lessons learned from the Quad Cities failures. The staff had several comments and questions regarding the FMEA and root cause analyses. GENE stated that much of this work was still preliminary. GENE proposed that the staff wait for the issuance of the SIL, so that the various analyses could be discussed in detail at a later meeting. The staff agreed and requested GENE to provide the SIL when available. GENE stated they expect the SIL to be issued in mid-August 2003 (the SIL was issued in early September). Docket No. 7195 Attachment 4-2 4 Pages

S. Dembek Joe Conen, Vice-Chairman of the Boiling Water Reactors Owners Group. (BWROG) noted that the industry is taking these failures seriously even though the~equipment is not safety-related.. He stated that the BWROG is holding discussions with the BWR Vessels and Internals Projects' to determine a course of action for accelerating activities related to cracking on non-safety components. A BWROG meeting is planned in late August when a draft of the GENE SIL becomes available. The staff stated that it-would like a meeting in September to discuss industry plans regarding the steam dryer failures and its impact on current and future uprates. In addition, the staff requested GENE to provide the SIL when available. The staff thanked GENE and the BWROG for the presentation and emphasized the need for an update on developments after the SIL has been issued. This meeting was informational. No regulatory decisions were made. The BWROG agreed to meet in 4-to 6 weeks. The meeting handout can be found in ADAMS under Accession No. ML032390172. The attendance list is attached. Project, No. 710

Attachment:

Meeting Attendees cc w/att: See next page

Project No. 710 'GE Nuclear Energy cc: Mr. George B. Stramback Manager Regulatory Services Project GE Nuclear Energy 175 Curtner Avenue San Jose, CA 95125 Mr. Charles M. Vaughan, Manager Facility Licensing Global Nuclear Fuel P.O. Box 780 Wilmington, NC 28402 Mr. Glen A. Watford, Manager Nuclear Fuel Engineering Global Nuclear Fuel P.O. Box 780 Wilmington, NC 28402 Mr. James F. Klapproth, Manager

.Engineering & Technology GE Nuclear Energy 175 Curtner Avenue San Jose, CA 95125

MEETING WITH GE NUCLEAR ENERGY ATTENDANCE LIST -'JULY 25, 2003 GE NUCLEAR ENERGY D. Pappouk T. Hurst EXELON R. Gesien A. Uhamkarant J. Meister K. Jury U. Bohlke G. DeBos T. Talon S. Eldridge T. Wojcik K. Nicely OTHER J. Conen (Vice Chairman, BWROG) L. Collins (Westinghouse) M. Grantham (Progress Energy) L. Yemma (Progress Energy) C. Nichols (Entergy) B. Hobbs (Entergy) D. Girrour (Entergy) G. Ohlemacher (Detroit Edison) J. Brown (Framatome.ANP) E. Martwis (TVA Browns Ferry) R. Hermann (SI) B. Sherman (State of Utah) D. Atwood (SNC) D. Tubbs (Mid-American Energy) G. Twachtman (McGraw-Hill) NRC J. Nakoski S. Bloom B. Elliot H. Chernoff L. Rossbach M. Shuaibi Z. Abdullahi E. Kendrick

October 12, 2005 Mr. Michael Kansler President Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION - EXTENDED POWER UPRATE REVIEW SCHEDULE AND LICENSE CONDITIONS (TAC NO. MC0761)

Dear Mr. Kansler:

By letter dated September 10, 2003, as supplemented by letters dated October 1, and October 28 (2 letters), 2003, January 31 (2 letters), March 4, May 19, July 2, July 27, July 30, August 12, August 25, September 14, Septe mnber 15, September 23, September 30 (2 letters), October 5, October 7 (2 letters), December 8 and December 9, 2004, and February 24, March 10, March 24, March 31, April 5, April 22, June 2, August 1, August 4, September 10, September 14, September 18, and Septembew 28, 2005, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a proposed license amendment to the Nuclear Regulatory Commission (NRC) for the Vermont Yankee Nuclear Power Station (VYNPS). The proposed amendment, "Technical Specification Proposed Change No. 263, Extended Power Uprate," would allow an increase in the maximum authorized power level for VYNPS from 1593 megawatts thermal (MWT)to 1912 MWT. In a letter dated December 15, 2003, the NRC staff informed Entergy that, based on a review of the VYNPS extended power uprate (EPU) application dated September 10, 2003, the supplement dated October 1, 2003, and the two supplements dated October 28, 2003, sufficient information had not been provided to allow the NRC staff to establish a review schedule. Entergy provided additional information in two supplements dated January 31, 2004, to address the NRC staff's concerns. Subsequently, in a letter dated February 20, 2004, the NRC staff informed Entergy that the staff had completed its acceptance review of the VYNPS EPU license amendment application and had established a forecast review completion date of January 31, 2005. In a letter dated October 15, 2004, the NRC staff notified Entergy that the staff's review schedule for the proposed VYNPS EPU amendment would be impacted, primarily due to concerns regarding the steam dryer analysis. The letter noted that during the review, in an attempt to resolve our steam dryer concerns, the NRC staff had requested additional information, held three public meetings with Entergy, and performed an audit of the steam dryer analysis at the General Electric (GE) office in San Jose, California. The letter also noted that information was needed to address technical issues raised during the VYNPS engineering inspection that was completed in September 2004. The letter stated that the EPU review schedule would be reassessed following receipt and review of supplemental information from Entergy. Docket No. 7195 Attachnienlt 6-1 10 Pages

M. Kansler

-2.

On April 5, 2005, Entergy submitted a supplement to the EPU application that completed submittal of a series of supplements to address the concerns in the October 15, 2004, letter. These supplements collectively contained a substantial amount of information that necessitated significant NRC staff review time. As a result of the review of this information, the NRC staff issued a request for additional information (RAI) on July 27, 2005. The RAI contained 200 questions, of which 132 pertained to the steam dryer analysis, and 35 pertained to issues related to the methods used by GE to perform reactor neutronic and thermal/hydraulic analysis. To expedite the review, several draft ve'rsions of the RAls were provided to Entergy prior to formal RAI issuance on July 27, 2005, a technical audit of the steam dryer analysis was conducted on June 15 and 16, 2005, at the GE office in Washington, DC, and a public meeting on the GE methods issues was held at the NRC on June 30, 2005. Entergy provided 'responses to the RAI in supplements dated August 1, and August 4, 2005. The NRC staff reestablished the VYNPS EPU review schedule in a conference call with the Atomic Safety and Licensing Board (ASLB) on August 3, 2005. The transcript for the conference call can be accessed from the Agencywide Documents Access and Management System (ADAMS) Public Electronic Reading Room on the NRC Web site at http://www.nrc.gov/reading-rm/adams.html by entering Accession No. ML052210402. As discussed during the conference call, in which Entergy also participated, the next major milestone in the schedule is for the NRC staff to provide a draft safety evaluation (SE) to the Advisory Committee for Reactor Safeguards (ACRS) by October 21, 2005. The draft SE is needed to support an ACRS Subcommittee meeting in Vermont on November 15 and 16, 2005, and a second ACRS Subcommittee meeting at NRC Headquarters on November 30 and December 1, 2005. Other milestones discussed include an ACRS Full Committee meeting on December 8, 2005, and issuance of the final SE by February 24, 2006. As discussed during the conference call, and as also documented in the NRC-staff's status report to the ASLB dated August 15, 2005 (ADAMS Accession No. ML052310345), the staff noted that the schedule could be delayed if the responses dated August 1 and August 4, 2005, do not fully address the issues raised in the RAI dated July 27, 2005. The NRC staff's review of the August 1 and August 4, 2005, responses determined that the issues raised in the RAI dated July 27, 2005, were not fully addressed by Entergy and that further information would be required for the staff to complete its review. The staff's efforts to expedite receipt of this information included: (1) an audit of GE's steam dryer scale model test facility in Vallecitos, California on August 15 and 16, 2005; (2) an audit of the steam dryer analysis at GE's office in Washington, DC on August 22 through August 25, 2005; (3) an audit of the methods used by GE to perform reactor neutronic and thermal/hydraulic analysis at GE's office in Washington, DC on September 7, 2005; (4) issuance of an RAI on September 7, 2005; (5) a meeting at GE's office in Washington, DC on September 14 and 15, 2005, to discuss the GE methods issues; and (6) a meeting at the NRC on September 21, 2005, a!so to discuss the GE methods issues. Entergy provided additional information to address the issues raised in the RAI, audits, and meetings in supplements dated September 10, 14, 18, and 28, 2005.

' M. Kansler The NRC staff's status report to the ASLB dated September 1.5, 2005, stated that the staff does not believe it is likely that the draft SE can.be completed by October 21, 2005. Our assessment of the schedule was primarily based on the fact that Entergy has not been able to adequately resolve the staff's concerns regarding the steam dryer analysis and the GE methods issue. In addition, through several rounds of RAls, Entergy has also not resolved the staff's concerns regarding the heed for post-EPU testing of modifications made to the condensate and feedwater system. The NRC staff has decided that several license conditions and a regulatory commitment, as shown in the enclosure to this letter, will be necessary to address the staff's concerns or to confirm predictions and assertions .you have made. One of the conditions slightly modifies a condition proposed in. Entergy's letter dated September 28, 2005,. pertaining to the minimum critical power ratio (addresses concerns related to uncertainties in the GE methods). Another condition, pertaining to monitoring and evaluating potential adverse flow effects (including steam *tyer structural integrity), adds new requirements to a condition proposed in Entergy's letter dated September 14, 2005. A third condition, proposed by the NRC staff, pertains to transient testing of the condensate and feedwater system. The proposed regulatory commitment pertains to actions associated with the license condition addressing potential adverse flow effects. In order to support the issuance of the draft SE by October 2.1, 2005, Entergy is requested to submit a supplement to the EPU application by October 17, 2005, accepting the license conditions and regulatory commitment proposed in the enclosure to this letter. It should be noted, however, that your acceptance does .not constitute completion of the staffs review of the EPU application. If you have any questions, please contact the VYNPS Project Manager, Mr. Richard Ennis, at (301) 415-1420. Sincerely, IRA/ J. E. Dyer, Director Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosure:

As stated cc w/encl.: See next page

Vermont Yankee Nuclear Power Station cc: Regional Administrator, Region I Ms. Carla A. White, RRPT, CHP Radiological Health U. S. Nuclear Regulatory Commission 475 Allendale Road Vermont Department of Health P.O. Box 70, Drawer #43 King of Prussia, PA 19406-1415 108 Cherry Street Mr. David R. Lewis Burlington, VT 05402-0070 Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W. Mr. James M. DeVincentis Manager, Licensing Washington, DC 20037-1128 Vermont Yankee Nuclear Power Station P.O. Box 0500 Ms. Christine S. Salembier, Commissioner 185 Old Ferry Road Vermont Department of Public Service 112 State Street Brattleboro, VT 05302-0500 Montpelier, VT 05620-2601 Resident Inspector Mr. Michael H. Dworkin, Chairman Vermont Yankee Nuclear Power Station Public Service Board U- S. Nuclear Regulatory Commission State of Vermont P.O. Box 176 112 State Street Vernon, VT 05354 Montpelier, VT 05620-2701 Director, Massachusetts Emergency Management Agency Chairman, Board of Selectmen Town of Vernon ATTN: James Muckerheide P.O. Box 116 400 Worcester Rd. Vernon, VT 05354-0116 Framingham, MA 01702-5399 Operating Experience Coordinator Jonathan M. Block, Esq. Main Street Vermont Yankee Nuclear Power Station P.O. Box 566 320 Governor Hunt Road Vernon, VT 05354 Putney, VT 05346-0566 G. Dana Bisbee, Esq. Mr. John F. McCann Deputy Attorney General Director, Nuclear Safety Assurance 33 Capitol Street Entergy Nuclear Operations, Inc. Concord, NH 03301-6937 440 Hamilton Avenue White Plains, NY 10601 Chief, Safety Unit Office of the Attorney General Mr. Gary J. Taylor One Ashburton Place, 19th Floor Chief Executive Officer Boston, MA 02108 Entergy Operations 1340 Echelon Parkway Ms. Deborah B. Katz Jackson, MS 39213 Box 83 Shelburne Falls, MA 01370

Vermont Yankee Nuclear Power Station cc: Mr. John T. Herron Mr. Ronald Toole 1282 Valley of Lakes Sr. VP and Chief Operating Officer Box R-10 Entergy Nuclear Operations, Inc. Hazelton,, PA 18202 440 Hamilton Avenue White Plains, NY 10601 Ms. Stacey M. Lousteau Treasury Department Mr. Danny L. Pace Entergy Services, Inc. Vice President, Engineering 639 Loyola Avenue Entergy Nuclear Operations, ,Inc. New Orleans, LA 70113 440 Hamilton Avenue White Plains, NY 10601 Mr. Raymond Shadis New England Coalition Mr. Brian O'Grady Post Office Box 98 Vice President,. Operations Support Edgecomb, ME 04556 Entergy Nuclear Operations, Inc. 440 Hamilton Avenue Mr. James P. Matteau White Plains, NY 10601 Executive Director Windham Regional Commission Mr. Michael J. Colomb 139 Main Street, Suite 505 Director of Oversight Brattleboro, VT 05301 Entergy Nuclear Operations, Inc. 440 Hamilton Avenue Mr. William K. Sherman White Plains, NY 10601 Vermont Department of Public Service 112 State Street Mr. John M. Fulton Drawer 20 Assistant General Counsel Montpelier, VT 05620-2601 Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601 Mr. Jay K. Thayer Site Vice President Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. Kenneth L. Graesser 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801

Proposed New License Conditions and Regulatory Commitment for Facility License DPR-28 In Support of Vermont Yankee Nuclear Power, Station Extended Power Uprate Review Proposed License Conditions As part of the proposed extended power uprate amendment for the Vermont Yankee Nuclear Power Station, license conditions 3.K, 3.L, and 3.M would be added to Facility Operating License DPR-28 as follows:. K. Minimum Critical Power Ratio When operating at thermal power greater than 1593 megawatts thermal, the safety limit minimum critical

      *cycle-specific      power ratio SLMCPR           (SLMCPR) shall be established by adding 0.02 to the value calculated using the NRC-approved methodologies documented in General Electric Licensing Topical Report NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel,"-as amehded, and documented in the Core Operating Limits Report.

L. Transient Testing During the extended power uprate (EýU) power ascension test program and prior to exceeding 168 hours of plant operatioh at the nominal full EPU reactor power level, with feedwater and condensate flow rates at approximately the EPU 'full power

                                                                                               ,tabilized level, Entergy Nuclear    Operations,    Inc.' shall confirm  (1) through   performance      of transient  testing that the  loss  of one  condensate    pump    will not result in a  complete    loss of reactor feedwater    and   (2) through  performance     of additional   transient  testing,  or analysis of the results of the testing conducted in (1) above, that the loss of one reactor feedwater pump will not result in a reactor trip.

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

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

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

b.- Entergy Nuclear Operations, Inc. shall hold the facility for 24 hours at 105%, 110%, and 115% of OLTP to collect data from the 32 MSL strain gages required by Condition M.1.a, conduct plant inspections and walkdowns, and evaluate Enclosure

steam dryer performance based on these data.; shall provide the evaluation to the NRC staff by facsimile or electronic transmission to the NRC project manager upon completion of the evaluation; and shall not increase power above each hold point until 96 hours after the NRC project manager confirms receipt of the transmission.

c. If any frequency peak from the MSL strain gage data exceeds the limit curve

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

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

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

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

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

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

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

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

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

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

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

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

3. Entergy Nuclear Operations, Inc. shall prepare the EPU startup test procedure to include the (a) stress limit curve to be applied for evaluating steam dryer performance; (b) specific hold points and their duration during EPU power ascension; (c) activities to be accomplished during hold points; (d) plant parameters to be monitored; (e) inspections and walkdowns to be conducted for steam, feedwater, and condensate systems and components during the hold points; (f) methods to be used to trend plant parameters; (g) acceptance criteria for monitoring and trending plant parameters, and conducting the walkdowns and inspections; (h) actions to be taken if acceptance criteria are not satisfied; and (i) verification of the completion of commitments and planned actions specified in its application and all supplements to the application in support of the EPU license amendment request pertaining to'the steam dryer prior to power increase above OLTP. Entergy Nuclear Operations, Inc. shall submit the EPU startup test procedure to the NRC by facsimile or electronic transmission to the NRC project manager prior to increasing power above OLTP.

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

Enclosure

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

b. Level 1 performance criteria; and

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

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

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

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

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

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

Proposed Regulatory Commitment In addition to the license conditions proposed above, the licensee is requested to make the following regulatory commitment: With regard to License Condition 3.M, "Potential Adverse Flow Effects," Entergy will provide information on plant data, evaluations, walkdowns, inspections, and procedures associated with the individual requirements of that license condition to the NRC staff prior to increasing power above 1593 MWt or each specified hold point, as applicable. If any safety concerns are identified during the NRC staff review of the provided information, Entergy will not increase power above 1593 MWt or the applicable hold Enclosure

(9 point, and the specific requirements in the license condition will not be satisfied. Enclosure

0 March 2, 2006 Mr. Michael Kansler President Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: EXTENDED POWER UPRATE (TAC NO. MC0761)

Dear Mr. Kansler:

The Commission has issued.the enclosed Am ndment No. 229 to Facility Operating License No. DPR-28 for the Vermont Yankee Nuclear Power Station (VYNPS), in response to your application dated September 10, 2003, as supplemented by letters dated October 1, and October 28 (2 letters), 2003; January 31 (2 letters), March 4, May 19, July 2, July 27, July 30, August 12, August 25, September 14, September 15, September 23, September 30 (2 letters), October 5, October 7 (2 letters), December 8, and December 9, 2004; February 24, March 10, March 24, March 31, April 5, April 22, June 2, August 1, August 4, September 10, September 14, September 18, September 28, October 17, October 21 (2 letters), October.26, October 29, November 2, November 22, and December 2, 2005; January 10, and February 22, 2006. The amendment increases the maximum authorized power level for VYNPS from 1593 megawatts thermal (MWt) to 1912 MWt, which is an increase of approximately 20 percent. The increase in power level is considered an extended power uprate (EPU). The amendment includes revisions to the VYNPS Operating License and Technical Specifications that are necessary to implement the EPU. The related Safety Evaluation (SE) has been determined to contain proprietary information pursuant to Title 10 of the Code of FederalRegulations, Section.2.390. Accordingly, the NRC staff has prepared a redacted, publicly-available, non-proprietary version of the SE. Copies of the proprietary and non-proprietary versions of the SE are enclosed. Docket No. 7195 Attachment 6-2 15 Pages

M. Kansler A copy of the "Notice of Issuance of Amendment to Facility Operating License and Final Determination of No Significant Hazards Consideration," which is being forwarded to the Office of the Federal Register for publication, is also enclosed. Sincerely, IRA/ Richard B. Ennis, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket, No. 50-271

Enclosures:

1. Amendment No. 229 to License No. DPR-28

2. Non-proprietary SE

3. Proprietary SE

4. Notice cc w/encls 1, 2, and 4: See next page

Distribution for letter dated: March 2, 2006

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION (TAC - ISSUANCE OF RE: EXTENDED POWER UPRATE NO. MC0761) AMENDMENT. DISTRIBUTION: PUBLIC LPL1-2 Reading JDyer RBorchardt BSheron BBoger CHaney CHolden EHackett DRoberts REnnis JShea CRaynor SLittle TAlexion QNguyen OGC ACRS GHill (2) CAnderson, RGN I STurk, OGC VBucci, OIG HGarg NTrehan APal BElliot RDavis KParczewski TScarbrough PSekerak CWu RPettis RPedersen JCai JBongarra DReddy RGallucci .MStutzke RLobel HWalker MHart MRazzaque ZAbdullahi GThomas LWard THuang

Vermont Yankee Nuclear Power Station cc: Regional Administrator, Region I Ms. Carla A.:White, RRPT, CHP U. S. Nuclear Regulatory Commission Radiological Health 475 Allendale Road Vermont Department of Health King of Prussia, PA 19406-1415 P.O. Box 70, Drawer #43 108 Cherry Street Mr. David R. Lewis Burlington, VT 05402-0070 Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W. Mr. James M. DeVincentis Washington, DC 20037-1128 Manager, Licensing Vermont Yankee Nuclear Power Station Mr. David O'Brien, Commissioner P.O. Box 0500 Vermont Department of Public Service 185 Old Ferry Road 112 State Street .Brattleboro, VT 05302-0500 Montpelier, VT 05620-2601 Resident Inspector Mr. James VoIz, Chairman Vermont Yankee Nuclear Power Station Public Service Board U. S. Nuclear Regulatory Commission State of Vermont P.O. Box 176 112 State Street Vernon, VT 05354 Montpelier, VT 05620-2701 Director, Massachusetts Emergency Chairman, Board of Selectmen Management Agency Town of Vernon ATTN: James Muckerheide P.O. Box 116 400 Worcester Rd. Vernon, VT 05354-0116 Framingham, MA 01702-5399 Operating Experience Coordinator Jonathan M. Block, Esq. Vermont Yankee Nuclear Power Station Main Street 320 Governor Hunt Road P.O. Box 566 Vernon, VT 05354 Putney, VT 05346-0566 G. Dana Bisbee, Esq. Mr. John F. McCann Deputy Attorney General Director, Licensing 33 Capitol Street Entergy Nuclear Operations, Inc. Concord, NH 03301-6937 440 Hamilton Avenue White Plains, NY 10601 Chief, Safety Unit Office of the Attorney General Mr. Gary J. Taylor One Ashburton Place, 19th Floor Chief Executive Officer Boston, MA 02108 Entergy Operations 1.340 Echelon Parkway Jackson, MS 39213

Vermont Yankee Nuclear Power Station cc: Mr. John T. Herron Ms. Stacey M. Lousteau Treasury Department Sr. VP and Chief Operating Officer Entergy Services, Inc. Entergy Nuclear Operations, Inc. 440 Hamilton .Avenue 639 Loyola Avenue New Orleans, LA 70113 White Plains, NY 10601 Mr. Oscar Limpias Mr. Raymond Shadis Vice President, Engineering New England Coalition Entergy Nuclear Operations, Inc. Post Office Box 98 Edgecomb, ME 04556 440 Hamilton Avenue White Plains, NY 10601 Mr. James P. Matteau Mr. Christopher Schwarz Executive Director Vice President, Operations Support Windham Regional Commission Entergy Nuclear Operations, Inc. 139 Main Street, Suite 505 Brattleboro, VT 05301 440 Hamilton Avenue White Plains, NY 10601 Mr. William K. Sherman Mr. Michael J. Colomb Vermont Department of Public Service Director of Oversight 112 State Street Entergy Nuclear Operations, Inc. Drawer 20 Montpelier, VT 05620-2601 440 Hamilton Avenue White Plains, NY 10601 Mr. Michael D. Lyster Mr. Travis C. McCullough 5931 Barclay Lane Assistant General Counsel Naples, FL 34110-7306 Entergy Nuclear Operations, Inc. 440 Hamilton Avenue Ms. Charlene D. Faison Manager, Licensing White Plains, NY 10601 440 Hamilton Avenue Mr. Jay K. Thayer White Plains, NY 10601 Site Vice President Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. James H. Sniezek 5486 Nithsdale Drive Salisbury, MD 21801

ENTERGY NUCLEAR VERMONT YANKEE. LLC AND ENTERGY NUCLEAR OPERATIONS, INC. DOCKET NO. 50-271 VERMONT YANKEE NUCLEAR POWER STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 229 License No. DPR-28

1. The Nuclear Regulatory Commission '.(the Commission) has found that:

A. The application for amendment filed by Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operatiorhs, Inc. (the licensee) on September 10, 2003, as supplemented by letters dated Pctober 1, and October 28 (2 letters), 2003; January 31 (2 letters), March 4, May 19, July 2, July 27, July 30, August 12, August 25, September 14, September 15, September 23, September 30 (2 letters), October 5, October 7 (2 letters), December 8, and December 9, 2004; February 24, March 10, March 24, March 31, April 5, April 22, June 2, August 1, August 4, September 10, September 14, September 18, September 28, October 17, October 21 (2 letters), October 26, October 29, November 2, November 22, and December 2, 2005; January 10, and February 22, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Facility Operating License No. DPR-28 is hereby amended to read as follows:

(B) Technical Specifications The Technical Specifications contained in Appendix A, as revised through

           .Amendment No. 229, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

In addition, the license is amended to revise paragraph 3.A of Facility Operating License No. DPR-28 to reflect the new maximum licensed reactor core power level of 1912 megawatts thermal. The licensee is also amended to add new license conditions 3.K, 3.L, and 3.M as follows: K. Minimum Critical Power Ratio When operating at thermal power greater than 1593 megawatts thermal, the safety limit minimum critical power ratio (SLMCPR) shall be established by adding 0.02 to the cycle-specific SLMCPR value calculatpd using the NRC-approved methodologies documented in General Electric Licen~ing Topical Report NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel," as amended, and documented in the Core Operating Limits Report. L. Transient Testinq

1. During the extended power uprate (EPU) power ascension test program and prior to exceeding 168 hours of plant operation at the nominal full EPU reactor power level, with feedwater and condensate flow rates stabilized at approximately the EPU full power level, Entergy Nuclear Operations, Inc. shall confirm through performance of transient testing that the loss of one condensate pump will not result in a complete loss of reactor feedwater.

2. Within 30 days at nominal full-power operation following successful performance of the test in (1) above, through performance of additional transient testing and/or analysis of the results of the testing conducted in (1) above, confirm that the loss of one reactor feedwater pump will not result in a reactor trip.

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

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

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

b. Entergy Nuclear Operations, Inc. shall hold the facility for 24 hours at 105%,

110%, and 115% of OLTP to collect data from the 32 MSL strain gages required by Condition M.1 .a, conduct plant inspections and walkdowns, and evaluate steam dryer performance based on these data; shall provide the evaluation to the NRC staff by facsimile or electronic transmission to the NRC project manager upon completion of the evaluation; and shall not increase power above each hold point until 96 hours after the NRC project manager confirms receipt of the transmission.

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

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

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

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

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

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

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

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

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

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

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

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

3. Entergy Nuclear Operations, Inc. shall prepare the EPU startup test proced ure to include the (a) stress limit curve to be applied for evaluating steam dryer performance; (b) specific hold points and their duration during EPU power ascension; (c) activities to be accomplished during hold points; (d) plant parameters to be monitored; (e) inspections and walkdowns to be conducted for steam, feedwater, and condensate systems and components during the hold points; (f) methods to be used to trend plant parameters; (g) acceptance criteria for monitoring and trending plant parameters, and conducting the walkdowns and inspections; (h) actions to be taken if acceptance criteria are not satisfied; and (i) verification of the completion of commitments and planned actions specified in its application and all supplements to the application in support of the EPU license amendment request pertaining to the steam dryer prior to power increase above OLTP. Entergy Nuclear Operations, Inc. shall provide the related EPU startup test procedure sections to the NRC by facsimile or electronic transmission to the NRC project manager prior to increasing power above OLTP.

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

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

b. Level 1 performance criteria; and

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

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

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

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

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

8. This license condition shall expire upon satisfaction of the requirements in.

paragraphs 5, 6, and 7 provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw or unacceptable flaw growth that is due to fatigue.

6-

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days.

FOR THE NUCLEAR REGULATORY COMMISSION IRAI J. E. Dyer, Director Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and Technical Specifications Date of Issuance: March 2, 2006

ATTACHMENT TO LICENSE AMENDMENT NO. 229 FACILITY OPERATING LICENSE NO. DPR-28 DOCKET NO. 50-271 Replace the following pages of the Facility Operating License and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Facility Operatinq License Remove Insert 3 3 9 9 10

                                          --                  11 12-Tehna S13 Technical Spjecifications Remove                       Insert 3                            3 6                            6 7                            7 10                           10 12                            12 13                            13 14                            14 15                            15 17                            17 21                           21 24                           24 30                           30 83                           83 90                           90 92                           92 94                           94 97                           97 98                           98 135                          *135 136                           136 137                           137 138                           138 142                           142 224                           224 225                           225 226                           226 228                          228

7590-01-P U.S. NUCLEAR REGULATORY COMMISSION ENTERGY NUCLEAR VERMONT YANKEE, LLC AND ENTERGY NUCLEAR OPERATIONS, INC. DOCKET NO. 50-271 NOTICE OF ISSUANCE OF AMENDMENT TO FACILITY OPERATING LICENSE AND FINAL DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The U.S. Nuclear Regulatory Commission (Commission) has issued Amendment No. 229 to Facility Operating License No. DPR-28, issued to Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (the licensee), which revised the Technical Specifications (TSs) and License for operation of the Vermont Yankee Nuclear Power Station (VYNPS) located in Windham County, Vermont. The amendment was effective as of the date, of its issuance. The amendment increases the maximum authorized power level for VYNPS from 1593 megawatts thermal (MWt) to 1912 MWt, which is an increase of approximately 20 percent. The increase in power level is considered an extended power uprate. The application for the amendment complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations. The Commission has made appropriate findings as required by the Act and the Commission's rules and regulations in 10 CFR Chapter I, which are set forth in the license amendment. The Commission published a "Notice of Consideration of Issuance of Amendment to Facility Operating License and Opportunity for a Hearing" related to this action in the FEDERAL REGISTER on July 1, 2004 (69 FR 39976). This Notice provided 60 days for the public to

request a hearing. On August 30,'2004, the Vermont Department of Public Service and the New England Coalition filed requests for hearing in connection with the proposed amendment. By Order dated November 22, 2004, the Atomic Safety, and Licensing Board (ASLB) granted those hearing requests and by Order dated December. 16, 2004, the ASLB issued its decision to conduct a hearing using the procedures in 10 CFR Part 2, Subpart .L,"Informal Hearing Procedures for NRC Adjudications." The Commission published a "Notice of Consideration of Issuance of Amendment to Facility Operating License and Proposed No Significant Hazards Consideration Determination" related to this action in the FEDERAL'REGISTER on January 11,'2006 (71 FR 1744). This Notice provided 30 days for public comment. The Commission received comments on the proposed no significant hazards consideratior as discussed below. Under its regulations, the Commission Tay issue and make an amendment immediately effective, notwithstanding the pendency before it of a request for a hearing from any person, in advance of the holding and completion of any required hearing, where it has determined that no significant hazards consideration is involved. The Commission has applied the standards of 10 CFR 50.92 and has made a final determination that the amendment involves no significant hazards consideration. Public comments received on the proposed no significant hazards consideration determination were considered in making the final determination. The basis for this determination is contained in the Safety Evaluation related to this action. Accordingly, as described above, the amendment has been issued and made immediately effective and any hearing will be held after issuance. The Commission published an Environmental Assessment related to the action in the FEDERAL REGISTER on January 27, 2006 (71 FR 4614). Based on the Environmental Assessment, the Commission concluded that the action will not have a significant effect on the

O quality of the human environment. Accordingly, the Commission determined not to prepare an environmental impact statement for the proposed action. For further details with respect to this action, see the application for amendment dated September 1 0, 2003, as supplemented by letters dated October 1, and October 28 (2 letters), 2003; January 31 (2 letters), March 4, May 19, July 2; July 27, July 30, August 12, August 25, September 14, September 15, September 23, September 30 (2 letters), October 5, October 7 (2 letters), December 8, and December 9, 2004; February 24, March 10, March 24, March 31, April 5, April 22, June 2, August 1, August 4, September 10, September 14, September 18, September 2 8 , October 17, October 21 (2 letters), October 26,,October 29, November 2, November 22, and December 2, 2005; Janua~ry 10, and February 22, 2006, which is available for public inspection at the Commission's PDbi, located at One White.Flint North, Public File Area 01 F21, 11555 Rockville Pike (first floor)ý, Rockville, Maryland. Publicly available records will be accessible electronically from the Agencywide .Documents Access and Management System's (ADAMS) Public Electronic Reading Room on the Internet at the NRC Web site, http://www.nrc.gov/reading-rm/adams.html. Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS, should contact the NRC PDR Reference staff by telephone at 1-800-397-4209, 301-415-4737, or by e-mail to pdrcnrc.gaov. Dated at Rockville, Maryland, this 2nd day of March, 2006. FOR THE NUCLEAR REGULATORY COMMISSION IRAI Richard B. Ennis, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

April 5, 2006 MEMORANDUM TO: Darrell J. Roberts, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Kamal A. Manoly, Chief IRA! Engineering Mechanics Branch Division of Engineering Office of Nuclear Reactor Regulation

SUBJECT:

STAFF TECHNICAL BASIS FOR CONTINUED POWER ASCENSION OF VERMONT YANKEE NUCLEAR POWER STATION UP TO 110% ORIGINAL LICENSED THERMAL POWER (TAC NO. MD0263) Introduction On" March 2, 2006, the U.S. Nuclear Regulatory Commission (NRC) approved the request by Entergy Nuclear Operations, Inc. (Entergy) to increase the maximum authorized power level for Vermont Yankee Nuclear Power Station (Vermont Yankee) from 1593 Megawatts thermal (MWt) to 1912 MWt as an extended power uprate (EPU) equivalent to 120% of the original licensed thermal power (OLTP). During the subsequent power ascension at Vermont Yankee, plant instrumentation reached an initial administrative limit that required the licensee to evaluate the plant data before continuing the power ascension. On March 26, Entergy submitted its justification for continued power ascension at Vermont Yankee up to 110% OLTP. The NRC staff has reviewed the licensee's justification for continued power ascension at Vermont Yankee. Entergy will need to justify power ascension beyond 110% OLTP based on its review, of plant data collected up to that power level. A narrative of the NRC staffs review of the licensee's justification for continued power ascension at Vermont Yankee is provided below.

Background

Following receipt of the EPU license amendment, Entergy began to slowly increase reactor power above OLTP on March 4, 2006, at Vermont Yankee in accordance with its power ascension test procedure. The EPU amendment included a license condition that provides for monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of power uprate operation on structures, systems, and components (including verifying the continued structural integrity of the steam dryer) at Vermont Yankee. CONTACT: Thomas G. Scarbrough, DCI/CPTB 301-415-2794 Docket No. 7195 Attachment 7-1 4 Pages

                                                   *2 D. Roberts specifies that (1) the power ascension rate The Vermont Yankee power ascension procedure performance data be monitored hourly and dryer be no more than 16 MWt per hour; (2) steam level  be held for 4 hours at each 40 MWt step compared to acceptance criteria; (3) power plant performance data; and (4) power level be (2.5% OLTP) to obtain and evaluate additional                                                           to (5% OLTP) to conduct plant walkdowns and held for 96 hours at each 80 MWt plateau review. Entergy has made a regulatory perform steam dryer analysis with NRC staff                          if the NRC staff identifies a safety commitment to not increase power at Vermont Yankee data.

concern during its evaluation of the plant data collects Main Steam Line (MSL) strain gage As part of the plant data evaluation, Entergy flow. The licensee inputsthe MSL strain to monitor pressure fluctuations within the main steam calculate pressure loads on the steam dryer gage data into an acoustic circuit model (ACM) to using a finite element model (FEM). The and the resulting stress in steam dryer components the (SDMP) establishes a Level 1 limit curve for Vermont Yankee Steam Dryer Monitoring Plan American Society of Mechanical Engineers MSL strain versus frequency spectra based on the fatigue stress limit of 13,600 pounds per square (ASME) Boiler & Pressure Vessel Code (Code) 80% of that fatigue limit. If the Level 2 limit curve inch (psi), and a Level 2 limit curve based on be suspended until an engineering is reached, the SDMP specifies that power ascension is justified. If the Level 1 limit curve is evaluation concludes that further power ascension curve is not exceeded. untiltthe reached, the licensee must reduce power the MSL, strain gage data from the "A" MSL at On March 5, Entergy notified the, NRC staff tha) MSL at 105% OLTP. Entergy's evaluation of the Vermont Yankee had reached the Level 2 limit that it was acceptable to maintain plant strain gage and accelerometer data concluded evaluation was performed. The NRC staff operation at 105% OLTP while the engineering at and concluded that continued plant operation independently evaluated the 105% OLTP data, 105% OLTP was reasonable and acceptable. Licensee Justification for Power Ascension up to 110% OLTP of the Verr-nont Yankee On March 26, 2006, Entergy completed its engineering evaluation OLTP. The power ascension to 110% steam dryer and its justification for continued bounding of actual steam dryer that is more engineering evaluation used (1) an improved ACM that refines the assessment of the gusset FEM loads with reduced uncertainty; (2) an updated in a similar steam dryer at the Dresden nuclear power plant; shoe area that was of concern system designed to redLu ce the (3) a more precise MSL strain gage data acquisition and (4) MSL strain gage dat.a collected at measurement uncertainty in the acoustic signals; 105% OLTP. Yankee steam dryer compone nts remains Entergy verified that the stress in the Vermont limit of 13,600 psi at 105% OLTP. Further, significantly below the ASME Code fatigue stress MSL strain gage data acquisition system allowed the reduced uncertainty in the ACM and the gage measurements while maintaining the Entergy to raise the limit curve for the MSL strain Code fatigue stress limit. The new limit ASME resulting stress in the steam dryer below the into a revision of the Vermont Yankee SDMP. curve has been incorporated

D. Roberts 3 Based on its engineering evaluation, Entergy has determined that continued power ascension to 110% OLTP will not cause stress exceedance in the steam dryer components that would challenge the structural integrity of the dryer.

NRC Staff Evaluation

The NRC staff, with support from its consultants from Argonne National Laboratory, has reviewed Entergy's engineering evaluation consist.ing of multiple analyses, data, and figures. The staff's review of the licensee's generic application of uncertainty assumptions for the revised ACM and improved MSL strain gage instrumentation is continuing. At this time, the staff has evaluated the licensee's basis for continued power ascension at Vermont Yankee up to 110% OLTP, including the calculation of the stresses on the steam dryer components at 105% OLTP and the establishment of new limit curves for MSL strain gage data in support of operation up to 110%. OLTP. is The Vermont Yankee steam dryer analysis indicates that the steam dryer gusset shoe area the Vermont Yankee steam dryer for EPU operation. The the most limiting stress location on stress on this component at 105% OLTP is calculated to be 2321 psi from the ACM and 599 psi from the Computational Fluid Dynamics (CFD) analyses. If the MSL strain gage measurements increase up to the new Level 1 limit curve in all four steam lines, the stress at this location is of projected to be 9866 psi. This stress is about 40% less than the ASME Code fatigue limit 13,600 psi. The Vermont Yankee SDMP provides additional margin in that power ascension must be halted and the collected data evaluated if any portion of the measured MSL strain-frequency spectra reaches the Level 2 limit (80% of the 13,600 psi limit) for any of the four steam lines. As part of its review, the staff compared the Vermont Yankee MSL strain gage limit curves and established for initial power ascension to the new limit curves based on the revised ACM more accurate MSL strain gage data. Although the new limit curves permit a higher MSL strain gage signal than the initial curves, the allowed MSL strain levels continue to be low. Higher strain peaks at the resonance frequencies experienced at 105% OLTP were acceptable to be included in the limit curve based on their insignificant contribution to the total resulting stress. Since the only instrumented steam dryer among the operating U.S. boiling water reactors is that at U.S. at Quad Cities Unit 2 and the original steam dryers at Quad Cities were the only dryers the revised Level 1 limit plants that have experienced severe damage under EPU conditions, at Quad Cities Unit 2. curve for Vermont Yankee was compared to the MSL data measured The comparison indicated that the Vermont Yankee revised Level 1 limit was significantly below the MSL data measured at Quad Cities Unit 2. Further, the Vermont Yankee SDMP will require MSL strain the licensee to halt power ascension if any. acoustic signal from the Vermont Yankee gage data in any MSL reaches the Level 2 limit curve, which is 80% ofthe Level 1 limit curve. With respect to the low-frequency regions of MSL strain gage data, the staff will ensure that ascension where the Entergy closely monitors those low frequency areas during future power Vermont Yankee Level 1 limit curve is above the measured Quad Cities Unit 2 MSL data.

D. Roberts 4 in the skirt region of the steam dryer The NRC staff is reviewing the. recently identified cracking initiated an extensive effort to determine at Quad Cities Unit 2. The Quad Cities licensee has Quad Cities Unit 2 operated at up to the cause of the cracking. Prior to the current outage, substantial high-frequency acoustic 117% of the original licensed power for about 6 months with applicability of the Quad Cities Unit 2 loads on the steam dryer. Entergy has evaluated the evaluation of the applicability of information to Vermont Yankee. The staff reviewed Entergy's Ya'nkee. Entergy applied a more the Quad Cities Unit 2 steam dryer cradking to Vermont steam dryer skirt at Vermont conservative damping assumption in its assessment of the conservative damping assumption, Yankee than that used at Quad Cities. 'Even with this more dryer is calculated to be less than the stress in the skirt region of the Vermont Yankee steam margin in the stress analysis for the 1000 psi at 1 05% OLTP. Therefore, there is considerable and other assumptions. The staff does skirt region at Vermont Yankee to account for damping Cities Unit 2 steam dryer to raise a not consider the cracking in the, skirt region of the Quad up to 11 /%OLTP. safety concern with power ascension at Vermont Yankee Conclusion the NRC staff concludes that the Based on its review of the Entergy's engineering evaluation, power ascension up to 110% OLTP at licensee has provided a reasonable basis for cqntinuing that maintain MSL strain gage Vermont Yankee, including (1) plant performande limit curves acoustic range; (2) frequent data far lower than the Quad Cities data in the hligh-frequency of the MSL strain gage data; monitoring of plant performance data, including hourly collection of the measured MSL strain and (3) plant procedures that halt power ascension if any portion Yankee MISL. On vs. frequency spectra reach the Level 2 limit curve for any Vermont the staff did not object to the continued March 31, 2006, the NRC staff informed Entergy that OLTP. The staff will continue to power ascension process at Vermont Yankee up to 110% Entergy as part of the review of the discuss the steam dryer analysis and its assumptions with nuclear power plants. The staff will revised ACM for generic use at Vermont Yankee and other data for any increases toward the ensure that Entergy closely monitors the MSL strain gage staff will review Entergy's limit curves during the power ascension at Vermont Yankee. The power ascension, based on justification for continued power uprate operation, including further step. the plant data collected during this next power ascension DISTRIBUTION: DCI r/f Mmayfield Elmbro

previously concurred ADAMS NO.: ML060970111 IDAE K CManoly NAIbrLouh 0 "/40 CWu 04/05/06 04/05/06 OFFICIAL RECORD COPY

April 28, 2006 MEMORANDUM TO: Darrell J. Roberts, Chief Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Kamal A. Manoly, Chief IRA/ Engineering Mechanics Branch Division of Engineering Office of Nuclear Reactor Regulation

SUBJECT:

STAFF TECHNICAL BASIS FOR CONTINUED POWER ASCENSION OF VERMONT YANKEE NUCLEAR POWER STATION UP TO 115% ORIGINAL LICENSED THERMAL POWER (TAC NO. MD0263) Introduction On March 2, 2006, the U.S. Nuclear Regulatotý Commission (NRC) approved the request by Entergy Nuclear Operations, Inc. (Entergy) to increase the maximum authorized power level for Vermont Yankee Nuclear Power Station (Vermont Yankee) from 1593 Megawatts thermal (MWt) to 1912 MWt as an extended power uprate (EPU) equivalent to 120% of the original licensed thermal. power (OLTP). During the initial power ascension at Vermont Yankee, plant instrumentation reached an administrative limit at 105% OLTP that required the licensee to. evaluate the plant data before continuing the power ascension. As documented in a staff memorandum dated April 5, 2006, the licensee justified continued power ascension at Vermont Yankee. Upon achieving 112.5% OLTP (1791 MWt) on April 6, Entergy informed the staff that plant instrumentation at Vermont Yankee had again reached an administrative limit that required evaluation. On April 20, Entergy submitted its evaluation to justify continued power ascension beyond 112.5% OLTP. On April 21, the staff informed Entergy that it did not object to the continued power ascension of Vermont Yankee up to 115% OLTP. A narrative of the NRC staff's reView of the licensee's justification for continued power ascension at Vermont Yankee is provided below.* Backqround Following receipt of the EPU license amendment, Entergy began to slowly increase reactor power at Vermont Yankee above OLTP on March 4, 2006, in accordance with its power ascension test procedure. The EPU amendment included a license condition that provides for monitoring and evaluating plant data at Vermont Yankee, and taking prompt action in response to potential adverse flow effects as a result of power uprate operation on structures, systems, and components (including verifying the continued structural integrity of the steam dryer). CONTACT: Thomas G. Scarbrough, DCI/CPTB 301-415-2794 Docket No. 7195 Attachment 7-2 4 Pages

                                                                                                     -Y D. Roberts                                     2 The Vermont Yankee power ascension procedure specifies that (1) the power ascension rate be no more than 16 MWt per hour; (2) steam dryer performance data be monitored hourly and compared to acceptance criteria; (3) power level be held for 4 hours at each 40 MWt step (2.5% OLTP) to obtain and evaluate additional plant performance data; and (4) power level be held for 96 hours at each 80 MWt plateau (5% OLTP) to conduct plant walkdowns and to perform steam dryer analysis whose results would be examined by the NRC staff. Entergy made a regulatory commitment to not increase power at Vermont Yankee if the NRC staff identified a safety concern during its evaluation of the plant data.

As part of the plant data evaluation, Entergy collects Main Steam Line (MSL) strain gage data to monitor pressure fluctuations within the main steam flow. The licensee inputs the MSL strain gage data into an acoustic circuit model (ACM) to calculate pressure loads on the steam dryer and the resulting stress in steam dryer components using a finite element model (FEM). The Vermont Yankee Steam Dryer Monitoring Plan (SDMP) establishes a Level 1 limit curve for the MSL strain versus frequency spectra based on the American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code (Code) fatigue stress limit of 13,600 pounds per square inch (psi,), and a Level 2 limit curve based on 80% of that fatigue limit. If the Level 2 limit curve is reached, the SDMP specifies that power ascension be suspended until an engineering evaluation concludes that further power ascension is justified. If the Level 1 limit curve is reached, the licensee must reduce power until thecurve is not exceeded. On March 5, Entergy notified the NRC staff that the MSL strain gage data from the "A" MSL at Vermont Yankee had reached the Level 2 limit at 105% OLTP. On March 26, Entergy completed its engineering evaluation of the Vermont Yankee steam dryer and its justification for continued power ascension to 110% OLTP. Entergy verified that the stress in the Vermont Yankee steam dryer components remained significantly below the ASME Code fatigue stress limit of 13,600 psi at 105% OLTP. Based on its engineering evaluation, Entergy determined that continued power ascension to 110% OLTP would not cause stress exceedance in the steam dryer components that would challenge the structural integrity of the dryer. The NRC staff reviewed the licensee's justification for continued power ascension at Vermont Yankee beyond 105% OLTP. The NRC staff informed Entergy on March 31 that it did not have a safety concern with power ascension up to 110% OLTP, and documented its decision in a memorandum dated April 5, 2006. Subsequently, the licensee continued the power ascension at Vermont Yankee, and achieved 110% OLTP with the collected data remaining within the acceptance criteri8. The staff reviewed the plant data, and did not object to continued power ascension up to 115% OLTP. Licensee Justification for Power Ascension uw to 115% OLTP During further power ascension at Vermont Yankee, Entergy informed the NRC staff on April 6 that plant instrumentation at Vermont Yankee had reached an administrative limitat 112.5% OLTP that required evaluation. In particular, the licensee reported that the MSL strain gage data from the "A" MSL reached the Level 2 limit at a frequency resonance peak of 143 Hz. The licensee provided the specific plant data that supported its decision to remain at 112.5% OLTP while evaluating the data. The staff reviewed the plant data and held telephone discussions regarding the data with the licensee. Based on its review, the staff did not object to Vermont Yankee remaining at 112.5% OLTP while the licensee evaluated the plant data.

D. Roberts 3 On April 20, Entergy submitted its evaluation of the plant data to justify continued power ascension at Vermont Yankee beyond 112.5% OLTP. The licensee recalculated the stress on the steam dryer using the plant data from 112.5% OLTP and its current version of the ACM. As part of its analysis, the licensee adjusted the uncertainty associated with the ability of the ACM to match the frequency spectra from 15% to 25%. The licensee then recalculated the Level 1 and Level 2 limit curves for the MSL strain gage data using plant data from 112.5% OLTP and the updated uncertainty values. The licensee incorporated the new limit curves into a revision of the Vermont Yankee SDMP. Based on its engineering evaluation, Entergy determined that continued power ascension to 115% OLTP would not cause stress exceedance in the steam dryer components that would challenge the structural integrity of the dryer.

NRC Staff Evaluation

The NRC staff, with support from its consultants from Argonne National Laboratory, reviewed Entergy's engineering evaluation consisting of multiple analyses, data, and figures. The staff's evaluation focused on the licensee's basis for continued power ascension at Vermont Yankee up to 115% OLTP. For example, the staff reviewed the calculation of the stresses on the steam dryer components at 112.5% OLTP, and the establishment of new limit curves for MSL strain gage data in support of operation up to 115% OLTP. The Vermont Yankee steam dryer analysis indicates that the steam dryer gusset shoe area is the most limiting stress location on the Vermont Yankee steam dryer for EPU operation. The stress on this component at 1.12.5% OLTP was calculated to be 2688 psi from the ACM and 599 psi from the Computational Fluid Dynamics (CFD) analyses. If the MSL strain gage measurements increase up to the new Level 1 limit curve in all four steam lines, the stress at this location is projected to be 9514 psi. This stress is about 30% less than the ASME Code fatigue limit of 13,600 psi. The Vermont Yankee SDMP provides additional margin in that power ascension must be halted and the collected data evaluated if any portion of the measured MSL strain-frequency spectra reaches the Level 2 limit (80% of the 13,600 psi limit) for any of the four steam lines. As part of its review, the staff compared the Vermont Yankee MSL strain gage limit curves from 105% OLTP to the new limit curves established at 112.5% OLTP. The 112.5% limit curves have a lower baseline limit resulting from the increased ACM uncertainty, but permit higher MSL strain gage signals at the resonance frequencies experienced at 112.5% OLTP. The higher resonance peaks are allowed to be included in the new limit curve based on their small contribution to the total resulting stress on the steam dryer. Also, the Vermont Yankee Level 1 limit remains below the MSL data measured in the high-frequency range of interest at Quad Cities Unit 2, which experienced severe steam dryer damage under EPU conditions. Further, the Vermont Yankee SDMP will require the licensee to halt power ascension if any acoustic signal from the Vermont Yankee MSL strain gage data in any MSL reaches the Level 2 limit curve, which is 80% of the Level 1 limit curve. With respect to the low-frequency regions of MSL strain gage data, the staff will ensure that Entergy closely monitors those low frequency areas during future power ascension.

D. Roberts 4 Conclusion concluded that the Based on its review of the Entergy's engineering evaluation, the NRC staff ascension up to 115% OLTP at licensee provided a reasonable basis for continuing power stress on the most Vermont Yankee. The staff's conclusion is based on: (1) the calculated OLTP is significantly below limiting component of the Vermont Yankee steam dryer at 112.5% data maintain MSL strain gage the ASME Code fatigue limit; (2) plant performance limit curves of (3) frequent monitoring lower than the Quad Cities data in the high-frequency acoustic range; strain gage data, during power plant performance data, including hodrly collection of the'MSL of the measured MSL ascension; and (4) plant procedures halt power ascension if any portion strain vs, frequency spectra reach the' Level 2 limit curve for any Vermont Yankee MSL. On not object to the continued April 21, 2006, the NRC staff informed Entergy that the staff did power ascension process at Vermont Yankee up to 115% .OLTP. The staff will ensure that Entergy closely monitors the MSL strain gage data for any increases toward the limit curves Entergy's justification for during the power ascension at Vermont Yankee. The staff will review based on the plant data continued power uprate operation, including further power ascension, condition notes that a license collected during the next power ascension step. Further, the staff issuance within 90 days of requires that Entergy resolve the steam dryer analysis uncertainties of the EPU license amendment.

June 20, 2006 MEMORANDUM TO: Darrell J. Roberts, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nudlear Reactor Regulation FROM: Kamal A. Manoly, Chief IRA! Engineering Mechanics Branch Division of Engineering Office of Nuclear Reactor Regulation

SUBJECT:

STAFF TECHNICAL BASIS FOR CONTINUED POWER ASCENSION OF VERMONT YANKEE NUCLEAR POWER STATION TO FULL EXTENDED POWER UPRATE CONDITIONS OF 120% ORIGINAL LICENSED THERMAL POWER (TAC NO. MD0263) Introduction On March 2, 2006, the U.S. Nuclear Regulatory Commission (NRC) approved the request by Entergy Nuclear Operations, Inc. (Entergy) to increase the maximum authorized power level for Vermont Yankee Nuclear Power Station (Vermont Yankee) from 1593 Megawatts thermal (MWt) to 1912 MWt as an extended power uprate (EPU) equivalent to 120% of the original licensed thermal power (OLTP). During the power ascension at Vermont Yankee, plant instrumentation reached an administrative limit at 105% OLTP (1673 MWt) and 112.5% OLTP (1791 MWt) that required the licensee to evaluate the plant data before continuing the power ascension. In memoranda dated April 5 and 28, 2006, the NRC staff documented its review of the licensee's justification for continued power ascension at Vermont Yankee from 105% and 112.5% OLTP, respectively. Upon achieving 117.5% OLTP (1872 MWt) on April 28, Entergy informed the NRC staff that plant instrumentation at Vermont Yankee had again reached administrative limits that required evaluation. On May 1, Entergy made available for NRC review its evaluation to justify continued power ascension beyond 117.5% OLTP up to full EPU conditions of 120% OLTP (1912 MWt). The licensee submitted this information to the NRC in a letter dated May 4, 2006. Subsequently, the NRC staff informed Entergy on May 4 that it did not object to the continued power ascension of Vermont Yankee up to full EPU conditions (120% OLTP). A narrative of the NRC staff's review of the licensee's justification for continued power ascension at Vermont Yankee is provided. CONTACT: Thomas G. Scarbrough, NRR/DCI/CPTB (301) 415-2794 Docket No. 7195 Attachment 7-3 5 Pages

D. Roberts Backcground Following receipt of the EPU ,license amendment, Entergy began to slowly increase reactor power at Vermont Yankee above OLTP on March 4, 2006, in accordance with its power ascension test procedure. The EPU amendment included a license condition that provides for monitoring and evaluating plant data at Vermont Yankee, and taking prompt action in response to potential adverse flow effects as a result of power uprateoperation on structures, systems, and components (including verifying the continued structural integrity of the steam dryer). The Vermont Yankee power ascension procedure specifies that (1) the power ascension rate be no more than 16 MWt per hour; (2) steam dryer performance data be monitored hourly and compared to acceptance criteria; (3) power level be held for 4 hours at each 40 MWt step (2.5% OLTP) to obtain and evaluate additional plant performance data; and (4) power level be held for 96 hours at each 80 MWt plateau (5% OLTP) to conduct plant walkdowns and to perform steam dryer analysis whose results would be examined by the NRC staff. Entergy made a regulatory commitment to not increase power at Vermont Yankee if the NRC staff identified a safety concern during its evaluation of the plant data. As part of the plant data evaluation, Entergy collects Main Steam Line (MSL) strain gage data to monitor pressure fluctuations within the main steam flow.. The licensee inputs the MSL strain gage data into an acoustic circuit model (ACM) to calculate pressure loads on the steam dryer and the resulting stress in steam dryer components using a finite element model (FEM). The Vermont Yankee Steam Dryer Monitoring Plan (SDMP) establishes a Level 1 limit curve for the MSL strain versus frequency spectra based on the American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code (Code) fatigue stress limit of 13,600 pounds per square inch (psi), and a Level 2 limit curve based on 80% of that fatigue limit. If the Level 2 limit curve is reached, the. SDMP specifies that power ascension be suspended until an engineering evaluation concludes that further power ascension is justified. If the Level 1 limit curve is reached, the licensee must reduce power to the next lower power hold point when the limit curve was not exceeded. On March 5, Entergy notified the NRC staff that the MSL strain gage data from the "A" MSL at Vermont Yankee had reached the Level 2 limit at 105% OLTP. On March 26, Entergy completed its engineering evaluation of the Vermont Yankee steam dryer and its justification for continued power ascension to 110% OLTP. Entergy verified that the stress in the Vermont Yankee steam dryer components remained significantly below the ASME Code fatigue stress limit of 13,600 psi at 105% OLTP. Based on its engineering evaluation, Entergy determined that continued power ascension to 110% OLTP would not cause stress exceedance in the steam dryer components that would challenge the structural integrity of the dryer. The NRC staff reviewed the licensee's justification for continued power ascension at Vermont Yankee beyond 105% OLTP, and informed Entergy on March 31 that it did not have a safety concern with power ascension up to 110% OLTP. The staff documented its decision in a memorandum dated April 5, 2006. Subsequently, the licensee continued the power ascension at Vermont Yankee, and achieved 110% OLTP with the collected data remaining within the acceptance criteria. The staff reviewed the plant data, and did not object to continued power ascension up to 115% OLTP.

D. Roberts On April 6, Entergy reported that the MSL strain gage data from the "A" MSL at Vermont Yankee reached the Level 2 limit at a frequency resonance peak of 143 Hz at 112.5% OLTP. On April 20, Entergy submitted its evaluation of the plant data to justify continued power ascension beyond 112.5% OLTP. The licensee verified that the stress in the Vermont Yankee steam dryer components remained significantly below the ASME Code fatigue stress limit of 13,600 psi. Based on its engineering evaluation, Entergy determined that continued power ascension to 115% OLTP would not cause stress exceedance in the steam dryer components that would challenge the structural integrity of the dryer. 'The NRC staff reviewed the licensee's justification for continued power ascension at Vermont Yankee beyond 112.5% OLTP, and informed Entergy on April 21 that it did not have a safety concern with power ascension up to 115% OLTP. The staff documented its decision in a memorandum dated April 28, 2006. Subsequently, the licensee continued the power ascension at Vermont Yankee, ,and achieved 115% OLTP on April 22, 2006. The data collected at 115% OLTP remained within the acceptance criteria. The staff reviewed the plant data, and did not object to continued power ascension beyond 115%.OLTP on April 26, 2006. Licensee Justification for Power Ascension Up to Full EPU Conditions (120% OLTP) During continued power ascension at Vermopt Yankee, Entergy informed the NRC staff on April 28 that plant instrumentation had reach d an administrative limit at 117.5% OLTP that required evaluation. In particular, the licenseL- reported that the upper and lower sets of MSL strain gages on the "A"MSL reached the Level 2 limit at a resonant peak frequency of 143 Hz. Plant chemistry measurements"also indicated that the Level 2 limit of 0.1% for moisture carryover was exceeded at 117.5% OLTP. The licensee provided specific plant data that supported its decision to remain at 117.5% OLTP while evaluating the data. The staff reviewed the plant data and held telephone discussions regarding the data with the licensee. Based on its review, the staff did not object to Vermont Yankee remaining at 117.5% OLTP while the licensee evaluated the plant data. On May 1, Entergy made available for NRC review its evaluation of the plant data in justifying continued power ascension at Vermont Yankee beyond 117.5% OLTP. Rather than applying the acoustic circuit model (ACM) at this intermediate power step, the licensee calculated the stress on the most limiting component (hood gusset shoe) of the Vermont Yankee steam dryer based on the combination of resulting stresses in the dryer that are derived using the measured MSL strain gage data at peak resonant frequencies during the power ascension. As a result, the licensee calculated that the steam dryer gusset shoe had a maximum stress of 3599 psi from acoustic loading. The stress from steam dryer loading calculated by the computational fluid dynamics (CFD) analysis remained at 599 psi. The licensee then recalculated the Level 1 and Level 2 limit curves for the MSL strain gage data using the plant data from 117.5% OLTP and the trend analysis. The licensee incorporated the new limit curves into a revision of the Vermont Yankee SDMP submitted on May 4, 2006. With respect to moisture carryover, Entergy initiated increased monitoring of plant data in response to the Level 2 limit of 0.1% being exceeded. The increased monitoring found the moisture carryover values to remain about 0.11%. Entergy predicted that the moisture carryover wouldtrend up to about 0.15% as power was increased to 120% OLTP.

' D. Roberts *Based on its engineering evaluation, Entergy determined that continued power ascension from 117.5% OLTP to full EPU conditions (120% OLTP) would not cause stress exceedance in the steam dryer components that would challenge the structural integrity of the dryer.

NRC Staff Evaluation

The NRC staff, with support from its consultants from Argonne National Laboratory, reviewed Entergy's engineering evaluation consisting of multiple analyses, data, and figures. The staff's evaluation focused on the licensee's basis for continued power ascension at Vermont Yankee from 117.5% upto full EPU conditions (120% OLTP). For example, the staff reviewed the calculation of the stresses on the steam dryer components at 117.5% OLTP, and the establishment of new limit curves for MSL strain gage data in support of operation up to 120% OLTP. The NRC license amendment for Vermont Yankee EPU operation dated March 2, 2006, 'specifies that, after reaching 120% OLTP, the licensee shall obtain measurements from the MSL strain gages, establish the steam dryer flow-induced vibration load fatigue margin, update the steam dryer stress. report, and re-establish the SDMP limit curve with the updated ACM load definition; and shall resolve the steam dryer analysis uncertainties within 90 days of issuance of the EPU license amendment. The staff will review the continued operation of Vermont Yankee at EPU conditions upon submittal of the EPU plant data and the licensee's analysis to support long-term EPU operation. For continued power ascension at Vermont Yankee from 117.5% OLTP to full EPU conditions (120% OLTP), the NRC staff reviewed the licensee's trend analysis of the MSL strain gage data used in calculating the stress in the steam dryer gusset' shoe of 3599 psi from the acoustic loads at 117.5% OLTP for Vermont Yankee. The stress on the steam dryer gusset shoe from CFD loads continued to be calculated as 599 psi. When combined, the resulting stress on the steam dryer gusset shoe remains significantly below the ASME Code fatigue limit of 13,600 psi. To support the reliability of MSL strain gage trend analysis for the power increase from 1872 to 1912 MWt, the licensee showed that the Level 1 limit curve calculated by the MSL strain gage data trend analysis compared closely to the Level 1 limit curve calculated using the ACM analysis at 1792 MWt. Based on its trend analysis of the MSL strain gage data, Entergy developed new limit curves for the continued power ascension up to 120% OLTP at Vermont Yankee. If the MSL strain gage measurements increase up to the new Level 1 limit curve in all four steam lines, the licensee projected that the stress in the steam dryer gusset shoe would be 9529 psi. This stress is about 30% less than the ASME Code fatigue limit of 13,600 psi. The Vermont Yankee SDMP provides additional margin in that power ascension must be halted and the collected data evaluated if any portion of the measured MSL strain-frequency spectra reaches the Level 2 limit (80% of the 13,600 psi limit) for any of the four steam lines. As part-of its review, the NRC staff compared the previous Vermont Yankee MSL strain gage limit curves to the new limit curves established at 117.5% OLTP. The 117.5% OLTP limit curves have a lower baseline limit, but permit higher MSL strain gage signals at the resonance frequencies experienced at 117.5% OLTP. The higher resonance peaks are allowed to be included in the new limit curve based on their small contribution to the total resulting stress on the steam dryer. Also, the Vermont Yankee Level 1 limit remains below previous MSL data measured in the high-frequency range of interest at Quad Cities Unit 2, which experienced

D. Roberts severe steam dryer damage under EPU conditions at that time. Further, the Vermont Yankee SDMP will require the licensee to halt power ascension if anyacoustic signal from the. Vermont Yankee MSL strain gage data in any MSL reaches the Level 2 limit curve, which is 80% of the Level 1 limit curve. The NRC staff is continuing to monitor the licensee's response to the increased values of moisture carryover with power ascension at Vermont Yankee. The moisture carryover values of about 0.11% at 117.5% OLTP are significantly below the Level 1 limit of 0.35%. Moisture carryover also remained steady with the more frequent data collection initiated with the Level 2 limit being exceeded. The predicted trend of moisture carryover to about 0.15% with additional power ascension is not unexpected with the reduced efficiency of the steam dryer during increased steam flow conditions. Conclusion Based 'on its review of the Entergy's engineering evaluation, the NRC staff concluded that the licensee provided a reasonable basis for continuing power ascension up to full EPU power (120% OLTP) at Vermont Yankee. The staff's conclusion is based on: (1)the calculated stress on the most limiting component of the Vermont Yankee steam dryer at 117.5% OLTP is significantly below the ASME Code fatigue limit; .(2) plant performance limit curves maintain MSL strain gage data lower than previous Quad Cities data in the high-frequency acoustic range; (3) frequent monitoring of plant performance data, including MSL strain gage data and moisture carryover, during power ascension; and (4) plant procedures halt power ascension if any portion of the measured MSL strain vs. frequency spectra reach the Level 2 limit curve for any Vermont Yankee MSL. On May 4, 2006, the NRC staff informed Entergy that the staff did not object to the continued power ascension process at Vermont Yankee up to full EPU power level (120% OLTP). The staff will review Entergy's justification for long-term power uprate operation, based on the plant data collected during the power ascension to full EPU conditions.

10 "UNITED STATES 0o, %.NUCLEAR REGULATORY COMMISSION

                                                                                      "       " U  r-WASHINGTON, D.C. 20555-0001 May 4, 2004                               .      "     0
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~HAIRMAN Mr. Michael H. Dworkin, Chairman Vermont Public Service Board 112 State Street, Drawer 20 Montpelier, Vermont 05620-2701

Dear Mr. Dworkin:

(NRC) to your I am responding on behalf of the U.S. Nuclear Regulatory Commission Vermont by Enrtergy Nuclear letters dated March 15 and 31, 2004, regarding the request to amend the Vermont Yankee Yankee, LLC, and Entergy Nuclear Operations, Inc. (Entergy), of the facility. In those letters, the Nuclear Power Station license to increase the'power level its review of the proposed conduct Vermont Public Service Board requested that the NRC about plant reliability power uprate in a way that would provide Vermont a level of assurancedecided to conduct a The NRC has equivalent to an independent engineering assessment. engineering inspection that we believe will. be appropriate for addressing. our oversight detailed This inspection will be responsibilities and is also responsive to the Board's concerns. that the NRC has been developing performed as part of a new engineering inspection program to enhance the Reactor Oversight Process. nuclear safety, whether NRC regulations and its oversight process focus on ensuring statutory authority does not extend the facility is operating at power or shut down. The NRC's recognizes, however, that there is to regulating the reliability of electrical generation. The NRC that contribute to some overlap between attributes that result in safe operation and those overall plant reliability. understands that the Board is concernedin about the reliability of The Commission in power level, especially light of operational issues Vermont Yankee following an increase implemented extended power that have occurred at some other plants that have recently and is taking steps to ensure that uprates. The NRC recognizes the importance of these issues example, in response to instances of they are satisfactorily addressed to maintain safety. For technical experts are assisting steam dryer cracking at some boiling water reactors, outside related to steam dryer NRC staff in performing an audit of General Electric's analysesWe continue to engage the performance and specific issues related to Vermont Yankee. additional regulatory action, if industry to ensure resolution of these issues and will consider needed. Docket No. 7195 Attachment 7-4 4 Pages

is independent, The NR C's established review process for power uprate applications review process is enclosed. Engineering thorough, and comprehensive. A description of the Under our safety activities. assessments have always been an integral part of the NRC's routinely and regional specialists current Reactor Oversight Process, NRC resident inspectors engineering organization to determine whether evaluate the work performed by the licensee's operation. Over the past several months, the engineering analyses adequately support safe program which we intend to pilot at NRC has been developing a new engineering inspection factors, including the Board's request selected plants. The NRC staff considered a number of . for an independent engineering assessment, and concluded it is appropriate to conduct this engineering assessment inspection

.engineering inspection at Vermont Yankee. This new                            inspections. The NRC will incorporates the best practices of the existing and past engineering correctly implemented for a sampling use this inspection to verify that design bases have been issues. The inspection of components across multiple. systems and to identify latentdesign and   engineering       analysis to select risk-process uses operating experience, risk assessment,                                      safety margins that   adequate significant components and operator actions, and will ensure is still being developed, it will include exist. Although the specific sampling of components by a power uprate such as the components from multiple systems that are potentially affected power conversion systems, and emergency core cooling systems, the containment system, by a team of approximately six inspectors, auxiliary systems. The inspection will be performed oversight experience with Vermont including some NRC inspectors who do not have recent Three weeks of on-site inspection Yankee and at least two contractors with design experience.

This level of effort exceeds that and over 700 hours of direct inspection time will be conducted. believes it is appropriate for of the-biennial safety system design inspection. The Commission is also responsive to the Board's concerns. addressing the NRC's oversight responsibilities and schedule for this inspection to facilitate The NRC staff will inform the State of Vermont of the with NRC policy. participation by State representatives, consistent will also review the The NRC Advisory Committee on Reactor Safeguards (ACRS) a statutory committee that reports Vermont Yankee power uprate request. The ACRS is where experts representing directly to the Commission and is structured to provide a forum factored into the NRC's decision-making many technical perspectives can provide advice that is including relevant review efforts, process. The NRC staff will provide the results of its ACRS completes its review, it will make inspection findings, to the ACRS for review. After the the proposed power uprate amendment an independent recommendation regarding whether should be approved. uprate, or any proposed change to a The NRC will not approve the Vermont Yankee change will be executed in a plant license, unless the NRC staff can conclude that the proposed to your request, the NRC staff manner that assures the public's health and safety. In response reviews to ensure that they will has taken a close look at proposed inspections and technical at uprated power conditions. The identify and address potential safety concerns for operating prescribed in the Extended Power Uprate staff has concluded that the detailed technical review, program of power uprate and Review Standard, coupled with the normal associated for the NRC staff to make a engineering inspections, will provide the information necessary

under uprated power conditions. The decision onthe safety of operation of Vermont Yankee particularly the new Commission believes thal the results of NRC reviews and inspections, concerns regarding the future engineering inspection, will assist in addressing the Board's to explain to meet with the Board reliability of Vermont Yankee. The NRC staff is prepared assessment inspection. further our revieW process andscope, including the engineering Sincerely, Nils J.D z

Enclosure:

Established NRC Power Uprate Review Process

I Established NRC Power Uprate Review'Process applications is independent, thorough, The NRC's established review process for power uprate in a minimum of 17 different and comprehensive. A team of engineers with specialties uprate application. The NRC plans to technical areas will review the Vermont Yankee power assessment of the engineering, design, expend about 4000 hours to perform a comprehensive "Review Standard for Extended Power and safety analyses related to the uprate. The NRC's The Review Standard also provides Uprates" guides the staff in its review of the application. should be performed at the plant or guidance for determining when and what type of audits analyses and independent vendor sites, as well as for performing our own confirmatory .calculations to supplement the review. includes on-site inspections. NRC The NRC's review of the power uprate application also made to allow operation at higher inspections will review selected activities and modifications will support safe plant operation and are in power levels to verify that changes to plant systems bases. The NRC will use Inspection accordance with Vermont Yankee's licensing and design of our bateline inspection procedures Procedure 71004, "Power Uprates," as well as a number inspections will assess changes to inspect issues specifically related to power uprate. These flow rates which could increase vibration that could impact the integrity of barriers (e.g.; higher post maintenance and at specific support points), safety evaluations, p lant modifications, integrated plant operation. Additionally, surveillance testing, heat exchanger performan e, and directed at power uprate activities, our other baseline inspection activities, while not specifically ability to operate safely at a higher will provide additional information about Vermonl Yankee's power level. audit plans, confirmatory analyses, or The NRC will adjust, as necessary, our technical review, may have a bearing on our decision on the inspection activities if any issues are identified which a recent examination of the steam Vermont Yankee power uprate application. For example, and exterior structures of the steam dryer at Vermont Yankee identified cracks on both interior the process for converting steam to dryer. The steam dryer is an important component in The NRC is interested in steam electrical energy, but is not used to mitigate any accidents. loose and impact the performance of dryer cracking because of the potential for parts to break the cracks are in low-stress, low-steam safety-related equipment. Entergy has indicated that flow areas of the dryer and not in the areas where cracks were observed at other plants that monitored Entergy's steam dryer implemented extended power uprates. NRC inspectors follow-up actions as part of our inspection activities, and we will thoroughly review Entergy's at a higher power level. evaluation of Vermont Yankee's request to operate part of the NRC's safety mission. In Assessment of engineering has always been an integral plants across the country to determine if the 1990s, the NRC performed extensive reviews at design bases. As part of this review, licensees were operating plants in accordance with their in 1997. One of these inspections two team inspections were conducted at Vermont Yankee contractors. In 1998, the NRC was led by staff from NRC headquarters and included six inspection to address operability issues conducted an engineering inspection, as well as a team program. Under our current resulting from Vermont Yankee's configuration improvement and regional specialists routinely evaluate Reactor Oversight Process, NRC resident inspectors to determine whether the the work performed by the licensee's engineering organization Our inspectors conduct both routine engineering analyses adequately supports safe operation. every two years. Since the engineering inspections, as well as an in-depth team inspection the NRC has conducted two such safety Reactor Oversight Process was implemented in 2000, system design team inspections.. Enclosure

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Sherman, William From: Sherman, William Friday, March 31, 2006 1:50 PM *O Sent: To: 'Rick Ennis'

Subject:

RE: VY Power Ascension Thank you. No questions. I am assuming that your specialists are satisfied with the characterization of (i.e., the reducing of) uncertainties by Entergy, to give them more "room" on the strain/frequency curves. Thanks for the heads up. I plan to monitor the ascension by phone contact over the weekend, and review the results at the site on Monday.

   ----- Original Message -----

From: Rick Ennis [1] Sent: Friday, March 31, 2006 1:45 PM To: Sherman, William

Subject:

VY Power Ascension iThe NRC staff has completed its evaluation of Entergy's justification for further power ýascension to 110%. The NRC staff has no objections to Vermont Yankee continuing the power ascension process to 110%. Entergy has beenl contacted and is expected to start power ascension tomorrow morning. I'll call you Ilso to see if you have any questions. thanks, Rick 301-415-1420 Doclket No. 7195 Attachment 8-2 I Page I

FW: Steam dryer data methodology Pagel of3 Sherman, William From: McElwee, David [dmcelwe@entergy.com] Sent: Monday, May 01, 2006 1:11 PM To: Sherman, William

Subject:

FW: Steam dryer data methodology Bill, please scroll down and see Craig's responses. David K. McElwee Senior Liaison Engineer Entergy Nuclear Vermont Yankee Office 802-258-4112 Cel0 802-258-0096 From: Nichols, Craig Sent: Monday, May 01, 2006 12:30 PM To: McElwee, David

Subject:

RE: Steam dryer data methodology See below for brief responses. Please let me know if more detail is needed. Thanx, Craig j. Nichols Entergy Nuclear Operations, Inc. (Vermont Yankee) Manager, Strategic Capital Projects Power Uprate Project Manager Telephone: 802-451-3190 Pager: 802-742-9095 Cell: 802-380-0893 This e-mail and any attachments thereto are intended only for the use by the addressee(s)

named herein and containproprietaryand confidential information. Ifyou are not the intended recipientof this e-mail, you are hereby noti/fied that any dissemination, distribution, or copying of this e-mail and any attachments thereto is strictlyprohibited Ifyou have received this e-mail in error;please notify me andpermanently delete the originaland any copy of any e-mail and any printout thereof From: McElwee, David Sent: Monday, May 01, 2006 9:56 AM To: Nichols, Craig

Subject:

FW: Steam dryer data methodology Craig, can you or Rico answer this? Docket No. 7195 Attachment 8-3 3 Pages

FW: Steam dryer data methodologyP . Page 2 of 3 David K. McElwee Senior Liaison Engineer Entergy Nuclear Vermont Yankee 0 Office 802-258-4112 Cell 802-258-0096 From: Sherman, William [2] Sent: Monday, May 01, 2006 9:39 AM To: McElwee, David

Subject:

FW: Steam dryer data methodology

David, I

Please see below the question I asked Rick Ennis. Perhaps Entergy can answer more promptly. As you know, opportunity to review the data collection methodology. Maybe if I-had, the answer would be haven't had the obvious. Thanks. -- Bill From: Sherman, William Sent: Monday, May 01, 2006 9:36 AM To: 'Rick Ennis'

Subject:

Steam dryer data methodology

Rick, and we I have a question about the data methodology from the strain gages at VY. I asked D. Pelton about it decided that I should next ask Hdqts.

When we review the frequency curve results .that Entergy sends, we review a single curve per location. I believe this single curve is the average - some type of combined result - of the six instruments at each location. However, I suspect that these readings are not stable but rather "jump" around. I had this question before the last is call, but on Friday's call Rico seemed to refer to the frequency peak "jumping between 137 and 142 hz." If this so:

1. When does Rico "push the button" to generate the data of record?

Entergy Response: We start taking data after the PACC/Control Room notify us that they are finished with power ascension and that plant conditions are stable.

2. Does the collection methodology include a number of "button pushes" and selection of the "most representative?"

Entergy Response: We will take a minimum of two sets of readings (they take several minutes to obtain and then more to process). We evaluate the average at each of eight points but also look at the six individual at each point. We look for signal validity, noise, acceptance criteria, and erroneous data.

FW: Steamdryer data methodology Page 3 of 3

3. Does the collection methodology include some kind of an average over a time period to smooth. out this variability of instanteous data?

Entergy Response: The data taken is a 40 second sample followed by a 40 second noise sample (system power off). This 40 seconds allows for natural variability as we always look at the FFT's in the frequency domain. We use the second (and more as necessary) runs to look for variability/issues/erroneous data.

4. Is the staff familiar with this aspect of the collection methodology or has the staff reviewed VY's data collection in progress?

Entergy Response: Although the staff is generally aware of the process used by Entergy (which is very similar to that employed by others) and they have asked many questions

.on the equipment, data acquisition, and analysis, they have not witnessed plant monitoring during power ascension.

This is probably. an obvious question and there is probably an obvious answer. It seems strange to me that the data of record for times we've been on hold have (almost each time) exactly just touched the Level 2 limit. Thanks. Bill Sherman State Nuclear Engineer Vermont Department of Public Service

(802) 828-3349

Sherman, William From: Sherman, William Sent: Monday, May 01, 2006 9:17 AM To: 'Rick Ennis'

Subject:

Steam dryer question

Rick, On the steam dryer phone calls, as you know I have not had questions as part of the calls. Tom has been very good to ask each call. Several times I've asked questions privately (and I have another one of those that I will send separately).

However, on the next call I think the time is appropriate to ask the question that is the state's basic concern. Considering the care taken in the power ascension tests, I believe the staff can be reasonably confident that there will be no safety problem with the dryer. Monitoring should identify whether problems occur before creating a safety issue. My question is, given all the staff and its consultants have seen so far in the power ascension tests, what level of confidence would they assign to whether the steam dryer will be found to have (additional) cracking at the Spring 2007 refuelling outage? I would appreciate the opportunity to ask. Thanks. Bill Sherman State Nuclear Engineer Vermont Department of Public Service (802) 828-3349 Docket No. 7195 Attachment 8-4 I Page

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FW: Draft Uncertainty Assessment: Page l'of 2. Sherman, William From: Sherman, William Sent: Monday, June 19, 2006 11:21 AM To: 'McElwee, David' Cc: BURKE, TERENCE A; SMITH, JAGER; Hofmann, Sarah

Subject:

questions re: RBetti presentation

Dave, I would like you to forward this to Rico if you would, and then perhaps we can speak about it. Also, please consider this part of compromise negotiations.

In the meeting here last Thursday, Rico seemed to be saying that the Level I and 2 limit curves were simple scale ups of last-previous acoustical measurement data. That was in response to my question whether "intelligence" was added in developing the limit curves. (By "intelligence,". I mean the best evaluation of how the system was expected to perform.) A. Based on Rico's answer, I have the following questions:

1. On the original 1593 MWt curves, for example:

On MSL A U, the limit curve peak at approx. 117 hz is much higher than the limit curve peak at 137 hz. And yet the baseline acoustical data for 137 hz is higher than for 117 hz. Why is that? The same is true for MSL A L.

2. Comparing the limit curves used at 1712 MWt, derived from the 1671 MWt data, for example:

On MSL D L, the limit peak at 137 hz is higher than the two limit peaks at approx. 130 hz. Yet the baseline data from the 1671 runs appears to have higher peaks (minus noise) at 130 hz. Why that relationship?

3. Comparing the limit curves used at 1832 MWt, derived from the 1792 MWt dita, for example:

On MSLA U, the data for 137 hz and 143 hz appear to be at the same level, but the limit curves are higher for 143 hz than for 137 hz. On MSL D L, the limit curves have similar height peaks at approx. 102 hz, 108 hz, and 122 hz. However, the input data from 1732 MWt, doesn't appear to have peaks at the same height. B. I thought Rico said that part of Dresden's problem was the discovery of high peaks at 77 % power. I Docket No. 7195 Attachment 8-6

FW: Draft Uncertainty Assessment: Page 2 of 2 presume this is 77% of uprated power. I think the math goes this way: CLTP equals OLTP + .178 OLTP equals 1.178 OLTP Former 100% power equals OLTP equals CLTP/1.178 equals 85% CLTP Therefore 77% CLTP equals (.77)(1.178) OLTP equals 91% OLTP.

1. If the Dresden high peaks are at 77% power, that is 91% of original power, why didn't

          *they develop steam dryer problems before power uprate?

2. Has VY developed acoustical data for operating points below 100% original power level?

Thanks. - Bill

Sherman, William From: Sherman, Williamr. Sent: Thursday, July 20, 2006 10:52 AM To: Sherman, William

Subject:

FW: VY Uprate news release yesterday Sent: Wednesday, March 08, 2006 10:47 AM

Subject:

WY Uprate news release yesterday Update: Vermont Yankee Power Increase Program Now at First Plateau Brattleboro -- On March 2, Entergy Vermont Yankee received permission from the Nuclear Regulatory pommission to increase its power output by up to 20 percent. On March 4, operators initiated the first planned ,increase of five percent and have since held at that plateau for planned data gathering and analysis as prescribed lin a formal Power Ascension Test Program. As planned, there will be several such plateaus at each five percent increment that will allow for data gathering and evaluation on all aspect of plant operation before proceeding to the next power level. During this process, engineers are closely monitoring the plant's steam dry r performance based on industry experience at other plants which implemented similar power, increases. The steam dryer performance is monitored remotely via specialized instruments that measure acoustical signal produced as the steam flows through piping. The data gathered is then analyzed by Vermont Yankee and specialized engineering contractors to determine the overall effect on the steam dryer. The extent of analysis required is determined by the acoustic signal characteristics at various frequencies. At the present five-percent level, one frequency requires additional analysis because its level reached an internal Verriont Yankee administrative limit. As required by the Power Ascension Test Program, that data is presently being evaluated by Entergy and General Electric engineers. The plant will remain at the current power plateau until the additional analysis is completed. Contrary to some press reports, the hold on the power increase was not imposed by regulators as the frequency in question is well below federal limits. At this plateau, the plant is producing an additional 26 megawatts for the New England electrical grid. The 26 megawatts is enough to power approximately 26,000 homes. Entergy Nuclear's online address is www.entergy-nuclear.com Bill Sherman State Nuclear Engineer Vermont (802) Department of Public Service 828-3349 Docket No. 7195 Attachment 9-1 I Page

September 26, 2003 Mr. Kenneth Putnam, Chairman BWR Owners Group Nuclear Management Company Duane Arnold Energy Center 3277 DAEC Rd. Palo, IA 52324

SUBJECT:

BOILING WATER REACTOR STEAM DRYER INTEGRITY

Dear Mr. Putnam:

On August 21, 2001, GE Nuclear Energy (GENE) issued Services Information Letter (SIL) No. 644, "Boiling Water Reactor Steam Dryer Integrity," to the licensebs of nuclear power plants with boiling water reactor (BWR) nuclear steam supply systems designed by General Electric (GE). The SIL described an event at a BWRP3 that involved the failure of a steam dryer cover plate and the generation of loose parts. In response to a second steam dryer failure at the same plant approximately one year later, GENE on September 5, 2003, issued Supplement 1 to SIL No. 644. Supplement 1 described the ýecond failure of a BWRI3-style steam dryer that occurred earlier in 2003 and updated and exppnded the scope of the recommendations initially provided in SIL No. 644 on steam dryer integrily to all GE-designed BWR nuclear power plants if currently operating, or planning to operate, above their original licensed thermal power (OLTP), During a July 25, 2003, meeting with the Boiling Water Reactors Owners Group (BWROG) and GENE on steam dryer failures, the BWROG stated that the steam dryer in a BWR does not perform a safety-related function. The NRC staff agreed. However, the NRC staff noted that the steam dryer must maintain its structural integrity such that an operational problem is not caused, or safe shutdown of the reactor is not prevented, by loose steam dryer parts in the reactor vessel or main steam lines (MSLs) leading to the turbine generator. Therefore, the NRC staff requested that the BWROG meet with the staff as soon as practicable after GENE had issued the revised SIL to discuss the recommendations in Supplement 1 and the response of BWR licensees to those recommendations. The NRC staff had requested that this meeting be held in the September 2003 timeframe. The NRC staff reviewed the SIL and conducted a teleconference with you on September 17, 2003, to discuss the SIL and future actions. During the teleconference, we noted that the recommendations in SIL No. 644, Supplement 1 represent a good start in addressing the steam dryer integrity issue. In addition, we stated that the staff would like to discuss several aspects of these recommendations with the BWROG in a future meeting. To assist the BWROG in preparing for this public meeting, the staff's comments on SIL No. 644, Supplement 1 are summarized as follows:

1. SIL No. 644, Supplement 1 does not appear to address all of the potential factors that could affect the susceptibility of a steam dryer to failure during operation of a BWR above the OLTP. For example, in addition to steam dryer design and maximum MSL Docket No. 7195 Attachment 10-1 4 Pages

K. Putnam steam velocity discussed in the SIL, the extent of the power level change from the OLTP, or the change in the MSL steam velocity, might also influence the susceptibility of a particular steam dryer to failure. Further, less stringent recommendations related to steam dryer integrity might be permissible where a BWR has only implemented or will only implement a minimal measurement uncertainty recapture power uprate. Please be prepared to discuss your criteria for establishing susceptible plants and the bases.

2. The recommendations in SIL No. 644, Supplement 1 focus on identifying steam dryer failure, such as by increased moisture content in the MSL steam flow and visual inspection of the steam dryer for cracks. However, these recommendations will only identify future failures of steam dryers after the fact. We believe that additional effort should be made to provide reasonable assurance that future steam dryer failures are highly unlikely, through such means as predictive analyses or instrumentation.

3. The basis for the applicability of internal steam dryer inspection recommendations in SIL No. 644, Supplement 1 only to the BWRI3 steam dryer design with internal braces is not apparent in that experience has su'pgested that cracking might initiate on the interior surface of the steam dryer.

4. SIL No. 644, Supplement 1 recommenqs the performance of "best effort" VT-1 visual inspections of the applicable steam dryers during an upcoming refueling outage.

Although steam dryers in BWRs might not be subject to ASME Code inservice inspections, the intent of SIL No. 644, Supplement 1 with respect to satisfying the Code provisions in performing VT-1 visual inspections of steam dryers should be clarified.

5. SIL No. 644, Supplement 1 recommends inspection of BWR/4 and later steam dryer designs prior to initial operation above the OLTP, or within the next two scheduled refueling outages if already operating above the OLTP. This recommendation has the potential to allow the steam dryer at some BWRs operating above the OLTP not to be inspected for almost 4 years. Please discuss your basis for the timeliness of this recommendation.

6. SIL No. 644, Supplement 1 discusses recent steam dryer failures at one BWR in the United States. Recommendations to address steam dryer integrity should also incorporate applicable experience from other BWRs in the U.S. and in other countries.

Please be prepared to discuss significant steam dryer failures in the U.S. and overseas.

7. With regard to power uprates, please be prepared to discuss what actions you intend to propose for BWRs planning to apply for future power uprates (i.e., measurement uncertainty recapture, stretch, and extended).

8. Please be prepared to discuss what actions not addressed in SIL No. 644, Supplement 1 should be taken for BWRs previously approved for power uprates.

The NRC staff is evaluating the development of an appropriate regulatory vehicle to ensure that all operational BWRs address the lessons-learned from the recent steam dryer failures and other applicable operating experience in a timely manner. As part of the upcoming public meeting, we request your assistance in providing the status of licensees' responses to

K. Putnam SIL No. 644, Supplement 1 for each operational U.S. BWR, including the results of any recent steam dryer inspections. We also would like your views on an efficient and effective means for the NRC staff to monitor licensees' activities in response to SIL No. 644, Supplement 1 and to verify the completion of those activities. Please contact me at 301-415-1445 to arrange the date for a public meeting to discuss the recommendations in SIL No. 644, Supplement 1 and the items noted above. Sincerely, IRA/ Alan B. Wang, Project Manager, Section 2 Project Directorate IV-2 Division of Licensing Project Management Office of Nuclear Reactor Regulation Project No. 691 cc: See next page

BWR Owners Group Project No. 691 cc: Mr. Joseph E. Conen Mr. William A. Eaton Vice Chairman, BWR Owners Group ENTERGY DTE Energy - Fermi 2 Grand Gulf Nuclear Station 200 TAC P.O. Box-.756 6400 N. Dixie Highway Port Gibson, MS 39150 Newport, MI 48166. Mr. Mark Reddeman Mr. J. A. Gray, Jr. Vice President Engineering Regulatory Response Group Chairman Point Beach Nuclear Plant BWR Owners Group 6610 Nuclear Road, Entergy Nuclear Northeast Two Rivers, WI 54241 440 Hamilton Avenue Mail Stop 12C White Plains, NY 10601-5029 Mr. Richard Libra DTE Energy Mr. H. Lewis Sumner Fermi 2 Southern Nuclear Company. M/C 280 OBA 40 Inverness Center Parkway 6400 North Dixie Highway P.O. Box 1295 Newport, MI 48166 Birmingham, AL 35242 Mr. James F. Klapproth Mr. Carl D. Terry Vice President, Nuclear Engineering GE Nuclear Energy M/C 706 Nine Mile Point - Station 175 Curtner Avenue OPS Building/2nd Floor San Jose, CA 95125 P.O. Box 63 Lycoming, NY 13093 Mr. Thomas G. Hurst GE Nuclear Energy M/C 782 175 Curtner Avenue San Jose, CA 95.125 Mr. Thomas A. Green GE Nuclear Energy M/C 782 175 Curtner Avenue San Jose, CA 95125 Mr. James Meister Exelon Cornerstone II at Cantera 4300 Winfield Road Warrenville, IL 60555

w This information is strictly for-the use of our customers and is not to be redistributed without the prior written consent of Icap Energy. Icap Energy specifically disclaims any and all information contained herein with respect to its accuracy, errors or omissions in, or any action that is taken because of said information. Icap Energy, Inc is acting as an agent, and not as a principal. Any and all parties that receive and act upon this information agree to absolve and hold harmless Icap Energy, Inc. from any liabilities and damages including, I 23/\/CF' but not limited to, actual, incidental and consequential, which may result.

Contact:

Tarreck Yennes at 502-327-1416 '6 For Current Nepool Prices Nepool Quote Sheet 21-Jul-06 13-Jan

Entergy Nuclear Operations, Inc.

'*i*,.* : Vermont Yankee

 '*      V                                                                          P.O. Box 0500 En                     tff~yTel 185 Old Ferry Road Brattleboro, VT 05302-0500 802 257 5271 February 26, 2006 Docket No. 50-271 BVY 06-019 TAC No. MC0761 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

, Vermont Yankee Nuclear Power Station Extended Power Uprate - Regulatory Commitment Information Regarding Steam Dryer Monitoring and FIV Effects

References:

1) Entergy letter to U.S. Nuclear Regulatory Commission, "Vermont Yankee Nuclear Power Station, License No. DPR-28 (Docket No. 50-.

271), Technical Specification Proposed Change No. 263, Extended Power Uprate," BVY 03-80, September 10, 2003

2) Entergy letter to U.S. Nuclear Regulatory Commission, "Vermont Yankee Nuclear Power Station, Technical Specification Proposed Change No. 263 - Supplement No. 36, Extended Power Uprate -

Response to NRC's Letter re: License Conditions," BVY 05-096, October 17, 2005

3) Entergy letter to U.S. Nuclear Regulatory Commission, "Vermont Yankee Nuclear Power Station, Technical Specification Proposed Change No. 263 - Supplement No. 33, Extended Power Uprate -

Response to Request for Additional Information," BVY 05-084, September 14, 2005 This letter provides information pursuant to a regulatory commitment made in connection with the application by Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Entergy) for a license amendment (Reference 1, as supplemented) to increase the maximum authorized power level of the Vermont Yankee Nuclear Power Station (VYNPS) from 1593 megawatts thermal (MWt) to 1912 MWt. In Reference 2, Entergy proposed a license condition and madea regulatory commitment to provide information regarding potentially adverse flow effects on plant structures, systems, and components (SSCs) that might result from extended power uprate (EPU) operation. The subject regulatory commitment relates to actions required prior to exceeding 1593 MWt, and states in relevant part: Docket No. 7195 Attachment 13-1 266 Pages

BVY O6-019 Docket No. 50-271 Page 2 of 3 With regard to [proposed] License Condition 3.M, "Potential Adverse Flow Effects," Entergy will provide information on plant data, evaluations, walkdowns, inspections, and procedures associated with the individual requirements of that license condition to the NRC staff prior to increa.sing power above 1593 MWt or each specified hold point, as applicable... Attachment 1 to this letter is the Steam, Dryer Monitoring, Plan (SDMP) that will be applicable during power ascension~to full EPU conditions. The SDMP will remaih in effect until proposed License Condition ý3.M expires. The SDMP, together with the EPU Power Ascension Test Procedure (PATP) provide for monitoring, inspecting, evaluating, and prompt action in response to potential adverse flow effects on the steam dryer as a result of power uprate operation. These actions provide assurance of the continued structural integrity of the steam dryer under EPU conditions. Included in the SDMP are the "steam drypr stress limit curve's." These curves establish operating limits in accordance with proposed License Condition $.M (Reference 2). Continuous monitoring of pressure fluctuations from strain gage signals relative to the curves provides assurance of the structural integrity of the steamn dryer. If necessary, changes to the SDMP will be made in accordance with the provisions of License Condition 3.M. to this letter'are those portions of the power ascension test procedure (PATP) for EPU that are applicable to flow-induced vibration monitoring during power ascension testing for a representative power plateau. Any future changes to the PATP will be made in accordance with governing VYNPS change processes and will be available on-site to NRC inspectors. to this letter provides a description of the data acquisition system that will be used to collect and record signals indicative of pressure loads on the steam dryer. This description is an update to the information provided in Reference 3. The information contained herewith is provided in accordance with the cited regulatory commitment and in anticipation of actions required to comply with proposed License Condition 3.M. There are no new regulatory commitments contained in this submittal. If you have any questions or require additional information, please contact Mr. James DeVincentis at (802) 258-4236. Sincerely, Norman L. Rademacher Director, Nuclear. Safety Assurance Vermont Yankee Nuclear Power Station

BVY 06-019 Docket No. 50-271 Page 3 of 3 Attachments (3) Cc: Mr. Samuel J. Collins (w/o attachments) Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406'1415 Mr. Richard B. Ennis, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0 8 BI Washington, DC 20555 USNRC Resident Inspector (w/o attachmnents) Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 Vernon, Vermont 05354 Mr.. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-26001

BVY 06-019 Docket No. 50-271 Attachment I Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 263 Extended Power Uprate - Regulatory Commitment Information Regarding Steam Dryer Monitoring and FIV Effects Steam Dryer Monitoring Plan Total number of pages in Attachment 1 (excluding this cover sheet) is 19.

0%. STEAM DRYER MONITORING PLAN Vermont Yankee Nuclear Power Station Revision 0 Preparer: Date: 0 c A o 4C. J. Nichols Reviewer: , Date: Approver: Date: 2- 2Z -06d

VYNPS Steam Dryer Monitoring Plan Page 1 of 18 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. 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. 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

VYNPS Steam Dryer Monitoring Page 2 ofPlan 18 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. 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 hour 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 outl'ihes 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 will provide early detection capability of off-normal performance. Proposed License Condition 3.M will require 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, based on the steam dryer structural analysis of record, will provide predictive capabilities toward determining steam dryer structural integrity under EPU conditions.

Main Steam Line Strain Gages 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. Entergy has installed strain gages at eight locations on the MSLs in the primary containment and a data acquisition system"(DAS) designed to reduce uncertainties. in the evaluation of steam dryer loads.

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.

VYNPS Steam Dryer Monitoring Plan Page 3 of 18 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 ope~ation will not ekceed 1593 MWt. These planned actions are in compliance with proposed License Condition 3.M. Moisture Carryover o Moisture carryover trending provides an indicator of steam dryer integrity. o At each 40 MWt step, moisture carryover data will be taken and compared to the predetermined acceptance criteria (Table 2).

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

o The data taken at each 80 MWtplateau will be evaluated and documented in the assessment sent to the NRC for inforrmation. Other Monitoring o 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 monitoringof selected plant parameters will be controlled by the PATP and other plant procedures. NRC Notifications o In accordance with proposed License Condition 3.M., at discrete power levels, and ifthe 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. o 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. In addition the final full EPU power performance criteria, spectra (i.e., steam dryer stress limit curve) will be 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

VYNPS Steam Dryer Monitoring Page 4 ofPlan 18 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. Lonq Term Monitoring 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 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 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.

VYNPS Steam Dryer Monitoring Plan Page 5 of 18 Table 1 Steam Dryer Surveillance Requirements During Reactor Power Operation Above a Previously Attained Power Level Parameter Surveillance Frequency

1. Moisture Carryover Every 24 hours (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 hours of achieving an 80 MWt power plateau, an orderly power reduction shall be made within the subsequent 12 hours 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.

VYNPS Steam Dryer Monitoring Plan Page 6 of 18 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

    *Moisture carryover exceeds             evaluation concludes that further power ascension is justified.

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

Press'Lire data exceed Level 2 Spectra1 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) 0 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 hours, re-measure moisture carryover and perform an

Pressure data exceed Level engineering evaluation of steam dryer structural integrity. If the 1 Spectra' 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 hours. 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 1011 cycles (i.e., 13.6 ksi).

VYNPS Steam Dryer Monitoring Plan Page 7 of 18 Table 3 Steam Dryer License Conditions License Condition Requirement Implementing Actions 3.M.l.a Entergy shall monitor hourly the 32. During initial power ascension above 1593 MWt, main steam line (MSL) strain gages data from at least 32 strain gages will be collected during power ascension above 1593 and evaluated by Entergy's power ascension test MWt for increasing pressure team to verify that acoustic signals indicative of fluctuations in the steam lines. 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-Q4-VY1-1409-000) (Reference. PCRS tracking item WT-VTY-2005-00000-01.803) 3.M.l.b Entergy shall hold the facility for 24 The PATP has established test plateau increments hours at 105%, 110%, and 115% of cf approximately 80 MWt (corresponding to 105%, OLTP (i.e., 1593 MWt) to collect 110%, and 115% of 1593 MWt). Reactor power will data from the 32 MSL strain gages nýt be increased above the plateau for a minimum required by License Condition of 96 hours. During the first 24 hours of steady 3.M.l.a, conduct plant inspections state operation at each plateau, strain gage data and walkdowns, and evaluate steam will be collected from all available strain gages dryer performance based on these (minimum of 32). and evaluated to demonstrate data; shall provide the evaluation to acceptable steam dryer performance. Additionally, the NRC staff by facsimile or moisture carryover measurements will be made at electronic transmission to the NRC each. plateau and every 24 hours during power project manager upon completion of ascension testing. At the 80 MWt plateau hold the evaluation; and shall not points, Entergy will conduct plant walkdowns and increase power above each hold inspections of plant equipment, including piping and point until 96 hours after the NRC components identified as potentially vulnerable to project manager confirms receipt of flow-induced vibration (FIV) in accordance with the the transmission. 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

VYNPS Steam Dryer Monitoring Plan Page 8 of 18. License Condition Requirement Implementing Actions designated website. Upon the NRC Project Manager confirming receipt of the steam dryer data and performance evaluation, the 96 hours 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.l.c If any frequency peak from the MSL The steam dryer stress limit curve provided strain gage data exceeds the. limit herewith contains Level 1 and Level .2 criteria. If curve. established by Entergy frequency peaks from MSL strain gage data exceed Nuclear Operations, Inc. and either Level 1 or Level 2 criteria, prompt action will submitted to the NRC staff prior to be taken in response to the potential adverse flow operation above OLTP, Entergy effects that might result. Similar actions will occur if Nuclear Operations, Inc. shall return moisture carryover is excessive and previously the facility to a power level at which established Level . 1 or Level :2 criteria are the limit curve is not exceeded. exceeded. The Level 2 criteria represent a Entergy Nuclear Operations, Inc. conservative action level for evaluation and close shall resolve the uncertainties in the monitoring of steam dryer performance-not a limit. steam dryeranalysis, document the The Level 1 criteria represent analytical limits and continued structural integrity of the 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 thee adequate. structural integrity of the steam dryer, and (3) provide that documentation to the NRC staff. Any revision to the

VYNPS Steam Dryer Monitoring Plan Page9 of 18 0 License Condition Requirement Implementing Actions limit curve based on this evaluation will be provided to the NRC staff. (Reference PCRS tracking item WT-VTY-2005-00000-01803) 3.M.l.d In addition to evaluating the MSL Accelerometers mounted on MSL piping will be strain gage data, Entergy Nuclear monitored on an hourly basis during power Operations, Inc. shall monitor ascension testing to identify if resonances are reactor pressure vessel water level 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 adecuate 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-VYl-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.l.e Following start-up testing, Entergy After collecting strain gage data at approximately Nuclear Operations, Inc. shall the EPU full power level, Entergy will resolve the resolve the uncertainties in the uncertainties in the steam dryer analysis and steam dryer analysis and provide provide documentation of the resolution to the NRC that resolution to the NRC staff by staff. If these actions cannot be achieved within 90 facsimile or electronic transmission days of issuance of the license amendment, reactor to the NRC project manager. If the power Will be limited to 1593 MWt. This uncertainty uncertainties are not resolved within evaluation may be prepared and provided to the 90 days of issuance of the license NRC prior to reaching EPU full power levels amendment authorizing operation at associated with any proposed revision to the steam 1912 MWt, Entergy _ Nuclear dryer limit curve. Operations, Inc. shall return the (Reference PCRS tracking item WT-VTY-2005-facility to OLTP. 00000-01803) 3.M.2.a Prior to operation above OLTP, To enhance performance and improve the accuracy Entergy Nuclear Operations, Inc. of the steam dryer measurement system, Entergy shall install 32 additional strain has installed 48 strain gages on MSL piping and will gages on the main steam piping and maintain a minimum of 32 operable strain gages shall enhance the data acquisition during power ascension testing. The data system in order to reduce the acquisition system (DAS) was upgraded to reduce measurement uncertainty the uncertainty associated with the ACM.

VYNPS Steam Dryer Monitoring Plan ePage 10 of 18 License Condition Requirement Implementing Actions associated with the acoustic circuit (Reference Entergy VYNPS Temporary Alteration model (ACM). TA-2005-15 R11) 3.M.2.b In the event that acoustic signals If acoustic signals indicative of increasing pressure are identified that challenge the limit fluctuations in the steam lines are identified as curve during power , ascension challenging'the steam dryer stress limit curve (i.e., above OLTP, Entergy Nuclear Level 1 criterion), in addition to reducing reactor Operations, Inc. shall evaluate power to a previously acceptable power level, steam dryer loads and re-establish Entergy will conduct an evaluation and re-establish the limit curve based on the new the limit curve based on the latest strain gage data. strain gage data, and shall perform As part of .the redevelopment of the limit curve,

          .a frequency-specific assessment of       Entergy      will ,prepare      a    frequency-specific ACM uncertainty 'at. the acoustic        assessment of ACM uncertainty at the acoustic signal frequency.                        signal frequency. This uncertainty evaluation may be prepared and provided to the NRC in advance of this condition being met.

(Reference ERSTI-04-VY1-1409-000) 3.M.2.c After reaching '120% of OLTP, ,efter collecting strain gage data at approximately Entergy Nuclear Opera'tions, Inc. the EPU full power level, Entergy will establish the shall obtain measurements from the steam *dryer flow-induced vibration load fatigue MSL strain gages and establish the margin for the facility, update the steam dryer stress steam dryer flow-induced vibration report, and re-establish the stress limit curve with load fatigue margin for the facility, the updated ACM load definition and revised update the steam dryer stress instrument uncertainty. This information will be report, and re-establish the steam included in the report to the NRC staff being made dryer monitoring plan (SDMP) limit in accordance with License Condition 3.M.l.e. curve with the updated ACM load (Reference PCRS tracking item WT-VTY-2006-definition and revised instrument 00000-00249) uncertainty, which will be provided to the NRC staff. 3.M.2.d During power ascension above If an evaluation or analysis of the structural integrity OLTP, if an engineering evaluation of the steam dryer is required because acoustic is required in accordance with the signals indicative of increasing pressure fluctuations SDMP, Entergy Nuclear Operations, in the steam lines are identified as potentially Inc. shall perform the structural challenging the steam dryer stress limit curve (i.e., analysis to address frequency Level 1 criterion), Entergy will address frequency uncertainties up to +/-10% and uncertainties up to + 10% and assure that peak assure that peak responses that fall responses that fall within this uncertainty band are within this uncertainty band are addressed. This uncertainty evaluation may be addressed. prepared and provided to the NRC in advance of this condition being met. (Reference ERSTI-04-VY1-1409-000)

VYNPS Steam Dryer Monitoring Plan Page 11 of 18 License Condition Requirement Implementing Actions 3.M.2.e Entergy Nuclear Operations, Inc. The revised SDMP provides long-term monitoring of shall revise the SDMP to reflect steam dryer performance in accordance with GE long-term monitoring of plant 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 steam dryer inspection program with The SDMP and the PATP identify the NRC Project General Electric Services Manager for the VYNPS EPU as the point of Information Letter 644, Revision 1; contact for providing SDMP information during and to identify the NRC Project power ascension. Manager for the facility as the point (Reference ERSTI-04-VYI-1409-000) of contact for providing SDMP information during power ascension. For moisture carryover, procedures OP-0631 and ON-3178 provide for long-term monitoring and controls. 3.M.2.f Entergy Nuclear Operations, Inc. The final EPU steam dryer load definition will be shall submit the final extended included in the report provided to the NRC staff in power uprate (EPU) steam dryer accordance with License Conditions 3.M.l.e. and load definition for the facility to the 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. Entergy letter BVY 06-019 forwards the FIV-related shall submit the flow-induced portions of the EPU power ascension test vibration related portions of the EPU procedure to the NRC. (Reference ERSTI-04-VY1-startup test procedure to the NRC, 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)

VYNPS Steam Dryer Monitoring Plan Page 12 of 18 License Condition Requirement Implementing Actions 3.M.3(a) Entergy shall prepare the EPU The steam dryer stress limit curve to be applied for startup test procedure to include the evaluating steam dryer performance during power stress limit curve to be applied for ascension is provided herewith. The limit curve was evaluating steam dryer developed on the basis of calculation VYC-3001, performance. which is incorporated by reference into the EPU PATP. (Reference ERSTI-04-VYI-1409-000) 3.M.3(b) Entergy shall prepare the EPU Specific hold points and durations are specified in startup test procedure to include the PATP. specific hold points and their (Reference ERSTI-04-VY1-1409-.000). duration during EPU power ascension. 3.M.3(c) Entergy shall prepare the EPU Activities to be accomplished during hold points are startup test procedure to include specified in the PATP. activities to be accomplished during (Reference ERSTI-04-VY1-1409-000) hold points. 3.M.3(d')" Entergy shall prepare the EPU Plant parameters to be monitored are specified in startup test procedure to include 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 Inspections and walkdowns to be conducted for startup test procedure to include steam, feedwater, and condensate systems and inspections and walkdowns to be components during hold points are specified in conducted for steam, feedwater, 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 Methods to be used to trend plant parameters are startup test procedure to include specified in Attachment 9 to the PATP. methods to be used to trend plant (Reference ERSTI-04-VY1-1409-000) parameters. 3.M.3(g) Entergy shall prepare the EPU Acceptance criteria for monitoring and trending startup test procedure to include plant parameters, and conducting the walkdowns acceptance criteria for monitoring and inspections are specified in Attachment 9 to the and trending plant parameters, and PATP. (Reference ERSTI-04-VY1-1409-000) conducting the walkdowns and inspections. 3.M.3(h) Entergy shall prepare the EPU Actions to be taken if acceptance criteria are not startup test procedure to include satisfied are specified in the PATP. actions to be taken if acceptance (Reference ERSTI-04-VY1-1409-000) criteria are not satisfied.

VYNPS Steam Dryer Monitoring Plan Page 13 of 18 O i Entergy shall prepare the EPU Verification of the completion of commitments and startup test procedure to include planned actions specified in the license amendment verification of the completion of application and all supplements to the application in commitments and planned actions support of the EPU license amendment request specified in the license amendment pertaining to the steam dryer is specified in the application and all supplements to PATP. the application in support- of the (Reference ERSTI-04-VYI -1409-000) EPU license amendment request pertaining to the steam dryer. i 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 with the quidance of NEI 99-04. 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)

VYNPS Steam Dryer Monitoring Plan ('-Page 14 of 18 License Condition Requirement Implementing Actions (Reference PCRS tracking item WT-VTY-2006-00000-00255) 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 powe4 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) SReference PCRS tracking item WT-VTY-2006-10000-00258) 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. Ifan (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 ojerating 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. ,

I. VYNPS Steam Dryer Monitoring Plan Page 15 of 18 MSL A Upper 1.0E-00 1.0E-01 1.0E-02 E 1.0E-03 1.0E-04

                                                     ,1J 1.0E-05 j

1.0E-06 v 50 100 150 200 250 Frequency, Hz

                          ,--   LC_2 Ave MSL A_Upper                 "               LC_1 AveMSLA Upper Figure 1: Steam Dryer Stress Limit Curve - MSL 'A' Upper MSL A Lower 1.0E+00 1.0E-01 1.0E-02 N

I 1.0E-03 k'4z,' '2*- , .. p*f;. - .-. 1.OE-04 1.OE-05 I.0E-06 050 100 150 200 250 Frequency,.Hz

                      -LC_2        AveeMSL ALower                               -- LCI AveMSL A_Lower Figure 2: Steam Dryer Stress Limit Curve - MSL 'A' Lower

VYNPS Steam Dryer Monitoring Plan Page 16 of 18 MSL B Upper 1.OE+00 1.0E-01 1.0E-02 T V 2'1.0E-03 jýj Li

2. ~ 3/4 '3/4 3/4 -

S. I, 4 , . 4 r r -.o'-' -' 4 4~ '4"' j4 '~ 4.4>1'I,~ 4

4. r44

                      --          I        -                    -'   4,          4',

I A~' - 4 4< -' - 1.0E-f 06 .. . . . . . . . . . . . . - . . . . . . . . . . . . . . 0 50 100 150 200 250 F'requenty, Hz

                                      -  LC*2 Ave_MSLB_Upper                                                               -       LC_1 AveMSL_B_Upper Fiqure 3: Steam Dryer St*ress Limit Curve - MSL 'B"Uiper MSL B Lower 1.OE+00 E

3/4' . I' '

                                                                                                              '41
                                                                                                                             ~~'
                                                                                                                         .'l'j~

2' 4'4

                                                                                     *4,'4
                                                                                           -      .'                                  I   44 0                          50                                  100                                 150                                 200              250 Frequency, Hz
                                     -- LC_2 AveMSL_B_Lower                                                                      'LC_   1 AveMSL_B_Lower Fioure 4: Steam Dryer Stress Limit Curve - MSL 'B' Lower

VYNPS Steam Dryer Monitoring Plan Page 17 of 18 MSL C Upper 11E,00 1.E-01 1.E-02 i .E-03

                    * . ¸. .  * , i*.4 h "  W, .*iA*  .4ir *,,
                                                  , "AL         .
             ,...*;1;*-

I~i E-04 0 50 100 150 ' 200 250 Frequency, Hz uLCe2 Ave MSLtCmUpper SLC_L Ave_MSL C Upper

               *Figqure 5: Steam Dryer Stress, Limit Curve - MSL 'C' Upper MSL C Lower E

0 50 100 150 200 250 Frequency, Hz

                                                                               -LC  1 Ave MISL-C-Lower L--                 LC_2 Ave._MSLC_Lower Figure 6: Steam Dryer Stress Limit Curve - MSL 'C' Lower

I . VYNPS Steam Dryer Monitoring Plan Page 18 of 18 MSL D Upper ZI 50 100 150 200 250 Frequency. Hz

                 --    LC_2 AveMSL_DUpper                    -LC_1    AveMSL_DUpper Fiaure 7: Steam Drver Stress Limit Curve - MSL 'D' UDDer U9 MSL D Lower 1.0E-01 1.OE-02 1.OE-03 1.OE-04 1.OE-05 1.0E-06 50                 100               150                  200         250 Frequency, Hz
              -LC_2     AveMSLDLower                          -    LC0 AveMSL_0DLower Figure 8: Steam Dryer Stress Limit Curve - MSL 'D' Lower

BVY 06-019 Dock(ý No. 50-271 Attachment 2 Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 263 Extended Power Uprate - Regulatory Commitment Information Regarding Steam Dryer Monitoring and FIV Effects Power Ascension Test Procedure (FIV Portions) Total number of pages in Attachment 2 (excluding this cover sheet) is 228.

Power Ascension Testing for Extended 'Power Uprate Conditions ATTACHMENT 9.6 *TEST PROCEDURE COVER SHEET Sheet I of I TEST COVER SHEET TEST TYPE: [] ERT Procedure . ERSTI Procedure Page 1 of 118 TEST#: ERSTI-04-VYI-1409-,000 Quality Class: E QR EJ NQR TEST Power Ascension Test Procedure for Extended Power Conditions 1593 to 1912 TITLE: MWth REVIEW (Print/Sign/Date) Bryan Croke / "2"1(((g, Test Engineer (TE): Technical Reviewer: Paul Stello . (A/ r_-/, CROSS-DISCIPLINE REVIEW - 5 IX Fi-v/- I Hj4-/J. - '2. -/S"*)6 Operations Department:. Z

                                                     ~.L/    0 C/  Chemistry       :      _     per Organization:

Radiation Protection j . Enzineering / Organization: Organization 6/) " Quality Assurance : ( / Maintenance __--iLI_,.,IS/ Organization (7 , -/ P<,C,(--(P.(,'" F1V04d M* .CI)pt4*,fL g 5 Fv._ta 011 , .*Al s 406a l"" 7 / - ADDITIONAL ERSTI (ONLY) PROCEDURE REQUIREMENTS q0,c--* _r Ihd-' W- bJAA j, ENN-LI-100 Review: Z Attached 0 Other (0091 Risk tevicw) 10CFR50.59 Evaluation: R Not Required [I Attached El Other V (COO .P( OSRC Ann~roval [-l Not Reouired Mto No.-,,v~-,t.Y1" Date:=3 Hi9/O Chairman Y*o1,*JI * 'A

&i~

TE-Supervisor: ,,Craig Nichols ., '/ TEST COMPLETION REVIEW /ACCEITANCE Summary of Test Results: Test Engineer (TE) / TE Supervisor: / ERST1-04-VY I - 1409-000 Page 1 of-44 I1

Power Ascension Testing for Extended Power Uprate Conditions Table of Contents

1. O B JE C T IV E ..................................................................................................................................................... 5 1.1. Intent ................................................................................... 5 1.2 . D iscu ssio n ..................................................................... ,................................................... 8 1.3 . D efin ition s ..................................................................... ................................ ........... .. 9 1.4. Responsibilities ......................................................................................................... 14

2. REFERENCES ............................................................................................................................................... 17

3. APPARATUS/TEST EQUIPMENT ......................................................................................................... 21

4. PRECAUTIONS AND LIMITATIONS .............................................. 22

5. TERMINATION CRITERIA ......................................................................................................................... 24

6. PREREQUISITES ........................................................................................................................................... 27

7. PROCEDURE .................................. :............................................................................................................... 47 7.1. 1593 MW th................................................................................. 48 7.2. Increasing to 1633 MW th ............................................................................................. 51 7.3. Increasing to 1673 MW th ...................................................................................... 54 7-4. Increasing to 1712 MW th ....................................................................................... 68

  *7.5.      Increasing        to    1752       MWth           .........................................                                                                         71 7.6. Increasing to 1792 MW th .......................................................................................                                                    85 7.7. Increasing to 1832 MW th ........................................................................................                                                   88 7.8. Increasing to 1872 MW th ...........................................................................................                                               102
  . 7.9. Increasing to 1912 MW th                                                           .........................................                                       105 7.10. Remaining at 1912 MW th .........................................................................................                                                  115

8. RESTORATION ............................................................................................................................................. 116

9. ATTACHMENTS ......................................................................................................................................... 116 IA Dryer Data Collection 1593 MWth lB Dryer Data Collection 1609 MWth IC Dryer Data Collection 1625 MWth ID Dryer Data Collection 1633 MWth lE Dryer Data Collection 1649 MWth IF Dryer Data Collection 1665 MWth 1G Dryer Data Collection 1673 MWth iH Dryer Data Collection 1689 MWth 11 Dryer Data Collection 1705 MWth 1J Dryer Data Collection 1712 MWth 1K Dryer Data Collection 1728 MWth 1L Dryer Data Collection 1744 MWth IM Dryer Data Collection 1752 MWth ERSTI-04-VY I -1409-000 Page 2 of 118

Power Ascension Testing for Extended Power Uprate Conditions IN Dryer Data Collection 1768 MWth 10 Dryer Data Collection 1784 MWth IP Dryer Data Collection 1792 MWth IQ Dryer Data Collection 1808 MWth IR Dryer Data Collection 1824 MWth IS Dryer Data Collection 1832 MWth IT Dryer Data Collection 1848 MWth 1U Dryer Data Collection 1864 MWth 1V Dryer Data Collection 1872 MWth 1W Dryer Data Collection 1888 MWth IX Dryer Data Collection 1904 MWth 1Y Dryer Data Collection. 1912 MWth 2A Flow Induced Vibration Data 1593 MWth 2B Flow Induced Vibration Data 1633 MWth 2C Flow Induced Vibration Data 1673 MWth 2D Flow Induced Vibration Data 1712 MWth 2E Flow Induced Vibration Data 1752 MWth 2F Flow Induced Vibration Data 1792 MWth 2G Flow Induced Vibration Data 1832 MWth -2H Flow Induced Vibration-Data 1872 MWth 21 Flow Induced Vibration Data 1912 MWth 3 Radiation Surveys 4 Core Performance Data Sheet various MWth 5A Moisture Carryover 1633 MWth 5B Moisture Carryover 1673 MWth 5C Moisture Carryover 1673 MWth 5D Moisture Carryover 1673 MWth 5E Moisture Carryover 1673 MWth 5F Moisture Carryover 1712 MWth 5G Moisture Carryover 1752 MWth 5H Moisture Carryover 1752 MWth 5I Moisture Carryover 1752 MWth 5J Moisture Carryover 1752 MWth 5K Moisture Carryover 1792 MWth 5L Moisture Carryover 1832 MWth 5M Moisture Carryover 1832 MWth. 5N Moisture Carryover 1832 MWth 50 Moisture Carryover 1832 MWth 5P Moisture Carryover 1872 MWth 5Q Moisture Carryover 1912 MWth 5R. Moisture Carryover 1912 MWth 5S Moisture Carryover 1912 MWth 5T Moisture Carryover 1912 MWth ERSTI-04-VY 1-1409-000 Page 3 of 118

Power Ascension Testing for Extended Power Uprate Conditions C 6A Feedwater Runout Data. Coilection 1673 MWth 6B Feedwater. Runout Data Collection 1752 MWth 6C Feedwater Runout Data Collection 1832 MWth 6D Feedwater Runout Data Collection 1912 MWth 7A Feedwater Level Changes 1673 MWth 7B Feedwater Level Changes 1752 MWth 7C Feedwater Level Changes 1832 MWth 7D Feedwater Level Changes 191 2 MWth 8A MHC Pressure Change 1673 MWth 8B MHC Pressure Change 1752 MWth 8C MHC Pressure Change 1832 MWth 8D MHC .Pressure Change 1912 MWth 9A System Data 1593 MWth 9B System Data 1673, MWth 9C System Data 1572 MWth 9D System Data 1832 MWth 9E System Data 1912 MWth 10 Site Boundary Dose Measurements Various MWth I1A Chemistry Data 1673 MWth 10B Chemistry Data 1572 MWth 10C Chemistry Data 1832 MWth 1OD Chemistry Data 1912 MWth 11A Recombiner Performafnce Data 1673 MWth 11B Recombiner Performance Data 1752 MWth liC Recombiner Performance Data 1832 MWth liD Recombiner Performance Data 1912 MWth 12 Signature Identification Log 13 Test Deficiency Log 14 Performance Summary 15 ENN-LI- 100 Process Applicability Determination 16 ENN-LI-101, 10.59 Screen 17 Risk Management Worksheet VYAPF 0172.02 ERSTI-04-VY I - 1409-000 Page 4 of 118

Power Ascension Testing for Extended Power Uprate Conditions Objective The objective is to confirm acceptable plant performance for operation at extended power uprate to 1912 MWth per Nuclear Change 2005-1409, EPU. This Test Instruction provides step by step guidance and verification for performing Power Ascension Testing requirements for Extended Power Uprate (EPU) conditions. The Test Instruction supplements OP-0105; Reactor Operations, to provide direction to maneuver the plant from 1593 MWth [83.32% LPU] to 1912 MWth [100.00% LPU]. First and foremost is the safety of the reactor, nuclear plant and personnel. This procedure was written with this specifically in mind, providing the necessary criteria, instruction, oversight, and precautions to successfully execute the Power Ascension Testing for Extended Power Uprate Conditions. Separate procedures are written to: Determine the maximum safe power level when MSIV, turbine bypass and turbine stop valve testing can be performed. This determination is accomplished separately from this procedure.

Demonstrate plant response to a condensate pump trip.

1.1. Intent 1.1.1. Document the plant physical modifications, instrumentation setpoint changes, and prerequisite testing have been satisfactorily completed and to meet: the established acceptance criteria to raise reactor power above 1593 MWth to 1912 MWth. 1.1.2. Implement tests contained in EPU Project Task Report VY-RPT 00041, "T1005: Startup Test Specifications" 1.1.2.1. Maintain control of and knowledge of the reactor coolant chemistry and radiochemistry at extended uprate conditions. ERSTI-04-VY 1-1409-000 Page 5 of 118

Power Ascension Testing for Extended Power Uprate Conditions 1.1.2.2. 'Monitor radiation levels at the extended uprate power conditions to assure that personnel exposures are maintained ALARA, radiation survey maps are accurate, radiation zones are properly posted, site boundary doses are as expected, and offsite boundary doses comply with state and federal regulations. 1.1.2.3. Measure and evaluate core thermal power and fuel thermal margins to ensure a careful, monitored approach to the next power uprate level. 1.1.2.4. Monitor feedwater level control system for acceptable reactor water level control. 1.1.2.5. Confirm acceptable calibra~ion of the feedwater flow elements' at uprated power conditions. 1.1.3. Demonstrate that i affected plant parameters and equipment performance remairs within the acceptable limits as power is increased from .1593 vWth to 1912 MW.th. 1.1.4. Monitor plant system response via the System Engineering System Monitoring Plans. 1.1.5. Provide Shift Operations personnel clear instructions on testing and operational maneuvers to be performed as power level is increased in a step-wise manner to assure safe plant operation. 1.1.6. Provide management reviews and approvals of the test data and the authorization needed to increase power level in a safe, controlled, step wise manner. 1.1.7. Assure that procedures requiring revision to operate at uprated power conditions have been revised as required and are available to plant personnel. 1.1.8. Assure that regulatory commitments have been completed as required to increase power, above 1593 MWth. This includes commitments contained within the License Amendment Request (LAR), correspondence to the NRC Request for Additional Information (RAI), the NRC issued Safety Evaluation Report (SER) and any license conditions. This will be accomplished via the Pre-requisite section of this procedure. ERSTI-04-VY 1-1409-000 Page 6 of 118

Power Ascension Testing for Extended Power Uprate Conditions( 1.1.9. Verify that training has been completed to meet licensing commitments and provide safe operation of the plant. 1.1.10. Document and collect data, including baseline data at 1593 MWth, which will be used to prepare an EPU Test Report to be submitted to the NRC upon completion. ERSTI-04-VY 1-1409-000 Page 7 of 118

Power Ascension Testing for Extended Power Uprate Conditions 1.2. Discussion 1.2.1. The EPU Project utilized a generic methodology from General Electric for evaluating plant systems and equipment for operating at uprated power levels. This. methodology provided system, program, and equipment task evaluations, which identified the acceptability to operate at an increased power level., These task evaluation documents provided input into the testing program which is implemented by this test procedure. 1.2.2. The steps contained in this document were a culmination of inputs from numerous sources. The GE Licensing Topical Report (GELTR) required operational tests for systems which have revised performance requirements because of the extended power uprate. A test plan was submitted with the License Amendment Request, which specified the operational tests to be performed. A review of the original start-up test specifications was completed and tests were selected based on the change resulting from the extended power uprate. Test requirements were also added to this procedure based on the System Task Reports to ensure that analyses were accurate and closely monitored. Finally, test requirements were added based on Engineering judgment, discussion with plant personnel and Lessons Learned from other plant power uprates. 1.2.3. Test requirements that are satisfied by completion of existing surveillances, calibrations or post modification testing need not be repeated for the purposes of this procedure unless specifically identified in this procedure. 1.2.4. Plant maneuvers and operation shall be performed in accordance with applicable .VY Station Procedures including power changes in accordance with OP 2404, Determination and Implementation of Rod Movement Sequences and OP 0105, Reactor Operations. 1.2.5. A Power Ascension Control Center (PACC) is established to support implementing this procedure. Personnel from various functional areas, together with senior managers, are assigned to provide continuously available resources to address issues that may arise during the performance of this procedure. Additional peer assessments and reviews will be available, if required. ERSTI-04-VY 1 -1409-000 Page 8 of 118

Power Ascension Testing for Extended Power Uprate Conditions 0 1.3. Definitions 1.3.1. CPPU - Constant Pressure Power Uprate - Operating at increased steam and feedwater flows without increasing maximum reactor recirculation flow or reactor vessel operating pressure. 1.3.2. Decay ratio - is a term used to describe the amplitude dampening of an oscillatory signal. Decay ratio is less than 0.25 if there are no more than two positive peaks. IF more than two positive peaks exist, THEN decay ratio must be calculated as follows:

Draw baseline through inflection poihlts of trace.
Amplitudes of peaks should be measured from this reference line, e.g., AO, Al, A2, A3, and A4 as shown in Figure below.
Calculate ratios oJ~ amplitudes between successive peaks of same polarity, e.g., A2/A0, A3/A1, A4/A2.
Decay ratio determined by averaging all ratios determined in previous step, e.g.,
Decay Ratio (A2/AO + A3/AI + A4/A2) , 3.

ERSTI-04-VY 1-1409-000 Page 9 of 11I

Power Ascension Testing for Extended Power Uprate Conditions 1.3.3. EPR - Electrical Pressure Regulator - the electrical/mechanical system which controls the turbine control valves and turbine bypass valves based on main steam pressure. This is the primary turbine pressure control system. 1.3.4. FIV - Flow Induced Vibration 1.3.5. FRV - Feedwater Regulating Valves - air operated feedwater control valves FCV-6-12A and FCV-6-12B that throttle reactor feedwater flow based on signals received from the Feedwater Level Control System. 1.3.6. Intrusive Activities - activities that do have the potential to or change parameters associated with reactor power including backwashing and pre-coating condensate demineralizers, pump swaps, raising or lowering reactor power, changing reactor pressure, etc. 1.3.7. Lead Test Performer - In accordance with ENN-DC-l 17, a person or group assigned by the Test Engineer to assist in the performance of an ERT or STI. The Lead Test Performer may perform the duties of the Test Engineer, in performing the test, as directed by the Test Engineer. 1.3.8. LPU - License Power Uprate = 1912 MWth 1.3.9. MHC Mechanical Hydraulic Control - the combined pressure control system made up of the EPR and MPR. 1.3.10. MPR - Mechanical Pressure Regulator - the mechanical system which controls the turbine control valves and turbine bypass valves based on main steam pressure. This is the backup turbine pressure control system. 1.3.11. Non intrusive activities - activities that do not change any parameters associated with reactor power including data collection, obtaining chemistry samples, etc. 1.3.12. RE - Reactor/Computer Engineering 1.3.13. Responsible Engineer - in accordance with ENN-DC-117, an individual assigned primary responsibility and cognizance for development of an ER Response. ERSTI-04-VY 1 - 1409-000 Page 10 of118

Power Ascension Testing for Extended Power Uprate Conditions 1.3.14. Termination and Hold Criteria 1.3.14.1. Level 1: Criteria associated with plant safety. When a criterion is not met, TERMINATE the test and: 1.3.14.1.1. Hold at the most secure point and place the plant in a condition that is judged to be satisfactory and safe, based upon prior testing, reducing power if necessary. 1.3.14.1.2. Follow plant operating procedures, test procedures or the Technical Specifications on the decision of actions to be taken. 1.3.14.1.3. Generate a CR (condition report) and pursue resolution of the problem. through investigating related adjustments as well as measurement and analytical methods. 1.3.14.1.4. Following resolution, repeat the applicable test portion to verify that the Level 1 requirement is satisfied. ERSTI-04-VY 1-1409-000 Page 11 of 118

Power Ascension Testing for Extended Power Uprate Conditions D 1.3.14.2. Level 2 Criteria is associated with design performance or plant parameters that are not expected to be exceeded while implementing this procedure and at that value are not immediately adverse to plant or equipment safety. When a criterion is not met, place the test onHOLD and: 1.'3.14.2.1. Hold at the most secure point and place the plant in a safe condition including reducing power if necessary. 1.3.14.2.2. Generate a CR and pursue resolution of the problem through investigating related adjustments as well as measurement and analytical methods. 1.3.14.2.3. Repeat the applicable test portion to verify that the Level 2 requirement is satisfied following the resolution unless the as-found condition is found to be satisfactory. ERSTI-04-VY 1-1409-000 Page 12 of 118

Power Ascension Testing for Extended Power Uprate Conditions ( 1.3.14.3. Level 3: Criteria associated with plant surveillance acceptance criteria. When criteria is noi met:

Normal plant procedures will be followed if Level 3 Acceptance Criteria is exceeded.

1.3:14.4. Level 4: Criteria associated with plant operating procedures, for example, operator rounds, operating procedures, alarm response sheets, etc. When criteria is not met: SNormnal-plant procedures will be followed if Level 4 Acceptance Criteria is exceeded. 1.3.15. 'Test Engineer - Peg ENN-DC-117 a qualified individual for any organization, designated by the Testing Authority to perform the responsibilities of the Test Engineer. Qualifications for filling the Test Engineer function are in accordance with ENN-TQ- 104. 1.3.1.6. Testing Authority - Per ENN-DC-l 17, the Testing Authority is the individual who owns the testing process. The System Engineering Manager is the Testing Authority. ERSTI-04-VY 1 - 1409-000 Page 13 of 118

Power Ascension Testing- for Extended Power Uprate Conditions 1.4. Responsibilities The roles and responsibilities established to support this procedure are as follows:, 1.4.1. Management Designee: A management person who holds an SRO license/certification, DCO qualified, a superintendent or higher level member of the plant, staff or other individual that has been designated by the General Manager Plant Operations with responsibility for management oversight as defined in this procedure. He/she shall provide overall, line management authority for the safe conduct of an infrequently performed test or evolution. The Management Designee does not replace any individual involved in the test or evolution, nor supervise the evolution. The Management Designee's function is management oversight. 1.4.2. Shift Manager - The SM has the responsibility for the safe operation of the plant at all times. The SM's approval is required prior to performance of.this test and has the authority to stop the test at. any time. The SM's approval is also required to continue testing if a test was terminated. 1.4.3. Control Room Supervisor (CRS) provides direction to Licensed Operators and other on-shift Operations personnel involved in the performance of this test. ERSTI-04-VY I-1409-000 Page 14 of 118

Power Ascension Testing for Extended Power Uprate Conditions 1.4.1. Principal IPTE Coordinator [PIPTEC] - is responsible for overall implementation of the procedure. His responsibilities are spelled out ifi AP 6100. The PIPTEC will maintain control of all test activities and seek assistance from support departments as necessary. The PIPTEC or their designees will be responsible for signing, off steps as completed within this procedure. The PIPTEC have the following duties and responsibilities with respect to the activities being. controlled by this procedure. The SM shall not be assigned as a PIPTEC.

       *0      Reports test status and significant issues to station management.

Coordinates the activities requiring completion by this procedure to assure they are completed in a safe and timely manner. Responsible for assuring this procedure is updated and maintained current with work and testing activities controlled by this procedure. Reviews the exceptions to this procedure and expedites the resolution. if exceptions affect power ascension testing. Authorizes the next step in power ascension testing if the test data results meet the acceptance criteria. May add additional equipment performance monitoring data collection at any time during the performance of this procedure. Assures that shift personnel are knowledgeable of test activities being controlled and performed by this procedure. ERSTI-04-VY 1-1409-000 Page 15 of 118

Power Ascension Testing for Extended Power Uprate Conditions V.) 1.4.2. Test Engineer' - Per ENN-DC-1 17 a qualified individual for any organization, designated by the Testing Authority to perform the responsibilities of the Test Engineer. Qualifications for filling the Test Engineer function are in accordance with ENN-TQ-104. The Test Engineer will have the following duties and responsibilities with respect to the activities being controlled by this procedure. The, Test: Engineer may assist in the development and/or presentation of technical aspects of this evolution. Has administrative and physical control of this procedure.

Maintains a log.
Maintains technical control of this procedure and is authorized to make changes to the acceptande limits of the system and equipment following an engineering evaluation that justifies the change in accordance with ENN-DC- 117 1.4.3. Operations ,Support Personnel (AO's) - Operations Control Room personnel and auxiliary operators will perform the necessary plant control manipulation to operate various valves, equipment, and systems.

1.4.4. Test Team [IPTE Team]: A team of individuals, led by the Management Designee, will monitor extended or complex IPTEs. Oversight team members do not replace any individuals involved in the test or evolution. The team's function is to provide additional oversight. 1.4.5. Responsible Engineers, in conjunction with the Test Engineer and Shift Manager, have authority to change system and equipment acceptance limits or predicted performance values following an engineering evaluation that justifies the change in accordance with ENN-DC- 117. ERSTI-04-VY 1-1409-000 Page 16 of118

Power Ascension Testing for Extended Power Uprate Conditions

2.

References:

2.1. AP 0020 Control Of Temporary And Minor Modifications 2.2. AP 0052 Pre Job Briefing 2.3. AP 0503 Establishing And Posting Restricted Areas 2.4. AP 6100, Infrequently Performed Test or Evolutions 2.5. DP 0636 Collection and Digestion of Metal Samples 2.6. DP 0643 Filterable Solids 2.7. EN-AD-103 Document Control and Records Management Activities 2.8. EN-LI- 102 Corrective Action Process 2.9. ENN-DC-1 17 Post Modification Testing and Special Test Instructions 2.10. ENN-IT-104 Software Quality Assurance Program 2.11. ENN-OP-104 Resolution of Equipment Operability Concerns Related to Degraded or Nonconforming Conditions 2.12. ER 04-0529 ""EPU Instrumentation Upgrade Non Outage" 2.13. GE EPU Final Task Reports: 2.13.1. VY-RPT-05-00041, "T 1005: Startup Test Specifications" 2.13.2. VY-RPT-05-00065, "T0500: Neutron Monitoring System" 2.13.3. VY-RPT-05-00066, "T0504: Feedwater Control System" 2.13.4. VY-RPT 05-00067, "T0506: NSSS TS Instrument Setpoints" 2.13.5. VY-RPT-05-00104, "T0316: NSSS Piping Flow Induced Vibration Evaluation" 2.14. GE SIL 467, Recirculation System Bi-stable Flow in Jet Pump BWRs 2.15. GEl 88578 "Overspeed Operation Preparatory Procedure for Cold Starts" ERSTI-04-VYI-1409-000 Page 17 of118

Power Ascension Testing for Extended Power ,Uprate Conditions 2.16. GEK 459371, "Recommendation for Reading and Recording Generator Resistance Temperature Detectors and Thermocouples" 2.17. GEK 75526A "Operator Action on High Temperature Alarms" 2.18. I&T 2003-004.01 FWH Level Control System Installation and Test procedure 2.19. Licensing Topical- report,. "Generic Evaluations for General Electric Boiling Water Reactor Extended Power Uprate," NEDC-32523P-A Class III, February 2000 (ELTR-2) 2.20. Licensing Topical report, "Generic Guidelines for General Electric Boiling Water Reactor Extended Power Uprate," NEDC-32424P-A Class III, February 1999 (ELTR-1) 2.21. MM 2004-002 "EPR Modification for EPU" 2.22. MM 2004-039 "NSSS/BOP Inst umentation Upgrades for EPU" 2.23. NF 102 Corporate Fuel Reliability 2.24. Nuclear Change ER 2004-1409, Extended Power Uprate 2.25. OP 2199 Hydrogen Water Chemistry System 2.26. OP 0105 Reactor Operations 2.27. OP 0631 Radiochemistry 2.28. OP 2172 Feedwater System 2.29. OP 2404 Determination And Implementation Of Rod Movement Sequences 2.30. OP 2429 Recirculation Flow System Baseline Data Collection and Instrument Calibration 2.31. OP 2457, PCIOMR Implementation 2.32. OP 2613, Sampling and Analysis of the Off Gas System 2.33. OP 4110 Reactor Recirc System Surveillance ERSTI-04-VY 1- 1409-000 Page 18 of 118

Power Ascension Testing for Extended Power Uprate Conditions 2.34. OP 4160 Turbine Generator Surveillance 2.35. OP 4401 Core Thermal Hydraulics Limits Evaluation 2.36. OP 4612 Sampling and Treatment of the Reactor Water System 2,37. OP 4617 Calculation of Qhemistry Controlled Setpoints 2.38. OP 5399 I/C Calibration Of Important Computer Analog Inputs 2.39. Original GE Startup Test Instructions, Spec. No. 22A2219 KV Rev:0 2.40. Original GE Startup Test Instructions, Spec. No. 22A2219 KV Rev.0 2.41. OT 3110 Positive Reactivity In~ertion 2.42. OT 3113 Reactor Low Level 2.43. OT 3114 Reactor High Level 2.44. OT 3115 Reactor Pressure Transients 2.45. PP 7401, Fuel Reiiability Program 2.46. Safety Analysis Report for Vermont Yankee Nuclear Power Station Constant Pressure Power Uprate NEDC-33090P, dated September 2003. 2.47. STP 2002-004, Pressure Regulator Dynamic Testing. 2.48. STP 2003-004 Power Ascension Test Procedure 2.49. STP-22, Original Plant Startup Testing for the Pressure Regulator. 2.50. STP-23, Original Plant Startup Testing for the Feedwater Flow Control System 2.51. Technical Evaluation 2004-037, Benchmarking Feedwater FCV Performance for EPU. 2.52. VY EPU License Amendment Request, PC 263 2.53. VYDC 2000-027, Main Turbine EPR replacement. 2.54. VYDC 2001-002, Feedwater Level Controls Upgrade. ERSTI-04-VY 1-1409-000 Page 19ofl118

Power Ascension Testing for Extended Power Uprate Conditions 2.55: VYDC 2002-007, Feedwater Control System Replacement - Phase 2. 2.56. VYDC 2003-003 "New Main Generator TC's and RTD's and the ERFIS Software Modification" 2.57. VYDC 2003-004 Feedwater Heater Level Control System 2.58. VYNPS Startup Test ERSTI-04-VY 1 - 1409-000 Page 20 of 118

Power Ascension Testing for Extended Power Uprate Conditions

3. Apparatus/Test Equipment 3.1. Dryer Data Collection per TA 2005-0015, Additional Strain Gauge Installation 3.2. Feedwater Heater Performance per TM 2003-035 Feedwater Heater Performance 3.3. Flow Induced Vibration Equipment per TM 2003-022, FIV Instrumentation 3A4. Hand held vibration equipment 3.5.' Any other monitoring equipment required based on System Engineering System Monitoring Requirements 3.6. Calibrated Pressurized Ion Chamber (PIC) 3.7. Other instrumentation and equipment as required ERSTI-04-VY 1-1409-000 Page 21 of 118

Power Ascension Testing for Extended Power Uprate Conditions 0

4. Precautions and Limitations . ,

  .4.1. Reactor power levels given in percent are a percentage of the Extended Power Uprate of 1912 MWth = 100.00% LPU.

4.2. System and equipment performance shall be closely monitored to assure that operating limits and test criteria are not exceeded. Condition reports shall be submitted as required. Any discrepancies noted are reported to the Test Engineer and the PIPTEC with an evaluation to determine plant impact (discrepancy resolved or power ascension terminated and/or power reduction commenced): Attach evaluations within Attachment 9 as discussed in Section 9. 4.3. If during power operation any of the following occurs, it may be indication of vessel internals -damage and debris carry over. Notify the Shift Manager, the General Manager, Plant Operations, the Test 'Engineer and the PIPTEC immediately. (OE14300)

Unbalance of Main Steam Line steam flow indication - 5% greater than baseline values
Unbalance 'RPV water level -3 inches between level instruments from different reference legs.

Sudden drop in steam dome pressure 2-3 psig.

Unexpected or unexplained step increase of moisture carryover.

4.4. Any pressure or level step changes at a power plateau shall be made first in the downward direction, then in the upward direction. This includes testing the EPR, the MPR, and the feedwater level control system. 4.5. IF during any pressure or level step changes, the system shows signs of becoming unstable or the acceptance limits are approached, THEN stabilize the condition, OTHERWISE exit the condition. The next larger step change shall not be performed until an acceptable response is achieved from the previous smaller steps. This may require repeating a previous step. 4.6. Reactor Engineering shall ensure the testing will avoid operation in the buffer and exclusion regions of the power to flow map. ERSTI-04-VYI -1409-000 Page 22 of 118

Power Ascension Testing for Extended Power Uprate Conditions 0 4.7. IF the EPR is inoperable (the MPR in control) for a time period greater than two hours per occurrence, THEN initiate a CR per ENN-LI-102. Ensure an operability determination, per ENN-OP- 104, is completed within 24 hours. 4.8. The Test Engineer with the assistance of the Test Team shall coordinate the review and evaluation of the data package for each step of this procedure for acceptance criteria compliance. 4.9. ALARA principles should be balanced with observing plant systems during power ascension system inspections. 4.10. Power levels tolerances are -19 MWth, + 0 MWth. 4.11. Intentional operation greater than the current plateau (1593 MWth, 1673 MWth, 1752 MWth, 1832 MWth and 1912 MWth) is not permitted. The average CTP level over any eight-hour period shall not exceed the current plateau power level. It is permissible to inadvertentlý exceed current power plateau by as much as 2% (nominal 1912 MWth) for as lcng as 15 minutes. Lesser power excursions are permitted for longer periods (i.eý, 1% excess for 30 minutes, 1/2%'for one hour, etc.) as long as the 8 hour average does not exceed the current power plateau. (NRC Letter SSINS-0200, dated 8/22/80). 4.12. After any change in plant power level above 1593 MWth by the steps in this procedure, an approximate 60-minute stabilization period shall occur prior to recording system and equipment performance data with the exception of dryer and FIV data. Following the stabilization period and during the data collection period the plant shall be maintained in as stable a condition as is possible (i.e., no backwashing and pre-coating condensate demineralizers, pump swap-over, etc) until data collection has been completed. 4.13. Record dryer data collection every hour during power ascension (16 MWth change in reactor power) and within one hour of achieving the next power plateau per Attachment 1 (A-Y). ERSTI-04-VY 1-1409-000 Page23 of 118

Power Ascension Testing for Extended Power Uprate Conditions

5. Termination Criteria 5.1. If an unexpected action results during performance of this procedure:

STOP, PLACE SYSTEM OR COMPONENT IN A SAFE CONDITION, AND NOTIFY THE SHIFT MANAGER, THE TEST ENGINEER AND THE PIPTEC. 5.2, Terminate the IPTE upon the occurrence of: 5.2.1. Exceeding any Level 1 Criteria 5.2.2. Any specific termination/abort criterion defined in applicable procedures or attachments. 5.2.3. Any relatedevent that causes an unexpected reactivity transient, such as that associated with reactor water level, pressure, core flow, temperature, or control rod position. 5.2.4. Any event which requires entering a Technical Specification Limiting Condition for Operation (LCO). 5.2.5. Any IPTE related event that is reportable or potentially reportable to the NRC, such as reactor scram, ECCS actuation, an uncontrolled radiation release or other Condition Report of noteworthy concern. 5.2.6. Any other condition which, in the determination of the PIPTEC, Management Designee, upper management or SM, requires the IPTE to be terminated. 5.3. IF this test is TERMINATED, THEN record and document the exception on test deficiency log in accordance with ENN-DC-117, and generate a CR. Any CRs effecting operability must be reviewed by SM and the Management designee. Notify the GMPO and 91 -01 Coordinator (or equivalent). ERSTI-04-VY 1-1409-000 Page 24 of 118

Power Ascension Testing for Extended Power Uprate Conditions 5.4. If the decision is made to restart or continue an IPTE which was terminated/aborted, the Management Designee and/or PIPTEC shall performri the following prior to proceeding with the test: 5.4.1. Obtain GMPO approval and review by OSRC (if required). 5.4.2. Obtain SM permission. 5.4.3. Ensure resumption will not have unacceptable impact on plant status, operating equipment, or the remainder of the evolution. 5.4.4. Verify prerequisites are met and conditions have not changed since. entering the terminated/aborted. condition. If conditions have changed, complete applicable steps on the original prerequisites page or on additional pages and attach to the procedure. 5.4.5. Document the re-verification of prerequisites and continuation in the Control-Room Log. 5.4.6. Ensure the Operating creýv has been re-briefed and has taken a Take Two to refocus on the task. 5.5. IF during the performance of this procedure, testing is stopped for whatever reason, THEN refer to Termination Criteria for actions to be taken PRIOR to resuming testing. ERSTI-04-VY 1-1409-000 Page 25 of 118

Power Ascension Testing for Extended Power Uprate Conditions 5.6. If an unexpected event occurs at any time during system testing, the system shall be placed in a safe and stable mode using existing operating procedures. Testing activities shall be suspended and placed on. HOLD until the event is understood and the SM and the PIPTEC has granted permission to resume testing. The test engineer shall document the decision making on test deficiency log, recording the resolution and approvals granted in accordance with ENN-DC-117. Submit a Condition Report per EN-LI-102. Some examples are; If inadequate manpower is available on site or via telephone to ensure successful completion of the evolution. To resolve concerns with the evolution or with personnel assigned to the evolution.

Upon loss of required communications.

If plant impacts or conflicts with other procedures are identified that are not addressed by the procedures governing the special evolution. ERSTI-04-VY 1-1409-000 Page 26 of 118

Power Ascension Testing for Extended Power Uprate Conditions

6. Prerequisites Verify the following items, identified in this section have been implemented and are complete and/or are operable, as appropriate:

NOTE Prerequisites do not have to be completed in sequence up to step 6.17, Shift Manager's permission to commence license implementation for EPU. Steps prior to 6.17 can be signed off prior to the receipt of the license amendment.

                   ' The following modifications have -been completed' in accordance with design engineering requirements.

Applicable post modification testing has been scheduled or completed, based on plant conditions, and procedures revised as required. Operations has accepted the modified system and there are NO exceptions which preclude power operation up to 1912 MWth. Confirmation of the completion of a modification is initialed by the Test Engineer, another, member of the Test Team, or the Responsible Engineer for the modification. 6.1. Minor Modifications: Responsible Engineer 6.1.1. MM 2003-017, Modify RHRSW A Motor Cooling Piping

                                                                              /1 Initial  Date   Time 6.1.2. MM 2003-018, Modify RHRSW B Motor Cooling Piping Initial   Date  Time ERSTI-04-VY 1-1409-000 Page 27 of 118.

Power Ascension Testing for Extended Power Uprate Conditions 0 6.2. Temporary Modifications/Alterations:, Responsible-Engineer 6.2.1. TM 2003-022, FIV Instrumentation (Vibration sensors)

Initial Date Time 6.2.2. TM 2003-035 Feedwater Heater Performance Monitoring. Initial Date Time 6.2.3. TA 2005-0015, Additional Strain Gauge Installation Initial Date Time 6.3. Technical Specification Changes1 6.3.1. PC-263, EPU

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Initial Date Time 6.3.2. PC-262, AST

                                                                     /      /

Initial Date Time 6.4. VYDC completed and implemented: Responsible Engineer 6.4.1. VYDC 2003-020, Replacement 381 Breaker

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Initial Date Time 6.4.2. VYDC 2003-016, Alternate Source Term

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 28 of 118

Power Ascension Testing for Extended Power Uprate Conditions 0 6.5. Nuclear Changes 6.5.1. ER 200470705, Cooling Tower Fahs/Motors

                            */                                                /

Initial Date Time 6.5.2. ER 2004-1298, LP Turbine 8 th Stage Diaphragms

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Initial Date Time 6.5.3. ER 2004-1267, MS Low Point Sockolet Reinforcement

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Initial Date Time 6.5.4.. ER 2004-0971, Main Transformer (GSU) Differential Protection Initial Date Time 6.5.5. ER 2005-073 1, Isokinetic Sample Probes

                                                                      /       /

Initial Date Time 6.5.6. ER 2005-0776,*Feedwater Pump Trip Initial Date Time 6.5.7. ER 2004-0975, Generator CT Upgrade

/ /

Initial Date Time 6.5.8. ER 2004-1409, EPU

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 29 of 118

Power Ascension Testing for Extended Power Uprate Conditions 6.5.9. ER 2004-0529, Setpoints and Scaling Changes Required by EPU (approval of document only, implementation is controlled by this procedure.)

/.

Initial Date Time 6.5.10. ER 2006-1099, Reactor Recirculation Runback Termination Point Change

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Initial Date Time 6.5.11. ER 2005-1002 Modification to Feedwater Level Control System to Support EPU

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Initial Date Time ERSTI-04-VY I-1409-000 Page 30 of 118

Power Ascension Testing'for Extended Power Uprate Conditions 6.6. OPERATIONS EPU TRAINING (Training) 6.6.1. The required training to operate the plant under EPU conditions has been conducted. Classroom training includes plant design changes in support of EPU including setpoint changes, changes to parameters, procedures and system operation, all related Technical Specification changes, and this Power Ascension Special Test. Simulator training has provided Operators with a demonstration of transients that show the greatest change in plant response at EPU power levels compared to the original maximum power level.

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Initial Date Time NOTE This prerequisite does not pertain to any particular Just-in-Time training Operations Management chooses to conduct for Operations personnel performance of power ascension testing. 6.6.2. Evaluation Comments:

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 31 of 118

Power Ascension Testing for Extended Power Uprate Conditions 6.7. EPU Project Action Items 6.7.1. Throughout the EPU Project, action items have been tracked on an internal Action Item List and via PCRS assignments. These tracking mechanisms have been reviewed for items requiring completion prior to or during power ascension testing. The items requiring completion prior to exceeding 1593 MWth have been completed* or will be completed as controlled by this:procedure. (EPU)' Comments:

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Initial Date Time 627.2. Steam Dryer Action Itemý (EPU) The commitments and planned actions specified in the EPU license amendment pertaining to the steam dryer required prior to power ascension have been completed. This step shall be completed prior to increasing power above 1593 MWth. Comments: Verified By: Licensing Manager/Date Verified By: EPU Project Manager/Date ERSTI-04-VY1 - 1409-000 Page 32 of 118

Power Ascension Testing for. Extended Power Uprate Conditions 6.7.3. Technical Specifications and TRM (OPS) LCO Tracking Database has been reviewed and evaluated for any impact on the ability of the plant to support power ascension testing and has been found acceptable for power increase. Exceptions requiring action shall be listed below by exception number and shall be annotated in Test Deficiency Log. Comments:

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Initial Date Time 6.8. LOG REVIEWS 6.8.1. TEMPORARY ALTERATION (MODIFICATIONS) LOG REVIEW (System Engineering) 6.8.1.1. The Temporary Alteration (Modifications) Log has been reviewed and all installed Temp Alts have been evaluated for their impact on this Power Ascension Test and have been found acceptable. Exceptions requiring action shall be listed in Test Deficiency Log. Comments:

/ /

Initial Date Time ERSTI-04-VY.1 -1409-000

Page 33 oflI8

Power Ascension Testing for Extended Power Uprate Conditions 6.8.2. Operability Evaluation/ODMILog Review: (OPS) 6.8.2.1. All Operability Evaluations/ODMIs that have EPU constraints been evaluated for their impact on Power Ascension and have been found acceptable'. Exceptions requiring action shall be listed in Test Deficiency Log. Comments:

//

Initial Date Time ERSTI-04-VY l-1409-000 1 Page 34 of 118

Power Ascension Testing for Extended Power Uprate Conditions 0 6.9. PROCEDURE REVIEW AND ISSUANCE 6.9.1. The EPU Project has resulted in the completion of many modifications, Technical Specification revisiorns and system operating parameter changes. These changes affect many Site procedures. This prerequisite requires the responsible Department Head review the procedures under their control and verify that: They have reviewed the procedures under their control for minor modifications, design changes, temp modifications, and license amendments.

Have evaluated the impact of the differences between the Final License amendment and the proposed License amendment on various procedure changes.
Training of personnel within their- department has been completed as required by the revised procedures.

0 Procedures requi*red for power ascension have been issued and distributed for plant usage.

By signing for ýtheir respective department procedures, the responsible department head verifies that plant procedures assigned to the department required for power ascension have been revised accordingly.

Functional Group Dept Head/ Signature Exceptions Date/Time

Maintenance Operations Chemistry Radiation Protection Engirfeering Training Emergency Preparedness Reactor Engineering General Manager Licensing Safety Quality Assurance CA&A Record exceptions on the Test Deficiency Log and enter the log number on this page.

ERSTI-04-VY 1-1409-000 Page 35 of 118

Power Ascension Testing for Extended Power Uprate Conditions 6.10. SER Review 6.10.1. The NRC Final Safety Evaluation Report and License Amendment have been reviewed against the License Amendment Request and an'y-. differences have been evaluated for their affect on; 0 Plant Operating Procedures 0 Plant Processes and Programs This Power Ascension Test Procedure This evaluation has been completed and there are no additional changes to the documents listed above prior to the start of Power Ascension Testing as performed by this procedure. Evaluation Comments Comments: Verified By: Licensing Manager/Date Verified By: EPU Project Manager/Date ERSTI-04-VY 1-1409-000 Page 36 of 118

I .. Power Ascension Testing for Extended Power Uprate Conditions 6.11 EQUIPMENT CLEARANCE ORDERS AND EQUIPMENT STATUS TAGS (OPS) 6.11.1. The equipment that is Out-of-Service that can affect the ability of the plant to support power ascension testing has had its plant impact reviewed and evaluated and found acceptable for power increase. Exceptions requiring action shall be listed below by exception number and shall be annotated in Test Deficiency Log in accordance with ENN-DC-1 17. 6.11.2. Review Comments:,

/ /

Initial Date Time ERSTI-04-VY1-1409-000 Page 37 of 118

Power Ascension Testing for Extended Power Uprate Conditions 6.12. Verify the follov~ing Instrumentation Prerequisites completed: 6.12.1. ERFIS is available for monitoring test parameters (RE) including: 6.12.1.1. VYOPF 0452.01 2005-037 ERFIS Condensate and Feedwater Pump and Motor Bearing Temperature Setpoint Increase for EPU.

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Initial Date Time 6.12.1.2. VYOPF 0452.01 2005-021, ERFIS F605, CQ08 Condensate FlovY Re-range for EPU Initial Date Time 6.12.1.3. VYOPF 9452.01 2005-025, ERFIS Miscellanýeous EPU Change

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Initial Date Time 6.12.2. TA 2005-0015 Strain Gauges (DE)

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Initial Date Time 6.12.3. TM 2003-0035, Feedwater Heater Perforrnan-e Monitoring (DE)

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Initial Date Time 6.12.4. TM 2003-022, FIV Monitoring (DE)

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Initial Date Time ERSTI-04-VY 1 -1409-000 Page 38 of 118

Power Ascension Testing for Extended Power Uprate Conditions 0 6.12.5. ER 04-529, EPU Instrument Changes:.(I&C) 6.12.5.1. 2005E-060 Condensate Pump Motor Amp Control Room Indication Amber Band'(Optional)

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Initial Date Time 6.12.5.2. 2005C-005 Condensate Pump Discharge Pressure Control Room Pressure Indication Green Band (Optional)

                                                                /      /

Initial Date Time 6.12.5.3. 2004C-023 PT-6-56 Main Turbine Bowl Pres~sure Transmitter / / Initial Date Time 6.12.5.4. Calibration of FS-6-95 Steam Leak Detection

                                                                /       /

Initial Date Time 6.12.5.5. -Calibration Data Sheet for FT-102 1 and Fl- 102-9 Condensate flow input to Oxygen Injection System

                                                                /       /

Initial Date Time ERSTI-04-VY 1- 1409-000 Page 39 of 118

Power Ascension Testing for Extended Power Uprate Conditions 6.13. Administrative Controls: The signature below signifies that power ascension above 1593'MWth may commence with all issues resolved or otherwise addressed. 6.13.1. Licensing Manager

                                                /               /

Signature / Date / Time 6.13.2. EPU Manager

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Signature / Date / Time 6.13.3. Engineering Director Signature / Date / Time 6.13.4. Operations Manager

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Signature / Date / Time 6.13.5. Reactor Engineering Superintendent

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Signature / Date / Time 6.13.6. CA&A Manager

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Signature / Date / Time 6.13.7. Quality Assurance Manager

                                                /              /_    _     _

Signature / Date / Time 6.13.8. Maintenance Manager

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Signature / Date / Time ERSTI-04-VY 1-1409-000 Page 40 of 118

Power Ascension Testing for Extended Power Uprate Conditions 6.13.9. Chemistry Manager _ _ _ / /_ _ _ Signature / Date / Time 6.13.10. RP Manager Signature / Date / Time 6.14. All test team members have read and understood: 6.14.1. ERSTI-04-VY1-1409-000, Power Ascension Test Procedure for Extended Power Conditions 1593 to 1912 MWth 6.14.2. EN-DC-117 Post Modification Testing and Special Testing Instructions. 6.14.3. AP 6100 Infrequently ýerformed Tests or Evolutions

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Days Initial Date Time 2 / Nights Initial Date Time ERSTI-04-VY 1- 1409-000 Page 41 ofll8

Power Ascension Testing for Extended Power Uprate Conditions 6.15. PRE-JOB BRIEFS: 6.15. 1. A pre-job brief has been performed per.AP 6100 for PACC personnel involved on day shift.

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Initial Date Time 6.15.2. A pre-job brief has been performed per AP 6100 for PACC personnel involved on night shift.

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Initial Date Time 6.15.3. A pre-job brief has been performed per AP 6100 for day shift test team members.

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Initial Date Time 6.15.4. A pre-job brief has been performed per AP 6100 for night shift test team members.

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Initial Date Time 6.15.5. A pre-job brief ha's been conducted per AP 6100 for Operating Crews

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 42 of 118

Power Ascension Testing. for Extended Power Uprate Conditions 6.16. Shift Manager's Permission to start: 6.16.1. THE SM'S PERMISSION HAS BEEN GRANTED TO COMMENCE LICENSE IMPLEMENTATION FOR EXTENDED POWER UPRATE. Shift Manager/Date /Time 6.17. OSRC recommends license implementation for Extended Power Uprate to the GMPO. OSRC Review Meeting #: / / Initial Date Time 6.18. The GMPO authorizes implementation of the: 6.18.1. The license change per PC 263

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Initial Date Time 6.18.2. The remaining prerequisites (Step 6.21) listed in this procedure which will effectively raised authorized reactor power limit to 1912 MWth

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Initial Date Time 6.19. Verify that new license has been implemented in the control room.

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 43 of 118

Power Ascension Testing for Extended Power Uprate Conditions 0 6.20. Implement the following changes: 6.20.1. ERFIS Changes 6.20.1.1. VYOPF 0452.01 2004-070, ERFIS 3D Monicore Extended Power Uprate Initial Date Time 6.20.1.2. VYOPF 0452.01 2004-073, ERFS EPU Operating Map Display Update

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Initial Date Time 6.20.1.3. VYOPF '0452.01 2005-020, ERFIS EPU Related SPDS Display Initial Date Time 6.21.2 Setpoint Changes: 6.21.2.1 Setpoint Change for Main Steam Line Radiation Monitors RM- 17-251 A/B/C/D at EPU Conditions Initial Date Time ERSTI-04-VY1-1409-000 Page 44 of 118

Power Ascension Testing for Extended Power Uprate Conditions ( 6.21.3 Work orders that implement ER 2004-0529, Setpoints and Scaling Changes Required by EPU: 6.21.3.1 2005C-OO1APRM Flow Bias Scram (A/M) Initial Date Time 6.21.3.2 2005C-002 APRM Flow Bias Rod Block (A/M)

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Initial Date Time 6.21.3.3 2005C-003 MSL High FlowM/S in RUN

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Initial Date Time 6.21.3.4 2005C-00*4 MSL High Flow M/S Not in Rui\

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Initial Date Time 6.21. Confirm the following documents are approved after. the receipt of the NRC License Amendment. 6.21.1. Nuclear Change 04-1493

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Initial Date Time 6.21.2. TRM

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Initial Date Time 6.21.3. Input Assumption Source Document

. /

Initial Date Time 6.21.4. Calculation VYC-808 I. / Initial Date Time ERSTI-04-VY1 -1409-000 Page 45 of 118

Power Ascension Testing for Extended Power Uprate Conditions 6.21.5. Calculation VYC-2374

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Initial Date Time, 6.21.6. Calculation VYC-2398

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Initial Date Time 6.21.7. Calculations VYC-2405

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Initial Date Time 6.22. All prerequisites are complete and any exceptions are authorized and approved. Verified By: Test Engineer/Date/Time ERSTI-04-VY 1-1409-000 Page 46 of 118

Power Ascension Testing for Extended Power Uprate Conditions

7. Procedure NOTES

Power levels tolerances are -19 MWth, + 0 MWth.
Intentional operation greater than the current plateau (1593 MWth, 1673 MWth, 1752 MWth, 1832 MWth and 1912 MWth) is not permitted.

The average CTP level over any eight-hour period shall not exceed the current plateau power level. It is permissible to inadvertently exceed current power plateau by as much as 2% (nominal 1912 MWth) for as long as 15 minutes. Lesser power excursions are permitted for longer periods (i.e., 1% excess for 30 minutes, 1/2% for one hour, etc.) as long as the 8 hour average does not exceed the current power plateau. (NRC Letter SSINS-0200, dated 8/22/80). Data collection and evaluation at each power level may be performed in any order at that power level unless the section provides different direction. IF during the performance of this procedure, testing is stopped for whatever reason, THEN refer to Termination/Hold Criteria, for actions to be taken PRIOR to resuming testing.

        ,  After any change in plant power level above 1593 MWth by the steps in this procedure, an approximate 60-minute stabilization period shall occur prior to recording system and equipment performance data with the exception of dryer 'data and FIV data. Following the stabilization period and during the data collection period the plant shall be maintained in as stable a condition as is possible (i.e., no backwashing and pre-coating condensate demineralizers, pump swap-over, etc.) until data collection has been completed.

The Test Engineer with the assistance of the Test Team shall coordinate the review and evaluation of the data package for each step of this procedure for acceptance criteria compliance: ERSTI-04-VY 1- 1409-000 Page 47 of118

Power Ascension Testing for Extended Power Uprate Conditions 0 7.1. 1593 MWth With reactor power at 1574 MWth to 1593 MWth, and with three (3) Feedwater pumps running, perform the following: 7.1.1. Verify performed or perform dryer data collection per Attachment 1A.

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Initial Date 'Time 7.1.2. Verify performed or perform flow induced vibration measurement per Attachment 2A.

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Initial Date Time 7.1.3. Verify performed or' request RP to perform Radiation Surveys per Attachment 3.

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Initial Date Time 7.1.4. Verify or request Operations to verify or place the "B" recombiner in service and the ."A" recombiner in standby per OP 2150.

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Initial Date Time 7.1.5. Verify performed or request RE to predict anticipated thermal limits for 1673 MWth per Attachment 4.

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Initial Date Time 7.1.6. Verify performed or request Chemistry to obtain baseline offgas samples per OP 2613, Sampling and Analysis of the Off Gas System. Attach per-Section 9.0.

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Initial Date Time ERSTI-04-VY 1.- 1409-000 Page 48 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.1.7. Verify performed or request System Engineering to perform the System Engineering System Monitoring Plan baseline data at 1593 MWth and has been included within Attachment 9A.

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 49 of 118

Power Ascension Testing for Extended Power Uprate Conditions NOTES: EPU power ascension testing above 1593 MWth will be conducted in approximately 40 MWth steps and 80 MWth plateaus. The maximum power increase will not exceed a 80 MWth in a 24-hour period. Steam Dryer Moisture Carryover Analysis needs to be performed at least once daily when reactor power is greater than 1593 MWth per Attachment 5. 7.1.8. If needed, raise reactor tpower and maintain 1593 MWth (1574 MWth to 1193 MWth).

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Initial Date Time 7.1.9. Authorization for Power Ascension: 7.1.9.1. General Manager, Plant Operations permission has been granted, to exceed 1593 MWth.

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Initial Date Time 7.1.9.2. Shift Manager's permission has been granted to implement power ascension testing.

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 50 of 118

Power Ascension Testing for Extended Power Uprate Conditions , NOTE: Dryer data collection readings (strain gauge and accelerometer data) are to be taken and evaluated every hour during power ascension (16 .MWth change in reactor power) and within one hour of achieving the next power plateau per Attachment 1. 0 Reactor Power will need to be held constant, (within -19 MWth, +0 MWth) for approximately 2 minutes before and 15. minutes during the dryer data collection per Attachment 1. 7.2. Increasing to 1633 MWth Allowing no other concurrent intrusive activities, raise reactor power by 40 MWth to 1633 MWth (1614 MWth to 1633 MWth) in accordance with OP 0105, Reactor

    .Operations, as follows:

7.2.1. While raising reactor power: 7.2.1.1. Perform dryer data collection after the first 16 MWth change in reactor power per Attachment lB at 1609 MWth (1590 MWth to 1609 MWth).

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Initial Date Time 7.2.1.2. Perform dryer data collection after the second 16 MWth change in reactor power per Attachment 1C at 1625 MWth (1606 MWth to 1625 MWth). Initial Date Time 7.2.1.3. Perform dryer data collection per Attachment 1D after achieving 1633 MWth (1614 MWth to 1633 MWth). Initial Date Time ERSTI-04-VY 1-1409-000 Page 51 of I 8

Power Ascension Testing-for Extended Power Uprate Conditions 7.2.2. Maintain reactor power (1614 MWth to 1633 MWth) for four hours while performing the following non intrusive activities: 7.2.2.1. Perform flow induced vibration measurement per Attachment 2B. (non intrusive) Initial Date Time 7.2.2.2. Request RE to: 7.2.2.2.1. Verify current reactor conditions are within acceptable - values of the power-flow map (COLR figure 2.4-1). (non intrusive) Initial Date Time 7.2.2.2.2. Verify all inputs to the heat balance 'acceptable by reviewing ERFIS display HBI (Heat Balance Inputs). Attach HBI screen per Section 9.0. (non intrusive) Initial Date Time 7.2.3. One hour after achieving 1633 MWth (1614 MWth to 1633 MWth), perform moisture carryover determination per Attachment 5A. (non intrusive)

                                                                               /I Initial  Date     Time ERSTI-04-VY I - 1409-000 Page 52 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.2.4. Four hours after achieving, 1633 MWth (1614 MWth to 1633 MWth), perform Extraction Steam Reverse Current (RC) Valve Test in accordance with OP 4160 Section B, Extraction Steam Reverse Current Valve Test using VYOPF 4160.07. Hold each RCV test switch for 30 seconds or until a closed (green light) indication-is observed. Record whether the valve indicated intermediate or closed. Attach VYOPF 4160.07 per Section 9.0. (Intrusive)

Initial Date Time 7.2.5. Request Chemistry and RE to evaluate offgas levels for fuel integrity per PP 7401 Fuel Reliability Program and NF 102, Corporate Fuel Reliability. Both parties to sign when complete. (non intrusive) iD / Initial Date Time Initial Date Time 7.2.6. Request Chemistry to verify the Main Steam Line Radiation Monitor response is within the expected dose range per OP 4617, Calculation of Chemistry Controlling Setpoints or new Setpoint Change has been implemented (non intrusive)

                                                                    /      .

Initial Date Time ERSTI-04-VY 1-1409-000 Page 53 of 118

Power Ascension Testing for Extended Power Unrate Conditions NOTE: Dryer data collection readings (strain gauge and accelerometer data) are to be taken and evaluated every hour during power ascension (16 MWth change in reactor power) and within one hour of achieving the next power plateau per Attachment 1.

Reactor Power will need to be held constant, (within -19 MWth, +0 MWth) for approximately 2 minutes before and 15 minutes during the dryer data collection per Attachment 1.

7.3. Increasing to 1673 MWth Allowing no other concurrent intrusive activities, raise reactor power by 40 MWth to 1673 MWth (1654 MWth to 1673 MWth) accordance/ with OP-0105, Reactor Operations, as follows: 7.3.1. While raising reactor power: 7.3.1.1. Perform dryer data collection after the first 16 MWth change in reactor power per Attachment IE at 1649 MWth (1630 MWth to 1649 MWth).

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Initial Date Time 7.3.1.2. Perform dryer data collection after the second 16 MWth change in reactor power per Attachment 1F at 1665 MWth (1646 MWth to 1665 MWth).

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Initial Date Time 7.3.1.3. Perform dryer data collection per Attachment IG after achieving 1673 MWth (1654 MWth to 1673 MWth).

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Initial Date Time ERSTI-04-VY1- 1409-000 Page 54 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.3.1.4. Notify the test team to complete report preparation that evaluates dryer data (strain, gauge results, evaluations, acceptance criteria, etc,) and makes a recommendation to OSRC to continue power ascension. OSRC Review Meeting #: / / Initial Date Time 7.3.2. Perform flow induced vibration measurement per Attachment 2C. (Non intrusive).

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Initial Date Time 7.3.3. Maintain reactor power 1654 MWth to 1673 MWth for a total of four hours. Initial Date Time 7.3.4. Once each 24 hours:, 7.3.4.1. Verify moisture carryover per Attachment 5B. (non intrusive)

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Initial Date Time 7.3.4.2. Verify moisture carryover. per Attachment 5C. (non intrusive)

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Initial Date Time 7.3.4.3. Verify moisture carryover per Attachment 5D. (non intrusive)

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Initial Date Time 7.3.4.4. Verify moisture carryover for per Attachment 5E. (non intrusive)

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 55 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.3.5. Once the dryer data has been evaluated and approved by OSRC and the General Manager, Plant. Operations, perform the following (non-intrusive): 7.3.5.1. For the transmission of small data files (i.e., < 5 MB), email directly to: Rick Ennis at rxe(Zinrc.gov Jim Shea at fis(nrc.gov. Jim Devincentis at idevinc(eentergy.com Enrico Betti at ebetti(entergv.com Tom Scarbrough at tgs@(nrc.gov John Wu at ciwr&,nrc.gov Kamal Manoly at kam H)nrc.gov

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Initial Date Time 7.3.5.2. For the transmission of large data files (i.e., 5 MB or larger), upload to web folder at www.ibackup.com Account name: envydryer Password: Later and email the following persons the files have been uploaded on ibackup.com: Rick Ennis at rxe(nrc.gov Jim Shea at iis(anrc.gov Jim Devincentis at idevincgentergy.com Enrico Betti at ebettigentergy.com Tom Scarbrough at tgs(w-,nrc.gov John Wu at ciwgnrc.gov Kamal Manoly at kamonrc.,gov

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 56 of 118

Power Ascension Testing for Extended Power Uprate Conditions 0 7.3.5.3. Confirm receipt via telephone to NRC Project Manager Rick Ennis (or acting NRC Project Manager) at one of the following numbers (start at top and proceed down list until a single contact is made. If Rick Ennis (or acting NRC PM) Icannot immediately confirm receipt, ask for call back. Date stamp or other positive acknowledgment of NRC receipt. Initial Date Time Contact Order I. 301-415-1420 (RickEnnis office)

2. 301-972-8225 (Rick Ennis home)

3. 301-814-5965 (Rick Ennis cellular phone)

4. 301-415-1388 (Jim Shea offile)

5. 609-220-0306 (Jim Shea celhglar phone).

6. 301-415-0560 (Darrell Robertds office)

7. 301-385-3326 (Darrell Roberts cellular phone)

8. 301-415-1430 (NRC secretary-request contact with Ennis or Shea)

9. 301-415-0550 (NRC Operations Center-request contact Ennis or Shea)

10. 301-816-5100 (NRC Operations Center-request contact Ennis or Shea) 7.3.5.4. Once confirmation has been received, record below the start and end time of the 96 hour clock.

Start of 96 hour clock: Date / Time

Initial Date Time End of 96 hour clock: Date /Time

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 57 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.3.6. Cognizant Engineers to perform walkdowns per Engineering Monitoring Plans, including inspections where practicable based on ALARA and safety reasons, a review of ERFIS indications, local indications, control room indications, etc., for systems (components) affected by EPU. An evaluation needs to be. completed, for ANY discrepancy noted.' Include this documentation within Attachment 9 to this procedure as discussed in Section 9. (non intrusive) System Engineering Mechanical / Initial. Date Time System Engineering Electrical / / Initial Date Time Programs and Component Engineering Plant Programs / / Initial Date Time 7.3.7. Perform feedwater runout data per Attachment 6A and complete the analysis. (non intrusive) S/ / Initial Date Time 7.3.8. Perform radiation surveys per Attachment 3. (non intrusive)

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 58 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.3.9. Contact Chemistry ,to perform the following and include data within Attachment IOA-IOD, as appropriate, to this procedure as discussed in Section 9.0. (non intrusive): 7.3.9.1. Monitor and record site boundary dose rates in accordance with Attachment 10. Initial Date Time 7.3.9.2. Perform Reactor Coolant Iodine Activity in accordance with OP 0631, Radiochemistry. Initial Date Time 7.3.9.3. Perform Reactor Coolant Chloride and Conductivity Analysis in accordance with OP 4612, Sampling and Treatment of the Reactor Water System. Initial Date Time 7.3.9.4. Perform Reactor Coolant Filterable Solids Analysis per DP 0643, Filterable. Solids, Section C.

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Initial Date Time 7.3.9.5. Perform Reactor Coolant Isotopic (8 hour decay) in accordance with* OP 0631, Radiochemistry, Appendix B.

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Initial Date Time 7.3.9.6. Perform Reactor Coolant 2 liter Metals Sample per DP 0636, Collection and Digestion of Metal Samples.

                                                                    /       /1 Initial   Date   Time ERSTI-04-VY I - 1409-000 Page 59 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.3.9.7. Perform Feedwater Chemistry Analysis (02 and conductivity) in accordance with OP 4612, Sampling and. Treatment of the Reactor Water System. Initial Date Time 7.3.9.8. Verify the Main Steam Line Radiation Monitor response is within the expected dose range per OP 4617 Calculation of Chemistry Controlling Setpoints or new Setpoint Change has been implemented.

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 60 of 118

Power Ascension Testing for Extended Power Uprate Conditions D Note: VY is one of several GE-designed BWRs which experience recirc bi-stable flow patterns on a periodic basis. With no change in pump speed, these fluctuations can produce step-changes in drive flow, typically ranging from 0.1 mlbs/hr to 0.35 mlbs/hr. Corresponding changes will also occur in jetpump flow, core flow, core power and electrical output, ranging from 0.1% (with short-lived flow changes) to 2% or more (with longer-lived flow changes and/or at core flows greater than 100%). These fluctuations have been observed at VY and at other' facilities with a duration lasting a few seconds to about 1 minute, and at frequencies typically ranging from one to ten occurrences per hour, although up to 200 occurrences per hour have been observed. The magnitude, duration, and frequency of each flow pattern is random and is sensitive to small changes in influencing parameters such as recirc flow rate or pump speed. GE has performed plar~t-specific safety analyses and has concluded that the occurrence of recirc bi-stabl'b flow is neither a safety concern nor an operability issue. 7.3.10. Operations to observe control room indications including ERFIS for bi-stable flow for several minutes. If bi-stable flow is observed, submit a condition report. (non intrusive) Observed / not observed

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Initial Date Time 7.3.11. Run 3-D Monicore Official Case. Perform Core Thermal Limits Verification in accordance with OP 4401. Attach per Section 9.0. (non intrusive)

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 61 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.3.12. Request RE to: 7.3.12.1. Verify current reactor conditions are within acceptable values of the power-flow map (COLR figure 2.4-1). (non intrusive)

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Initial Date Time 7.3.12.2. Verify all inputs to the heat balance are acceptable by reviewing ERFIS display HBI (Heat Balance Inputs). Attach HBI screen per Section 9.0. (non intrusive)

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Initial Date Time 7.3.12.3. Verify the ERFIS heat balance (C047) is +/- 3% to other alternate power indications by reviewing the APD display. Attach EFRIS APD screen per Section 9.0. (non intrusive)

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Initial Date Time 7.3.12.4. Submit a 3-D Monicore case and review thermal limits at 1673 MWth. Record and compare them against the predicted values on Attachment

4. Attach the 3-D Monicore case per Section 9.0. Predict anticipated thermal limits for 1752 MWth and record on Attachment 4. (non intrusive)

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Initial Date Time ERSTI-04-VY 1-1409-000 Page 62 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.3.12.5. Verify that the Process Computer is using jet pump based core flow and not the core flow based* upon the drive flow-core flow relationship. (non intrusive)

//

Initial Date Time 7.3.12.6. After a minimum of 12 hours at this power plateau, save PCIOMR statepoint and compose the envelope per OP .2457, PCIOMR Implementation. (non intrusive)

//

Initial Date Time ERSTI-04-VY 1-1409-000 Page 63 of Il8

Power Ascension Testing for Extended Power Uprate Conditions 7.3.13. Allowing no other concurrent intrusive activities, perform feedwater level control testing per Attachment 7A. (intrusive) Initial Date Time 7.3.14. Allowing no other concurrent intrusive activities, perform MHC -demonstration per Attachment 8A. (intrusive)

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Initial Date Time 7.3.15. Perform Recombiner Performance Monitoring per Attachment 11A. .(non intrusive)

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Initial Date Time 7.3.16. Request Chemistry and AE to evaluate offgas levels for fuel integrity per ýP 7401 Fuel Reliability Program and NF 102, qorporate Fuel Reliability. Both parties to sign when complete. (non intrusive)

. /

Initial Date Time

/ /

Initial Date Time 7.3.17. Complete a report to be presented at OSRC used as a basis to recommend to the General Manager, Plant Operations, to continue the power ascension. (non intrusive) OSRC Reyiew Meeting #/ / Initial Date Time ERSTI-04-VY1 -1409-000 Page 64 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.3.18. Authorization for Power Ascension The results of testing and data collection performed at the last power level plateau have been analyzed and. presented to the General Manager, Plant Operations, and approval to proceed has been obtained. (Non intrusive)

                                                                       /   /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 65 ofl8

Power Ascension Testing for Extended Power Uprate Conditions O 7.3.19. After 96 hours from the time'NRC NRR received the dryer data and evaluation submittal and with no objections from NRC NRR, then call the NRC Project Manager Rick Ennis (or acting NRC Project Manager) at one of the following numbers (start at top and proceed.down list until a single contact is made) and inform the NRC that VY is continuing with the power ascension. (non intrusive) 7.3.19.1. If Rick Ennis (or acting NRC PM) cannot immediately confirm receipt, ask for call back. Date stamp or other positive acknowledgment of NRC receipt.,

                                              ,                        ~/      /

Initial Date Time Contact Order

1. 301-415-1420 (Rick Ennts office)

2. 301-972-8225 (Rick Ennis home)

3. 301-814-5965 (Rick Ennil cellular phone)

4. 301-415-1388 (Jim Shea office)

5. 609-220-0306 (Jim Shea cellular phone)

6. 301-415-0560 (Darrell Roberts office)

7. 301-385-3326 (Darrell Roberts cellular phone)

8. 301-415-1430 (NRC secretary-request contact with Ennis or Shea)

9. 301-415-0550 (NRC Operations Center-request contact Ennis or Shea)

10. 301-816-5100 (NRC Operations Center-request contact Ennis or Shea) 7.3.19.2. Email the following individuals to inform them VY is continuing with the power ascension. Attach email per step 9.

Rick Ennis at rxe@.nrc.g0V Jim Shea at jjs(nrc.gov Jim Devincentis at jdevinc(,entergy.com Enrico Betti at ebetti aientergy.com Tom Scarbrough at tgsanrc.g4ov John Wu at ciw wnrc.gov Kamal Manoly at karn a)nrc.gov

                                                                        /      /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 66 of 118

Power'Ascension Testing for Extended Power Uprate Conditions 7.3.19.3. Continue with the power ascension. iD / Initial Date Time Licensing: (Print/Sign) (Date) ERSTI-04-VY 1-1409-000 Page 67 of 118

Power Ascension Testing, for Extended Power Uprate Conditions NOTE: Dryer data collection readings (strain gauge and accelerometer data) are to be taken and evaluated every hour during power ascension (16 MWth change in reactor power) and within one hour.of achieving the next power plateau per Attachment 1. Reactor Power will need to be held constant, (within -19 MWth, +0 MWth) for approximately 2 minutes before and 15 minutes during the dryer data collection per Attachment 1. 7.4. Increasing to 1712 MWth Allowing' no other concurrent intrusive activities, raise reactor power by 40 MWth to 1712 MWth (1693 MWth to 1712 MWth) in accordance with OP 0105, Reactor Operations, as follows: 7.4.1. While raising reactor power: 7.4.1.1. Perform. dryer data collection after the first 16 MWth change in reactor power per Attachment 1H at 1689 MWth (1670 MWth to 1689 MWth).

Initial Date Time 7.4.1.2. Perform dryer data collection after the second 16 MWth change in reactor power per Attachment 11 at 1705 MWth (1686 MWth to 1705 MWth).

                                                                         /      /

Initial Date Time 7.4.1.3. Perform dryer data collection per Attachment 1J after achieving 1712 MWth (1693 MWth to 1712 MWth).

                                                                         /      /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 68 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.4.2. Maintain reactor power 1712 MWth (1693 MWth to

        .1712 MWth) for four hours while performing the following non intrusive activities:

7.4.2.1. Perform flow induced vibration measiýrement per. Attachment 2D. (non

                   ,intrusive)
                                                                          /       /

Initial Date Time 7.4.2.2. Request RE to: 7.4.2.2.1. Verify current reactor conditions are within acceptable values of the power-flow map (COLR fipure 2.4-1). (non intrusive)

                                                                          /       /

Initial .. Date Time 7.4.2.2.2. V~rify all inputs to the heat balance acceptable 'by reviewing ERFIS display HBI (Heat Balance Inputs). Attach HBI screen per Section 9.0. (non intrusive)

                                                                          /.      /

Initial Date Time 7.4.3. One hour after achieving 1712 MWth (1693 MWth to 1712 MWth), perform moisture carryover determination per Attachment 5F. (non intrusive)

                                                                          /    .  /

Initial Date Time ERSTI-04-VY 1- 1409-000 Page 69 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.4.4. Four hours after achieving 1712 MWth (1693 MWth to 1712 MWth), perform Extraction Steam Reverse Current (RC) Valve Test in accordance with OP 4160 Section B, Extraction Steam Reverse Current Valve Test using VYOPF 4160,07. Hold each RCV test switch for 30 seconds or until a closed (green light) indication is observed. Record whether the valve indicated intermediate or closed. Attach VYOPF 4160.07 per Section 9.0. (Intrusive)

                                                                    /      /

Initial Date Time 7.4.5.. Request Chemistry and RE to evaluate offgas levels for fuel integrity per PP 7401 Fuel Reliability Program and NF 102, Corporate Fuel Reliability. Both parties to sign when complete. (non intrusive) Initial Date Time Initial Date Time 7.4.6. Request Chemistry to verify the Main Steam Line Radiation Monitor response is within the expected dose range per OP 4617, Calculation of Chemistry Controlling Setpoints or new Setpoint Change has been implemented (non intrusive)

                                                                       /   /

Initial Date Time ERSTI-04-VY 1- 1409-000 Page 70 of 118.

NOTE: Dryer data collection readings (strain gauge and accelerometer data) are to be taken and evaluated every hour during power ascension (16 MWth change in reactor power) and within one hour of achieving the next pQwer plateau per Attachment 1. Reactor Power will need to be held constant, (within -19 MWth, +0 MWth) for approximately 2 minutes before and 15 minutes during the dryer data collection per Attachment 1. 7.5. Increasing to 1752 MWth Allowing no other concurrent intrusive activities, raise reactor power by 40 MWth to 1752 MWth (1733 MWth to 1752 MWth) per hour in accordance with OP-0105, Reactor Operations, as follows: 7.5.1. While raising reactor power: 7.5.1.1. Perform dryer data collection after the first 16 MWth change in reactor power per Attachment 1K at 1728 MWth (1709 MWth to 1728 MWth).

                                                                        /       /

Initial Date Time 7.5.1.2. Perform dryer data collection after the second 16 MWth change in reactor power per Attachment 1L at 1744 MWth (1725 MWth to 1744 MWth).

                                                                        /       /

Initial Date Time 7.5.1.3. Perform dryer data collection per Attachment IM after achieving 1752 MWth (1733 MWth to 1752 MWth).

                                                                            /   /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 71 of 118

Power Ascension Testing for Extended Power Uprate Conditions (') 7.5.1.4. Notify the test team to complete report prekaration that evaluates dryer data (strain gauge results, evaluations, acceptance criteria, etc,) and makes a recommendation to OSRC to continue power ascension. OSRC Review Meeting #: / Initial Date Time 7.5.2. Perform flow induced vibration measurement per Attachment 2E. (Non intrusive). / / Initial Date Time 7.5.3. Maintain reactor power after achieving 1751 MWth (1733 MWth to 1752 MWth) for a total of four hours.

                                                                 /      /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 72 of 118

Power Ascension Testing for Extended Power Uprate Conditions 0 7.5.4. Once each 24 hours: 7.5.4.1. Verify moisture carryover per Attachment 5G. (non intrusive) i D / Initial Date Time 7.5.4.2. Verify moisture carryover per

                 'Attachment 5H. (non intrusive)
                                                               /D Initial    Date   Time 7.5.4.3. Verify moisture carryover per Attachment 51. (non intrusive)
                                                               /      /

Initial Date Time 7.5.4.4. Verifyrmoisture, carryover for per Attachment 5J. (non intrusive)

                                                               /      /

Initial Date Time

ERSTI-04-VY 1-1409-000 Page 73 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.5.5. Once the dryer data has been evaluated and approved by OSRC and the General Manager, Plant Operations, perform the following (non-intrusive): 7.5.5.1. For the transmission of small data files (i.e.,< 5 MB), email directly to: Rick Ennis at rxetnrc..*ov Jim Shea at jjsgnrc.gov Jim Devincentis at jdevinc(aentergy.com Enrico Betti at ebetti(ciyentergy.com Tom Scarbrough at tgs*cnrc.gov John Wu at ciw(w-,nrc.gov Kamal Manoly at kam(Wnrc.oov Initial Date Time, 7.5.5.2. For the transmission of large data files (i.e., 5 MB or larger), upload to web folder at www.ibackup.comn Account name: envydryer Password: Later and email the following persons the files have been uploaded on ibackup.com: Rick Ennis at rxe(nrc.gov Jim Shea at jjs(T,)nrc.gov. Jim Devincentis at jdevinc(Zientergy.com Enrico Betti at ebetti(Lentergy.corn Tom Scarbrough at tgs@nrc..zov John Wu at ciw~ nrc.gov Kamal Manoly at kamninrc.gov Initial Date Time ERSTI-04-VY I -1409-000 Page 74 of 118

    *Power Ascension Testing for Extended Power Uprate Conditions
            -7.5.5.3. Confirm receipt via telephone to NRC Project Manager Rick Ennis (or acting NRC Project Manager) at one of the following numbers (start at top and proceed down list until a single contact is made. If Rick Ennis (or acting NRC PM) cannot immediately. confirm receipt, ask for call back. Date stamp or other positive acknowledgment of NRC receipt.
                                                                          /      /

Initial Date Time "Contact Order I. 301-415-1420 (Rick Ennis office)

2. 301-972-8225 (Rick Ennis home)

3. 301-814-5965 (Rick Ennis cellular phone)

4. 301-415-1388 (Jim Shea office)

5. 609-220-0306 (Jim Shea cellular phone)

6. 301-415-0560 (Darrell Roberts office)

7. 301-385-3326 (Darrell Roberts cellular phone)

8. 301-415-1430 (NRC secretary-request contact with Ennis or Shea)

9. 301-415-0550 (NRC Operations Center-request contact Ennis or Shea)

10. 301-816-5100 (NRC Operations Center-request contact Ennis or Shea) 7.5.5.4. Once confirmation has been received, record below the start and end time of the 96 hour clock.

Start of 96 hour clock: Date/ Time

                                                                          /*     /

Initial Date Time End of 96 hour clock: Date Time

                                                                          /      /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 75 of I18

Power Ascension Testing for Extended Power Uprate Conditions 0 7.5.6. Cognizant Engineers to perform walkdowns per the Engineering Monitoring Plans, including inspections where practicable based on ALARA and safety reasons, a review of ERFIS indications, local indications, control room indications, etc., for systems (components) affected by EPU. An evaluation needs to be completed for ANY discrepancy noted. Include this 'documentation within Attachment 9 to this procedure as discussed in Section 9. (non intrusive) System Engineering Mechanical / / Initial Date Time System Engineering Electrical / / Initial Date Time Programs and Componerit Engineering Plant Programs / / Initial Date Time 7.5.7. Perfonn feedwater runout data per Attachment 6B and complete the analysis. (non intrusive)

                                                                     /      /

Initial Date Time 7.5.8. Perform radiation surveys per Attachment 3. (non intrusive)

                                                                     /      /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 76 of 118

Power Ascension Testing. for Extended Power Uprate Conditions 7.5.9. Contact Chemistry to perform the following and include data within Attachment IOA-I0D, as appropriate, to this procedure as discussed in Section 9.0. (non intrusive): 7.5.9.1. Monitor and record site boundary dose rates in accordance with Attachment 10.

                                              ~/                          /

Initial Date Time 7.5.9.2. Perform Reactor Coolant Iodine Activity in accordance with OP 0631, Radiochemistry.

                                                                  /       /

Initial Date Time 7.5.9.3. Perform Reactor Coolant Chloride and Conductivity Analysis in accordance with OP 4612, Sampling and Treatment of the Reactor Water System.

                                                                  /       /

Initial Date Time 7.5.9.4. Perform Reactor Coolant Filterable Solids Analysis per DP 0643, Filterable Solids, Section C.

                                                                  /1 Initial   Date    Time 7.5.9.5. Perform Reactor Coolant Isotopic (8 hour decay) in accordance with OP 0631, Radiochemistry, Appendix B.
                                                                  /       I Initial   Date    Time 7.5.9.6. Perform Reactor Coolant 2 liter Metals Sample per DP 0636, Collection and Digestion of Metal Samples.
                                                                  //

Initial Date Time ERSTI-04-VY 1-1409-000 Page 77of118

Power Ascension Testing for Extended'Power Uprate Conditions 7.5.9.7. Perform Feedwater Chemistry Analysis (02 and conductivity) in accordance with OP 4612, Sampling and'Treatment of the Reactor Water System.

Initial Date Time 7.5.9.8. Verify the Main Steam Line Radiation Monitor response is within the expected dose range per OP 4617 Calculation of Chemistry Controlling Setpoints or new Setpoint Change has been implemented.

                                                                    / /.

Initial Date Time ERSTI-04-VY 1-1409-000 Page 78 of 118

Power Ascension Testing for Extended Power Uprate Conditions Note: VY is one of several GE-designed BWRs which experience recirc bi-stable flow patterns on a periodic basis. With no change in pump speed, these fluctuations can produce step-changes in drive .flow, typically ranging from 0.1 mlbs/hr to 0.35 mlbs/hr. Corresponding changes will also occur in jet pump flow, core flow, core power and electrical output, ranging from 0.1% (with short-lived flow changes) to 2% or more (with longer-lived flow changes and/or at core flows greater than 100%). These fluctuations have been observed at VY and at other facilities with a duration lasting a few seconds to about '1 minute, and at frequencies typically ranging from one to ten occurrences per hour, althotigh up to 200 occurrences per hour have been observed. The magnitude, duration, and frequency of each flow pattern is random and is sensitive to small changes in influencing parameters such as recirc flow rate or pump speed. GE has performed plarqt-specific safety analyses and has concluded that the occurrence of recirc bi-stabl flow is neither a safety concern nor an operability issue. 7.5.10. Operations observe control room indications including ERFIS for bi-stable flow for several minutes. If bi-stable flow is observed, submit a condition report. (non intrusive) Observed / not observed

                                                                             / . /

Initial Date Time 7.5.11. Run 3-D Monicore Official Case. Perform Core Thermnal Limits Verification in accordance with OP 4401. Attach per Section 9.0. (non intrusive)

                                                                         /       /

Initial Date Time ERSTI-04-VY 1-.1409-000 Page 79 of 118

Power Ascension Testing for Extended Power:Uprate Conditions 7.5.12. Request RE to: 7.5.12.1. Verify current reactor conditions are within acceptable values of the power-flow map (COLR figure 2.4-1). (non intrusive)

                                                                         /   /

Initial Date Time 7.5.12.2. Verify all inputs to the heat balance are acceptable by reviewing ERFIS display HBI (Heat Balance Inputs). Attach HBI screen per Section 9.0. (non intrusive)

                                                                         /   /

Initial Date Time 7.5.12.3. Verify the ERFIS heat balance (C047) is +/- 3% to other alternate power indications by reviewing the APD display. Attach EFRIS APD screen per Section 9.0. (non intrusive)

                                                                         /   /

Initial Date Time 7.5.12.4. Submit a 3-D Monicore case and review thermal limits at 1752 MWth. Record and compare them against the predicted values on Attachment

4. Attach the 3-D Monicore case per Section 9.0. Predict anticipated thermal limits for 1832 MWth and record on Attachment 4. (non intrusive)

/.

Initial Date Time ERSTI-04-VY 1-1409-000 Page 80 of 118

Power Ascension, Testing for Extended Power Uprate Conditions 7.5.12.5. Verify that the Process Computer is using jet pump based core flow and not the core flow based upon the drive flow-core flow relationship. (non intrusive)

                                                                   /       /

Initial Date Time 7.5.12.6. After a minimum of 12 hours at this power plateau, save PCIOMR statepoint and compose the envelope per OP 2457, PCIOMR Implementation. (non intrusive)

                                                                   /      /

Initial Date Time 7.5.13. Allowing no other concurrent intrusive activities, perform feedwater level control testing per Attachment 7B. (intrusive)

                                                                   /       /

Initial Date Time 7.5.14. Allowing no other concurrent intrusive activities, perform MHC demonstration per Attachment 8B. (intrusive)

                                                                   /       /

Initial Date Time ERSTI-04-VY I - 1409-000 Page 81 of118

Power Ascension Testing for Extended Power Uprate Conditions 7.5.15. Perform Recoinbiner Performance Monitoring per Attachment 11 B. (non intrusive) Initial Date Time 7.5.16. Request Chemistry and RE to evaluate offgas levels for fuel integrity per PP 7401 Fuel Reliability Program and NF 102, Corporate Fuel Reliability. Both parties to sign when complete. (non intrusive)

                                                                    /      /

Initial Date Time

                                                                    /      /

Initial Date Time 7.5.17. Complete a report to be presented at OSRC used as a basis to recommend to the General Manager, Plant Operations, to continue the power ascension. (non intrusive) OSRC Review Meeting #:_ / / Initial Date Time 7,5.18. Authorization for Power Ascension The results of testing and data collection performed at the last power level plateau have been analyzed and presented to the General Manager, Plant Operations, and approval to proceed has been obtained. (Non intrusive)

                                                                    /       /

Initial Date Time ERSTI-04-VY I - 1409-000 Page 82 of 118

Power Ascension Testing for Extended Power Uprate Conditions ) 7.5.19. After 96 hours from the time NRC NRR received the dryer data and evaluation submittal and with no objections from NRC NRR, then call the NRC Project Manager Rick Ennis (or acting NRC Project Manager) at one of the following numbers (start at top and proceed down list until a single contact is made) and inform the NRC that VY is continmiing with the power ascension. (non intrusive) 7.5.19.1. If Rick Ennis (or acting NRC PM) cannot immediately confirm receipt, ask for call back. Date stamp or other positive acknowledgment of NRC receipt. Initial Date Time Contact Order

1. 301-415-1420 (Rick Ennis office)

2. 301-972-8225 (Rick Enni. home)

3. 301-814-5965 (Rick Ennis cellular phone)

4. 301-415-1.,388 (Jim Shea office)

5. 609-220-0306 (Jim Shea cellular phone)

6. 301-415-0560 (Darrell Roberts office)

7. 301-38573326 (Darrell Roberts cellular phone)

8. 301-415-1430 (NRC secretary-request contact with Ennis or Shea)

9. 301-415-0550 (NRC Operations Center-request contact Ennis or Shea)

10. 301-816-5100 (NRC Operations Center-request contact Ennis or Shea) 7.5.19.2. Email the following individuals to inform them VY is continuing with the power ascension. Attach email per step 9.

Rick Ennis at rxe(Thnrc.pgov Jim Shea at Jjs(Znrc.gov Jim Devincentis at idevinc(Thentergy.com Enrico Betti at ebetti(aentergy.com Torn Scarbrough at t.gs.(Tnrc.gov John Wu at ciw(-nrc.,ov Kamal Manoly at kam(rnrc.gov

                                                                       /      /I Initial   Date  Time ERSTI-04-VY 1-1409-000 Page 83 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.5.19.3. Continue with the power ascension.

                                                                   /       /

Initial Date Time Licensing: / ~ (Pnint/Sign) (Date) ERSTI-04-VY 1-1409-000 Page 84 of 118

Power Ascension Testing for Extended Power Uprate Conditions c NOTE: Dryer data collection readings (strain gaiige and accelerometer data) are to be taken and evaluated every hour during powerI ascension (16 MWth change in reactor power) and within one hour of achieving the next power plateau per Attachment.1.

Reactor Power will need to be held constant, (within -19 MWth, +0 MWth) for approximately 2 minutes before and 15 minutes during the dryer data collection per Attachment 1.

7.6. Increasing to 1792 MWth Allowing no other concurreni intrusive activities, raise reactor power by 40 MWth to41792 MWth (1773 MWth to 1792 MWth) in accordancý with OP 0105, Reactor Operations, as follows: 7.6.1. While raising reactor power: 7.6.1.1. Perform dryer data collection after the first 16 MWth change in reactor power per Attachment IN at 1768 MWth (1749 MWth to 1768 MWth).

                                                                             /   /

Initial Date Time 7.6.1.2. Perform dryer data collection after the second 16 MWth change in reactor power per Attachment 10 at 1784 MWth (1765 MWth to 1784 MWth).

                                                                             /   /

Initial Date Time 7.6.1.3. Perform dryer data collection per Attachment 1P after achieving 1792 MWth (1773 MWth to 1792 MWth). Initial Date Time ERSTI-04-VY 1- 1409-000 Page 85 of118

Power Ascension Testing for Extended Power Uprate Conditions 7.6.2. Maintain reactor power 1792 MWth (1773 MWth to 1792 MWth) for four hours while performing the following non intrusive activities: 7.6.2.1. Perform flow induced vibration measurement per Attachment 2F. (non intrusive)

                                                                          /   /I Initial  Date    Time 7.6.2.2. Request RE to 7.6.2.2.1. Verify       current     reactor conditions       are. within acceptable values of the power-flow map (COLR figure 2.4-1). (non intrusive)

Initial Date Time 7.6.2.2.2. Verify all inputs to the heat balance acceptable by reviewing ERFIS display HBI (Heat Balance Inputs). Attach HBI screen per Section 9.0. (non intrusive)

                                                                          /   /

Initial Date Time 7.6.3. One hour after achieving 1792 MWth (1773 MWth to 1792 MWth), perform moisture carryover determination per Attachment 5K. (non intrusive)

                                                                          /   /

Initial Date Time ERSTI-04-VY 1-1409-000 Page.86 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.6.4. Four hours after achieving 1792 MWth (1773 MWth to 1792 MWth), perform Extraction Steam Reverse Current (RC) Valve Test in accordance with OP 4160 Section B, Extraction Steam Reverse Current Valve Test using VYOPF 4160.07. Hold each RCV test switch for 30 seconds, or until a closed (green light) indication is observed. Record whether the valve indicated intermediate or closed. Attach VYOPF 4160.07 per Section 9.0. (Intrusive)

                                                                   /       /

Initial Date Time 7.6.5. Request Chemistry and RE to evaluate offgas levels for fuel integrity per PP 7401 Fuel Reliability Program and NF 102, Corporate Fuel Reliability. Both parties to sign when complete. (non intrusive)

                                                                   /       /

Initial Date Time

                                                                   /       /

Initial Date Time 7.6.6. Request Chemistry to verify the Main Steam Line Radiation Monitor response is within the expected dose range per OP 4617, Calculation of Chemistry Controlling Setpoints or new Setpoint Change has been implemented (non intrusive)

                                                                   /       /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 87 of 118

Power Ascension Testing for Extended' ower Uprate Conditions

NOTE:

Dryer data collection readings (strain gauge and accelerometer data) are to be taken and evaluated every hour during power ascension (16 MWth change in reactor power) and within one' hour of achieving the next power plateau per Attachment 1. Reactor Power will need to be held constant, (within -19 MWth, +0 MWth) for approximately 2 minutes before and 15 minutes during the dryer data collection per Attachment 1. 7.7. Increasing to 1832 MWth Allowing no other concurrent intrusive activities, raise reactor power by 40 MWth to 1832 MWth (1813 MWth to 1832 MWth) in accordance with OP-0105, Reactor Operations, as follows: 7.7.1. While raising reactor power: 7.7.1.1. Perform dryer data collection after the first 16 MWth change in reactor power per Attachment IQ at 1808 MWth (1789 MWth to 1808 MWth).

                                                                        /       /

Initial Date Time 7.7.1.2. Perform: dryer data collection after the second 16 MWth change in reactor power per Attachment 1R at 1824 MWth (1805 MWth to 1824 MWth).

                                                                            /   /

Initial Date Time 7.7.1.3. Perform dryer data collection per Attachment 1S after achieving 1832 MWth (1813 MWth to 1832 MWth).

                                                                        /       /

Initial Date Time ERSTI-04-V\Y I-1409-000 Page 88 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.7.1.4. Notify the test team to complete r'eport preparation that evaluates dryer data (strain gauge results, evaluations, acceptance criteria, etc;) and* makes a recommendation to OSRC to continue power ascension. OSRC Review Meeting #: _ / / Initial Date Time 7.7.2. Perform flow induced vibration measurement per Attachment 2G. (Non intrusive).

                                                                   /      /

Initial Date Time 7.7.3. Maintain reactor power 1832 MWth (1813 MWth to 1832 MWth) for a total oI four hours.

                                                                   /      /

Initial Date Time 7.7.4. Once each 24 hours: 7.7.4.1. Verify moisture carryover per Attachment 5L. (non intrusive)

                                                                   /      /

Initial Date Time 7.7.4.2. Verify moisture carryover per Attachment 5M. (non intrusive)

                                                                   /      /

Initial Date Time 7.7.4.3. Verify moisture carryover per Attachment 5N. (non intrusive)

                                                                   /      /

Initial Date Time 7.7.4.4. Verify moisture carryover for per Attachment 50. (non intrusive)

                                                                   /      /

Initial Date Time ERSTI-04-VY 1- 1409-000 Page 89 of 118

Power Ascension Testingfor Extended Power Uprate Conditions 7.7.5. Once the dryer data has been evaluated and approved by OSRC and the General Manager, Plant Operations, perform the following (non-intrusive): 7.7.5.1. For the transmission of small data files (i.e., < 5 MB), email directly to: Rick Ennis at rxe Wnrc.gov. Jim Shea at ijs(2cnrc.gov Jim Devincentis at jdevincC(Zentergy.com Enrico Betti at ebetti(Rentergv.com Tom Scarbrough at tgs&nrc.gov John Wu at ciw((nrc.gov Kamal Manoly at kam ainrc.gov

                                                                    /      /

Initial Date Time 7.7.5.2. For the transmission of large data files (i.e., 5 MB or larger), upload to web folder at www.ibackup.com Account name: envydryer Password: Later and email the following persons the files have been uploaded on ibackup.com: Rick Ennis at rxe(Onrc.gov Jim Shea at jjs(anrc.gov Jim Devincentis at jdevinc Lcyentergy.com Enrico Betti at ebetti(ZlDentergy.com Tom Scarbrough at tgsgnrc.gov John Wu at Ciw(nrc.gov Kamal Manoly at kam@nrc.0ov Initial Date Time ERSTI-04-VY 1-1409-000 Page 90 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.7.5.3. Confirm receipt via telephone to NRC Project Manager Rick Ennis, (or acting NRC Project Manager) at one of the following numbers (start at top and proceed down list until a single contact is made. If Rick Ennis (or acting NRC PM) cannot immediately confirm receipt, ask for call back. Date stamp or other positive acknowledgment of NRC receipt.

Initial. Date Time Contact Order '-1. 301-415-1420 (Rick Ennis office)

2. 301-972-8225. (Rick Ennis home)

3. 301-814-5965 (Rick Ennis cellular phone)

4. 301-415-1388 (Jim Shea office)

5. 609-220-0306 (Jim Shea cellular phone)

6. 301-415-0560 (Darrell Roberts office)

7. 301-385-3326 (Darrell Roberts cellular phone)

8. 30.1-415-1430 (NRC secretary-request contact with Ennis or Shea)

9. 301-415-0550 (NRC Operations Center-request contact Ennis or Shea)

10. 301-816-5100 (NRC Operations Center-request contact Ennis or Shea) 7.7.5.4. Once confirmation has been received, record below the start and end time of the 96 hour clock.

Start of 96 hour clock: Date /Time Initial Date Time End of 96 hour clock: Date /Time Initial Date Time ERSTI-04-VY 1-1409-000 Page 91 of 118

Power Ascension Testing for Extended Power Uprate Conditions C 7.7.6. Cognizant Engineers to perform walkdowns per the Engineering Monitoring Plans, including inspections where practicable based on ALARA and safety reasons, a review of ERFIS indications, local indications, control room indications, etc., for systems (components) affected by EPU. An evaluation needs' to be completed for ANY discrepancy noted. Include *this documentation within Attachment 9 to this procedure as discussed in Section 9. (non intrusive) System Engineering Mechanical / Initial Date Time System Engineering Electrical / Initial Date Time Programs and ComponentýEngineering Plant Programs/' / Initial Date Time 7.7.7. Perform feedwater runout data per Attachment 6C and complete the analysis. (non intrusive)

                                                                    /*     /

Initial Date Time 7.7.8. Perform radiation surveys per Attachment 3. (non intrusive)

                                                                    /      /

Initial Date Time ERSTI-04-VYI -1409-000 Page 92 of 118

Power Ascension Testing for Extended Power.Uprate Conditions 7.7.9. Contact Chemistry to perform the following and include data within Attachment I1A-10D, as appropriate, to this procedure as discussed in Section 9.0. (non intrusive): 7.7.9.1. Monitor and record site boundary dose rates in accordance with Attachment 10.

//

Initial Date Time 7.7.9.2. Perform Reactor Coolant Iodine Activity in accordance with OP 0631, Radiochemistry.

                                                                      /  /

Initial Date Time 7.7.9.3. Perform Reactor Coolant Chloride and Conductivity Analysis in , accordance with OP 4612, Sampling and Treatment of the Reactor Water System. Initial Date Time 7.7.9.4. Perform Reactor Coolant Filterable Solids Analysis per DP 0643, Filterable Solids, Section C.

                                              ~/                         /

Initial Date Time 7.7.9.5. Perform Reactor Coolant Isotopic (8 hour decay) in accordance with OP 0631, Radiochemistry, Appendix B.

                                                                  /      /

Initial Date Time 7.7.9.6. Perform Reactor Coolant 2 liter Metals Sample per DP 0636, Collection and Digestion of Metal Samples.

                                                                  /       /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 93 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.7.9.7. Perform Feedwater Chemistry Analysis (02 and conductivity) in accordance with OP 4612, Sampling and Treatment of the Reactor Water System.

Initial. Date Time 7.7.9.8. Verify the Main Steam Line Radiation Monitor response is within the expected dose range per OP 4617 Calculation of Chemistry Controlling Setpoints or new Setpoint Change has been implemented.

                                                  */                    /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 94 of 118

Power Ascension Testing for Extended Power Uprate Conditions © Note: VY is one of several GE-designed BWRs which experience recirc bi-stable flow patterns on a periodic basis. With no change in pump speed, these fluctuations can produce step-changes in drive flow, typically ranging from 0.1 mlbs/hr to 0.35 mlbs/hr. Corresponding changes will also occur in jet pump flow, core flow, core power and electrical output, ranging from 0.1% (with short-lived flow changes) to 2% or more (with longer-lived flow changes and/or at dore flows greater than 100%). These fluctuations have been observed at VY and at othet facilities with a duration lasting a few seconds to about' 1 minute, and at frequencies typically ranging from one to ten occurrences per hour, although up to 200 occurrences per hour have been observed. The magnitude, duration, qnd frequency of each flow pattern is random and is sensitive to small changes in infuencing parameters such as recirc flow rate or pump speed. GE has performed plant-specific safety analyses and has concluded that the occurrence of recirc bi-stabie flow is neither a safety concern nor an operability issue. 7.7.10. Operations observe control room indications including ERFIS for bi-stable flow for several minutes. If bi-stable flow is observed, submit a condition report. (non intrusive) Observed / not observed

                                                                         /      /

Initial Date Time 7.7.11. Run 3-D Monicore Official Case. Perform Core Thermal Limits Verification in accordance with OP 4401. Attach per Section 9.0. (non intrusive)

                                                                         /      /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 95 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.7.12. Request RE to: 7.7.12.1. Verify current reactor conditions are within acceptable values of the power-flow map (COLR figure 2.4-1). (non intrusive)

                                                                     /       /

Initial Date Time 7.7.12.2. Verify all inputs to the heat balance

                     -are acceptable by reviewing ERFIS display HBI (Heat Balance Inputs).

Attach HBI screen per Section 9.0. (non intrusive)

                                                                     /       /

Initial Date Time 7.7.12.3. Verify the ERFIS heat balance (C047) is +/- 3% to other alternate power indications by reviewing the APD display. Attach EFRIS APD screen per Section 9.0. (non intrusive)

                                                                     /       /

Initial Date Time 7.7.12.4. Submit a 3-D Monicore case and review thermal limits at 1832 MWth. Record and compare them against the predicted values on Attachment

4. Attach the 3-D Monicore case per Section 9.0. Predict anticipated thermal limits for 1912 MWth and record on Attachment 4. (non intrusive)

                                                                     /      "/

Initial Date Time ERSTI-04-VY 1 - 1409-000 Page 96 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.7.12.5. Verify that the Process Computer is using jet pump based core flow and not the core flow based upon the drive flow-core flow relationship. (non ifitrusive)

                                                               /      /

Initial Date Time 7.7.12.6. After a minimum of 12 hours at this power plateau, save PCIOMR statepoint and compose the envelope per OP .2457, PCIOMR Implementation. (non intrusive)

                                                                   /  /

Initial Date Time ERSTI-04-VY I-1409-000 Page 97 of 118

Power Ascension Testing for Extended 'Pbwer Uprate Conditions 7.7.13. Allowing no other concurrent intrusive activities, perform feedwater ievel control testing per Attachment 7C. (intrusive) S/ / Initial Date Time 7.7.14. Allowing no other concurrent intrusive activities, perform MHC demonstration per Attachment 8C. (intrusive)

                                                                    /      /

Initial Date Time 7.7.15. Perform Recombiner Performance Monitoring per Attachment 11 C. (non intrusive)

                                         ,/~                               /

Initial Date Time 7.7.16. Request Chemistry and tkE to evaluate offgas levels for fuel integrity per ýP 7401 Fuel Reliability Program and NF 102, qorporate Fuel Reliability. Both parties to sign when complete. (non intrusive) iD / Initial Date Time

                                                                    /      /

Initial Date Time 7.7.17. Complete a report to be presented at OSRC used as a basis to recommend to the General Manager, Plant Operations, to continue the power ascension. (non intrusive) OSRC Review Meeting #: / / Initial Date Time ERSTI-04-VY I - 1409-000 Page 98 of 118

Power Ascension Testing for Extended Power Uprate Conditions (- 7.7.1 8. Authorization for Power Ascernsion The results of testing and data collection performed at the last power level plateau haye been analyzed and presented to the General Manager, Plant Operations, and approval, to proceed has been obtained. (Non intrusive) Initial Date Time ERSTI-04-VY 1 -1409-000 Page 99 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.7.19. After 96 hours from the time NRC NRR received the dryer data and. evaluation submittal and with no objections from NRC NRR, then call the NRC Project Manager Rick Ennis (or acting NRC.Project Manager) at one of the following numbers (start at top and proceed down list until a single contact is made) and inform the NRC that VY is continuing with the power ascension. (non intrusive) 7.7.19.1. If Rick Ennis (or acting NRC PM) cannot immediately confirm receipt, ask for call back. Date stamp or other positive acknowledgment of NRC receipt.

                                                                           /      /

Initial Date Time Contact Order

1. 301-415-1420 (Rick Ennis office)

2. 301-972-8225 (Rick Ennis home)

3. 301-814-5965 (Rick Ennis cellular phone)

4. 301-415-1388 (Jim Shea office)

5. 609-220-0306 (Jim Shea cellular phone)

6. 301-415-0560 (Darrell Roberts office)

7. 301-385-3326 (Darrell Roberts cellular phone)

8. 301-415-1430 (NRC secretary-request contact with Ennis or Shea)

9. 301-415-0550 (NRC Operations Center-request contact Ennis or Shea) 10.. 301-816-5100 (NRC Operations Center-request contact Ennis or Shea) 7.7.19.2. Email the following individuals to inform them VY is continuing with the power ascension. Attach email per step 9.

Rick Ennis at rxe(nrc.gov Jim Shea at iis(@inrc.gov Jim Devincentis at jdevincaentergy. corn Enrico Betti at ebettinmenter.gy.com Tom Scarbrough at tgs(nrc.gov John Wu at ciw((4nrc.gov Kamal Manoly at kamrnnrc.gov

Initial Date Time ERSTI-04-VYI -1409-000 Page 100 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.7.19.3. Continue with the power ascension. 0 Initial Date Time Licensing: (Print/Sign) ' (Date) ERSTI-04-VYI -1409-000 Page 101 of 118

Power Ascension Testing for Extended Power Uprate Conditions NOTE: Dryer data collection readings (strain gauge and accelerometer data) are to be taken and evaluated every hour during power ascension (16 MWth change in reactor power) and within one hour of achieving the next power plateau per Attachment 1.

Reactor Power will need to be held constant, (within -19 MWth, +/-0 MWth) for approximately 2 minutes before and 15 minutes during the dryer data collection per Attachment 1.

7.8. Increasing to 1872 MWth Allowing no other concurrent intrusive activities, raise reactor power by 40 MWth to 1872 MWth (1853 MWth to 1872 MV/th) in accordance with OP 0105, Reactor Operations, as follows: 7.8.1. While raising reactor power: 7.8.1.1. Perform dryer data collection after the first 16 MWth change in reactor power per Attachment IT at 1848 MWth (1829 MWth to 1848 MWth).

                                                                         /      /

Initial Date Time. 7.8.1.2. Perform dryer data collection after the second 16 MWth change in reactor power per Attachment 1U at 1864 MWth (1845 MWthto 1864 MWth).

                                                                         /      /

Initial Date Time 7.8.1.3. Perform dryer data collection per Attachment IV after achieving 1872 MWth (1853 MWth to 1872 MWth).

                                                                         /      /

Initial Date Time ERSTI-04-VY I - 1409-000 Page 102 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.8.2. Maintain reactor power 1872 MWth (1853 MWth to 1872 MWth) for four hours while performing the following non intrusive activities: 7.8.2.1. Perform flow induced vibration measurement per Attachment 2H. (non intrusive)

/ /

Initial Date Time ( 7.8.2.2. Request RE to 7.8.2.2.1. Verify current reactor conditions are within acceptable values of the power-flow map (COLR figure 2.4-1). (non intrusive)

                                                                         /     */

Initial Date Time 7.8.2.2.2. Verify all inputs to the heat balance acceptable by reviewing ERFIS display HBI (Heat Balance Inputs). Attach HBI screen per Section 9.0. (non intrusive)

                                                                         /        /

Initial Date Time 7.8.3. One hour after achieving 1872 MWth (1853 MWth to 1872 MWth), perform moisture carryover determination per Attachment 5P. (non intrusive) 1~ / Initial Date Time ERSTI-04-VY 1-1409-000 Page 103 of 118

Power Ascension Testing for Extended, Power Uprate Conditions 7.8.4. Four hours after achieving 1872 MWth (1853 MWth to 1872 MWth), perform Extraction Steam Reverse Current (RC) Valve Test in accordance with OP 4160 Section B, Extraction Steam Reverse Current Valve Test using VYOPF 4160.07. Hold each RCV test switch for 30 seconds or until a closed (green light) indication is observed. Record whether the valve indicated intermediate or closed. Attach VYOPF 4160.07 per Section 9.0. (Intrusive)

                                                                     /      /

Initial Date Time 7.8.5. Request Chemistry and RE to evaluate offgas levels for fuel integrity per PP 7401 Fuel Reliability Program and NF 102, -Corporate Fuel Reliability. Both parties to sign when complete. (non intrusive) Initial Date Time

                                                                     /      /

Initial Date Time 7.8.6. Request Chemistry to verify the Main Steam Line Radiation Monitor response is within the expected dose range per OP 4617, Calculation of Chemistry Controlling Setpoints or new Setpoint Change has been implemented (non intrusive) Initial Date Time ERSTI-04-VYI-1409-000 Page 104 of118

Power Ascension Testing for Extended Power Uprate Conditions 0 NOTE: Dryer data collection readings (strain gauge and accelerometer data) are to be taken and evaluated every hour durin~g power ascension (16 MWth change in reactor power) and within one hour of achieving the next power plateau per Attachment 1. Reactor Power will need to be held constant, (within -19 MWth, +0 MWth) for approximately 2 minutes before and 15 minutes during the dryer data collection per Attachment 1. 7.9. Increasing to 1912 MWth Allowing no other concurrent intrusive activities, raise reactorpower by 40 MWth to 1912 MWth (1893 MWth to 1912 MWth) in accordance with OP-0105, Reactor Operations, as follows: 7.9.1. While raising reactor power: 7.9.1.1. VPerform dryer data collection after the first 16 MWth change in reactor power per Attachment 1W at 1888 MWth (1869 MWth to 1888 MWth). Initial Date Time 7.9.1.2. Perform dryer data collection after the second 16 MWth change in reactor power per Attachment IX at 1904 MWth (1885 MWth to 1904 MWth).

                                                                            / I Initial   Date Time 7.9.1.3. Perform dryer data collection per Attachment lY after achieving 1912 MWth (1893 MWth to 1912 MWth).

I. / Initial Date Time ERSTI-04-VY 1-1409-000 Page 105 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.9.1.4. Notify the test team to complete report preparation that e'aluates dryer data (strain gauge results, evaluations, acceptance criteria, etc,) and, makes a recommendation to OSRC to continue power ascension. OSRC Review Meeting #: " / / Initial Date Time 7.9.2. Perform flow induced vibration measurement per Attachment 21. (Non intrusive).

                                                                   /      /

Initial Date Time 7.9.3. Maintain reactor power 1912 MWth (1893 MWth to 1912 MWth) for a total of four hours.

                                    ~/                                    /

Initial Date Time ERSTI-04-VY 1 -1409-000 Page 106 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.9.4. Once each 24 hours: 7.9.4.1. Verify moisture carryover per. Attachment 5Q. (non intrusive)

                                                             /         i Initial     Date   Time 7.9.4.2. Verify moisture carryover per' Attachment 5R. (non intrusive)
                                                                     /

Initial Date Time 7.9.4.3. Verify moisture carryover per Attachment 5S. (non intrusive)

                                                             /       /

Initial Date Time 7.9.4.4. Verify moisture carryover for per Attachment 5T. (non intrusive)

//

Initial Date Time ERSTI-04-VY 1-1409-000 Page 107 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.9.5. Cognizant Engineers to perforn walkdowns per the C Engineering Monitoring Plans, including inspections where practicable based on ALARA and safety reasons, a review of ERFIS indications, local indications, control room indications, etc., for systems (components) affected 'by EPU. An evaluation needs to be' completed for ANY discrepancy noted. Include this documentation within Attachment 9 to this procedure as discussed in Section 9. (non intrusive) System Engineering Mechanical / / Initial Date Time System Enigineering Electrical / / Initial Date Time Programs and Component Engineering Plant Programs / / Initial Date Time 7.9.6. Perform feedwater runoilt data per Attachment 6D and complete the analysis. (non intrusive)

                                                                      /      /

Initial Date Time 7.9.7. Perform radiation surveys per Attachment 3. (non intrusive) Initial Date Time ERSTI-04-VY 1-1409-000 Page 108 oflI8

Power Ascension Testing for Extended Power Uprate Conditions 7.9.8. Contact Chemistry to perform the following and include data within Attachment IGA-i GD, as appropriate, to this procedure as discussed in Section 9.0. (non intrusive): 7.9.8.1. Monitor and record site boundary dose rates in accordance with Attachment 10.

                                                                    /      .

Initial Date Time 7.9.8.2. Perform Reactor Coolant Iodine Activity in accordance with OP 0631, Radiochemistry.

                                            ~/                               /

Initial Date Time 7.9.8.3. Perform Reactor Coolant Chloride and Conductivity Analysis in accordance with OP 4612, Sampling and Treatment of the Reactor Water System.

                                                                    /   .    /

Initial Date Time 7.9.8.4. Perform Reactor Coolant Filterable Solids Analysis per DP 0643, Filterable Solids, Section C.

                                                                    /        /

Initial Date Time 7.9.8.5. Perform Reactor Coolant, Isotopic (8 hour decay) in accordance with OP 0631, Radiochemistry, Appendix B.

                                                                    / .      /

Initial Date Time 7.9.8.6. Perform Reactor Coolant 2 liter Metals Sample per DP 0636, Collection and Digestion of Metal Samples.

                                                                     /        I/

Initial Date Time ERSTI-04-VY!-1409-000 Page 1.09 of 118

Power Ascension Tes'ting for Extended Power Uprate Conditions 7.9.8.7. Perform Feedwater Chemistry Analysis (9 (02 hnd conductivity)- in accordance with OP 4612, Sampling and Treatment of the Reactor Water System.

                                                                 /       /

Initial Date Time 7.9.8.8. Verify the Main Steam Line Radiation Monitor response is within the expected dose range per OP 4617 Calculation of Chemistry Controlling Setpoints or new Setpoint Change has been implemented.

//

Initial Date Time ERSTI-04-VY 1- 1409-000 Page 110 of 118

Power Ascension Testing for Extended Power Uprate Conditions (I Note: VY is one of several GE-designed BWRs which experience recirc bi-stable flow patterns on a periodic basis. With no change in pump speed, these fluctuations can produce step-changes in drive flow, typically- ranging from 0.1 mlbs/hr to 0.35 mlbs/hr. Corresponding changes will also occur in jet pump flow, core flow, core power and electrical output, ranging from 0.1% (with short-lived flow changes) to 2% or more (with longer-lived flow changes and/or at core flows greater than 100%). These fluctuations have been observed at VY and at other facilities with a duration lasting a few seconds to about 1 minute, and at frequencies typically ranging from one to ten occurrences per hour, although up to 200 occurrences per hour have been observed. The magnitude, duration, and frequency of each flow pattern is random and is sensitive to small changes in influencing parameters such as recirc flow rate or pump speed. GE has performed plarnt-specific safety analyses and has concluded.. that the occurrence of recirc bi-stable1 flow is neither a safety concern nor an operability issue. 7.9.9. Operations observe control room indications including ERFIS for bi-stable flow for several minutes. If bi-stable flow is observed, submit a condition report. (non intrusive) Observed / not observed

                                                                         /      /

initial Date Time 7.9.10. Run 3-D Monicore Official Case. Perform Core Thermal Limits Verification in accordance with OP 4401. Attach per Section 9.0. (non intrusive)

                                                                         /      /

Initial Date Time ERSTI-04-VY1 -1409-000 Page lIlof 118

Power Ascension Testing for Extended Power Uprate Conditions 7.9.11. Request RE to: 7.9.11.1. Verify current reactor conditions are within acceptable values of the power-flow map (COLR figure 2.4-1). (non intrusive)

                                                                         /   /

Initial Date Time 7.9.11.2. Verify all inputs to the heat balance are acceptable by reviewing ERFIS display HBI (Heat Balance Inputs). Attach HBI screen per Section 9.0. (non intrusive)

                                                         */                  /

Initial Date Time 7.9.11.3. Verify the ERFIS heat balance (C047) is +/- 3% to other alternate power indications by reviewing the APD display. Attach EFRIS APD screen per Section 9.0. (non intrusive)

                                                                     /      ./

Initial Date Time 7.9.11.4. Submit a 3-D Monicore case and review thermal limits at 1912 MWth. Record and compare them against the predicted values on Attachment

4. Attach the 3-D Monicore case per Section 9.0. (non intrusive)

S / Initial Date Time ERSTI-04-VY 1-1409-000 Page 112 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7.9.11.5. Verify that the Process Computer is using jet pump based core flow and not the core flow based :upon the drive flow-core flow relationship. (non intrusive)

                                                                /       /

Initial Date. Time 7.9.11.6. After a minimum of 12 hours at this power plateau, save PCIOMR statepoint and compose the envelope per OP 2457, PCIOMR Implementation. (non intrusive)

                                                                /       /

Initial Date Time ERSTI-04-VY 1-1409-.000 Page 113 of 118

Power Ascension Tes~ing for Extended Power Uprate Conditions 7.9.12. Allowing no other concurrent intrusive activities, O perform feedwvater level control, testing per Attachment 7D. (intrusive) S / / Initial Date Time 7.9.13. Allowing no other concurrent intrusive activities, perform MHC demonstration per Attachment 8D. (intrusive)

                                                                         /  /

Initial Date Time 7.9.14. Perform Recombiner Performance Monitoring per Attachment I1D. (non intrusive) i / / Initial Date Time 7.9.15. Request Chemistry and RE to evaluate offgas levels for fuel integrity per Pl 7401 Fuel Reliability Program and NF 102, Corrporate Fuel Reliability. Both parties'to sign.when cbmplete. (non intrusive) In/ i Initial Date Time

                                                                             /
                                                                             /.

Initial Date Time 7.9.16. Complete a report to be presented at OSRC used as a basis to recommend to the General Manager, Plant Operations, to remain at 1912 MWth. (non intrusive) OSRC Review Meeting#: / Initial Date Time ERSTI-04-VY 1-1409-000 Page 114 of 118

Power Ascension Testing for Extended Power Uprate Conditions (I 7.10. Remaining at 1912 MWth 7.10.1. Authorization to remain at 1912 MWth. The results of testing and data collection performed at the last power level plateau have been analyzed and presented to the General Manager, Plant Operations, and approval to remain at 1912 MWth been obtained. (Non intrusive)

Initial Date Time GMP'O: __ _ _ GMPO: (Prinit/Sign) (Date) I 7.10.2. Prior to exceeding 168 hcaurs of plant operation at the nominal full EPU reactor power level, with feedwater and condensate\ flow rates stabilized at approximately the EPU full power level, confirm through performance 'of transient testing that the loss of one condensate pump will not result in a complete loss of reactor feedwater. (intrusive)

                                                                               /      /

Initial Date Time 7.10.3. Test Complete.

                                                                               /      /

Initial Date Time ERSTI-04-VY 1-1409-000 Page 115 of 118

I .. Power Ascension Testing for Extended Power Uprate Conditions

8. Restoration

8. 1. 'Perform an "End of Evolution" critique. Capture lessons learned Initial Date Time

9. Attachments Attachment Index Sheet Instructions:

This procedure requires that "data packages" and other performance monitoring data collection be attached to this procedure. Known attachments have been identified. For additional attachments, select the next sequential attachment nuiiiber and record the attachment number in this index, with the document title, number of pages and associated procedure step and on the attached document. Indicate the consecutive page number and total attachment pages at the bottom of each page. Verified By: Test Engineer/Date IA Dryer Data.Collection 1593 MWth 1B Dryer Data Collection 1609 MWth 1C Dryer Data Collection 1625 MWth ID -Dryer Data Collection 1633 MWth 1E Dryer Data Collection 1649 MWth 1F Dryer Data Collection 1665 MWth 1 Dryer Data Collection 1673 MWth 1H Dryer Data Collection 1689 MWth II Dryer. Data Collection 1705 MWth 1J Dryer Data Collection 1712 MWth 1K Dryer Data Collection 1728 MWth 1L Dryer Data Collection 1744 MWth IM Dryer Data Collection 1752 MWth IN Dryer Data Collection 1768 MWth 10 Dryer Data Collection 1784 MWth IP Dryer Data Collection 1792 MWth 1Q Dryer Data Collection 1808 MWth IR Dryer Data Collection 1824 MWth IS Dryer Data Collection 1832 MWth ERSTI-04-VY I -1409-000 Page 116 of 118

Power Ascension Testing for Extended Power Uprate Conditions I D T IT. Dryer Data Collection 1848 MWth IU Dryer Data Collection 1864 MWth IV Dryer Data Collection 1872 MWth 1W Dryer Data Collection 1888 MWth 1X Dryer Data Collection 1904 MWth 1Y Dryer Data Collection 1912 MWth 2A Flow Induced Vibration Data 1593 MWth 2B Flow Induced Vibration Data 1633 MWth 2C Flow Induced Vibration Data 1673 MWth 2D Flow Induced Vibration Data 1712 MWth 2E Flow Induced Vibration Data 1752 MWth 2F Flow Induced Vibration Data 1792 MWth 2G Flow Induced Vibration Data 1832 MWth ~2H Flow Induced Vibration Data 1872 MWth 21 Flow Induced Vibration Data 1912 MWth 3 Radiation Surveys 4 Core Performance Data Sheet various MWth 5A Moisture Carryover 1633 MWth 5B Moisture Carryover 1673 MWth 5C Moisture Carryover 1673 MWth 5D Moisture Carryover 1673, MWth 5E Moisture Carryover 1673 MWth 5F Moisture Carryover 1712 MWth 5G Moisture Carryover 1752 MWth 5H Moisture Carryover 1752 MWth 5I Moisture Carryover 1752 MWth 5J Moisture Carryover 1752 MWth 5K Moisture Carryover 1792 MWth 5L Moisture Carryover 1832 MWth 5M Moisture Carryover 1832 MWth 5N Moisture Carryover 1832 MWth 50 Moisture Carryover 1832 MWth 5P Moisture Carryover 1872 MWth 5Q Moisture Carryover 1912 MWth 5R Moisture Carryover 1912 MWth 5S Moisture Carryover 1912 MWth 5T Moisture Carryover 1912 MWth 6A Feedwater Runout Data Collection 1673 MWth 6B Feedwater Runout Data Collection 1752 MWth 6C Feedwater Runout Data Collection 1832 MWth 6D Feedwater Runout Data Collection 1912 MWth 7A. Feedwater Level Changes. 1673 MWth 7B Feedwater Level Changes 1752 MWth ERSTI-04-VY 1-1409-000 Page 117 of 118

Power Ascension Testing for Extended Power Uprate Conditions 7C Feedwater Level Changes 1832 MWth 7D Feedwater Level Changes 1912 MWth 8A MHC Pressure Change 1673 MWth 8B MHC Pressure Change 1752 MWth 8C MHC Pressure Change 1832 MWth 8D MHC Pressure Change 1"912 MWth 9A System Data 1593 MWth 9B System Data 1673 MWth 9C System Data 1572 MWth 9D Systern Data 1832 MWth 9E System Data 1912 MWth 10 Site Boundary Dose Measurements Various MWth IOAChemistry Data 1673 MWth I OB Chemistry Data 1572 MWth IOCChemistry Data 1832 MWth 10DChemistry Data 1912 MWth I IA Recombiner Performance Data 1673 MWth 111B Recombiner Performance Data 1752 MWth 11 C Recombiner Performance Data 1832 MWth l1D Recombiner Perfomrance Data 1912 MWth 12 Signature Identification Log 13 Test Deficiency Log 14 Performance Summary 15 ENN-LI- 100 Process Applicability Deten-nination 16 ENN-LI-101, 10.59 Screen 17 Risk Management Worksheet VYAPF 0172.02 ERSTI-04-VY 1-1409-000 Page 118 of 118

Attachment 1A Dryer Data Collection 1593 MWth (1574 MWth to 1593 MWth) NOTES: Additional data collection may be performed at other power levels as directed by the Test Coordinator. Strain gauges and accelerometers are assumed to be installed and tested via the work order process. The NI Data Acquisition Computer (NIDAC) and NI Hardware in the Reactor Building is on and operational. It is preferred that this system is controlled and monitored via a PC work station from outside the RCA.

Reactor Power, steam flow, and recirc flow -needs to be held steady, (within -19 MWth,

+0 MWth) for approximately 2 minutes before and 15 minutes during the data collection at each test step. The data shall be recorded and evaluated within one hour of reaching each p6')iver step.

The strain gauge and accelerometer surveillance shall be performed hourly when increasing power above a level, at which data was previously obtained. Operations. shall identify windows during power ascension when steam flow is approximately steady state for the hourly data collection. The process of increasing power from one step to the next level should be (but is not required) accomplished within one hour, including time to collect and evaluate data. If the step increase (including collection and evaluation of data) cannot be accomplished in one hour, then the collection and evaluation process should be repeated hourly until such time as the step increase is achieved, For each data collection Strain Gauges are calibrated and nulled. Then there are two sets of data collected; each set approximately 40 seconds in length. The first set will include bridge excitation to produce/measure signal and noise. This will be followed by a second set with zero bridge excitation. This second set of data is used to identify recirc power electrical noise and AC power electrical noise from the strain signal. The data is then processed and plotted by Steam Dryer Engineer Within the hour. Engineering shall provide plots, a written summary of data changes. Engineering shall assess the margin to the limit curve, assess the rate of change in sequential data, and provide a recommendation whether power ascension. should continue. The MSL accelerometer data shall also be compared with strain gauge data. Engineering shall assess whether accelerometer data provides evidence that there are acoustic frequencies not identified by the SG data. ERSTI-04-.VY I - 1409-000 Attachment 1A Page 1 of 12

Attachment IA Dryer Data Collection 1593 MWth (1574 MWth to 1593 MWth) 1.0 Test team to monitor the following ERFIS pointsi

B064 Main Steam Line Flow A 0 B065 Main Steam Line Flow B 0 B066 Main Steam Line Flow C
B067 Main Steam Line Flow D
B022 Total Steam Line Flow e C047 Core Thermal Power
M134 Recirc Pump A Speed
M135 Recirc Pump B Speed 3DMAO15 Recirc Pump A Flow 3DMAO18 Recirc Pump B Flow

                                                                       /       /

Initial Date Time 2.0 Confirm that NI Data Acquisition Computer (NIDAC) and NI Hardware on 252' elevation of the Reactor Building are on and operational. / / Initial Date Time 3.0 Confirm that the Steam Dryer Engineer is prepared to acquire and process data / / Initial Date Time 4.0 When the plant is at steady state power, confirm with the Steam Dryer Engineer to collect and evaluate strain gauge and accelerometer data. / /* Initial Date Time ERSTI-04-VYI -1409-000 Attachment !A Page 2 of 12

Attachment IA Qryer Data Collection 1593) MWth (1574 MWth to 1593 MWth) 0 5.0 Confirm the with the reactor building, data recorder station, and the Main Steam line strain gauge data collection, was successful. Record time and date below; Time and date:

                                                                        /D Initial Date Time 6.0 Confirm with      the Steam Dryer Engineer the data evaluation has     been completed within one hour of collecting the    strain gauge and accelerometer data.

Record date and time of data evaluation completion. Date and time evaluation complete_

                                                                        /    ./

Initial Date Time Determine time for evaluation: 7.0 IF valid strain. gauge and accelerometer \data cannot be recorded and evaluated hourly or withii one hour of initially reaching a 80 MWth power step from at least three of the four main steam lines, THEN 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.

                                                                        /D Initial Date Time
                                                              .ERSTI-04-VY 1-1.409-000 Attachment 1A Page 3 of 12

Attachment 1A Dryer Data Collection 1593 MWth (1574 MWth to 1593 MWth)

8.0 Evaluation

8.1 IF.the conditions of Table 1 can not be met, 8.1.1 THEN 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.

                                                                      /      /

Initial Date Time

/ /

Verified Date Time ERSTI-04-VY 1-1409-000 Attachment 1A Page 4 of 12

Attachment IA Dryer Data Collection 1593 MWth (1574 MWth to 1593 MWth) 8.2 If the Level 2 performance criteria is exceeded based on Table 2, THEN 8.2.1 Promptly suspend reactor power ascension until an engineering evaluation concludes that further power ascension is justified.

                                                                    /    /

Initial Date Time

                                                                    /    /

Verified Date Time 8.2.2 Initiate a condition report.

                                                                /        /

Initial Date Time

                                                                /      */

Verified Date Time 8.2.3 Evaluate the cause of any exceedance of the performance criteria.

Initial Date Time

                                                                /         /

Verified Date Time 8.2.4 Before resuming reactor power ascension, the steam dryer performance data shall be reviewed as part of an engineering evaluation to assess whether further power ascension can be made without exceeding* the Level I criteria.

                                                                /         /

Initial Date Time

                                                                 /        /

Verified Date Time 8.2.5 Obtain GMPO permission to continue the power ascension.

                                                                 /        /

Initial Date Time,

                                                                 /        /

Verified Date Time ERSTI-04-VY 1-1409-000 Attachment IA Page 5 of 12

Attachment IA Dryer Data Collection 1593 MWth (1574 MWth to 1593 MWth) 8.3 If the Level I performance criteria is exceeded based on Table 2, THENM 8.3.1 Promptly initiate a reactor power reduction to a previously acceptable power level (i.e., reduce power to a previous step level) within two hours, unless an engineering evaluation concludes that continued power operation or power ascension is acceptable.

                                                                   /        /

Initial Date Time

                                                                   /        /

Verified Date Time 8.3.2 Initiate a condition report.,

                                                                   /        /

Initial Date Time

                                                 /                      ~//

Verified Date Time 8.3.3 Evaluate the cause of 'any exceedance of the performance criteria.

                                                                   /        /

Initial Date Time

                                                                   /      */

Verified Date Time 8.3.4 If the results of the engineering evaluation support continued power operation, reduce further power ascension step and plateau levels to nominal increases of 20 MWth and 40 MWth respectively, for any additional power ascension.

                                                                    /        /

Initial Date Time

                                                                    /        /

Verified Date Time ERSTI-04-VYI-1409-000 Attachment 1A Page 6 of 12

I ý. Attachment 1A Dryer Data Collection 1593 MWth (1574 MWth to 1593 MWth) 8,.3.5 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.

                                                              /      /

Initial Date Time

                                                              /      /

Verified Date Time 8.3.6. Obtain GMPO permission to continue the power ascension.

                                                              /      /

Initial Date Time

                                                              /      /

Verified Date Time ERSTI-04-VY 1-1409-000 Attachment 1A Page 7 of 12

Attachment 1A Dryer Data Collection. 1593 MWth (1574 MWth to 1593 MWth) 8.4 IF any frequency peak from the MSL strain gage data exceeds the limit curve establi~hed by Entergy Nuclear Operations, Inc. and submitted to the NRC staff prior to operation above OLTP, 8.4.1 THEN reduce reactor power to where the limit curve was not exceeded. Engineering shall resolve the uncertainties in the steam dryer analysis, document the continued structural integrity of the steam dryer, and provide that documentation to the NRC staff by facsimile or electronic transmission to the NRC project manager prior to further increases in reactor power.

                                                                         /   /

Initial Date Time

                                                                     /       /

Verified Date Time 8.5 IF resonance frequencies are identified as increasing above nominal levels in proportion to strain gage instrumentation data, 8.5.1 THEN hold reactor power, and document the continued structural integrity of the steam dryer, and provide that documentation to the NRC staff by facsimile or electronic transmission to the NRC project manager prior to further increases in reactor power.

                                                                     /       /

Initial Date Time

                                                                     /        /

Verified Date Time ERSTI-04-VY 1- 1409-000 Attachment 1A Page 8 of 12

Attachment 1A Dryer Data Collection 1593 MWth (1574 MWth'to 1.593 MWth) 8.6 IF the acoustic signals are identified that challenge the limit curve during, power ascensilon above OLTP, 8.6.1 THEN Engineering to evaluate dryer loads and re-establish the limit curve based on the new strain gage data, and shall perform a frequency-specific assessment of ACM uncertainty at the acoustic signal frequency.

                                                                    /         /

Initial Date Time

                                                                    /         /

Verified Date Time 8.7 IF an engineering evaluation is required in accordance with the Steam Dryer Monitoring Plan, 8.7.1 THEN Entergy Nuclear ýperations, Inc. shall perform the structu*-al. analysis to address frequency uncertainties up to +/- 10% and assure that peak responses that fall within this uncertainty band are addressed.

                                                                    /         /

Initial Date Time

                                                                    /         /

Verified Date Time 8.8 If the Level 1 or Level 2 performance criteria are NOT exceeded based on Table 2, 8.8.1 THEN recommend to OSRC that power ascension testing should continue.

                                                                    /     **/

Initial Date Time

                                                                     /         /

Verified Date Time ERSTI-04-VY1-1409-000 Attachment 1A Page 9 of 12

Attachment 1A Dryer Data Collection 1593 MWth (1574 MWth to 1593 MWth) Table 1 Parameter Surveillance Frequency

1. Main steam line pressure data Hourly when initially increasing power above a from strain gauges previously attained power level.

                                                                      -AND-At least once at every 40 MWth power step above

_1593 MWth (Note 1)

2. Main steam piping accelerometer At least once at every 40 MWth LPU power step data from accelerometers in above 1593 MWth (Note 1) drywell -AND-Within one hour after achieving every 40 MWth power step above 1593 MWth.

Notes to Table 1:

1. The strain gauge and accelerometer surveillance shall be performed hourly when increasing power above a level at which data was previously obtained. The surveillance of both the strain gauge data and accelerometer data is also required to be performed once.

at each 40 MWth power step above 1593 MWth and within one hour of achieving each

    ""'40 MWth step in power. If the surveillance is met at a given power level, additional surveillances do not need. to be performed at that power level where data had previously been obtained.

If valid strain gauge data cannot be recorded hourly or within one. hour of initially reaching a 40 MWth power step from at least three of the four main steam lines, 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. ERSTI-04-VY1 - 1409-000 Attachment 1A Page 10 of 12

Attachment IA Dryer Data Collection 1593 MWth (.1,574 MWth to 1593 MWth) Table 2 Performance Criteria Not to be Exceeded Required Actions if Performance Criteria Exceeded and 6 Required Completion Times Level 2: 1. Promptly suspend reactor power ascension until an engineering evaluation concludes that further power

Pressure data exceed Level 2 Spectral ascension is justified.

per VYC-3001.

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

Level 1: 1. Promptly initiate a reactor power reduction and achieve a previously acceptable power level (i.e., Pressure data exceed Level 1 Spectral reduce power to a previous step level) within two per VYC-3001. hours, unless an engineering evaluation concludes that continued power operation-or power ascension is acceptable.

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

3. 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.

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 (S,) value at

       <-10'I 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).

ERSTI-04-VY 1- 1409-000 Attachment 1A Page II of 12

Attachment IA Dryer Data Collection 1593 MWth (1574 MWth'to 15993 MWth) Reactor power operation that results in Steam pressures *that are less than the Level 2 performance criteria in Table 2 is representative of fully acceptable steam dryer performance. ERSTI-04-VY 1-1409-000 Attachment 1A Page 12 of 12

Attachment 2A Flow Induced Vibration Data, Collection At 1593 MWth (1574 MWth to 1593 MWth) o D'RYWELL A {*EA' Accel No./Dir. Measured Acceptance Acceleration (g) Criteria (g) MSA1 N-S _<0.545 MSA2 Vert <0.230 MSA3 E-W <0.326 MSBI N-S k0.274 MSB2 E-W <0.160 MSB3 N-S <0.269 MSB4 Vert <0.133 MSB5 E-W <0.248 MSB6 N-S <0.259 MSB7 E-W <0.202 MSB8 N-S <0.271 MSB9 Vert <0.286 MSB IOE-W <0.263 MSC1 N-S <0.264 MSC2 Vert <0.193 MSC3 E-W <0.170 MSD1 N-S <0.271 MSD2 Vert <0.254 MSD3 E-W <0.193 MSD4 N-S <0.271 MSD5 E-W <0.293 FDWA1 N-S <0.123 FDWA2 Vert <0.184 FDWA3 E-W <0.068 FDWB I N-S <0.172 FDWB2 Vert <0.198 FDWB3 E-W <0.084 FDWB4 N-S <0.184 FDWB5 E-W <0.185 FDWB6 N-S <0.162 FDWB7 E-W <0.144 ERSTI-04-VY 1-1409-000 Attachment 2A Page 1 of 6

Attachment 2A Flow Induced Vibration Data Collection At 1593 MWth (1574 MWth to 1593 MWth) HEATER BAY AREA Accel No./Dir. Measured Acceptance Sat I Unsat Acceleration (g) Criteria; (g) MSHB 1 N-S <0.057 MSHB2 E-W <0.047 MSHB3 N-S <0.048 MSHB4 E-W <0.058 FDWHB1 N-S <0.103 FDWHB2 Vert <0.162 FDWHB3 E-W <0.076 Performed by: Sign/Date (Design Engineering) Verified by: Sign/Date (Design Engineering) Note: Any UNSAT. indication requires a Condition Report and an Engineering Evaluation. Request Operations to lower reactor power to the last tested power level. ERSTI-04-VY I -1409-000 Attachment 2A Page 2 of 6

Attaclunent 2A . Flow Induced Vibration Data Collection At 1593 MWth (1574 MWth to 1593 MWth) Turbine Building Branch Piping Vibration Acceptance Criteria Valve(s) ID# Measured Measured Measured SRSS (g) Acceptance Sat Displacement Displacement displacement Criteria Unsat mils (g) N-S mils (g) E-W mils (g) mils Vertical V64-63B & V64-124 <34 V64-63A & V64-120 <28 V66-12E <44 V64-127 <6 V63-812A & B <27 V63-814A & B <26 V63-808C, D <15 V64-16A <4 V64-16B <4 V64-16C <4 SRSS = SQRT [(N-S iils) 2 + (E-W) 2 + (vertical 2 )] Note: Any UNSAT indication requires a Condition Report and an Engineering Evaluation. Request Operations to lower reactor power to the last tested power level. Perforned by: Sign/Date (Design Engineering) Verified by: Signi/Date (Design Engineering) 0 ERSTI-04-VY I - 1409-000 Attaclhnent 2A Page 3 of 6

1 .1 Attachment 2A Flow Induced Vibration Data Collection At 1593 MWth (1574 MWth to 1593 MWth) Turbine Building FW Piping (FW Pump Room) Vibration Acceptance Criteria Peak to Peak Displacements (mils) N-S Vertical E-W Location Meas. Accep. Meas. Accep. Meas, Accep. Sat/ _ Crit. Cnrt. Cnit. Unsat Pipe Support <27.5 <25.6 <59.4 H-35 FCV-6-12A <31.6 <170.7 <104.7 FCV-6-12B <20.5 <11.3 <32.6 Performed by: Sign/Date (Design Engineering) Verified by: Sign/Date (Design Engineering) Acceptance Criteria Met: Sign/Date (Design Engineering) Note: Any UNSAT condition requires a Condition Report and an Engineering Evaluation. Request Operations to lower reactor power level to the last tested power level. ERSTI-04-VY1 -1409-000 Attachment 2A Page 4 of 6

Attachment 2A Flow Induced Vibration Data Collection At 1593 MWth,(1574 MWth to 1593 MWth) FIV Walkdowns Heater Bay, Condensate and Feedwater Pump Rooms Plant Location Vibration Level Observation Sat/Unsat Sign/Date Comments* Condensate Pump Room Piping ______________________/__________ Feedwater Pump Room Piping .... _/ Heater Bay Piping Systems:

 *Condensate Piping                                            /

Feedwater Piping / Main Steam Piping / MS Low Point Drains' / Extraction Steam / Heater Drains / Feedwater Heater Level Control. Miscellaneous Remaining Systems ERSTI-04-VY 1-1409-000 Attachment 2A Page 5 of6

Attachment 2A Flow Induced Vibration Data Collection At 1593 MWth (1574 MWth to 15593 MWth) Acceptance Criteria: Piping: For main piping, if the level of vibration is too small to be perceived, and the possibility of fatigue issues is judged to be minimal, the piping system is acceptable. Any observed vibration levels piping judged by walkdown personnel to be a potential concern will be monitored utilizing hand-held vibration meters and' evaluated. System/Components: Baseline. inspections of systems and components were performed at OLTP (documented in Calculation VYC-2330). Results of EPU power ascension testing inspections/walkdowns will be compared to baseline inspection results to determine if acceptability is maintained. Any UNSAT condition requires a Condition Report and an Engineering Evaluation. Request Operations to lower reactor power level to the last tested power level. Performed by: Sign/Date (Design Eigineering) Verified by: Sign/Date (Design Engineering) Acceptance Criteria Met Sign/Date (Design Engineering) Record instruments used and calibration due dates:

Add additional pages as needed.

ERSTI-04-VY 1-1409-000 Attachment 2A Page 6 of 6

Attachment 5A Moisture Carryover 1633 MWth (1614 MWth to 1633 MWth) 0 CAUTIONS

Any of the following may. be indications of vessel internals damage and potential debris generation (loose parts). (SIL 644 Revision 1)

Main Steam Line steam flow indication imbalance of 5% or more. (B064, B065, B066, B067) RPV water level difference >3 inches step change between level instruments from different reference legs. (B040, B041, B047 versus. B021, B042,'B043) Sudden. drop (<l minute) in' steam dome pressure. of >2 psig. (B048, B049)

Statistically significant step increase of moisture carryover >50% of previous value .(perOP 0631, ýadiochemistry, Appendix F)
Unexpected trends in parameter values that may be indicative of loss of steam dryer integrity, particularly unexplained changes in trends.

1.0 Monitor the following ERFIS points;

     " B021          REACTOR WATER LEVEL 72A

B040 REACTOR WATER LEVEL 72B
B048 REACTOR PRESSURE 56B
B049 REACTOR PRESSURE 56A

     " B022          MAIN STEAM FLOW

B064 MAIN STEAM LINE A FLOW
B065 MAIN STEAM LINE B FLOW
B066 MAIN STEAM LINE C FLOW ERT-04-VY 1- 1409-000 Attachlnent 5A Page 1 of 6

Attachment 5A Moisture Carryover 1633 MWth (1614 MWth to 1633 MWth)

B067 MAIN STEAM LINE D FLOW
M084 RX A UPPER REF. LEG TEMP

    " M085        RX A LOWER REF LEG TEMP M086      RX B UPPER REF LEG TEMP M087      RX B LOWER REF LEG TEMP
                                                                        /       /

Initial Date Time 1.0 Hold Criteria: 1.1 Moisture carryover exceeds 0.10%. 2.0 Request Chemistry to perform moisture carryover testing per OP 0631, Appendix F. Attach results per Step 9.0 of, the main body of the procedure. Initial Date Time

3.0 Record

reactor power: % Recirc flow: % Moisture carryover: %

                                                                         /       /

Initial Date Time ERT-04-VYI -1409-000 Attachment 5A Page 2 of 6

I ., Attachment 5A Moisture Carryover 1633 MWth (1614 MWth to 1633 MWth) 4.0 Evaluate results as follows: 4.1 IF moisture carryover is equal to less than 0.10%, THEN no further actions are required.

                                                                             */       /

Initial Date Time Vf/ / Verified Date Time 4.2 IF moisture carryover is greater than 0.10%, THEN: 4.2.1 Notify Shift'Manager and Test Engineer.

                                                                              /D Initial     Date Time 4.2.2    Enter ON       3178,    Increased  Moisture Carryover
                                                                               /       /

Initial Date Time

                                                                               /       /T Verified Date Time 4.2.3    Take actions per the Attachment, Table 2.

Consult Technical Specifications.

                                                                               /       /.

Initial Date Time Verified Date Time ERT-04-V\Y 1-1409-000 Attachment 5A Page 3 of 6

Attachment 5A Moisture Carryover 1633 MWth (1614 MWth to J633 MWth) 4.2.4 Request Reactor Engineering to -store data for individual bundle powers and flows for the approximate time Chemistry obtained the moisture carryover samples. per OP 0631. Attach results per Sectibn 9 of the main body of the procedure.

                                                                             /       /

Initial Date Time Verified Date Time 5.0 Acceptance Criteria: 5.1 Level 1: Moisture Carr-yover less than or equal to'0.35% 5.2 Level 2: 5.21 MSL moisture contenl ratio as determined by Chemistry shall be less than or equal to 0.10 %. (Reference 21A3317, Revision 0 Standard Requirement4 for Steam Dryer.Units). 5.2.2 MSL moisture content ratio as determined by Chemistry shall be less than or. equal to 0.35% WITH an approved engineering evaluation that supports continued plant operation. ERT-04-VY1 -1409-000 Attachment 5A Page 4 of 6

Attachment 5A Moisture Carryover 1633 MWth (.1614 MWth to 1633 MWth) Table 1 Parameter

1. Moisture Carryover Notes to Table 1:

                                                     -Surveillance Frequency Every 24 hours (Notes I and 2)

I

1. If a determination of moisture carryover cannot be made within 24 hours of achieving an 80 MWth power plateau, an orderly power reduction shall made within the subsequent 12 hours to a power level at which moisture carryover was previously determined to be acceptable.

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.

ERT-04-VY1-1409-000 Attachment 5A Page 5 of 6

Attachment 5A Moisture Carryover 1633 MWth (1614 MWth to' 11633 MWth) C Table 2 Performance Criteria Not to be Exceeded Required Actions if Performance Criteria Exceeded and Required Completion Times Level 2: 1 Promptly suspend reactor power ascension until an engineering evaluation concludes that further power ascension is justified.

Moisture carryover exceed& 0.1%

                       -OR-                           2. Before resuming reactor power ascension, the steam dryer performance data shall be reviewed as part of an engineering

Moisture carryover exceeds 0.1% and increases evaluation to assess whether further power ascension can be made by > 50% over the average of the three previous without exceeding the Level 1 criteria.

measurements taken at > 1593 MWt Level 1: 1. Promptly initiate a reactor power reduction and achieve a previously acceptable power level (i.e., reduce power to a

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

2. WMthin 24 hours, re-measure moisture carryover and perform an enqineering evaluation of steam dryer structural integrity. If the resillts of the evaluation of dryer structural integrity do not support continued plant operation, the reactor shall be placed in a hot shutdown condition within the following 24 hours. If the results of the engineering evaluation support continued power operation, implement step 3 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 MWth and 40 MWth, respectively, for any additional power ascension.

TABLE 2 NOTES: IF the Level I or Level 2 performance criteria are exceeded, THEN either suspend reactor power ascension (Level 2 Performance Criteria) or reduce reactor power (Level I Performance Criteria), initiate a Condition Report, and evaluate the cause of any exceedance of the performance criteria. Reactor power operation that results in moisture carryover that are less than the Level 2 performance criteria in Table 2 is representative of fully acceptable steam dryer performance. ERT-04-VYI -1409-000 Attachment 5A Page 6 of 6

0 BVY 06-019 Docket No. 50-271 VYNPS EPU Portions of Test Procedur4 ERSTI-04-VY1-1409-000 Power Ascension Test Procedure for Extended Power Conditions 1593 to 1912 MWth (February 24, 2006) Attachment 9 to PATP. Supplemental System Monitoring Plans for EPU Plan Total number of pages in this Attachment (excluding this cover sheet) is 85.

VYNPS EPU Power Ascension Testing 345 KV System Monitoring Plan (3 pages)

EPU Power Asicention Testing -345K System Monitoring Plan System Number: 345KV System Engineer: Ken Sweet Equipment Para Alert andother Name Action Levels Level Alert and Action Actions Required Info 1593 MwTh 1673 MwTh 1752 MwTh 1835 MwTh 1912 MwTh NamesisLevels ID Basis Info Increased Monitoring, VELCO Normal VELCO Line Limits for to notify VY Operations of Monitored By SE by 340 Line ERFIS Pt. E037 System 2 Ambient and possible PA hold. VELCO (MVAR) Monitoring Reliable Grid may resolve by dispatching Contacting Velco system load. increased Monitoring, VELCO Normal VELCO Line Limits for to notify VY Operations of M 340 Line EFIS Pt. E036 System 2 Ambient and possible PA hold. VELCO Monitored By SE by (MW) Monitoring Reliable Grid may resolve by dispatching Contacting Velco system load. Increased Monitoring, VELCO

                                    ! Normal VELCO            Line Limits for   to notify VY Operations of 379ERFIS              Pt. E016      System          2     Ambient and      possible PA hold. VELCO     Contacting Velco Monitoring             Reliable Grid    may resolve by dispatching system load.

Increased Monitoring, VELCO ERFIS Pt. E002 Velco System Line Limits for to notify VY Operations of Monitored By SE by 379 Line (MW) Monitoring 2 Ambient and possible PA hold. VELCO (MW) System Reliable Grid may resolve by dispatching Contacting Velco system load. EPU Power Ascention Testing - 345K System Monitoring Plan Page 1 of 3

Equpmnt Para Alert n and an cinReason or other Equipment cton Levels Level Alert and Action Actions Required 1593 MwTh 1673 MwTh 1752 MwTh 1835 MwTh 1912 MwTh Name Levels Info ID Basis Circle A or B increased Monitoring, VELCO ERFIS Pt. E017 Normal VELCO Line Limits for to notify VY Operations of Monitored By SE by 381 Line ERFAS System 2 Ambient and possible PA hold. VELCO Monitoredy b (MVAR) Monitoring Reliable Grid may resolve by dispatching Contacting Veico system load. Increased Monitoring, VELCO ERFIS Pt. E003 Normal VELCO Line Limitsand for to notify VY 381 Line System 2 Ambient possible PA Operations of hold. VELCO Monitored By SE by (W Monitoring Reliable Grid may resolve by dispatching system load. VELCO Voltage increased Monitoring, VELCO 345 KV Voltage34 K Vltge VYGeerto VY Generator VLC VELCO Vltge Voltage 2 Sceue(2V (123V Schedule possible to PA Operations notify VY hold. V-RCO-- of CnatnBy SE Monitored ec by (South Bus) (Relay House) Schedule light load, 125V Contacting Veico peak load may resolve by dispatching psystem load. i,0 EPU Power Ascention Testing - 345K System Monitoring Plan Page 2 of 3

1593 MWth Data Recorded By: Date: 1593 MWth Data Recorded By: Date: 1673 MWth Data Recorded By: Date: 1673 MWth Data Reviewed By: Date: 1752 MWth Data Recorded By: Date: 1752 MWth Data Reviewed By: Date: 1853 MWth Data Recorded By: Date: 1853 MWIh Data Recorded By: Date: 1912 MWth Data Recorded By: Date: 1912 MWth Data Reviewed By: Date: EPU PowerAscentlon Testing - 345K System Monitoring Plan Page 3 of 3

VYNPS EPU Power Ascension Testing AOG / AOGCCW System Monitoring Plan (9 pages)

EPU Power AscentiOn Testing - AOG/AOGCCW System Monitoring Plan System Number: AOG: NIA AOGCCW: V70-xx System Engineer Brian Naeck Equipment Para Alert and Alert and Action Reason or 1 Action Levels Levels Actions Required 1593 MwTh 1673 MwTh 1752 MwTh 1832 MwTh 1912 MwTh Name ID Basis Circle A or B Recombiner H2AN-2921A/B Both Units: 1. Per ARS 50-C-5, Notify H2 Detector 1. >25% Engineering < 5% OP 0150 Monitored by ARS: 50-C-5 2. >50% 2. Per ARS 50-C-6, Notify Ops -

                                    & 50-P-5                           Engineerinb R&combiner                                        3. >10%                                     Level 4 H2 Detector  H2AN-29223B                      Disagreement    3. Declare Inop & Swap                          < 5%

Recombiners OP0150 1. 5,000cpm 1. NotifyRP& -- - -312: 600 RAN-OG-3127 ODCM 4.3.4 Engineering Monitored by cpm Rad Monitors & T.4.1.2. 2. 10,000 cpm Per AS00 Ops RAN-OG-3128 ARS 50-M-4 & 2. Per ARS pm-M-4 3128:4300 50-M-6 3. 200,000 cpm 3. Per ARS 50-M-6 3. 50M-6W11 Pr AS 10%

                                                   < 300 IF     1. Verylfy valve line-up    Monitored by Steam Temp to TE-OG-2301A/B       OP 0150                                                                            0 HE101J                                 0 F-       2 Thermography on

2. o350 Ops 35°" F HE-100MS > 400°F- I MS-114-1A Level 4 0

EPU Power Ascentlon Testing - AOG / AOGCCW System Monitoring Plan Page 1 of 5

Equipment Para Alert and Alert and Action Reason or Name Actionls Actions Requare otherInfo 1593 MwTh 1673 MwTh 1752 MwTh 1832 MwTh 1912 MwTh ID Basis Circle A or B Recombiner OP 0160 <295 IF Verify valve line-up, Monitored by Ops* Inlet TE-OG-2302A/B ARS 50-N-2 & -313 IF Temperature 50-N-6 > 315 IF notify Engineering Level 4 Recombiner Op 0150 < 300 IF Verify valve line-up, Monitored by Top TE-OG-2303A/B ARS 50-A-3, A- O 535 IF Temperature 4, N-3, & N-4 > 650 IF notify Engineering Level 4 OP 0150 Recombiner < 450 IF Verify valve line-up, Monitored by s Bottom TE-OG-2304A/B ARS 50-A-3, Op 490 - 540 0 Temperature A-4, B-6, N-3, > 650 F notify Engineering Level 4 F N-4, 0-6 OP 0150-Recombiner < 300 IF Verify valve line-up, Monitored by Center TE-OG-2305A1B ARS 50-A-3. Ops 530 550 Temperature A-4, B-6, N-ý3, > 650 IF notify Engineering LF N-4, 0-6 OP 0150i OP 0150Monitored by MS-101-IA/B < 75 OF Verify valve line-up, Ops Fy Outlet TE-OG-2307AJB ARS 50-A-3, So - 95IF Temperature A-4, A-5. B-6, N > 145 IF notify Engineering Level 4 3, N-4, N-5. 0-6 Monitored by Evaporator < 35 OF Verify valve line-up, opr b Glycol Inlet TE-OG-5251A/B OP 0150 35 - 45 IF Temperature > 50 IF notify Engineering Level 4 EPU Power Ascention Testing - AOG / AOGCCW System Monitoring Plan Page 2 of 5

amet ParaiAertean Action Levels Alert and Action dActons ' *Reason Required Reanoor 1593 MwTh 1673 MwTh 1752 MwTh 1832 MwTh 1912 MwTh Equamet AtoLels Levels other info Nm Basis ID Circle A or B Evaporator < 35 IF Verify valve line-up, Monitored by Glycol Outlet TE-OG-5252A1B OP 0150 Ops 35 - 45 IF Temperature > 50 IF notify Engineering Level 4 Verify valve line-up, Monitored by System Inlet P1-1301 OP 0150 <0 psig -0.75 psig Pressure notify Engineering Level 4 Adsorber "G"

                                                            ~Monitored                              by Verify valve line-up,         Ops Outlet         P1-1306         OP 0150         < -1 psig                                               -1.25 pslg Pressure                                                       notify Engineering         Level 4 Monitored by Verify valve line-up.         Opsnitpsig System Outlet     P1-1307          OP 0150       -1 to 1 psig Pressure                                                                                                   0 psig notify Engineering         Level 4 EPU Power Ascentlon Testing - AOG / AOGCCW System Monitoring Plan   Page 3 of 5

Equipment Para Alert and Alert and Action Reason or S Action Levels Basis Levels Actions Required Reasnfo 1593 MwTh 1673 MwTh 1752 MwTh 1832 MwTh 1912 MwTh ID

1. notify engineering, verity

1. 25 scfm valve line-up OP 2150 2. Initate corrective actions OP 0150 to prevent exceeding 100 Monitored by Delay Pipe I System Flow FI-2002 ODCM Table 2. 30 scfm 5scfm Ops 18 scfm 3.1.2

3. reduce power to Level 4 maintain <100 scfm

3. <100 scfm

4. Agree within 10 scfm of FI-2004

1. 25 scfm 1. notify engineering, verify valve line-up OP 2150 2. 30 scfm OP 0150 2. Initate corrective actions Monitored by Delay Pipe System Flow FI-2004 ODCM Table 3.. <100 scfm to prevent exceeding 100 Ops 18 scfm 3.1.2 scfm-

4. Agree within 10 scfm of 3. reduce power to -

FI-2002 maintain <100 scfmr-- OP 0150 50 IF - 90 *F, & Adjust temperature per OP Monitored by AOGCCW T-104-7153 OP 2150 (<15 IF above 2150 & Ops Temperature ambient when >70 288 RPFair IF 218temp) Notify Engineering- Lvl

                                                                                        . Level 4 EPU Power Ascentlon Testing - AOG / AOGCCW System Monitoring Plan  Page 4 of 5

1673 MWth Data Recorded By: Date: 1673 MWth Data Reviewed By: Date: i 1752 MWth Data Recorded By: Date: 1752 MWth Data Reviewed By: Date:

                                                                                 '1 q

1832 MWth Data Recorded By: Date: 1832 MWth Data Reviewed By: Date: 1912 MWth Data Recorded By: Date: 1912 MWth Data Reviewed By: Date: EPU Power Ascentlon Testing - AOG / AOGCCW System Monitoring Plan Page 5 of 5

VYNPS EPU Power Ascension Testing Condensate Demineralizer System Monitoring Plan (2 pages).

                                               .EPU Performance Monitoring for Condensate Demine'alizer System Increased Power Level Evaluation Points Alarm                1              1673 MWth1752Mth 1832 MWth.1912 MWth Equiument No. Parameter       Values/Limits     Level     (83.32%)       (8748%)      (91.65%)      (95.8)       (                            Action dP                   25p             2         25             20             18      -17              15    Evaluate margin to 55psid limit for Data I                             __pin_,_                              system dP; Fluff resin; Backwash DM--1A                                                                                             -3095gpm     -3250gpm Flow               3250             21    -2600Gpm       -2760gpm      -2925gpm Data                                                                    Investigate why flows are not balanced dP                   25sid          2                         20         '25 18          17          15     Evaluate margin to 55psid limit for DM11B                                              Data                                                                    system dP: Fluff resin; Backwash Flow               3250       m     2     -2600gpm       -2760gpm.     -2925gpm     -3095gpm    -3250gpm Data              -         -                                           Investigate why flows are not ballanced dP                   25psid         2          25            20              18          17          15    Evaluale margin to 55psid limit for Data                  _                                                 system dP; Ruff resin; Backwash Flow      .        3250 pm          2      272600gpm -27601gpm        -2925gpm      -3095gpm    -3250gpm Data                                                                    Investigate why flows are not ballanced dP                   25id_*        2           25            20             18           17          15    Evaluate margin to 55psid limit for Data  ______T__                                                         system dP; Fluff resin; Backwash Flow              3250       m     2      -2600gpm       -2760gpm     -2925gpm      -3095gpm    -3250gom

Data Investigate why flows are not balanced dP . 25osid 772T 25 20 18 17 15 Evaluate margin to 55psid limit for DM-i" Data system dP; Fluff-resin; Backwash Flow 3250gpm 2 -26Ogpm -2760gpm -2925gpm -3095gpm -3250gpm Data Investigate why flows are not battanced System dP_55psid 2 55psid 55psid 55psid 55psid 55psid Evaluate prior data for wtich vessel put Data system into Flow Balance Override S-14-1A dP 20 sid 2 15 16 17 19 20 Data Backwash Filter, Evaluate replacement S-14-1B dP,, 20psid 2 15 16 17 19 20 Data IBackwash Filter; Evaluate replacement S-14-1C dP 20psid. 2 15 16 17 19 20 Data Backwash Fitter; Evaluate replacement S-14-ID dP 20psid 2 15 16 17 19 20

                                                 'Data                                                                     Backwash Filter; Evaluate replacement S-14-IE         dP                   20psli        2          15             16             17           19          20 Data                I            I            I                          Backwash Filter, Evaluate replacement Conductiy                                                                        Monitored by Chemistry Comments:

General Guidance 1593 Mwth Reviewed By-. *Data can be collected at the Condtemin pmnt/Sign/Date control panel on the 232 level of the Approved By: Turbine building. System dP and vessel PrintSigni/Dat- flows are available on the recorder located at the panel. Vessel dP is 1673 Mwth Reviewed By. _ visible along the upper right comer of Pant/Signl/Ute the panel. Approved By: _ PnMtSignrtOet *Data can be obtained shifily via OP 0150.05 data sheets 1752 Mwth Reviewed By.

                            .pdn'Sig n/ONaW                                                                                 Chemistry is performing additional daily Approved By: _                                                                                              trending of Condemin performance for pesn/Sienl~ute                                                                               the scheduling of vessel backwashes 1832 Mwth       Reviewed By:                                                                                                *It is the intent of this monitoring plan P,,nvSign/[W-e                                                                              that any parameter approaching an Approved By:                                                                                                evaluation limit be monitored on a more Plineesin/Date                                                                              frequent basis to preclude the system from entering flow batlance override at 1912 Mwth       Reviewed By:                                                                                               55psid system dP before action is taken to reduce overall system dP.

Approved By: PnnylSign/Date 0212512006

SUMMARY

OF CONDEMIN FILTERED BYPASS FLOW CASES CASE DESCRIPTION MODELED TRAP dP TRAP Dp DEMIN Dp HEADER TOTAL FLOW MASS FLOW OUTLET E AVE DEMIN BYPASS BYPASS (@current flow) ACTUAL PSID Dp GPM E6 #/HR VALVE %OPEN FLOW GPM FLOW % OPEN 1 CURRENT POWER 7 8.7 5 27.5 13000 6.435 90 2600 0 2 CURRENT POWER 7 8.7 20 41 13000 6.435 70 2600 0 3 CURRENT POWER. 12 13.4 5 32.5 13000 6.435 90 2600 0 4 CURRENT POWER 12 13.7 20 46.5 13000 6.435 70 2600 0 5 105% 5demins online 7 9.8 5 29.5 13810 6.836 70 2760 0 6 105% 5deminsonline 7 10 17 40.7 13810 6.836 90 2760 0 7 105% 5deminsonline 12 15.6 5 37 13810 - 6.836 70 2760 0 8 105% 5demins online 12 15.5 17 46.5 13810 6.836 90 2760 0 9 105% 4demins online 12 NR 17 NR 13810 6.836 NR NR NR 10 110% 5 detains online 7 9.8 5 29.7 14625 7.239 70 2925 0 11 110% 5 detains online 7 10.1 17 41.7 14625 7.239 70 2925 0 12 110% 5 detains online 12 17.2 5 39 14625 7.239 70 2925 0 13 110% 5 detains online 12 17.1 17 51.7 14625 7.239 -90 2925 -0 14 110%4demins online 12 15.5 17 45 -14625 7.239 .70 2755 3600 15 115% 5 demins online 7 10.5 5 32.3 15465 7.655 70 3095 0 16 115%5demins online 7 8.5 17 34 15465-- -- 7-.655 70 3095 0 17 115% 5 detains online 12 18.7 5 42.1 15465 7.655 70 3095 0 18 115% 5 demins online 12 18.7 17 54 15465 7.655 90 3095 0 19 115% 4 detains online 12 16.7 17 51.2 15465 7.655 90 2930 3845 50 19A 115% 5 demins online 7 11.5 5 35 15465 7.655 70 30951 0 19B 115% 4 demins online 7 13 5 38.5 15465 7.655 70 3075 3170 50 20 120% 5 detains online 7 11.5 5 35.8 16250 8.044 70 3250 0 21 120%5 deminsonline 7 12 17 46.2 16250 8.044 - 90 3250 0 22 120% 5 demins online 12 19.8 5 45.8 16250 8.044 -70 3250 0 23 120% 5 demlns online 12 20.5 17 57.5 16250 8.044 90 3250 0 23A 120% 5 detains online 10 17 15 51.5 16250 8.044 3250 3250 90 23B 120% 5 detains online 10 17 17 53 16250 8.044 3250 3250 90 23C 120% 5 detains online 10 17 20 57.5 16250 8.044 3250 3250 90 23D 120% 5 detains online 12 20 15 54.5 16250 8.044 3250 3250 90 23E 120% 5 demins online 12 20 17 56.8 16250 8.044 3250 3250 90 23F 120% 5 detains online 13 23 15 57.5 16250 8.044 3250 3250 90 24 120% 4 detains online 12 18.8 17 52.5 16250 8.044 90 3095 3875 50 0 24A 120% 5 demins online 7 13 5 40 16250 8.044 70 3250 0 24B 120%4deminsonline 7 13 5 38.5 16250 8.044 70 3235 3310 50

VYNPS EPU Power\Ascension Testing Nuclear Boiler Vessel Instrumenlation System Monitoring Plan (2 pages)

VY EPUL NBVI Supplemental System Performance Monitoring Parameter AlertI : R: ?:: ID Parameter ID Action Source Required N - (ERFIS) Levels - equire IDate __ Time _ Calculated Reference Leg A Temp F C220 OP4390 4 Evaluate Calculated Reference Leg B Tamp "F C221 OP4390 4 Evaluate RX A Upper Reference Leg Tamp FM084 0P4390 4 Evaluate RX A Lower Reference Leg Tamp F M086 OP4390 4 Evaluate RX B Upper Reference Leg Tamp 'F M086 OP4390 4 Evaluate - RX B Lower Reference Leg Temp°F M087 OP4390 4 Evaluate Vessel Stud Tamp SF023 4 Evaluate Vessel Heed Flange Temp ° S024 4 Evaluate Vessel Head Adjacent to Flange Tamp 'F $025 4 Evaluate Vessel Bottom Drain Temp . Temp F S026 4 .Evaluate Vessel Skirt at MTG Flange Temp "F S027 4 Evaluate Vessel Bottom Head TF Temp S028 4 Evaluate Vessel Skirt Near Joint Tamp *F S029 4 Evaluate Vessel Above Skirt Joint Temp F S030 4 Evaluate Vessel DownSomer Temp °F S031 4 Evaluate Vessel Core Tamp °F S032 4 Evaluate Nozzle N4C In Board Temp °F S033 4 Evaluate Vessel Below Water Level TempTF S034 4 Evaluate Total Jet Pump Flow Loop A M#0HR 6013 4 Evaluate Total Jet Pump Flow Loop B M#/HR 8052 4 Evaluate Total RX Jet Pump Flow MN1HR 1012 51.05 M#IHR? 4 Evaluate Flow to Ref Leg FIT-400-A GPM NIA 0.001-0.005 GPM 0P0150 4 Evaluate i Flow to Ref Leg FIT-400-B GPM NIA 0.001-0.005 GPM OP0150 4 Evaluate Prepared by Stan Kol 02/2512006 Page I

VY EPU NBVI Supplemental System Performance Monitoring Parameter Alert/ Actions Asset Parameter ID Action > R (ERFIS) Levels Ru r- WO r T-r-,- - Date Time Flow to Ret Leg FIT-400-C GPM NIA 0.001.0.005 GPM OP0150 4 Evaluate Flow to Ref Leg FIT-400-D GPM NIA 0.001-0.005 GPM OP0150 4 Evaluate 1593 MWth Data Recorded By: Date: 1593 MWth Data Reviewed By: Date: 1673 MWth Data Recorded By: Date: 1673 MWth Data Reviewed By: Date: 1752 MWth Data Recorded By: Date: 1752 MWth Data Reviewed By: Date: 1835 MWth Data Recorded By: Date: 1835MWth Data Reviewed By: Date: 1912 MWth Data Recorded By: Date: 1912 MWth Data Reviewed By: Date: Prepared by Stan Ko0.02/25/2006 Page 2

VYNPS EPU Power Ascension Testing Core Spray System Monitoring Plan (1 page)

EPU Supplemental Performance Monitoring Plan for the Core Spray System System Engineer: Stephen Jonasch Previously Equip Parameter Pre 5% 10% 15%,, 20% Source Remarks Monitored ID EPU 1673 1752 1832 1912 Range MWth MWth Mwth Mwth Yes DPIS CS A -3.2 OP Note 1 Sparger. 0150 Note 2 43A DP I __ pg 10 Note 3 Yes DPIS CS B -2.9 OP Note 1 Sparger 0150 Note 2 43B. DP 0pg.0 Note 1: A minus reading is normal Gauge range is -5.0 to +5.0. Alarm setpoint is t0.6. Note 2: GE SIL 300, Supplement 001 was provided to VY with GE's discussion on what will be the response of this gauge during power uprate. GE has stated that there should essentially be NO CHANGE in readings. Data collected during various down powersand post refuel indicate that this is probably correct.

Note 3: CR 2005-4023 reported that the 43A DP gauge was fluctuating. While not certain, there may be a small weep in the restricting orifice flange located in the drywell that is giving these fluctuating readings. Because it is located in the drywell, this cannot be confirmed.

On/About Jan 4, the fluctuating stopped and was reading -4.5. Since that time, the reading has again changed and, as of 2/13/06, is reading -3.2. CR 2006-0460 was generated reporting this issue. 1673 Mwth Data Recorded BY: Date: ____ 1673 Mwth Data Reviewed BY: Date: 1752 Mwth Data Recorded BY: Date: ____ 1752 Mwth Data Reviewed BY: Date: 1832 Mwth Data Recorded BY: Date: ____ 1832 Mwth Data Reviewed BY: Date:

.1912 Mwth Data Recorded BY:                                                 Date:

1912 Mwth Data Reviewed BY: Date:

0 VYNPS EPU Power *scension Testing 22 KV System Monitoring Plan

           .(2 pages)

VY EPU System Performance Monitoring Asset Parameter ID Action - Retioed ' e e, w ID (ERFIS) Levels 3 c' a N L in Date Time _ Expected: 17.95 KA Phase A Bus Amps (GO00) Design I Operating Limit: Evaluate 19.KA Expected: 17.95 KA Phase B Bus Amps (G007) Design / Operating Limit: Evaluate 19KA Expected: 17.95 KA Phase C Bus Amps (G008) Design I Operating Umtt: Evaluate 19KA Phase A Bus Return Air F Temp Local Indication Alarm @ TI-22KV-IA @ 176'F

                                                                                     > 160*F   Alert               Evaluate Supply           Local  Indication    Alarm @

Phase B Bus Phase °FI@ B Bus TI-22KV-1 B or @ 176*F

                                                                                     > 120" I 20F  Alert Evaluate TI-22KV-ID Phase C Bus             Return Air Temp  Local Indication Alarm @ 176'F            Alert                Evaluate
                                           -F          TI-22KV-1C                @ > 160*F isophase Bus Cooler A (TBCCW)      Outlet Temp 'F  Local Indication          Aert@ > 110°F                        Evaluate Tl-10t4-31A                                                 Eaul Isophase Bus Cooler B (TBCCW)      Outlet Temp "F  Local Indication          Alert @ > 11OF                       Evaluate              -

TI-104-31B isophase Bus Cooler A ITBCCW) Plow (GPM) Local Indication Ft Alert @~ < 90 GPM Evaluate 104-2.A Local Indication FI l Isophase Bus Cooler B (TBCCW) Flow (GPM) 104-2B Aler @ < 90 GPM Evaluate Local Indicatlon Ft isophase Bus Fan (GLF-I A) or (GLF- Air Flow (CFM) 22KV-3A or Ft- Alert @ <16000 CFM Evaluate 1B) 22KV-39 Thermography performed by Component Engineering 1593 MWth Data Recorded by: Dlate: Date: 1 1 1593 MWth Data Reviewed by: Date: I Date:----- I r 1 1 I -i--i -i--i--I 1 5 1 1 T nnicit 1673 MWth Data Recorded by: ~-l -~ + ~ I- I I Date: 0 1673 MWth Data Reviewed by: n f-~

                                                                                                   .1 1 I. I-                                      -1*

1752 MWth Data Recorded by:- 1752 MWth Data Reviewed by: . Ma 4-ý Nick LUsai Page 1 of 2 22KV System Engineer

VY EPU System Performance Monitoring Asset Pa t Parameter Alert/ Actions Parameter D ActiredNon 0 (ERFIS) Levels J Reuired na N <a ý Date Time Expected: 17.95 KA Phase A Bus Amps (GO06) Design / Operating Limit: Evaluate 19 KA

                                                                          - Expected: 17.95 KA Phase B Bus                     Amps             (G007)        Design / Operating Limit:      Evaluate 19 KA Expected: 17.95 KA Phase C Bus                     Amps             (G008)        Design I Operating Limit:      Evaluate 19 KA Phase A Bus               Return Air Temp  Local Indication Alarm @ 176"F           Alert     Evaluate
                                            'F         TI-22KV-IA               @ > 160'F Phase B Bus               Supply Air Temp  Localndication      larm @ 17F           Alert
                                             °F       TI-22KV-DB or             @ , 120OF               Evaluate TI-22KV-1D Phase C Bus               Return Air Temp  Local Indication   Alarm @ 176°F         Alert PF         TI-22KV-1C              @ > 160'F                Evaluate Isophase Bus Cooler A (TBCCW)       Outlet Temp "F  Local  Indication       Alert@ > 110"F             Evaluate TI-104-31A
              ~TI-1 Isophase Bus Cooler B (TBCCW)       Outlet Temp "F  Local Indication 04,-31B         Alert@ , 110"F             Evaluate Isophese Bus Cooler A (TBCCW)        Flow (GPM)    Local Indication Fl 104-2A Alert @  n 90 GPM           Evaluate Isophase Bus Cooler B (TBCCW)        Flow (GPM)    Local 104,.28 Indication F     Alert @ < 90 GPM            Evaluate Isophase Bus Fan (GLF-1A) or (GLF-                   Local Indication Ft Air Flow (CFM)   22KV-3A or Ff-       Alert@ < 16000 CFM            Evaluate 1B) 22KV-3e Thermography performed by Component Engineering 1832 MWth Data Recorded by:                                                                   Date:

1832 MWth Data Reviewed by: Date: 1912 MWth Data Recorded by: Date: 1912 MWth Data Reviewed by: Date: I I T - i I - t1 1 1 1 Nick Lisa) 22KV System Engineer Page 2 of 2

VYNPS EPU Power Ascension Testing AE / RWCU System Monitoring Plan (12 pages)

VY EPU System Performance Monitoring Asset Parameter Alert/ Actions C4 C

                                                                                                                            *" -     5    5              FR Parameter               ID                  Action                       Actions          cj    NN ID                                                                              (D        Reuie                                                     C-4 (ERFIS)                 Levels                      R       r       _    _)     D g?.

t- r.v v - to Date Time SJAE Off SJAE Gas Radiation (BOPMIO2) n/a n/a SJAE RM-17-151 Alert - > 1E-6 > 2E restore SJAE Off Gas CRP 9-10 Action - > 2E-5 2 to < 1E-6; CR Lin Rad (Ci/sec) OP 0150.03 [pg. 16] ODCM = 1.6E-10C/sec (TS 4.8.K.1 = ODCM] SJAE SJAESteam (T032) We n/a 2 Flow (Ibm/hr) OP 0150.03 [pg. 51 nana P1101-23 SJAE SJAE Press CRP 9-6 Alert <111, >119 <110, >120 OP 0150.03 [pg. 4] Action <110, >120 psig adjust PCV-1 CR 12-132 (RWCU) DI Inlet Conductivity CRP 9-4 Alert/Action - > 0.3 Notify Chemistry OP 0150.03 [pg. 8] CR 12-135 (RWCU) DI Outlet Conductivity A CRP 9-4 Alert - > 0.1 Notify Chemistry OP 0150.03 (pg. 8) CR 12-135 Conductivity B CRP 9-4 Alert - > 0.1 Notify Chemistry OP 0150.03 (pg. 8) TI 12-137 (RWCU) Pt 1 Temperature CRP 9-4 per TS Fig. 3.6.1 1C OP 0150.03 (pg. 8) TI 12-137 TI 1-137Isolate Demineralizer (RWCU) Pt 3 CRP 9-4 Alert/Action - > 140 F I rner OP 0150.03 (pg. 8) (RWCU) P-49-1A Amps 12-A-M1/M2 CRP 9-4A>5* AlertmAction lrf~to WR, CR CRP ~ > 52 Amps OP 0150.03 (pg. 8) 12-A-MlIM2 AtarI/Action (RWCU) P-49-18 Amps CRP 9-4 Amps " R, CR OP 0150.03 (pg. 8) >62 Amps (RWCU) Avg of Demin Flows GPM (3DMA009) na nWa Alert/Action CR RWCU Flow M# / HR (>009) > 0.060 mlb/hr AlertJAction RWCU System Inlet Temp F (2(B023) > 550 F CR RWCU System Outlet Temp F (113024) Alýert/Action CR

                                                                        > 450 F      enFowA M H(1)nan (RWCU) Demin Flow A          M#/ HR             (B017)                    n/a                          n/a (RWCU) Demin Flow B          M# /HR             (BO18)                    n/a                          n/a (RWCU) ROC              F/HR               (C039)                    n/a                          n_21a (RWCU) Flow i            GPM               (B054)                    n/a                          nWa Paranmeter                 Alert/                      Actions-            3 .1

m r . 9 F .

Ae Parameter ID. Action > t In ID . (ERFIS) Levels Required m , -- - Jeff Melvin System Engineering Page 1 of 4

V'Y EPU System Performance Monitoring Date _ TimeI RHX Outlet Temp F (B055) n-/a n1a to NRHX _______ NRHX Outlet Temp F (B056) n/a n/a (RWCU) Thermal Power % (BOP014) n/a n/aB A Flow F r-T-75A na i/ (RWCU) A Flow F Local [2801 nWa n/We_ I FT-75B (RWCU) B Flow F FT-75B n/a n/a Local [280'1n/ d0I8-94A (RVVCU) Demin A DIP F Local [2801 n/a n/a (RWCU) Osmin 8 DIP F dPIS-94e na (RW.___U)___etain____D__ ______ _ Local [2801 "dPIS-72A n/a (RWCU) Resin Trap A DIP F n/a Weoc-720 n/a Local [280'] (RWCU) Resin Trap B DIP F dPIS-728 Local [280'1 a / PI-2-3-60B Reactor Pressure PSIG S of Rk 25-6 n/a n/a RWCU Pump Suct P1-12-114 n PSIG Rk 25-2 n/a n/a TIS-112-89A (RWCU) 'A' Pump Brg CIr Out F Rk 25-2 nal/ TiS-12-89B (RWCU) 'B' Pump Brg CIr Out F2-2n/a na F Rk 25-2nan/ RWCU Pump Disch P1 87 PSIG Rk 25-2 n/a n/a Regan HX Out . P1-i12-95 I PSIG Rk 25-2 n/a n/a Non-Regen HX Out PSIG Rk 25-2 nWa n/a

R O TIS-12-99 W Non-Regen HX Out F Rk 25-2 n/a n/a NRHX (RBCCW) Out TC-104-5 n/a na HX(RBCCW) OuF Rk 25-2 n/a n/a TIS-12-115 RWCU Detin InletF Rk 25-2 n/a n/a P1-12-11M (RWCU) Demin Effluent PGR2-I n/a n/a

__________________ PSIG Rk 25-2 _________ ________ ______________________ ______ Jeff Melvin System Engineering Page 2 of 4

VY EPU System Performance Monitoring 1- 1 T - - Parameter Alert/ Asset Actions ID RI Action e Required c~Jm (ERFIS) Levels CN,4 mO CJ 0)~~~ Date Time _ SJAE SJAE Off W Gas Radiation (BOPM002) n/a n/a SJAE RM-17-151 Alert - < I E-6 < 2E restore SJAE Off Gas CRP 9-10 Action - < 2E-5 2 to > 3E-2; CR Lin Red (Ci/sec) OP 0150.03 [pg. 16] ODCM = 1.6E-1CI/sec [TS 4.8.K.1 = ODCM] SJAE SJAESteam (T032) W Flow (Ibm/hr) OP 0150.03 [pg.25] n/a n/a PI 101-23 Alert _1>9101 SJAE SJAE Press CRP 9-6 Aert <111,>11 <110 a >120 OP 0150.03 [pg. 4] Action '110, >120 psig adjust PCV-1 CR 12-132 Ntf hmsr (RWCU) DI Inlet Conductivity CRP 9-4 Alert/Action - > 0.3 Notify Chemistry OP 0150.03 [pg. 8] [TS 4,6.B.3.b] CR 12-135 (RWCU) Dt Outlet Conductivity A CRP 9-4 Alert - > 0.1 Notify Chemistry OP 0150.03 (pg. 8) CR 12-135 Conductivity B CRP 9-4 A - > 0.1 Notify Chemistry OP 0150.03 (pg. 8) TI 12-137 (RWCU) Pt 1 Temperature CRP 9-4 per TS Fig. 3.6.1 1 [ R OP 0150.03 (pg. 8) TI 12-137 (RWCU) Pt 3 CRP 9-4 Alert/Action - > 140 F Isolate Demineraiizer __________OP 0150.03 (pg. 8) WR/CR / 12-A-M1/M2 lerAction (RWCU) P-49-1A Amps CRP 9-4 > 52 Amps WR, CR OP 0150.03 (pg. 0) . 12-A-Ml/M2 Alert/Action (RVWCU) P-49-1 B Amps CRP 9-4 > 52 Amps WR, CR OP 0150.03 (pg. 8) (RWCU) Avg of Demin Flows GPM (3DMA009) nla n/a RWCU Flow M# / HR (C009i Alert/Action CR I 0.060 mlb/hr RWCU System Inlet Temp F (1023) Alert/Action>550 FCR RWCU System Outlet Temp F (B024) AleFr__Action>4_0_F CR (RWCU) Detain Flow A M# / HR (B017) n/a n/a (RWCU) Demin Flow B M# / HR (B018) n/a f/a _W (RWCU) ROC F / HR (C039) nWa n/a Jeff Melvin System Engineering Page 3 of 4

VY EPU System Performance Monitoring F r *rr - Parameter Alert/ Asset Actions Parameter ID Action _1 0, ID Required N -i rt 6 CN0 N4 D (ERFIS) Levels C'4. Moo

                           +                 +

Date Time (RWCU) Flow GPM (B054) n/a n/a RHX Outlet Temp to NRHX F (BOSS) We n/a NRHXOutletTemp . F (B056) n/a n/a (RWCU) Thermal Power % (BOP014) n/a n/a (RWCU) A Flow F FT-75A n/a n/a Local_12801 __________ _________ (RWCU) B Flow F I FT-758 n/a n/a dPIS-94A (RWCU) Demin A DIP F Local 12801 /a n/a {RWCU) Detain B D/P F dPIS-94 n/a n/a Local [2801 dPIS-72A (RWCU) Resin Trap A DIP FLocal [2801 n/a n/a (RWCU) Resln Trap B DIP F dPIS-72B n/a n/a Local [280'1 PI-2-3-6eB i Reactor Pressure PSIG S of Rk 25-6 n/a n/a RWCU Pump Suct P1-12-1 14 - n/a PSIG Rk 25-2 (RWCU) 'A' Pump Brg CIr Out TIS-12-89A n/a n/a - - F Rk 25-2 (RWCU)'8' Pump Brg CIr Out TIS-12-89B n/a n/a F Rk 25-2 P1-1 2-87 RWCU Pump Disch. PSIG Rk 25-2 n/a n/a Regen HX Out P1-12-95 n/a n/a PSIG Rk 25-2 Non-Regen HX Out P1-12-96 n/a n/a PSIG Rk 25-2 Non-Regen HX Out TIS-12-99 n/a n/a F Rk 25-2 ________ ___ NRHX (RBCCW) Out TC-1 0425 n/a n/a P Rik 25-2 _______ __ _ ____ RWCU Demin inlet FRS-12-115 2 n/a F Rk 25-2 _________ ___ __________ P1-12-113 n/a We (RWCU) Detin Effluent PSIG Rk 25-2 1593 MWth Data Recorded by: ___________ I ____ I _______________ Reviewed by: ____________________________________________ 1673 MWth Data Recorded I _______________ Reviewed by: by: ____________________________________________

I ____ 0 1752 MWth Data Recorded by: _____________ / - Reviewed by: * /..

1832 MWth Data Recorded / _________________

                                                                    / _________________Reviewed by: _________________________________________________

by: __________________________________________________ 1912 MWth Data Recorded by: I Reviewed by: I Jeff Melvin Page 4 of 4 System Engineering

R'TIME (DO NOT EDIT!) ......... --n:9-os -, . -. ~14 Point ID BOPM002 T032 3DMA009 C009 B023 B024' B017 B018 C039 B054 B055 BOP014 RWCU SJAE INLET OFF RWCU RWCU RWCU RWCU TEMP RWCU RWCU RWCU GAS SJAE RWCU SYSTEM. SYSTEM DEMIN DEMIN RATE RECIRC REGEN LOOP ACT STEAM SYSTEM RWCU INLET OUTLET FLOW FLOW OF PUMP HX THERMAL Point Description 1AV FLOW FLOW FLOW TEMP TEMP A B CHANGE FLOW OUTLET POWER Engineering, Units LB/HR GPM MLB/HR DEG F DEG F M#/HR M#/HR F/HR GPM DEG F 2/01/06 .11:21:00 4.81 10657.03 64.74 0.06 510.82 445.27 0.03 0.03 0.01 154.49 184.35 1.43 2/01/06 11:22:00 4.89 10667.19 64.80 0.06 510.74 445.27 0.03 0:03 -0.19 154.49 184.16 1.43 2/01/06 11:23:00 4.85 10659.38 64.92 0.07 510.63 445.15 0.03 0.03 -0.12 154.49 184.21 1.44 2/01/06 11:24:00 4.87 10647.65 64.96 0.06 510.71 445.23 0.03 0.03 -0.99 154.49 184.45 1.43 2/01/06 11:25:00 4.85 10661.72 64.83 0.06 510.98 445.19 0.03 0.03 -0.94 154.49 184.12 1.43 2/01/06 11:26:00 4.94 10688.28 64.99 0.07 510.90 445.27 0.03 0.03 -0.77 154.49 184.64 1.44 2/01/06 11:27:00 4.88 10648.44 64.76 0.06 510.78 445.23 0.03 0.03 -0.38 154.49 184.16 1.43 2/01/06 11:28:00 4.89 10633.59 64.83 0.07 510.90 445.19 0.03 0.03 -0.18 154.49 184.16 1.44 2/01/06 11:29:00 4.85 10644.53 64.79 0.06 510.82 445.19 0.03 0.03 0.40 154.49 184.16 1.43 2/01/06 11:30:00 4.84 10619.53 64.89 0.06 510.86 445.23 0.03 0.03 0.73 154.49 184.21 1.43 2/01/06 11:31:00 4.85 10654.68 64.94 0.07 510.94 445.47 0.03 0.03 0.62 154.49 184.45 1.44 2/01/06 11:32:00 4.93 10631.25 64.78 0.06 510.75 445.27 0.03 0.03 0.68 154.49 184.26 1.43 2/01/06 11:33:00 4.88 10674.21 65.02 0.06 510.78 445.31 0.03 0.03 0.44 154.49 184.16 1.43 2/01/06 11:34:00 4.80 10640.62 65.03 0.07 510.86 445.23 0.03 0.03 0.00 154.49 184.49 1.43 2/01/06 11:35:00 4.95 10658.59 64.94 0.06 510.63 444.99 0.03 0.03 -0.58 154.49 184.16 1.43 2/01/06 11:36:00 4.87 10647.65 64.77 0.07 510.82 445.11 0.03 0.03 -0.58 154.49 184.26 1.44 2/01/06 11:37:00 4.83 10664.06 64.95 0.06 510.90 445.11 0.03 0.03 -0.65 154.49 184.16 1.43 2/01/06 11:38:00 4.82 10677.34 64.91 0.06 510.78 445.15 0.03 0.03 -0.53 154.49 184.07 1.43 4.87 10628.90 64.70 0.06 510.86 445.15 0.03 0.03 -0.25 154.49 184.21 1.43 2/01/06 11:39:00 4.87 10685.15 64.88 0.06 510.94 445.23 0.03 0.03 -0.08 154.49 184.17 1.43 2/01/06 11:40:00 4.85 10629.69 64.84 0.07 510.82 445.19 0.03 0.03 0.16 154.49 184.26 1.44 2/01/06 11:41:00 184.21 4.87 10678.91 64.74 0.06 510.86 445.23 0.03 0.03 0.51 154.49 1.43 2/01/06 11:42:00 4.80 10653.91 64.83 0.06 510.82 445.11 0.03 0.03 0.07 154.49 184.16 1.43 2/01/06 11:43:00 4.90 10667.97 64.81 0.06 510.86 445.31 0.03 .0.03 0.07 154.49 184.54 1.43 2/01/06 11:44:00 4.84 10670.31 64.88 0.06 510.98 445.27 0.03 0.03 0.00 154.49 184.12 1.44 2/01/06 11:45:00 4.88 10654.68 64.94 0.06 510.98 445;19 0.03 0.03 -0.02 154.49 184.21 1.43 2/01/06 11:46:00 4.91 10655.47 64.88 0.06 511.17 445.15 0.03 0.03 0.16 154.49 184.40 1.44 2/01/06 11:47:00 4.85 10657.03 64.87 0.06 510.90 445.27 0.03 0.03 0.31 154.49 184.36 1443 2/01/06 11:48:00 4.85 10652.34 64.92 0.07 511.05 445.27 0.03 0.03 0.46 154.49 184.21 1.43 2/01/06 11:49:00

2/01/06 11:50:00 4.86 10636.72 64.87 0.06 511.06 445.35 0.03 0.03 0.55 154.49 184.07 1.44 2/01/06 11:51:00 4.89 10643.75 64.86 0.07 510.75 445.27 *0.03 0.03 0.80 154.49 184.26 1.43 2/01/06 11:52:00 4.76 10660.94 64.76 0.06 510.86 445.23 0.03 0.03 0.74 154.49 184.26 1.44 2/01/06 11:53:00 4.91 10653.91 64.80 0.07 510.82 445.27 0.03 0.03 0.28 154.49 184.26 1.44 2/01/06 11:54:00 4.95 10667.97 64.98 0.06 510.94 445.15 0.03 0.03 o.f 0 154.49 184.16 1.43 2/01/06 11:55:00 4.77 10671.09 64.87 0.06 510.78 445.23 0'03 0.03 -0.22 154.49 183.98 1.43 2/01/06 11:56:00 4.89 10690.63 64.96 0.06 510.78 445.23 0.03 0.03 -0.22 154.49 184.40 1.43 2/01/06 11:57:00 4.88 10649.22 64.85 0.06 510.59 445.11 0.03 0.03 0.16 154.49 184.21 1.43 2/01/06 11:58:00 4.79 10644.53 64.93 0.06 510.90 445.27 0.03 0.03 0.09 154.49 184.12 1.43 2/01/06 11:59:00 4.89 10642.97 64.64 0.06 510.94 445.23 0.03 0.03 0.00 154.49 184.21 1.43 2/01/06 12:00:00 4.79 10657.81 64.82 0.06 510.71 445.31 0.03 0.03 0.03 154.49 184.17 1.43 2/01/06 12:01:00 4.88 10645.31 64.91 0.06 511.09 445.23 0.03 0.03 0.24 154.49 184.16 1.43 2/01/06 12:02:00 4.88 10668.75 64.88 0.06 510.82 445.11 0.03 0.03 0.10 154.49 184.17 1.43 2/01/06 12:03:00 4.77 10663.28 64.76 0.06 511.01 445.23 0.03 0.03 -0.29 154.49 184.21 1.43 2/01/06 12:04:00 4.75 10649.22 64.79 0.06 510.90 445.27 0.03 0.03 -0.17 154.49 184,07 1.43 2/0.1/06 12:05:00 4.90 10628.90 64.90 0.06 510.86 445.31 0.03 0.03 -0.07 154.49 184.17 1.44 2/01/06 12:06:00 4.86 10642.97 64.84 0.07 510.94 445.39 0.03 0.03 -0.07 154.49 184.21 .1.44 2/01/06 12:07:00 4.85 10665.62 64.93 0.06 510.67 445.19 0.03 0.03 0.30 154.49 184.12 1.44 2/01/06 12:08:00 4.83 10670.31 64.74 0.06 510.97 445.27 0.03 0.03 0.23 154.49 184.21 1.43 2/01/06 12:09:00 4.79 10650.78 64.87 0.06 511.09 445.31 0.03 0.03 0:33 .154.49 184.02 1.43 2/01/06 12:10:00 4.86 10633.59 64.94 0.06 510.82 445.43 0.03 0.03 0.27 154.49 183.98 1.44 2/01/06 12:11:00 4.79 10642.97 64.94 0.06 510.90 445.19 0.03 0.03 0.18 154.49 184.07 1.43 4.87 10696.87 64.79 0.06 510.94 445.23 0.03 0.03 0.06 154.49 184.12 1.43 2/01/06 12:12:00 2/01/06 12:13:00 4.81 10671.09 64.87 0.06 510.78 445.15 0.03 0.03 -0.25 154.49 183.98 1.43 2/01/06 12:14:00 4.81 10658.59 64.80 0.06 510.98 445.35 0.03 0.03 -0.20 154.49 183.98 1.44 4.82 10642.19 64.87 0.07 510.94 445.31 0.03 0.03 0.04 154.49 184.26 1.44. 2/01/06 12:15:00 4.80 10667.97 64.88 0.06 510.67 445.19 0.03 0.03 0.07 154.49 184.45 1.43 2/01/06 12:16:00 2/01/06 12:17:00 4.87 10636.72 64.87 0.06 511.13 445.27 0.03 0.03 0.09 154.49 184.16 1.43 4.80 10667.97 64.91 0.06 510.82 445.27 0.03 0.03 -0.18 154.49 184.26 1.43 2/01/06 12:18:00 4.80 10643.75 65.06 0.06 510.82 445.19 0.03 0.03 -0.09 154.49 184.16 1.43 2/01/06 12:19:00 4.82 10650.00 64.93 0.06 510.94 445.31 0.03 0.03 0.07 154.49 184.03 1.44 2/01106 12:20:00 4.91 10666.41 64.84 0.06 510.86 445.23 0.03 0.03 0.07 154.49 184.17 1.43 2/01/06 12:21:00

Open .xls from R*Time Highlight Cell Al R*Time Archive Date. Parameters (4037 for 1.4 days @ 1200)

SJAE Off-Gas Act (BOPM002) 5.00 4.95 ____ 4.90 - . - 4.85 4 .8 0 " .. .. .. . .. 4.75 - 4.70 - 4.65 00° 00 00o 00 00g 00 o o9g c?=o 00 0 c . 0 Q . -* .. 0 0 00 0 , SJAE Steam Flow (T032)

. (00 ~ COO (nO (no (nO (nO (nO (nO (nO (nO 00 ~0 00 00 00. 00 00 00 00 00 00 o~ O~ ~ o'~) o~ o~, o(n 00 00 o' 0~

0~ ~ .

RWCU Flow (3DMA009) 64.95 64.90 E4.85 64.80 64.75 64.70 64.60 I ... ....

           .0                                                0 0

( P oC Q01p~o 0 00 0 0 RWCU Flow (C009) 2 0.06 - IN

                     .,       c         oo          coo co coo               o. co RWCU Inlet Temp (B023) 511.30 511.20

___11n 511.00 510.90 510.701 510.60 510.50

     .510.40 510.30 0

00 o" o o(' W 0 0

RWCU Outlet Temp (B024) 445.60 4 4 5 .50 -. . .. . 445.40 445.20 IL. LL445.10 445.00 444.90 444.80 444.70

              .0   co* . ,fo  ,0   (lo    Co   ,OO   Coo tOO toO

RWCU Inlet Temp ROC (C039) RWCU Pump Flow (B054) 160,00 10q

RWCU Loop Thermal Power (BOP014) 1.45 144 1.44. A A A gg AA r-g ' 1.43 VV 1A3 1.42 (DO o (DO ~~ O DO CO (O (n it (0

VYNPS EPU Powe" Ascension Testing Feedwater Control Sy~tem Monitoring Plan (2 pages)

rdrn.600100006 EPU Steady-State Nominal Operating Conditions PID ORFISl 6sySI~ I (E(~ 7 L [I P 74Urm] ) CLWP 1%). PP (7/.] CLIP [%)3I60141'/.I CLTP 1%)2EPU[-%] CI - 1%1 IP ~J 1%] CLTPri%) EPUr) CUIP[%jI EPU[%I CL1[- I% LT CLTPVA) EPU16%1 I Nnin0146610 0.01-68. 3 1- 1011.0 83.3 I100.6 854 1oo aC n 4, RonA I0. 110.6 ai~a -a 16 .11 l~ o I Actual 6.4i7 6.475/ >> A.LERT << >> ALERT << I >> ALERT << 4.~. -- I 4I ".~.6>

                                                                                                                                                                                                                                                '    6~.~.??I      tkj.,flI>4
                                                                                                                                                                                                                                                                      ~       CC    SC ALLRI        CC A0.0DT~..
         .0opSIC St...

L065 SC65 11,l1c/nrl FIow Pedlc4ed 1.815 1.815 . - 1.66 " 1.705 1.750 1.76 .4 1.541 14885 1.931 1.9T7 6066 (baseline/4) - Act1ua 1.615 1.615 >>ALERT <<

                                                                    *                                                                    >ALERT <            >, ALERT<<            .>>   ALERT<                    ALERT <<

,- ALER << > ALERT ALET << >> ALERT R < > ALERT <

L04AIDSteam Flow Predicted46 1.690 1.670 1.738 t.78 1.835 03 11.0"

                                                                                                                                                                                              . 8 11                 1.627
                                                                                                                                                                                                                      .                       1.9 75                . 2.0 22                2 .0 69      -

05 JM iha 41rq 1. 3 1. 6. 6067 (bal-fin/4) -1.047 ActuaI 1.699 1.699 >1 ALERT << >> ALERT << >, ALERT < o>> ALERT C< >> ALERT-CC >> ALERT < >> ALERT CC >> ALERT << 1Tota Feed Flow[MtbohtI Predicted 8 .430 5,430 6.51t 6.792 .5973 7.154 7,335 7.516 7.697 7.70 Act-]I 6.448 6.448 >> ALERT CC '>ALERT C< >> ALERT << >> ALERT << >> ALERT << >> ALERT << s> ALERT cC , > ALERT << B0O1 Loop A Feed Flow (Abvdhr) Pediced 3.264 3.264 3.356 3.448 3.539 3.631 3.723 3.815 3.607 3.868 [bsln)"1.0152 I (A/5l 3.264 3.264 ALERT >> ALERT C >ALERT C >ALERT C<< S ALERT C ALERT ALERT >,

                                                                                                                                                                                                                                                                                              .3 ALERT CC 63016    -P   B F.-I FlowoIM1I-1         Predld.d                    3.168                    3.18"                     3.275                   3.365              -3.45                     3.564                   3.634                   3.T24                    3.814                 3.604
                                           .Actul                   3.185                    3.185              >> ALERT <<              >> ALERT            >>                     >> ALERT> -               >>             -         >, ALERT                >, ALERT                   ALERT letetet<

rtERT> 9,60a "A Feed (VeIu) 0emand1 %) Prdiced II*6' 48.50 42.00 45.25 48.50 515 - --- . " 58.25 61.50 (3 11ed pump baseline) 64.75 66.00 ActualI 48.48 ALERT ALERT 48.48 >> ALERT << >> ALERT ALERT ALERT CALERT ALERT B601 'S. Feed (Valv.) Demond (%] Pedicted 48.50 42.00 42.25 48.50 51.75 85.00 58.25 51.50 64.75 68,00

1. reoopumop ba0.110) Actul 48.51 >> ALERT < >> ALERT << 48.51 >> ALERT << >> ALERT << >> ALERT ><,CALERT << >> ALERT -C CO ALERT <

8062 FRV'A4 Stem P<, i-1%) P1edic.d I 40.50 42.00 45.25 48.50 51.75 . 55.60 58.25 6152 84.70 66,0 3 F 6-1.) ActualI 47.83 >> ALERT C< >> ALERT << 47.83 >> ALERT << >> ALERT << >> ALERT <,o >> ALERT << ,> ALERT << >> ALERT << FRV'6 St.. P o no(%] I Prodided I 46.50 42.00 45.25 48.50 51.75 58.00 1.25 61.50 64.75 68.00 (3 tend pump baseine}) ctual 47.50 ...- ALERT 75 >ALR <4.0 - ALERT 47.50 '> ALERTCAERTC-< > ALERT << >> ALERT -< >> ALERT < >>AET <<< > CALERT-c LR , -- AULPREDICTED D0T000500ESU-11 N 000XT,.c-TIO061166651503 0401.12 -- Vale Re66rded By fI0.t Data Recorded By / Date 1673 MWIh 17562 MWlh (07.5% EPU) (91.6% rPU) Data ReviewedBy I Date Data RaevewedBy I Date 0 Data Re0orded By IData Data Recr.ded By I Date 1832 MWth 1912 MW6h. (95.8% EPU) (100.0% EPUE V.I. Ra60606dBy1 D04 Data R6v.ewed By IDate 00,010#44.16,0616517160, 60640002Cy016 7.000.160 0..,00 4144010C?0 104.160,600116,0 Epus.M-l M.ý-Sl* 3 6101.16160661M00i'~40I

0ra000 820000

                                                   -MR-2        Poo*          O=o2a00 0ridbota2 hd,                              0      s0.ol System      Functions:                     MR-3        Pro000 5*t0           y    -0000. bpu= IW0   ýo*nbal  p-.r   00.02000 OAR-S        Foid.e Son       ,oooxbW.I oksod, odol bt. r0400u1   on     000.000(000]oym                          ________________

ECMjnord.0.o E~aomf2 0200 0004CdU1 psmetotr 0*0050,0.0 , ,, F..5

00.20 tAoo.0205 Rail. 0000r500/

SYSTEM SysmR NO MROO U0.0800 NIA T U , 4%13-pýed M04.4, ScOpobp B",0 SYSTEM Sy. No. R Re.

                                                                                "iy                    WA           T         M         3 MRFTF    I -yoorp01o0          M04.4 .500pn Baas STEWO  FLOW   ?P                                                    S... Ro D.         ?P.         ERFRS                          ICLIP: -1,0      Mut      IOj         R             nd
                                                                                                                                                                                         -W        PSS; TRA004ITTERS:               FT-O-51AO001 00           Ss            SLOOmFAhr.                        0022          M,          W NT    CUPU  -l.820M644..o@ 00%]                                     P 00'                                                                               04-0?PO6 806"067                                    1080 Mft011 00%                    C LOOPS ATH*OOG*

STEAMFL* ERFIS 0LPOJFIERS I SQUARE FT .- 735 Y-5 CSr R- 22CLTP: - 1.620M00 100%) E Co 1000 PSS:p0o02,02W ROOT EXTRACTORS; Los At-Do 068EPUJ: 30M 1.980 Mi 00o0o%] CT? LOOPSA 0HROUGH DI ITO7ALSTEAMLOW .ERS M11 ITOWS- 6.4,60640 @00 1%] Co. s.W P5580.; 010Wo. SU4MMER ,,,m 0022C000 T EPU:-7,.100Ml0,@1-% 1=1 CO FEEDFLOW?P TRoANSMITTERS; FT-6-5U/ 500 YTo Food RA-t BOF ERF.S 1 W D JCLTP:-3200 MEL0t@ 100%] ERF C0 CTPorolt PSSP06oo0000 Lo Atot8 8015.9016 IM:-3.OAOMa.@O0%] COO LOOPS AAND B 00 F-EEOWATER FLOW . AMPUFIERS ISQUARE FrA--110ID 110 II eB FR o FYod

ERFIS ICLIPS- 3210 MI0W,@000 I000% CO-r T. Y!,0I PSS; po00o1o.2 W ROOT EXTRACTORS; LcA AO 0 005.B010 0W0 MIT 0 (EPu: - 3.9400 .00tr 00%l CTP. 200 " Cm0D.

LOOPS A ANDB TOTAL FEEOWATER FPAA-l03 Too ERFI , CLTP - 6.430MhORo 1000] Cot 0000000000)0 PSS;0.0o01 w FLOW SUMMER cool EPA: - 78A0kb00 @ 100% E COP STEMFLOW - FEED SW-w IFed F-w ER a LOWE:RROR FPA0..74 YC Ol2, C*00; W INtWl ERRS Co..01T.0m00d W. PSS AM4PUIFER,,j 12 VESSEL WATER LEVEL ".vD 0 01-S*

                                                                                        ,E.01           RSC.                                         5                               000200004 PS;oboeot IP TIAN2BAT  F.JAO8          L5-0-520   2             To,                C        A as             0B04B  06,0     64I        0W              lS. 16      b               ES     c-apr     "

C.KAHNELSAAND6 LELEMENTERROR FpM106 Tl L-. 0 - P0o E0FIP RAMPLJRAR S00_01.5.000040008PoA 0000,8000 "TDWEFS .TW S MASTER WATER LC-0-03 Yft M0s0. F-d Ro- 0 ERRS M 0T D000W- ERRFS 00,0.400PS5 LEVEL CONTROLLER 006000Bo INDf0DUAL WATER ERFIP. CLad IP.4B [CLTP: - 47%C 100%(2 punl0 LEVEL CONTROLLERS RC-4A 0000 Yo O. 002 ER W - 42% @ 100%1300600)) ERFIS C-t bb00.d0.0*O* LOOPS A ANDB -M0.: Io% D00%(300.00)] RVPOSITIONa ERRS rCLTP:- 47% @ 100%(2 pbmps] 0P-20 Too P00l-A.n0 PV ; 0 063 R62.8 MT -42% @ 100%(3 1)) ERFIO C*t "so1lm. 04 PS. LOV A00*4 POS LOOPS AND 0EB1 FRVAd -"]EPU: - 68%@ 100%(3 i00 00 0 8 4 - . __________ F-]-----4-----~ 0 4-NOW0: P4.0Lwo, = GoboE- r E4S5 (> - 51%/6 D00000 00 noo a 100%C'M Aco - OW-MfgalW Cos aOVO, btso Monxw NOW 3 L5bA

MO. " W, REF' P-000 5 ;- -5 b-1000 M0 000002 0000200200 Iso-00 01 \AwOhored lOle IoartoooOSolt n EooloeerinoL'Svs1em Peoboooon* ortoE42040011050004 PA~o3:Ssooleoomerot.MoO0l0Pgo 0EPU Potstls 6oo.0oo 10d0 \lwAooAodO~looo*leosr n~LosooroEmnssoiooelroml~ PodonoooM soolopo0M OO*E00EPU possser oAsco ~ds 500l010PottSOO Em .,

Pors-s. M0015.010051oo5.OSV _Sn0 oý IAV Syssot0

VYNPS EPU Power Ascension Testing Nuclear Boiler System Monitoring Plan (2 pages)

Equipment Equipment Para Alert and Action Actions .1593 1673 1752 1832 1912 Name No.1lD ID Action Level Required Reason or MwTh MwTh MwTh MwTh MwTh Parameter Source Fren Level other info S00,S001 Recorded Mrotor Level 4 S002,S003 continuously Alarms at MG Set Motor and S004,S005 Incorporate 220F, Gen High temp Generator Winding data Into xAs alarms at degrades - Recirc MG Set MG-i-iA/B Temperatures S006,S007 ERFIS and raph 240F -Evaluate - Insulation Recorded continuously / High temp MG Set Motor and incorporate indicates Generator Bearing data Into xAs Alarms at bearing Recirc MG Set MG-I-1A/B Temperatures S035-S050 ERFIS and graph I6OF Level 4 Evaluate degradation Tecorded '" continuously! Incorporate data Into Als Com pare to Recirc MG Set MG-i-1A/B Vibration N/A AP-0211 and graph baseline, Level 4 Evaluate basesmed (. 1593 MWth. Recorded - Continuously, Incorporate Compare to Recirc MG Set MG-I-iA/B Thermography NIA AP-0211 Data Into DB baseline Level 4 Evaluate Recorade continuously / incorporate Recirc Pump data Into xAs Per OP. Motors P-18-lA/B Vibration N/A AP-0211 and graph 0211 Level 4 Evaluate Recorded continuously / incorporate Recirc Pump Winding data Into xAs Motors P-18-1A/B Temperature N/A ERFIS and graph 216F Level4 Evaluate Baseltned_ 1593 MWth, Recorded Continuously, Recdrc Pump Bearing Incorporate Motors P-18-IA/B Temperature N/A ERFIS DataintoDB1160F Level 4 Evaluate Recorded continuously / Incorporate Seat Stage TM-2003- data Into As Recirc Pumps P-18-INB Pressures N/A 023 and graph Deviation Level 4 Evaluate continuously / incorporate Seal Stage data into Als Recirc Pumps P-I-8-1AB Temperatures N/A ERFIS and graph 160F Level 4 Evaluate

Per Jet Pumps A-K, L-W Pump dP N/A OP-41 10 Daily Level 4 Evaluate OE 17950-The M-ratio of a _jet pump is its suction flow This Is divided Proposed by its add to OP Per drive Jet Pumps A-K, L-W M-ratio N/A 4110 Dally Procedure Level 4 Evaluate flow.

EvaJuate I Tallpipe Per OP- repair I SRVs Tailpipe Temp Baseline Dt ERFIS Continuous 2122 Level 4 rebasellne Dally Pressure Drywell Unidentified (recorded 4 Per tech Per tech Boundary Leakage N/A OP 4152 times daily) spec Level4 spec
Steam Dryer Moisture Carryover N/A Sample Per STP Attach 4 Level 2 Change from GE SIL 644 Steam Dryer Dryer Failure Numerous ERFIS ON 3178 baseline Level4 Investigate Supp 1 from AOGRecombO2 CP-HWC-5 02% _10% to <15% OP 0150 OP 2199 baseline Level4 Evaluate 1673 MwTh Data Recorded By: Date:

1673 MwTh Data Reviewed By:__ Date: 1752 MwTh Data Recorded By: Dale: 1752 MwTh Data Reviewed By:__ Date: 1832 MwTh Data Recorded By: Date:_ 1832 MwTh Data Reviewi d By: Dote: 1912 MwTh Data Recorded By: Date: 1912 MwTh Data Reviewed By:.__ Date: NB EPU Performance Monitoringi Plan

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VYNPS EPU Power Ascension Testing HVAC System Monitoring Plan (2 pages)

EPU Supplemental Performance Monitoring Plan for the HVAC System

                              -                                                                l      Increased Power Level Evaluation Points Previously Monitored      Equipment No.          Parameter Al arm Alaim Level 1593 MWThi MW    13             f 1673 MWth 1752 MWth      1832 MWth 1912 MWth        Source Mon   itored              *   .           Values/L    mits(83.32%-                   (87.48%)     :(91.65%)   (95.8% )    (100%)

x 2 Computer DWelevation Average250' Temp <135 °F 4 "YOPF 4115.05 Points 10 Computer DW Average Temp <150 °F 4 VYOPF 4115.05 _________ Points below elevation 270' < 150 -F 4 VYOPF 4115,05

                 .6 Computer     DW Average Temp           < 185   0F 4

__________ Points elevation 270' to 315' < 185 *F 4____4150 X* 4 Computer Points DW Average Temp above elevation 315'

                                                           <270 °F           4                                                                   VYOPF 4115.05
                                                           <_270_'F_4___                         ____4115.0 MNSMT--VM-1                                                                                                                                2-1 X            MN STM TE    Steam Tunnel Temp          < 160 oF          4
                     .126A.                              .                                                                                          CRP 9-21 HPCI TE     HPCI Steam Tunnel                                                                                                   VM.-12-1 X                  105A            . Temp               < 175 *F          4                                                                      CRP 9-21 HPCI TE    HPCI Steam Tunnel          <1750 F           4                                                                       VM-12-1 105B              Temp                                                                                                        CRP 9-21 RCIC Steam Tunnel                                                                                                    VM-1 2-1 X           RCIC.TE-13-77A           temp<...

Temp 175 'F 4 9-21 CRP 9-21 RCIC Steam Tunnel VM-1 2-1 X RCIC TE-13-77B Temp < 175 4 CRP CF 9-21. Feed Pumps Room <105 'F 4 Hand Held TB Rm B-6 average temp Thermometer

                                                           < 105 F           4Hand                                                                         Held TB Rm B3       Cond Pumps Room TB__m__-3_average temp               _                                                                                          Thermometer EPU PATP - HVAC Monitoring 02/25/2006                                                                                                                                   Page.1 of 2

EPU Supplemental Performance Monitoring Plan for the HVAC System 1593 MWth Data Recorded By: Date: 1593 MWth Data Reviewed By: Date: 1673 MWth Data Recorded By: Date: 1673 MWth Data Reviewed By.: Date: 1752 MWth Data Recorded By: Date: 1752 MWth Data Reviewed By: Date: 1832 MWth Data Recorded By: Date: 1832 MWth Data Reviewed By: Date: 1912 MWth Data Recorded By: Date: 1912 MWth Data Reviewed By: Date: 0 EPU PATP - HVAC Monitoring 02/25/2006 Page 2 of 2

() VYNPS EPU PowerýAscensionmTesting Motors Monitoring Plan (25 pages)

le.-Ve.oft Entesry N105 Yeesk-Power Uprato Power Acocntlon Tasting Parformanne Monitoring Plan 10033cph~v . 1712 4,.. 1 752

                                                                                                                                                                                     ',.1               17.2+~-v    > 82                  - 1072. 112 8542 v~~Si~E            856%1          s4~~E                9~20.

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                                                                                                                                                                                .           TInm: Dole:
                                                                                                                                                                                                   ..       Im. : Dow      v..

1 lime , Dale Time, °" Dole: EcPowrP levl Evaluate motor (VIS}audible hold point CE, SE Evaluate cater18 ontiwodles, noise. VlI Vibration Motes AP 0211 2115. E0th Por ISI level CE mE r-,,lott dmotor VIa 2120 hold pntddln S A MoIor 8 Molers C Motor Vsbr.LioePump AP 0211 CSI 2115. Eaeh P.-wer leel Evaluate Pump Via 2120 ts nlsc olol CF m.Odal ondgltion A Pum B Pr*m C Pump Thermogrephy Tlhomgsphy Eelh Power level E Ho spots Investigtel cuse of aTh-mes hole eolme <10De c Won tem. T Pur,.p earng emp ERFIS Points E.ch P-1.e, CeEes 160-deg F (20004d. Driven hold point C FPEPUI 212 S/D A W028 B WO32 W034 gcC W 9 O40 W034 B~ wodS CS FP-212 0 d! ER R S P oitssl Ea ch P o csr l e cl P ump aoron n e Tamp , Opp.. hold pin F EPU 212 S/D A _w52g _ S VV035 C W041 Motor Thsse '.Bearisg ERFIS Poinssi Each P-oerl-1 CE Oýdeg P 12O0<dog Inva*tigat ecauef Ilsev) Temp WC31, Wo03. W043 hold point F EPU] 212 SID high tamp IS-T..m A W031 c WO43 otorGPide b.tg SodEP.- "1-1 178Ideg F 1205'dog lnooligsu 0ceu0of Ml32, W038. W04d hold int CE EPUI 212 SOD high tamp W032,wawo- heP.pi masITao c* W044 Winding Temps ERFIS Points Each Power.,ee500500 DOGC 0000 Intelile 0,8u00o (W-TempI E028. E027, EO28 hold pcicl 100.-p EPU' high teomp A E026 E027 Equipment Status MotoreCE Evoluote motor Jud:eme PM mlol condition (Equip.Status) Corremm._ lo

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 .pp-I    Be..ng T0.-      ERFIS Poinl.

(B-T..p) E067 0000

      -IC                       E071 Lo.r bedng Temp          ERFIS Points

(-,Tamp) E006.E070,E072 A - EO8A 8 E070 C - E072 Winding Tempe R*F{SPom* (W-Temp) E020,E030, E031 A E031 5- C I E030 031 Equipment Status unginerng (Eauio. Stats) I Judaemint Colmm.lS 0

U ~ Unp'Peering io-Mpj ifkAS PoinsWOW. j tS.Tenn,) IW047. WO4S A Wo04 C i Wang

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begaringTbow* I ERiFIS WR4I. Points WO*WOOS. OM A WOO B - woog C W050 EquilpoeniS1o.1u Eogineenng (E.WE. SlsluO I Judogotont Conmments

olidii.liGiol2di i diA~,Mi idOlS lRS7d)Ai.kAlhod h dO VUSInpoh S levl Muhr. r. CEs ,ops E*,rdl'ul Eouluele ebo VISl_ aholdon rdllon Vibrtieon AP 0211 CSI 2115, OEh PowerlaCel bIywi tE..e pdotor 2120 hold oinlf CF hulde dtlon-(VIBI

0 ERFISPoints A: F000. F0O ,lF072 In-.Ii .1.

h of E.h Pow.r -1 CE 220 dug F

-'JW:di (W.-ltump)         F084. F065' Foaa        hoSF0d.FOS.oFSS                              nohlghl 0000 p C: F067. FOSS,FOBS         hold poigl 0: F061. F062. F03 A                 A:FOO "A                A: FO71 A                 A:F072 B                 B:F064 B '               B: F066                                                                                 ______

B 58FOSS ____5 :FD67 c C:F0m7 C C: FOOS

0 D:F061 _______

C D:FOSl Evluaite motor1 Pump Armperege OP 0150 SE 032 Aopo Oleurl 1o.ndlon A I D I Equipment Slatus Englnoedng EeIh Fow.ertaCEl EooCoue .o..o hold pogb material ondilon lEuup, Sloluo) Judgeme-l c ml~t 0

            .o..Io  SE01       Lss   . CEs~p                         EnatraF I

u .1. to, SGdtttt Freq.ony PlantOtq AlertAntlon Is-1i j 551005 ViIoSInpol SE. CE Lest Power snot M.cml.E, CE.SEops rvolve!. Eveloetstoonilon - - (Equip.srSta1uns Endg.-Iern Lest Power 1-1t Motor CE ntE"s -rtjon' _______ EqC. Ssut Jdsst _________ __________________ ________

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VAchPow 1.v0t CE by othEm (VIba hold m81tdal

                                                                                                  -in0       MoAdIon B

Pump bearing ERFS pots 606. , l trmp-lrs.. @ S071. M134. S 2, hold poerl CE speed 5074, M135 A M134 _:A A S060 A A: S071 B M135 ___0: S072 h B:SO74 o nrUpp.r S dg ERFIS Pints Sa51. Eoch Power oval CE 140 d.9 - lnvwaligal. .. u of t T052. S053. S054. hold point high amp A S051 A S082 B5053 8S054., Me.o- L.W.. b.arng ERFIS Polt. SM05. Enh Powerle~a CE 140 dog I 00000ofrnvigama Tw SOOO, S0 7. SOSB hold point high .amp A I $0557 B Soso WidigTemps iRFIS ,i PolnlsoS05e 00(.1010*S6,C Eaoh PowenrIasal 222 eo Innvotighat00000of W-VV-T np p) I SO063.

                                  .'SO Shod
                                         . g0.          holdp052.lg,1-Ig' d pon                                       high lorp u

A sos0 A S0At A I060 Equipment Sslas Enginfeerng IEho Power laai Motor CE ooluote 1m0,tr I I fEgoip. Stoatus C.-M. Judqemen hold point _ _ts_0 l condltlon M -- i

Source~lI Foquecop Pictr AME~clui 1/ealIreatrc CE, SE Los pow1.tao Moist. E, CESEo.ps Evaluate Emicate motor (C'S)______________ ______________ ______________ matrielconrdition ______ Eouipmorr Status Engicosarngi otp ,1 1 MtC Ecetuar motor (Equip. Stotust I Jtgmrt totpm c, MtrC eratarialcourdllon Comments Paramarar socrc Frqoacup Pl.ot OrtI Al. olAo....etlso Rtsponea

 -- viruol-Icopacl                                 EachPo       lacer1                                               E.oluala motor to'si                    CE._ SE               hodprt          Melm. E. CESEop           clao              mrra     coc         _______

hold point, d-udnt 'P' -% Endut cnotot Vibltioc AP 0211 CSI 211S Eoch Pomarleotl (Vie) 2`120 Soldpoint.and dcricg cE Eclate1 mlo'r pom.t 1eset changes matldal condition A Moro, A Geoa..tor SMoLtor "rdor ecl arrr T-P -EPFI S poIncrA Sod3. So*4 0: SOA Each Powr lcer CE 200 dag F, 1Zn Inestigare cac or SD46 hold poinrt Sd high temp A 5040 A 05 8 046 Gecereror aroring ERFI S pointc A: Tr'p S047. 0D48 3S0401 Each Powt lavel GE 200 dog F, 212 Intligate cauoa or S005 hold point S/d high latp A $047 -- A S048 _ S049. Motor Windrng ERFI S pointr Sc000, EachPower lecl t IF 1ilse.couse of SOOt. S002. sO03 hcd point GS deg F Ln h tem

,p

A 3 000 .

A soo0 3002 Gonolor T in ERFIS Points S004. Each Power loel loceetigatecocoaor Tampa s005. 5OO0,SOO7 hold point . CE 220 deg F Uim high ramp A S S004 Equi n Statu inering Each Power cooel Selcaa motor

u. Stc Jcdem t hord pointf condition I

oroort Source Frequency Elent Osg Atrlcincos Rsos viulnpcio Evolut.,moto

isua Inspeio CE, SE Porndic Moln. E,CESEopt Ev orotul E-ide contonr EquipmoontSalows lEqorp. S I Edlnoorlllg LatPro o Motor C vlot oo

             'o.s)    Judgoment IP                   e mol.rlo. conditlol

Entergy Nuclear - Vermont Yankee Performance Parameter Spreadsheet Component Type: Motors Component Enqineer: Chris Kowal

                                                   .17     IR                                 ui 2                        RR (Ass*iged Color)

Equipment

                     " Deferred PM's CM Backlog E1 Backlog" L                 Peforiorance Pa"hframieiters (Color) m,-To=1**o0i                      ].l

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Entergy Nuclear - Vermont Yankee Power Uprate Power Acecntton Testing Performance Monitoring Plan Component Engineer: Chris Kowal 1633 GZ31

                                                                                                                                                               . 6==ýý        -

Time: Date, Time: Date: Visual Inspection Each Power level hold Evaluate motor material (VIS) Engineer point CE. SE Evaluate condliton, audible noise. VibrationMotor Each Powerlevel holdEvlaemtraeil (VIB) AP 0211 CSI 2115, 2120 potEvaluate motor material Aoiotot"condition A Motor B Motor C Motor Vibration Pump Each Powerlevelhold Evaluate Pump watedal (VIB) AP 0211 CS1 2115, 2120 point CE condition matedl A Pump B Pump C Pump Theography T m h Each Power level hold CE Hot spots Investigate cause of high ITherm, Thermography aera ot 10 DI c tsppo Pump Bearing Tamp, ERFIS Points Each Power Ievel hold CE 160deg F [200<deg F Driven .0,01 2_PII W0p-n __________ A A W028 B W033 B W034 C W039 C W040 Pump Bearing Temp, Etais Points Each Power level hold CE " n0<degF [2500deg I Opo. point EPU 2212 SID A W029 B W035 C W041 Motor Thrs Bearing yfrThrust ERFIS Points W031, Each Power level hold CE ho60deg F 1200<deg F investigate cause of high (tront)BTemp) W037, W043 polnt EPU] 212 SID tamp

            'A                    W031 B                     W0037 C                     Wd043 Motor Guide bearing    ERFIS Points      W032   Each Power level hold                            178<deg F [200<deg f  Investigate cause of high (Rear) Tamp                                                                   CE (erTemp                W038. W044                  point                                       EPUJ 212 SID                 tamp A                     W032 B                     W038 C                    W044 Winding Temps        ERFIS Points       E026, Each Power level hold               p0a                 DoG C norm      n   Ugats            high (W-Temp)                 E027. EO28                point                                          eg CEPU                   tamp                                                    - I A                     E026 B                     E027 C                     E028 Equipment Status                                                                                                       Evaluate motor matedial status)

SEn]ui. Engineering Judgement Periodic Motor CE condltion Comments 0

.a

Visual Inspection Craft I Engineer Each Power level hold CE Eveua motor mateialo I-fy15) point - E condition Vibration Motor E Evaluate motor materil VS AP 0211 CSI 2115, 2120 Each Power ee hold condition A B C-Vibration Pump AP 0211 CSt 2115, 2120 Each Power level hold CE Evaluate Pump material (VII A point condition A B Investigate cause of high Ht1 spXL ThermloacrPweplvehhl (Ther apny Thermography cameras CE pohrrlnt____<___10_________..____ Upper Bearing Tamp ERFIS Points E067, Each Power level hold CE 172(160)uDeg2F (183 Investgatetcause of high Uir temp ( 201 EPU 200 1 p oit B 07 E06 E068 070E072 B-Tern (100) deg C [115 Investigateecause of high CE106 ERFIS Points Each Power level hold Windingera r Temp o e o f high Evalua CE Periodic Judgemetoin9 EnglPne Equipment Status Comments molar mat2n lemp ire Ena1e condition motse mateion ondvlate W047.s point B-ernp u E 0g9,eercoe Motor CE Sarmete Periodic E Judgemeot ngineering Equipment tatp vIne s a te cau tig s e of h igh CE La s t p o w er le ve l tern r De Up pe a rinTg a mp ER F IS P o ints W 0 4 5, Comments WV047 W049- aea ___B-Tern) W045 A _ W047*-auaemtr B C W049" Invesigat cause ofhih Loerquipnt STatus Engineerints W046,en Last powe leveloC Lý11uComments

                                                                                                                                                                         .,~lT-4 9316332 ý 67-

I mcuip. itawsi *J -ý - I comments 0

F m1QtnS11E I EWWWR~i PhI R-OR I, I...- Param star 11 Sorir ce 11 vlsuSE. CE inpec~on E Lst Power Lst te owerlevl 1 Mo'nt E. CESE~op" Evlte IEvaluateco. nditi""on motor material I Lqolprnenr ~~~~~~ Engineering Jodgemont j LostPowerlevel Motor CE I MtrC I I pue Et C:nmm*nI* I EgneigJdemn I -. .

                                                                   -s   oe lvl
                                                                                                                     ~I._

I CO*QIUUN _ _ _ I. I

            ýOmmen Vibration              BENY NEVADA                Each Power level hold            CE          by them     Evaluate motor material (VIB)                  Epoint                                                                                    condition A

B ERFIS Points S069. E Pump bearing temperatures @ speed SS071, M134. S072, ch Power level hold S074d M135 point C A M134 A A: S069 A A: S071 B M135 B B: S072

B B:S074 Motor Upper Beating ERFIS Points S051, Each Power level hold CE 1 d Investigate cause of high Temp S052, S053, S054, point 1 temp A S051 A S052 B S053 B S054.

Motor Lower bearing ERFIS Points S055, Each Power level hold CE 140 de Investgate cause of high Temp S 057. S 058, S050 point 1 temp A S055 A 8S057 S056 - B S058 Pointsh Power level hold Investigatetmcause of high (WI.gTamps ERFISPons Eah0owr5. hl CE j 220dl' (W-Tdrnp) nSgeo no61. S0, 064 S062, point tenp A S059 A SOGO B B " S061 S062 S063

                                                                                                                                                        .1 B

B S064 Equipment SttusEach Equipm. Statust Power level hold Evaluate motor material Engineering Judgement Po o MotorCE coniondition I. Comments

I ..... VIsual inspection Eqpment Status II J Enineer

                                    ------ S.........
                                    .. ..SE CE, uemn I         : ...'level .

Lost power Last power level II 1 Malnt. E,...CESE.ops Motor CE rane Evaluate___....... mornaiteo Evaluatemotormaterial a II_ _ _ _ _ _ I C S n )m I Engineering Judgeme condition Visual nsectoCE, II SE Each Power level hold Evaluate motor toatat -t _ (VISI point Mafnt. E, CE,Sr,ops Evaluate condition ate Vibragon Each Power level hold (VIB}(VE AP 0211 CSI2115. 2120 point,level een dung powe chan enqescnio CE Evaluate motor mealteri A Motor A Generator B Motor 1BGenerator Motor Bearing Temp ERFI S points A: 0043. Each Power level hold CE <200 deg F, 212 S/d Investigate cause o) hIgh 5044 B: 5045 l C040 t A S043 B S045 B S046 Generator Beaidng Tamp ERFI S points A: S047, Each Power level hold CE deg F. 2200 212S/d Investigate cause of high S048 B: S049, SOSO point temp A S047 A S04t A S048 B S049 - B SOSO 220 deg F Lira Investigate cause of high Motor Winding Temps ERFI S points SO00. Each Power level hold CE S00t, S002, S003 pon tem A S0OOO A S00t B S002 B SOO3I Generator Winding ERFIS Points SS04u Each Power level hold investigalte cause of higa Teumps SO0E, SOnngS007 point CE 22ndiliUntamp AS004 A S005 Equipment Status 8 ~S007" Engineering Judgement Each Power level hold Motor CE Eautmormteia ( quip. status) point condition

Cjomments *aliennuvS-eaualu 1.1..11...1....ange .1..1 i1 ) - Visualosopection 1 C E Periodic MalnI. E, CEoo. Sov.pu Evaluuateeon .. lla*)n i, EQu'p. Status Equipment .. vluate motor matedati Engineering Judgement Last Power Level Motor CE coodUoo " omments Comments

Time: Date: i m e D 3 D97.90% Tie Dt Tine: D.ate; Time: Date: Time; Date: Time: Date: ITm: Date:

       . 17121E:<::&..k*

F. 'i ,1:752 1792: .9 188272 4-. i 7-M a

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0 VYNPS EPU Power Ascension Testing Service Water System Monitoring Plan (4 pages)

EPU Supplemental Performance Monitoring Plan for the SW System Increased Power Level Evaluation Points Previously Alarm 1593 MWth 1673 MWth 1752 MWth 1912 MWth : Monitored Equipment No. Parameter Values/Limits Level Pre PAActvty (83.32%)-_ (87.48%) (91.65%) (100%) Source P-7-A-D Numer f Pmps 2 during Record # of P4F-1 A-D Number of Pumps 2eduran 2 Running 3 Pumps 3 Pumps 3 Pumps 3 Pumps I*RFIS - E516, Running (Noteb) 2 Pumps Running Running Running Running E517, E518, E519 - Record Aead Pressure Pressure Pressure PI-1 04-20A/B SW Header Pressure 97-117 psig 2 Header Pressure OP 0150.03 _________ _______________Pressure

                                                                                                   < 97 psig     < 97 psig      < 97 psig    < 97 psig  CRP 9-6 X       RD-1 7-332         SW Rad Monitor Flow            1.0 - 2.0 gpm    3    Record Flow        Flow             Flow        Flow          Flow   OP 0150.05 (Note 2)                            >2  gpm        > 2 gpm       > 2 gpm      >2   gpm  FI-104-332 32                               Amps         . Amps         Amps         Amps    OP 0150.03 P-7-1A            Running Amps                      (Note 2)      2    Record Amps         31                31         31           > 31   CRP 9-6 X       P-7-1 B            Running Amps                          32        2    Record Amps       Amps             Amps         Amps         Amps    OP 0150.03 (Note 2)                               31                31         31           > 31   CRP 9-6 P71C               R          A                          32                               Amps             Amps         Amps         Amps    OP 0150.03 7-1C            RunningAmps                       (Note 2)*     2    Record Amps        .31                31         31           > 31   CRP 9-6 32                               Amps           . Amps         Amps         Amps    OP 0150.03 P-7-1D             RunningAmps                       (Note 2)      2    Record Amps         31                31         31           > 31   CRP 9-6 X       P-7-1A-D           Motor Winding Temp                                           Monitored.by Components E-10-1A-D          H2 Temp                                               Monitored by Turbine Generator Program E-25-1A&B.        TLO Outlet Temp                                       Monitored by Turbine Generator Program E-26-1 A&B        SC Outlet Temp                                        Monitored by Turbine Generator Program Alterex            Temp                                                  Monitored by Turbine Generator Program TRU-5              Condensate Pump                                             Monitored by HVAC Program Room TRU-1,2,3,4        Feed Pump Room                                              Monitored by HVAC Program RRU-17A&B          Steam Tunnel Temp                                           Monitored by HVAC Program Record Valve TCV-104-20         H2 Cooler Outlet                     N/A        2   Stem Position    75% Open      75% Open       75% Open     75% Open TCV-104-20 Tcv-04-2 TLOCooer                                             RecordPosition Valve TCV-104-21         TLO Cooler OtletN/AStem Outlet            N/A        2                   75% Open       75% Open       75% Open     75% Open TCV-104-21 X      E-22-1A&B          TBCCW Outlet Temp.                <100 F            Record Outlet     > 950 F           > 950 F     > 95 F       > 950 F  ERFIS - M042 I                   (TBCCW not SW)                    (Note 3)   1___       Temp .                   I              I           I            I_

02/25/2006

EPU Supplemental Performance Monitoring Plan for the SW System

                                                                                                *{Increased Power Level Evaluation Points Previously                                             Alarm                                1593 MWth 1673 MWth 1752 MWth 1912 MWth Monitored   Eq~uipment No. Parameter               Values/Limits    Level Pre PA Activity    (83.32%)       (87.48%)    (91.65%)      (100%)  Source Record Valve TCV-104-3      "A"TBCCWHXOutlet              N/A          3     Stem Position   75% Open       75% Open    75% Open     75% Open TCV-1P04-3oo TCV                             "B TBCW H       Oulet        N/ARecord                  Valve TCV-.104-6      "B" TBCCW HX Outlet          N/A          3      Stem Position  75% Open        75% Open   75% Open     75% Open TCV-104-6 RBCCW Outlet Temp         < 100 OF               Record Outlet X       E-8-1 A         (RBCCW not SW)            (Note 3)        3          Temp         > 95° F         > 95? F     > 95° F     > 95* F ERFIS - M008 X .X  E-8-1 B         (BC       noSW(Nt3)

RBCCW Outlet Temp < 100 "F 3 Record TepOutlet > 95- F > 95' F > 95, F > 95* F ERFIS - M009 (RBCCW not SW) (Note 3) Temp "A" MGLO Outlet < 140 OF Record Outlet ERFIS - W082 E40-1A Temp (Oil not SW 3 > 130" F > 130" F > 130' F > 130' F ODMI CR-VTY-Temp) (Note*2) -Temp 2005-02391 "B" MGLO Outlet -ERFIS - W085

                                                     < 140 "F               Record Otitle     -EFS-W8 X       E40 1B         Temp (Oil not SW           (Note 2)                   Temp         > 130 F        > 130 F     > 130" F    > 130' F ODMI CR-V-I-

_Temp (Note 2) 1 1 Temp2005-02391 Note 3 - From USFAR/TS Note 2 - From Procedure or Alarm Set Point Note I - Based on Review of Trending Data Manual adjustment of valve positions to control flow/temperature must be recorded Prepared by: Date Reviewed by: Date 0 02/25/2006

SW EPU Monitoring Logs Alarm* Inreased Power Level Evaluation Points Equipment No. Parameter Values/Limits Level 9 Wth 1673 MWth 1752 MWth 1832 MWth 1912 MWth Source P7-1AD Number of Pumps > 2 during 2 2 Pumps - ERFIS - E516, Running - Feb/Mar 2 Running _E517, E518, E519 RD-7-332ur PI-104-20A/B SW Header Pressure 97-117 psig 2 <97 CP OP 9-6

                                                              < 97 psig1                                                   CRP0150.05 9-6 RID-1 7-332      SW Rad Monitor Flow   1.0 - 2.0 gpm      3      .Flow                                                      OP 0150.05
                                                               <2  gpm                                                     F1-1 04-332 P-7-IA           Running Amps                 32          2       < 31                                                      OP 0150.03 CRP 9-6 P-7-1B8          Running Amps                 32          2       < 31                                                      OP 0150.03 CRP 9-6 P-7-1C           Running Amps.                32          2       < 31                                                      OP 0150903 CRP 9-6 P-7-1D           Running Amps                 32          2       < 31                                                      OP 0150.03 Runnng Aps                                             _______       _______CRP       9-6 TCV-104-20       H2 Cooler Outlet            N/A          2   <75% Open                                                     TCV-1 04-20 TCV-104-21       TLO Cooler Outlet           N/A          2   <75% Open                                                     TCV-1 04-21 E-22-1A&B        TBCCW Outlet Temp        < 100 "F        3     < 95" F                                                     ERFIS - M042 (TBCCW not SW)
                                                                < 75%

TCV-104-3 ____ "A" _______ TBCCW ___ HX Outlet ____ ____ __

N/A

_ __Open 3 .___ _ _ _ _ __ TCV-104-3

                                                                < 75%                                     .

TCV-104-6 "B"TBCCW HX Outlet N/A 3 TCV-1 04-6 Open RBCCW Outlet Temp E-8-1A (RBCCW not SW) <.10ur- <5° ERFIS - M008 E78-1B RBCCW Outlet Temp <100 *F 3 < 95" F ERFIS - M009 (RBCCW not SW)

                "A" MGLO Outlet                                                                                            ERFIS - W082 E40-1A           Temp (Oil not SW         < 140 OF        3    < 130" F                                                     ODMI CR-V-TY-Temp)                                                                                                      2005-02391

SW EPU Monitoring Logs Equipment No. Parameter Alarm ValuesLimits Level 11 Increased Power Level Evaluation Points 1673*Mt 752 MWth 1832 MWth 1912 MVth Source "B" MGLO Outlet ERFIS - W085 E40-1B Temp (Oil not SW < 140 F 3 < 130' F ODMI CR-VTY-Temp "1 12005-02391 1673 MWth Data Recorded By: Date: 1673 MWth Data Reviewed By: Date:. 1752 MWth Data Recorded By: Date: 1752 MWth Data Reviewed By: Date: 1832 MWth Data Recorded By: Date: 1832 MWth Data Reviewed By: Date: 1912 MWth Data Recorded By: Date: 1912 MWth-Data Reviewed By: Date:

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VYNPS EPU Power Ascension Testing Turbine Generator System Monitoring Plan (6 pages)

System Name: Stator Cooling Date Issued: System Functions: MR-1 Provide cooling for the main generator System Code: SC MR-2 Provide necessary instrumentation to allow for identification of System Engineer: Bob Swanson operational status. MR-3 Provide necessary signals to initate a timed turbine trip System Performance Goalslindlcator: SCW P&ID Click Here Equipment Name Equipment No./ID Critical Parameter Instrument M/T Freq Acceptance Bands Source Reason or other info TG-1-1A STEAM TURBINE Generator MWe GENERATOR UNIT Yes ERFIS G002 M/T D -550 MWE ERFIS Can be Trended via PSS. TG-I-1A STEAM TURBINE Stator Cooling_ GENERATOR UNIT Yes Deionizer dP DPI-1 10-YGA T D <14 psid OP 0105 TG-1-1A STEAM TURBINE Stator Cooling DPIIIOYGA T <9psd op 010 - GENERATOR UNIT Yes Filter dP DP-1YAD<___OP_5 . TG-1-1A STEAM TURBINE Stator Winding GENERATOR UNIT Yes Inlet ERFIS G021 T ) - 40 Deg C ERFIS Can be Trended via PSS. Temperature TG-1-1A STEAM TURBINE " Stator Windmi P1-110-YGA-2 T D 34-38 psig OP 0105 GENERATOR UNIT Yes Inlet Pressure TG-1E-1A STEAM TURBINE Yes Stator Winding FIS-110-YFL-I T D 274-288 gpm OP 0105 GENERATOR UNIT Ys Coolant Flow ___ TG-1-1A STEAM TURBINE Generator GENERATOR UNIT Yes Outlet CDR-110-1, pt. T D <0.3 Wnho/cm OP 0105 Conductivity 3 ________ ___ TG-1-1A STEAM TURBINE Delonizer GENERATOR UNIT Yes Outlet D Conductivity TG--EA STEAM TURBINE Yes H2 Puri ERFIS G M > 95% ERFIS Can be Trended via PSS. TG-G-EA STEAM TURBINE GENERATOR UNIT e Yes Tem Machse Gas ERFIS M/i 30-50'C OP 0105 Can be Trend.ed via PSS. TG-1-IA STEAM TURBINE Machine Gas Canbe Trended via PSS. GENERATOR UNIT Yes Pressure ER950525_02 0 TG-I-IA STEAM TURBINE Yes F1T-II0-H-I T D - .277 scfm OP 0105 H2-.U sage GENERATOR UNIT

System Name: Turbine Lube Oil Date Issued: System Functions: MR-1 Provide lube oil for lubrication of the main turbine. System Code: TLO :- MR-2 Provide sufficient oil pressure for control of MS system turbine control and turbine bypass valves System Engineer: Bob Swanson and other MHC equipment. MR-3 Provide for emergency DC powered lube oil supply System Performance Goals/Indicator: TLO P&ID Click Here Equipment Name Equipment NoJlID Critical Parameter Instrument MIT Freq Acceptance Bands Source Reason or other Info TG-I-A Turbine Lube Oil Cooler. Yes Turbine Oil to Cooler Temperature T024 T. D 130-140 ERFIS TG-I-IA Turbine Lube Oil Cooler Yes YesATurbine Oil from Cooler Temperature T025 T o 110-120 ERFIS TG-1-1A STEAM TURBINE GENERATOR UNIT Yes Turbine Bmq Oil Pressure W008 T D 20-30 ERFIS TB-1 High Pressure Turbine. a Yes Turbine Bm qj 1 Oil Outlet W 0l 1 T j 1 10/ 1]5/ 35 d cgDi ff ERFIS Difference between Br qMet .,and oil drain temp TB-i High Pressure Turbine YesT D 1/ TB-1 Ligh Pressure Turbine Ys Turbine 13mg 2 Oil Outlet W012 T D 10/]5 /35 degDiff; ERFIS Difference between Brq Metal and Oil drain temp Yes Turbine Bmg 3 Oil Outlet W013 T D 10/15 / 35 deg Diff ERFIS Difference between Brg Metal and Oil drain temp TB-iA Low Pressure Turbine Yes eTurbine Bm 4 Oil Outlet W014 T o 0SDifference 10/,15/35dcgDuff ERFIS between-Brg Metal and Oil drain temp TB-1A Low Pressure Turbine Turbine Bmg 5 Oil Outlet W015 T O 10/15 / 35 deg Dff1 ERFIS Difference between Brg Metal and Oil drain temp Yes TB-1A Low Pressure Turbine Yes Turbine Bmg 6 Oil Outlet W016 T o 10 /15 / 35 deg Diff ERFIS TG-1-A Difference between-r Metal and Oil drain tern GENERATOR UNIT Yes Generator Bmg 7 Oil Outlet W017 T o 10 / 15 / 35 deg Diff ERFIS IDifference between Brg Metal and Oil drain temp TG-1-1A GENERATOR STEAMTURBINE UNIT Yes Generater Bmg78OII Outlet t W017 T D0 0 0.53dc~f

                                                                                                                          /5 / 35 deg Diff         RI ERFIS    Difference between Br Metal and Oil drain tern GENERATOR UNIT                         Generator2mg 8011l Outlet        waile                         0/     53       e Df        RI      Difference between Brg Metal and Oil drain temp Alterrex          Exciter                      Yes       Exciter Bmg 9 Oil Outlet         W019            T            10     10 3/35 deg Diff     ERFIS    Difference between Brg Metal and Oil drain temp Alterrex          Eixciter                     Yes       Exciter Bmg 10 Oil Outlet        W020            T      0     10 / 15 / 35 deg Diff       ERFIS    Difference betweenEr Metal and Oil drain temp

System Name: Seal Oil Date Issued: System Functions: MR-1 Provide shaft sealing for the main generator. System Code: SO System Engineer: Bob Swanson MR-2 Provide for emergency DC powered seal oil supply. System Performance Goalslindicator: SO P&ID Click Here Equipment Name Equipment No.11) Critical Parameter Instrument- MIT Freq Acceptance Bands Source Reason or other info TG-1-1A STEAM TURBINE Yes T D 45-51 ERFIS GENERATOR UNIT Hydrogen Seal Oil Pressure Bearing W009 T iTrending Avaialble in.System 1 TG-1-1A STEAM TURBINE Yes T D 45-52 ERFIS GENERATOR UNIT Hydrogen Seal Oil Pressure Bearing W01 0 -rending Avalalble in System 1 TG-l-1A STEAM TURBINE Yes T D 8 PSID ERFIS Tedn Avaialble Trending vill InnSse System 1 ____________ STGENERATOR UNiT Seal Oil / Gas Pressure Differential Calculation

System Name: Turbine Generator )ate Issued: TG System Functions: MR-1 Convert the thermodynamic energy of steam to provide electrical energy System Code: TG MR-2 Provide automatic and manual controls via both the EPR and the MPR MR-3 Control steam flow and pressure to the turbine to protect the turbine from System Engineer: Bob Swanson overpressure or excessive speed MR-4 Provide for automatic turbine generator trip under appropriate conditions MR-5 Provide for automatic and manual control of turbine speed, load, and trip MR-6 Provide for monitoring and control of generator hydrogen (H2) purity and System Performance Goals/Indicator: Main Steam Functions Below MS P&ID Click Here IVISFunctions

1) Conduct steam provided from the NB system to the main turbine at a controlled pressure during normal operation.

                  '2) Provide a supply of steam to the Extraction Steam (ES) system.

3) Provide a supply of steam to the Auxillieay Steam (AS) system.

                  '4) Provide a supply of steam at-a controlled pressure for turbine shaft sealing.
                 '5) Bypass steam directly to the main condenser to control reactor pressure via automatic and local-manual control.
                  '6) Control steam flow and pressure to the the main turbine to protect the turbine from overpressure or excessive spieed-.

7) Provide signalfor MSIV closure on low turbine Inlet pressure.

6) Provide signal for Turbine Trip on high exhaust hood temperature.

9) Provide necessary mechanical support to ensure accomplishment of other safety related functions (I.e., piping Integrity to ensure reactor coolant pressure boundary and containment boundry functions). --

Main Turbine Yes Turb/Gen Brng 9 T D < 6 mils, 1 Mil Delta ERFIS Reason or other Info TB-1 Vibration System 1 Turb/Gen Bmg 10 - T <Gmlls, 1 MiDelta ERFIS Main Turbine 6_mls,1_MlDlt Vibration System I T1D TB-1 Main Turbine Turb/Gen Front Thrust W021 T D ;130,150 deg F ERFIS Can be Trended via PSS. TB-1 Oil Outlet Main Turbine Yes Turb/Gen Rear Thrust Oi W022 T D <130.150 deg F ERFIS TB-1 Outlet I Main Turbine Yes Turb/Gen Front Thrust W023 T D <130,150 deg.F ERFIS TB-1 Bearing Metal Main Turbine Yes Turb/Gen Rear Thrust W024 D <30,150 deg F ERFIS Can be Trended via PSS. T D_<____CanbeTrndeva ___ TB-1 Yes Bearing Metal Main Turbine TB-1 Yes Thrust Bearing Wear Turbine End T D 20, 40 mils ERFIS Main Turbine TB-1 Yes Thrust Bearing Wear Generator End T D 20, 40 mils ERFIS Intercept Valve CIV 1/2 Yes Stoke Time Open StopWatch T 0 OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 112 Yes Stroke Time Closed StopWatch T Q OP 4160 (10% 20%) OP-4160 I-- intercept Valve CIV 3/4 Yes Stroke Time Open StopWatch T Q OP 4160 (10% 20%) OP-4160 I Intercept Valve CIV 3/4 Yes Stroke Time Closed StopWatch T Q OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 1 Yes Stoke Time Open StopWatch T Q OP 4160 (10% 20%) OP-4160 Intercept Valve CIV I Yes Stroke Time Closed StopWatch T Q OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 2 Yes Stoke Time Open StopWatch* T 0 OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 2 Yes Stroke Time Closed StopWatch T 0 OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 3 Yes Stoke Time Open - StopWatch T Q OP 4160 (10% 20%) OP-4160 intercept VaIve - CIV 3 Yes Stroke Time Closed StopWatch T Q OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 4 Yes Stoke Time Open ,StopWatch T Q OP 4160 (10% 20%) OP-4160.

intercept Valve CIV 4_ Yes Stroke Time Closed StopWatch T IQ lOP4 ; 20%)_1 OP-4160 intercept Valve CIV 1_ Yes Stoke Time Open Stopwatch T IQ. OP4 120%). OP-4160 Intercept Valve CIV 1 - Yes Stroke Time Closed Stopwatch T Q OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 2 Yes Stoke Time.Open StopWatch T Q OP 4160 (10% 20%P... OP-4160 Intercept Valve CIV 2 Yes Stroke Time Closed StopWatch T Q OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 3 Yes Stoke Time Open StopWatch T Q OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 3 Yes Stroke Time Closed StopWatch T Q OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 4 Yes Stoke Time Open Stopwatch T Q OP 4160 (10% 20%) OP-4160 Intercept Valve CIV 4 Yes Stroke Time Closed Stopwatch T Q OP 4160(10% 20%) OP-4160 Bypass Valves Z-1A-1 Yes Stroke Time Open Stopwatch T Q OP 4160(10% 20%) OP-4160 Bypass Valves Z-1A-1 Yes IStroke Time Closed Stopwatch T Q OP 4160('10% 20%) OP-4160 Bypass Valves Z-1B-2 Yes Stroke Time Open Stopwatch T Q OP-4160 (10% 20%) OP-4160 Bypass Valves Z-1B-2 Yes Stroke Time Closed StopWatch T Q OP 4160 (10% 20%) OP-4160 Bypass Valves Z-1A-3 Yes Stroke Time Open StopWatch T Q OP 4160 (10% 20%) OP-4160 Bypass Valves. Z-1A-3 Yes Stroke Time Closed StopWatch T 0 OP 4160 (10% 20%) OP-4160 Bypass Valves Z-1B-4 Yes Stroke Time Open StopWatch T Q OP 4160 (10% 20%) OP-4160 Bypass Valves Z-1B-4 Yes Stroke Time Closed StopWatch T Q OP 4160 (10% 20%) OP-4160 Bypass Valves Z-1A-5 Yes. Stroke Time Open Stopwatch T 0 OP 4160110% 20%) OP-4160 Bypass Valves Z71A-5 Yes Stroke TimeClosed Stopwatch TI Q OP 4160 (10% 20%) OP-4160 Bypass Valves Z-1B-6 Yes Stroke Time Open Stopwatch T 0 OP 4160 (10% 20%) OP-4160 Bypass Valves Z-1B-6 Yes Stroke Time Closed. Stopwatch T Q OP 4160(10% 20%) OP-4160 Bypass Valves Z-1A-7 Yes Stroke Time Open Stopwatch T Q OP 4160( 10% 20%) OP-4160 Bypass Valves Z-1A-7

Yes Stroke Time Closed StopWatch T 0 OP 4160 (10% 20%) OP-4160 Bypass Valves Z-1B-8 Yes Stroke Time Open Stopa T Q OP 4160 (10% 20%) OP-4160 Bypass Valves Z-1B-8 Yes Stroke Time Closed Stopwatch T. 0 OP 4160 (10% 20%)-- OP-4160 Bypass Valves Z-1A-9 Yes Stroke Time Open StopWatch T Q OP 4160 (10% 20%) OP-4160 Bypass Valves Z-1A-9 Yes Stroke Time Closed StopWatch T Q OP 4160 (10% 20%) OP-4160 Bypass Valves Z-1B-10 Yes Stroke Time Open StopWatch T 0Q OP 4160 (10% 20%) OP-4160 Bypass Valves Z-tB-10 Yes Stroke Time Closed StopWatch T ,Q OP 4160 (10% 20%) OP-4160 Yes ALTERREX EXCITER G025 T Alterrex Alterrex LTEMP SLOT 1 E i026 D 5 Deg, 10 deg dev ERFIS Yes ALTERREX EXCITER*. 02 T Alterrex Alterrex ITEMP SLOT 2 D 5 Deq, 10 deg dev ERFIS AYes AALTERREX EXCITER G027 T D 5 Dea.10 degdcv ERFIS Alterrex Alterrex *TEMP SLOT 3 T, e Alterrex Alterrex Yes GENERATOR SLOTS G039 - G158 T D 2 den, 5 deg dev ERFIS Yes GENERATOR HYD G G010 T ) >43. >41 Generator TG-l-1A PRESSURE psi . ERS Yes HYDROGEN TEMP TO G012 T Generator TG-1-1A COOLER A D 5Deq,10deqdev ERFIS

                  *G1                Ys     HYDROGEN TEMP OUT G017           T            D Generator        TG-I-IA             Yes    COOLER A                         T     D    5 Deg, 10 deg dev        ERFIS Generator        TG-I-1A             Yes    Cooler A Delta       Calculation T I.D      2 deg, 5 deg dev         Calculation Generator        TG-1-1A             Yes   HYDROGEN COOLER B TEMP TO     G013        T     D    5 Deg, 10 deg dev        ERFIS Yes    HYDROGEN TEMP OUT G018           T     D  1 Deo. 10 deg dcv Generator        TG-I-IA                    COOLER B                            _____e__,_1___de___ev            ERFIS Generator        TG-I-lA             Yes    Cooler B Delta       Calculation T    D   12 deg, 5 deg dev Generator        ITG-I-IA            *'es  HYDROGEN TEMP TO      G014        T            D Generator         ________           Yes   COOLER C ...                               15 Deg, 10 e     dev       ERFIS HYDROGEN TEMP OUT G019            T Generator        TG-I-lA             Yes   COOLER C                               D     5 Deg,_ 10deg dev       ERFIS*

,Generator TG-I-AA Yes Cooler C Delta T D 2 deg, 5 deg dev I _ _I

Ye HYDROGEN TEMP TO G015T Generator TG-1-1A Yes COOLER T T D 5 Deg. 10 deg dev ERFIS Generator HYDROGEN TEMP OUT G020 TG-1-1A Yes COOLER T T D 5 Deg, 10 deg dev ERFIS Generator TG-1-1A Yes Cooler D Delta Calculation T D 2 deg, 5 deq dev Generator TG-1-1A Yes Stator Coolant Temp T 5 Rise __D.. 2 deg, 5 deg dev ERFIS Generator Yes ALTERREX AIR OUT G023 T TG-1-1A TEMP _ 5 Deg,_D 10 deg dev ERFIS Yes ALTERREX AIR IN G024 T Generator TG-1-1A, TEMP D- 5 Deg. 10 deg dev ERFIS Generator TG-1-1A Yes Alterex Air Temp Rise Calculation T D 2 deg, 6 deq dev COOLANT TEMP OUT G022 Yes STATOR WINDING T Generator TG-i-1A G022 -D 5 Deg, 10 deg dev ERFIS COOLANT TEMP IN G021 Yes STATOR WINDING T Generator TG-1-1A G021 D 5 Deq. 10 deg dev ERFIS COOLANT TEMP Rise Calculation T- .1 Generator !TG-I-A Yes STATOR WINDING D 2 deg, 5 deg dev Yes GEN H2 GAS TEMP C027 T Generator TG-i-IA RISE D 2 deg_,5 deg_dev ERFIS Yes GEN HOT GAS C028 T Generator TG-1-IA AVERAGE TEMP D 5 Deg, 10 deg dev ERFIS Yes GEN COLD GAS C063 T Generator TG-1-1A AVERAGE TEMP D 5_Deg,_10_degdev ERFIS

BVY 06-019 Docket No. 50-271 0 Attachment 3 Vermont Yankee NL~clear Power Station Proposed Technical Specification Change No. 263 Extended Power Uprate - Regulatory Commitment Information Regarding Steam Dryer Monitoring and FIV Effects Data Acquisition System for Steam Dryer Pressure Signals Total number of pages in Attachment 3 (excluding this cover sheet) is 13.

Attachment 3 to BVY 06-019 DocketNo. 50-271 Page 1 of 13 Vermont Yankee Nuclear Power Station Data Acquisition System for Steam Dryer Pressure and Accelerometer Signals In Reference 11 Entergy committed to installing 32 additional strain gages (SG) on the main steam piping during the Fall 2005 refueling outage (RFO-25) to enhance the data acquisition system (DAS) and improve the accuracy of the steam dryer measurement system. The improvements in detection accuracy will reduce the measurement uncertainty associated with the acoustic circuit model. The commitment was met through the installation of 48 new strain gages and upgrades to the data acquisition system. Temporary Alteration change number TA-2005-15 R1 installed 48 new strain gages during RFO-25. The DAS consists of strain gages, instrument cabling located inside the drywell, and a computer located in the reactor building. There is second data acquisition system in the turbine building to collect accelerometer data from piping in the heater bay area. Both systems are remotely accessed over a local area network thereby minimizing test engineer dose during power ascension testing. Weldable, 350 ohm, high temperature strain gages with shielded high temperature cables were installed on the outside circumference of each of the four main steam lines inside the drywell at 60 degrees apart from at the locations described in Figure EMEB-B-77-1, Sheet 2 (see Attachment 3 to Reference 1). Installation of 6 strain gauges at each data input location' prQy,ides for improved assessment of internal pressure. Each strain gage is configured in a quarter bridge arrangement rather than 1/2 bridge arrangement. The quarter bridge arrangement and 6 gages provide margin for signal failures. An update to Figure EMEB-B-77-1, Sheet 2 is included in the attached portions of the Temporary Alteration. The upgrades to the DAS included 16-bit USB Digitizer with a sample rate of 200 kS/s. mounted in each chassis. Mounting. the digitizer in the chassis eliminates noise introduced by the computer. There are 3 DC chassis for the .SG signals and 1 AC chassis for the accelerometer signals. The SG chassis noise.was eliminated by providing external power to the DC powered fans in the chassis. The Endevco 7703A-100 accelerometer units are each screwed to a mounting block that is strapped .to the pipe. The accelerometer signal is routed to a charge converter in the drywell. The charge converter connects to an Endevco power supply located outside the drywell. The accelerometer signals are then routed to NI voltage conditioning cards then to a 16 bit digitizer. There is one personal computer controlling the 48 strain gages and 31 accelerometers for temporal collection of acceleration and strain data from the drywell. Strain acquisition software allows for automatic Wheatstone bridge null and calibration prior to each data acquisition. The data acquisition software allows variation in acquisition rate, acquisition period, and voltage span to best define the input signal. The accelerometer circuits are tested with a calibrated shaker to confirm the hardware and software are functioning properly. The data is processed with two software packages-MatLab and LabView-for cross checking results. 1 Entergy letter to U.S. Nuclear Regulatory Commission, "Vermont Yankee Nuclear Power Station, Technical Specification Proposed Change No. 263 - Supplement No. 33, Extended Power Uprate - Response'to Request for Additional Information," BVY 05-084, September 14, 2005

Attachment 3 to BVY 06-019 Docket No. 50-271 Page2 of 13 The Labview software will also calculate and plot the power spectral density data for each channel and display this data while running. Batch files have been developed efficiently to process the archived data with MatLab for Engineering evaluation and reporting.

Temporary Alteration 2005-15 Installation of Strain Gages on the Main Sieam Line

                       .Piping in the Drywell. REV-01 APPENDIX 'D' TEMPORARY ALTERATION ,SKETCHES Page 178 of 198

Temporary Alteration 2005-15 Installation of Strain Gages on. the Main Steam Line Piping in the Drywell REV-01 VY MAIN STEAM LINES PRQ OSED STRAIN GAGE LOCATIONS LE INDICATES STRAIN GAGE LOCATION TYPICAL EACH STRAIN GAGE LOCATION: CACES9W APART PIPE SECTIONI TA 2005-15 APPENDIX D SKETCH 01 Page 179 of 198

Temporary Alteration 2005-15 Installation of Strain Gages on the Main Steam Line Piping'in the Drywell REV-01 TA 2005-15 APPENDIX D SKETCH 04 PAGE 1 OF 8 MAIN STEAM LINE A UPPER STRAIN GAGE LOCATION AND "UT" TEMPLATE Prepar.ed By jcOr~-' Reviewed By 7-r4 Eev316' .*6___ 60 0C n 00 120 180' -(Backside) EIev %' 311 Bioshield wall S3 1 IA iCab~le II1Al 1800 (Vessel Side) 1S( 12A SC 19A 5/*= 2.40 DEG IN DEG "** 3b ("Able QA1) UTLOCAMiNS P2 2*'A Section A-A 0s SG 8A Cille 8A11 Page 187 of 198

Temporary Alteration 2005-15 Installation of Strain Gages on the Main Steam Line Piping in the Drywell REV-01 TA2005-15 APPENDIX D SKETCH 04 PAGE 2 OF S MAIN STEAM LINE UPPER STRAINGAGE LOCATION AND ";,U TEMPLATE Prepared By f* C' -- ',-..."Reviewed By _ " " Elev 316'- 6" ___

                                          *0                        ~60 18O                                 300 180    *(Backside)

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'Ternporary Alteration 2005-15 Installation of Strain Gages on the Main Steam Line Piping in the Drywell REV-01 TA 2005-15 APPENDIX D SKETCH 04 PAGE 3 OF 8 MAIN STEAM LIHE "C UPPER STRAIN GAGE LOCATION AND "UT" TEMPLATE Prepared By C - Reyiewed By '13-(

              ..... 31 ' 6 00 6%         30(

180 - , (Backside) Elev 311' Bloshield Wall Sk, tic IcatIle 114-11 (Vessel Side) SG led SG 12C1 120 DEG 3 1lle 12C-11 ical

                                          'lo 10CII UTLOCAMINS SHOWN  INCIRCLE1
                                                     \ 2                               SG1. ,Sec      tion A-A SI0DEG      N30                               [

S [Icab; 1(, -leI 13021 f4-Ale Kit1 Page 189 of 198

Temporary Alteration 2005-15 Installation of Strain Gages on the Main Steam Line Piping in the Drywell REV-01 TA 2005-15 APPENDIX D SKETCH 04PAGE 4 OF 8 MIAIN STEAM LINE'D' UPPER STRAIN GAGE LOCATION AND "UT" TEMPLATE Prepared By

                               -57o      L-~L~FeviewedR&r         By      &     i-( ,6 Elev 316'- 6" 64 00 1200 180,                                      180'       (Backside)

Elev 311' Bioshield Wall SG 11I) 1880 (Vessel Side) - SG,120 SG10p 240DEG 1 EG '\3 ICable 12[1) LUT LOCAiTDINS SHOWNIN CIRCLE 6 SGi13 300BEG SG 90 4IC-11e13011 A-A Section 1 0 DEIie I~he9D'I) 'I',- - SG 80 1C.lIle 8111) Page 190 of 198

Temporary Alteration 2005-15 Installation of Strain Gages on the Main'Steam Line Piping in the Drywell REV-01 TA 2005-15 APPENDIX D SKETCH 04 PAGE ; OF 8 MAIN STEAM LINE 'A' LOWER STRAIN GAGE LOCATION AND "UT" TEMPLATE © Prepared By Reviewed/By E:**ýt ,

                                              ~/iV/                                      YA/#f
                                                . 45 Elbow Ee~v 278'- 1t2" Ii          0 9 0

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                                                          -/  . o         \. SG 18A 240 DEG SG 16A                   **Cable                         18Al1 120 DEG      / 3 (Cable IGAI..

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                                                                                     /300DEG 2   -                                  Cable 19A11 SG15A GODEG'                                             SECTION A-A (Cable 1AA1)

Page 191 of 198

Temporary Alteration 2005-15 Installation of Strain Gages o~n the Main Steam Line Piping in the Drywell REV-0.1 TA 2005-15 APPENDIX D SKETCH 04 PAGE 6 OF 8 MAIN STEAM LINE B' 0 LOWER STRAIN GAGE LOCATION AND "UT" TEMPLATE Prepared By Z,2EL 6- eviewedf By C5 'UJ 45 Elbow Elev 278'- 9 112"

                                                                                           '180   '

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.Temporary Alteration 2005-15 Installation of Strain Gages on the Main. Steam Line Piping in the Drywell REV-01 TA 2005-15 APPENDIX D SKETCH 04 PAGE 7 OF 2 MAIN STEAM LINE 'C. LOWER STRAIN GAGE LOCATION AND "UT" TEMPLATE Prepared By Reviewed By C--"... 45 Elbow E-ev 278'- 9 112" CD 0

                                                                  -  00

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                                 .50 DEG                                                            i1A C1-able 15011 SE CT 1"IN A-A
                                                   'Cil0I Si;1i Page 193 of 198

Temporary Alteration 2005-15 Installation of Strain Gages on the Main Steam Line Piping in the Drywell REV-01 TA 2005-15 APPENDIX D SKETCH 04 PAGE S OF 8 MAIN STEAM LINED LOWER STRAIN GAGE LOCATION AND "UTP TEMPLATE Prepared By ' Reviewed By - -" 45 Elbow Elev 278'- 9 112" (Back~side) SG 171 ICable 17D11 1800 SG 180 240 DEG ICable 18111) SG 16VI 5 120 DE0 ICable1[1i UT LOCATIONS SHOWN IN CIRCLE 300 DEG S1, 1511 60 DEG (Cablle 15D11 SECTION A-A IC.-Ade*141111 Page.194 of 198

Temporary Alteration 2005-15 Installation of Strain Gages on the Main Steam Line Piping in the Drywell REV-01 STEWM A' f3 I LI 6o) 50) *C) S L2 5S 22S-L3 4t ____

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Entergy Nuclear Northeast Entergy Nuclear Operations, Inc. Vermont Yankee P.O. Box 0500 1.85 Old Ferry Road Brattleboro, VT 05302-0500 E ntoFAYTel 802 257 5271 March 26, 2006 Docket No. 50-271. BVY 06-031 TAC No. MC0761 Frl rn ATTN: Document Control Desk U.S. Nuclear Regulatory Commission o Washington, DC 20555-0001 =

Subject:

Vermont Yankee Nuclear Power Station Revision 1 to Steam Dryer Monitoring Plan

References:

1) Entergy letter to U.S. Nuclear Regulatory Commission, "Vermont Yankee Nuclear Power Station, License No. DPR-28 (Docket No. 50-271), Technical Specification Proposed Change No. 263, Extended Power .Uprate," BVY 03-80, September 10, 2003

2) Entergy letter to U.S. Nuclear Regulatory Commission, "Vermont Yankee Nuclear Power Station, Extended Power Uprate - Regulatory Commitment Information Regarding Steam Dryer Monitoring and FIV Effects,"

BVY 06-019, February 26, 2006 This letter provides updated information pursuant to a regulatory commitment made in connection with the application by Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Entergy) for a license amendment (Reference 1, as supplemented) to increase the maximum authorized power level of the Vermont Yankee Nuclear Power Station (VYNPS) from 1593 megawatts thermal (MWt) to 1912 MWt. includes a revision (Revision 1) to the Steam Dryer Monitoring Plan (SDMP) that was previously provided in Reference 2. The SDMP will remain in effect until License Condition 3.M expires. The SDMP, together with the EPU Power Ascension Test Procedure (PATP) provides for monitoring, inspecting' evaluating, and prompt action in response to potential adverse flow effects on the steam dryer as a result of power uprate operation. These actions provide assurance of the continued structural integrity of the steam dryer under Extended Power Uprate conditions. Attachment 2 provides the justification, consistent with License Condition 3.M.4 for why this change does not require prior NRC approval. Docket No. 7195 Attachment 13-2 27 Pages

BVY 06-031 Docket No. 50-271 Page 2 of 2 There are no new regulatory commitments contained in this submittal. If you have any questions or require additional information, please contact Mr. James DeVincentis at (802) 258-4236. Sincerely, Norman L. Rademacher Director Nuclear Safety Assurance Vermont Yankee Nuclear Power Station Attachments (2) cc: Mr. Samuel J. Collins (w/o attachments) Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Richard B. Ennis, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08B1 Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 06-031 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Steam Dryer Monitoring Plan Revision 1 Total number of pages in Attachment 1 (excluding this cover sheet) is 20.

Entergy Vermont Yankee Steam Dryer Monitoring Plan Revision 1 March 25, 2006 r Prepared B (Taig J. Nichols Date Reviewed By I ianes Call hi'an Date Approved B

 . .    .John      Dr   uss                 Date v

Page 1 of 19 Rev. 1 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 19 Rev. 1 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. 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 hour 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 will provide early detection capability of off-normal performance. Proposed License Condition 3.M will require 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 provide a means to assess continued steam dryer structural integrity under EPU conditions. Main Steam Fluctuating Pressure Monitoring System (Details.contained 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 19 Rev. 1 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. 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 0C2 benchmark assessment that provided the uncertainty bases for the prior ACM have been accordingly deleted from this calculation. The overall system uncertainty is based on the combination of the uncertainties of. each of the elements. The uncertainty in the ACM loads is derived from the following sources: o Uncertainty of the ACM to conservatively predict pressure response at the. significant frequencies o Uncertainty introduced by differences in sensor locations between QC2 and VY o Uncertainty introduced as a result of the ability of the ACM or Structural Model to match load and structural frequencies o Uncertainty resulting from strain gage and measure uncertainties. These uncertainties will then be combined by the square root sum of the squares (SRSS) method to assess the ACM load uncertainty. As calculated in VYC-3001 the overall system uncertainty is 38%. This value is used in the determination of the reduction of the limit curve factor resulting in the final limit curve, shown as Figures 1 through 8 of the SDMP. The contribution of each of the factors noted above is as follows: Maximum Uncertainty of the ACA MethodologV ACM ability to conservatively match peak response at the highest frequencies: 32% Difference in sensor locations from QC2 to VY 7% Ability of ACM or Structural Model to match response frequencies: 15% SG and DAS ability to measure pressure in Pipe 11% Combined Uncertainty by Square Root Sum of the Squares 38% 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% = +38%. 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%.

Page 4 of 19 Rev. 1 System Monitoring Requirements 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. 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, Ehtergy will iprovide 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. In addition the final full EPU power performance criteria spectra (i.e., steam dryer stress limit curve) will be 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

Page 5 of 19 Rev. 1 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 Monitoring 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 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.

Page 6 of 19 Rev. 1 Table 1 Steam Dryer Surveillance Requirements During Reactor Power Operation Above a Previously Attained Power Level Parameter Surveillance Frequency

1. Moisture Carryover Every 24 hours (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 hours of achieving an 80 MWt power plateau, an orderly power reduction shall be made within the subsequent 12 hours 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 7 of 19 Rev. 1 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 i 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 Spectra1 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 hours, re-measure moisture carryover and perform an

Pressure data exceed Level engineering evaluation of steam dryer structural integrity. If the 1 Spectra1 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 hours. 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 S, at 1011 cycles (i.e., 13.6 ksi).

Page 8 of 19 Rev. 1 Table 3 Steam Dryer License Conditions License Condition Requirement Implementing Actions 3.M.1 .a Entergy shall monitor hourly the 32 During initial power ascension above 1593 MWt, main steam line (MSL) strain gages data from at least 32 strain gages will be collected during power ascension above 1593 and evaluated by Entergy's power ascension test MWt for increasing pressure team to verify that acoustic signals indicative of fluctuations in the steam lines. 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) I The PATP has established test plateau increments 3.M.1 .b Entergy shall hold the facility for 24 hours at 105%, 110%, and 115% of of approximately 80 MWt (corresponding to 105%, OLTP (i.e., 1593 MWt) -to collect 110%, and 115% of 1593 MWt). Reactor power will

           ,data from the 32 MSL strain gages         not.be increased above the plateau for a minimum required by License Condition             of 96 hours. During the first 24 hours of steady 3.M.l.a, conduct plant inspections        state operation at each plateau, strain gage data and walkdowns, and evaluate steam         will be collected from all available strain gages dryer performance based on these           (minimum of 32) and evaluated to demonstrate data; shall provide the evaluation to      acceptable steam dryer performance. Additionally, the NRC staff by facsimile or              moisture carryover measurements will be made at electronic transmission to the NRC         each plateau and every 24 hours during power project manager upon completion of         ascension testing. At the 80 MWt plateau hold the evaluation; and shall not              points, Entergy will conduct plant walkdowns and increase power above each hold             inspections of plant equipment, including piping and point until 96 hours after the NRC         components identified as potentially vulnerable to project manager confirms receipt of       flow-induced vibration (FIV) in accordance with the the transmission.                          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 Manager confirming receipt of the steam dryer data I and performance evaluation, the 96 hours of hold

Page 9 of 19 Rev. 1 License Condition Requirement Implementing Actions 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 The steam dryer stress limit curve provided strain gage data exceeds the limit herewith contains Level 1 and Level 2 criteria. If curve established by Entergy frequency peaks from MSL strain gage data exceed Nuclear Operations, Inc. and either Level 1 or Level 2 criteria, prompt action will submitted to the NRC staff prior to be taken in response to the potential adverse flow operation above OLTP, Entergy effects that might result. Similar actions will occur if Nuclear Operations, Inc. shall return moisture carryover is excessive and previously the facility.to a power level at which established Level 1 or Level 2 criteria are the limit curve is not exceeded. exceeded. The Level 2 criteria represent a Entergy Nuclear Operations, Inc. conservative action level for evaluation and close shall, resolve the uncertainties in the monitoring of steam dryer performance-not a limit. steam dryer analysis, document the The Level 1 criteria represent analytical limits and continued structural integrity of the 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 10 of 19 Rev. 1 License Condition Requirement Implementing Actions 3.M.l.d In addition to evaluating the MSL Accelerometers mounted on MSL piping will be strain gage data, Entergy Nuclear monitored on an hourly basis during power Operations, Inc. shall monitor ascension testing to identify if resonances are reactor pressure vessel water level 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.l.e Following start-up. testing, Entergy After collecting strain gage data at approximately. Nuclear Operations, . Inc. shall the EPU full power level, Entergy will resolve the resolve, the uncertainties in the uncertainties in the steam dryer analysis and steam dryer analysis and provide provide documentation of the resolution to the NRC that resolution to the NRC staff by staff. If these actions cannot be achieved within 90 facsimile or electronic transmission days of issuance of the license amendment, reactor to the NRC project manager. If the power will be limited to 1593 MWt. This uncertainty uncertainties are not resolved within evaluation may be prepared and provided to the 90 days of issuance of the license NRC prior to reaching EPU full power levels amendment authorizing operation at associated with any proposed revision to the steam 1912 MWt, Entergy Nuclear dryer limit curve. Operations, Inc. shall return the (Reference PCRS tracking item WT-VTY-2005-facility to OLTP. 00000-01803) h,*i=. PIif-t al !inmstall-':,,3Z -- da .*itjon4 ,

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Page 11.of 19 Rev. 1 After reaching 120% of OLTP, After collecting strain gage data at approximately Entergy Nuclear Operations, Inc. the EPU full power level, Entergy will establish the shall obtain measurements from the steam dryer flow-induced vibration load fatigue MSL strain gages and establish the margin for the facility, update the steam dryer stress steam dryer flow-induced vibration report, and re-establish the stress limit curve with load fatigue margin for the facility, the updated ACM load definition and. revised update. the steam dryer stress instrument uncertainty. This information will be report, and re-establish the steam included, in the report to the NRC staff being made dryer monitoring plan (SDMP) limit in accordance with License Condition 3.M.l.e. curve with the updated ACM load (Reference PCRS tracking item WT-VTY-2006-definition and revised instrument 00000-00249) uncertainty, which will be provided to the NRC staff. Entergy Nuclear Operations, Inc. The revised SDMP provides long-term monitoring of shall revise the SDMP to reflect steam dryer performance in accordance with GE long-term monitoring of plant 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 steam dryer inspection program with -ThRSidMP 6OMPL~thE". 'and the General Electric Services NRC; _r~oject nYaP

                                                             ,PU:(Ihr the Information Letter 644, -Revision 1;   p~oint of9 ~cht~qLf orp~VovidJing             6SMRIforffiatin and to identify the NRC Project        during~p(?yWr ascension.

Manager for the facility as the point (Reffr~rnc . ,E,R§,TI04~-VY1-,t409-000 of contact for providing SDMP information during power ascension. ,COMPLETE -, For moisture carryover,, prpcedures OP-0631 an ON-~3178 provide :for lbig'terrti monitoring and controls..

Page 12 of 19 Rev..1 License Condition Implementing Actions Requirement 3.M.2.f Entergy Nuclear Operations, Inc. The final EPU steam dryer load definition will be shall submit the final extended iincluded in the report provided to the NRC staff in power uprate (EPU) steam dryer accordance with License Conditions 3.M.1 .e. and load definition for the facility to the 3.M.2.c. NRC upon completion of the power (Reference PCRS tracking item WT-VTY-2006-ascension test program. 00000-00251)

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Page 14 of 19 Rev. 1 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 with the guidance of NEI 99-04. 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 15 of 19 Rev. 1 I 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 16 of 19 Rev. 1 MSL A Upper 1.0E+00 1.OE-01 1.0E-02 E 1.OE-03 1.OE-04 1.0E-05 1.0E-06 50 100 150 200 2 50 Frequency, Hz

              -   LC_2 Ave MSL_AUpper                                LCI  Ave_MSL_AUpper Figure 1: Steam Dryer Stress Limit Curve - MSL 'A' Upper MSL A Lower 1.OE+00 1.0E-01 1.OE-02 1.OE-03 E

1.OE-04 1.0E-05 1.0E-06 0 50 100 150 200 250 Frequency, Hz

            -LC_2     AveMSLALower                                LCI Ave MSLALower Ii Figure 2: Steam Dryer Stress Limit Curve - MSL 'A' Lower

Page 17of19 Rev. 1 MSL B Upper 1.0E+000 1.0E-01 1.0 E-02 1.0E-03 1.0E-04 1.0E-05 1.0E-06 0 50 100 150 200 2550 Frequency, Hz

              --    LC-2 AveMSLBUpper                            -LC-1     AveMSL_B_Upper Figure 3: Steam Dryer Stress Limit Curve - MSL 'B' Upper MSL B Lower 1.0E400 1.0E-01 1.0E-02 1.OE-03 1.OE-04 1.0E-05 1.0E-06 50                   100                 150                 200              250 Frequency. Hz
                 -LC_2  Ave MSL-B Lower                               LC.1 Ave MSL-B.Lower Fiaure 4: Steam Dryer Stress Limit Curve - MSL 'B' Lower

Page 18 of 19 Rev. 1 MSL C Upper I.E+O0 I.E-01 I.E-02 2 1.E-03 1-0E-05 1.E-06 50 100 150 200 250 Frequency, Hz

                      -LC_2 Ave_MSL_C-Upper                          LC_1 AveMSLCUpper Figure 5: Steam Dryer Stress Limit Curve - MSL 'C' Upper MSL C Lower 1.0E+O0 1.OE-01 1.OE-02 I

1.0E-03 0) S 1.OE-04 1.0E-05 1.0E-06 0 50 100 150 200 250 Frequency, Hz

                  -  LC2 AveMSLC-Lowme                             -  LC_  AveMSL_CLower Figure 6: Steam Dryer Stress Limit Curve - MSL 'C' Lower

Page 19 of 19 Rev. 1 MSL D Upper 1.0EO00 1.0E-01 1.OE-02 I 1.0E-03 1-0E-04 1.OE-05 1.0E-06 0 50 100 150 200 250 Frequency, Hz

                          -    LC_2 AveMSL_DUpper                      -   LC.1 AveMSLD_Upper Figure 7: Steam Dryer Stress Limit Curve - MSL 'D' Upper MSL D Lower 1.0E-00 1.OE-01 1.0E-02 1.0E-03*

1.0E 1.OE-05 1.0E 0 50 100 150 200 250 Frequency, Hz LC_2 AveMSL_DLower - LC_1 AveMSLDLower Fiqure 8: Steam Dryer Stress Limit Curve - MSL 'D' Lower

BVY 06-031 Docket No. 50-271 Attachment 2 Vermont Yankee Nuclear Power Station Steam Dryer Monitoring Plan Basis for Compliance with License Condition 3.M.4 Total number of pages in Attachment 2 (excluding thiscover sheet) is 3).

Page I of 3 Bases for Compliance with License Condition 3.M.4

Reference:

ERSTI-04-VY1-1409-000, "Power Ascension Test Procedure for Extended Power Conditions 1593 to 1912 MWt (PATP)

Purpose:

This document assesses compliance of changes to the Vermont Yankee steam dryer monitoring models with Vermont Yankee License Condition 3.M.4. In addition, an assessment of the ability of the steam dryer to support operation at the next power plateau is also included herein. Discussion: On March 4, 2006 Vermont Yankee Nuclear Power Stations (VYNPS) raised reactor power from 1593 MWt to approximately 1673 MWt, the first power ascension plateau. At that power level the lower set of strain gages on the 'A' main steam line provided an indication at 137 Hz that exceeded the Level 2 Acceptance Criteria of the Steam Dryer Monitoring Plan (SDMP). Entergy Vermont Yankee entered the corrective action* program and performed an engineering evaluation which concluded that continuous operation at the first power plateau (1673 MWt) would not challenge steam dryer integrity. Entergy Vermont Yankee uses an Acoustic Circuit Model (ACM) and an ANSYS Finite Element Model (FEM) to monitor performance of the steam dryer. To address the aforementioned 137 Hz peak, these models have been updated in accordance with requirements established in License Condition 3.M of the Vermont Yankee Extended Power Uprate License Amendment. Details of these changes are discussed later. in this document. The scope of the analyses performed and the results are included in Entergy Vermont Yankee calculation VYC-3001, Revision 1. This calculation includes in part:

    " Strain Gage Data from 1593 MWt and 1673 MWt

Acoustic Circuit Model Benchmark Report
ACM Uncertainty Evaluation
Stress Analysis Model Description

    " Stress Analysis Results

Limit Curve Development
Revised Limit Curves Based on the improvements in the monitoring system and analysis techniques and evaluation of the VYNPS specific signals at 1673 MWt, an engineering evaluation has been completed and has concluded that the strain gage signals are expected to remain below the Level 1 Acceptance Criteria during operation up to and including the next power ascension plateau at 1753 MWt. A summary of the changes to the models and the uncertainty evaluation, along with the new Steam Dryer Strain Gage Limit Curves is contained in the Steam Dryer Monitoring Plan (SDMP) (Attachment 1 of BVY 06-031).

The details of these analyses, including any proprietary documents, have been made available to the NRC Technical Staff for review.

Page 2 of 3 The changes made to the steam dryer models and generation of revised steam dryer limit curves have been assessed against the requirements -of License Condition 3.M.4 which states:

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

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

b. Level 1 performance criteria;and

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

Changes to other aspects of the SDMP may be made in accordance with the guidance of NEI 99-04." As described above, License Condition 3.M.4 specifies those attributes of the approach to steam dryer monitoring that require NRC approval prior to being made less restrictive. As addressed below, Vermont Yankee concludes that the key attributes have NOT been made less restricted and, therefore, the proposed model and limit. curve changes do NOT require NRC approval. The following changes have been incorporated into the VY approach to steam dryer monitoring:

1. Incorporation of strain gage accu'racy improvements in accordance with License Condition 3.M requirements.

2. Use of an updated CDI AcousticCircuit Model (ACM) that has been modified to be conservative in the areas of interest and benchmarked against instrumented dryer data from several power levels at Quad Cities. The ACM update to address industry operating experience is required by the License Condition.

3. Revisions to the Finite Element Model (FEM) to incorporate refinement of model in areas of concern related to past failures at Quad Cities. and Dresden as required by the License Condition.

4. Generation of a new Uncertainty Calculation based on plant data and the changes above as required by the License Condition.

5. An updated Level 1 Limit Curve representing a conservative reduction of the ASME design limit (13.6 ksi) by the values obtained in the uncertainty assessment.

6. There have been no changes to the Computation Fluid Dynamics (CFD) Model or the role of the CFD analysis to provide additional conservatism for low frequency flow sources.

Page 3 of 3 This revision of the SDMP was evaluated against the criteria in License Condition 3.M.4 to determine if NRC approval is required as summarized below:

a. This revision proposes no change in the test plateau increments from those specified in the criteria.

b. The Level 1 performance criteria is defined as a limit curve for strain gage results that represents a stress on the dryer equal to the ASME Design Limit of 13.6 ksi minus the calculated total model and measurement uncertainty.

The application of model refinements that provide for higher accuracy in determining Vermont Yankee specific dryer stress limits does not constitute a change in methodology. The updated limit curves still represent the ASME criteria minus the calculated uncertainty.

c. The methodology for establishing stress spectra for the Level 1 and Level 2 criteria is not altered by this change.

As required by License Condition 3.M the output of the strain gages is generated as input to the Acoustic Circuit Model (ACM) analysis. The ACM generates pressure loads on the Steam Dryer. using the Helmholtz equations. The ANSYS FEM code is used to generate stress loads for affected components of the dryer. The above changes were evaluated using the guidance provided in NEI 99-04.

== Conclusion:==

1. Based on the analysis performed using VYNPS Strain Gage data taken at the 1673 MWt plateau and employing the improved models as required by the EPU License Amendment the VYNPS Steam Dryer is not expected to reach Level 1 Acceptance Criteria prior to or at the next power ascension plateau (1753 MWt) and Power Ascension can continue.

2. The SDMP has not been made less restrictive by the changes made to the ACM and FEM and prior NRC approval is not required to implement these changes.

Preparer: Craig Nichols Name K Signature

                                                                      &0 Date 1?

Reviewer: James Callaghan z- z--3j5,

Name (~f-" Signaifrre Date Reviewer: James DeVincentis - 7/ 7 Name .. Signature Date

/'

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc. Vermont Yankee P.O. Box 0500 En ter,ý, 185 Old Ferry Road Brattleboro, VT 05302-0500 Tel 802 257 5271 April 20, 2006 Docket No. 50-271 BVY 06-039 TAC No. MC0761

                                                                                                   ... Z't4 ATTN: Document Control Desk                                                                              z   -,

U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Vermont Yankee Nuclear Power Station Revision 2 to Steam Dryer Monitoring Plan

References:

1) Entergy letter to U.S. Nuclear Regulatory Commission, "Vermont Yankee Nuclear Power Station, License No. DPR-28 (Docket No' 50-271), Technical Specification Proposed Change No. 263, Extended Power Uprate," BVY 03-80, September 10, 2003

2) Entergy letter to U.S. Nuclear Regulatory Commission, "Vermont Yankee Nuclear Power Station, Revision 1 to Steam Dryer Monitoring Plan,"

BVY 06-031, March 26, 2006 This letter provides updated information pursuant to a regulatory commitment made in connection with the application by Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Entergy) for a license amendment (Reference 1, as supplemented) to increase the maximum authorized power level~of the Vermont Yankee Nuclear Power Station (VYNPS) from 1593 megawatts thermal (MWt) to 1912 MWt. includes a revision (Revision 2) to the Steam Dryer Monitoring Plan (SDMP) that was previously provided in Reference 2. The SDMP will remain in effect until License Condition 3.M expires. The SDMP, together with the EPU Power Ascension Test Procedure (PATP), provides for monitoring, inspecting, evaluating, and prompt action in response to potential adverse flow effects on the steam dryer as a result of power uprate operation. These actions provide assurance of the continued structural integrity of the steam dryer under Extended Power Uprate conditions. This revision has been reviewed in accordance with License Condition 3.M.4 and does not require prior NRC approval. Docket No. 7195 Attachment 13-3 23 Pages

BVY 06-039 Docket No. 50-271 Page 2 of 2 There are no new regulatory commitments contained in this submittal. If you have any questions or require additional information, please contact Mr. James DeVincentis at (802) 258-4236. Sincerely, Vermont Yankee Nuclear Power Station Attachments (1) cc: Mr. Samuel J. Collins (w/o attachments) Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Richard B. Ennis, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8B1 Washington, DC 20555 USNRC Resident Inspector, Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

Attachment 1 Vermont Yankee Nuclear Power Station Steam Dryer Monitoring Plan Revision 2

Entergy Vermont Yankee Steam Dryer Monitoring Plan Revision 2 April 20, 2006 Prepared By_ I/ raig J. Nichols Date Reviewed By Date Aoes B9 Cae Approved By_* } oh Dess Date

Page 1 of 19 Rev. 2 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, tothe 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 19 Rev. 2 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. 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 hour holds at each 80 MWt power plateau to perform steam dryer analysis allowing for NRC review, as appropriate (required by License Condition 3.M).

Monitorinq 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 will provide early detection capability of off-normal performance. Proposed License Condition 3.M will require 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 provide a means to assess continued steam dryer structural'integrity under EPU conditions. Main Steam Fluctuating Pressure Monitoring System (Details contained 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 19 Rev. 2

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.

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 assessmentthat provided the uncertainty bases for the prior ACM have been accordingly deleted from this calculation.

The overall system uncertainty is based on the combination of the uncertainties of each of the elements. The uncertainty in the ACM loads is derived from the following sources: o Uncertainty of the ACM to conservatively predict pressure response at the significant

           ,frequencies o Uncertainty introduced by differences in sensor locations between QC2 and VY o Uncertainty introduced as a result of the ability of the ACM or Structural Model to match load and structural frequencies o Uncertainty resulting from strain gage and measure uncertainties..

These uncertainties will then be combined, by the square root sum of the squares (SRSS) method to assess the ACM load uncertainty. As calculated in VYC-3001 the overall system uncertainty is 43%. This value is used in the determination of the reduction of the limit curve factor resulting in the final limit curve, shown as Figures 1 through 8 of the SDMP. The contribution of each of the factors noted above is as follows: Maximum Uncertainty of the ACA Methodoloqy (per VYC 3001 Rev. 2) ACM ability to conservatively match peak response at the highest frequencies: 32% Difference in Sensor Locations from QC2 to VY 7% Ability of ACM or Structural Model to match response frequencies: 25% SG and DAS ability to measure pressure in Pipe 11% Uncertainty of Dryer Pressure data Measurements at QC2 3% Combined Uncertainty by Square Root Sum of the Squares 43% The uncertainty of the ACM to predict peak response at observed dryer acoustic frequencies is the largest contributor to overall ACA load uncertainty. The other uncertainties including the sensor location uncertainty, frequency uncertainty, pipe pressure measurement uncertainty, and QC2 dryer pressure measurement uncertainty are independent elements of uncertainty because they are derived from unrelated variables such as location, frequency, independent benchmark assessment, and detection equipment. Therefore the SRSS combination methodology is appropriate. 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%

Page 4 of 19. Rev. 2 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 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. 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,

Page 5 of 19 Rev. 2 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. In addition the final full EPU power performance criteria spectra (i.e., steam dryer stress limit curve) will be 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 Monitoring 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 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 corducted 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.

Page 6 of 19 Rev. 2 Table 1 Steam Dryer Surveillance Requirements During Reactor Power Operation Above a Previously Attained Power Level Parameter Surveillance Frecluencv

1. Moisture Carryover Every 24 hours (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 hours of achieving an 80 MWt power plateau, an orderly power reduction shall be made within the subsequent 12 hours 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 7 of 19 Rev. 2 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 QR 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 Spectra1 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) 0 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 hours, re-measure moisture carryover and perform an Pressure data exceed Level engineering evaluation of steam dryer structural integrity. If the 1 Spectra1 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 hours. 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 8 of 19 Rev. 2 Table 3 Steam Dryer License Conditions License Condition Requirement Implementinq Actions 3.M.1 .a Entergy shall monitor hourly the 32 During initial power ascension above 1593 MWt, main steam line (MSL) strain gages data from at least 32 strain gages will be collected during power ascension above 1593 and evaluated by Entergy's power ascension test MWt for increasing pressure team to verify that acoustic signals indicative of fluctuations in the steam lines. 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) i 3.M.l.b 3.M.1 .b Entergy shall hold the facility for 24 The PATP has established test plateau increments hours at 105%, 110%, and 115% of of approximately 80 MWt (corresponding to 105%, OLTP (i.e., 1593 MWt) to collect 110%, and 115% of 1593 MWt). Reactor power will data from the 32 MSL strain gages not be increased above the plateau for a minimum required by License Condition of 96 hours. During the first 24 hours of steady 3.M.l.a, conduct plant inspections state operation at each plateau, strain gage data and walkdowns, and evaluate steam will be collected from all available strain gages dryer performance based on these (minimum of 32) and evaluated to demonstrate data; shall provide the evaluation to acceptable steam dryer performance. Additionally, the NRC staff by facsimile or moisture carryover measurements will be made at electronic transmission to the NRC each plateau and every 24 hours during power project manager upon completion of ascension testing. At the 80 MWt plateau hold the evaluation; 'and shall not points, Entergy will conduct plant walkdowns and increase power above each hold inspections of plant equipment, including piping and point until 96 hours after the NRC components identified as potentially vulnerable to project manager confirms receipt of flow-induced vibration (FIV) in accordance with the the transmission. PATP and other plant procqedures. 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 Manager confirming receipt of the steam dryer data and performance evaluation, the 96 hours of hold

Page 9 of 19 Rev. 2 License Condition Requirement Implementing Actions 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 The steam dryer stress limit curve provided strain gage data exceeds the limit herewith contains Level 1 and Level 2 criteria. If curve established by Entergy frequency peaks from MSL strain gage data exceed Nuclear Operations, Inc. and either Level 1 or Level 2 criteria, prompt action will submitted to the NRC staff prior to be taken in response to the potential adverse flow operation above OLTP, Entergy effects that might result. Similar actions will occur if Nuclear Operations, Inc. shall return moisture carryover is excessive and previously the facility to a power level at which established Level 1 or Level 2 criteria are the limit curve is not exceeded. exceeded. The Level 2 criteria represent a Entergy Nuclear Operations, Inc. conservative action level for evaluation and close shall resolve the uncertainties in the monitoring of steam dryer performance-not a limit. steam dryer analysis, document the The Level 1 criteria represent analytical limits and continued structural integrity of the 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 10 of 19 Rev. 2 License Condition Requirement Implementing Actions 3.M.1.d In addition to evaluating the MSL Accelerometers mounted on MSL piping will be strain gage data, Entergy Nuclear monitored on an hourly basis during power Operations, Inc. shall monitor ascension testing to identify if resonances are reactor pressure vessel water level 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.l .e Following start-up testing, Entergy After collecting strain gage data at approximately Nuclear Operations, Inc. shall the EPU full power level, Entergy will resolve the resolve the uncertainties in the uncertainties in the steam dryer analysis and steam dryer analysis and provide provide documentation of the resolution to the NRC that resolution to the NRC staff by staff. If these actions cannot be achieved within 90 facsimile or electronic transmission days of issuance of the license amendment, reactor to the NRC project manager. If the power will be limited to 1593 MWt. This uncertainty uncertainties are not resolved within evaluation may be prepared and provided to the 90 .days of issuance of the license NRC prior to reaching EPU full power levels amendment authorizing operation at associated with any proposed revision to the steam 1912 MWt, Entergy Nuclear dryer limit curve. Operations, Inc. shall return the (Reference PCRS tracking item WT-VTY-2005-facility to OLTP. 00000-01803)

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Page 11 of 19 Rev. 2 IQ After reaching 120% of OLTP, After collecting strain gage data at approximately Entergy Nuclear Operations, Inc. the EPU full power level, Entergy will establish the shall obtain measurements from the steam dryer flow-induced vibration load fatigue MSL strain gages and establish the margin for the facility, update the steam, dryer stress steam dryer flow-induced vibration report, and re-establish the stress limit curve with load fatigue margin for the facility, the updated ACM load definition and revised update the steam dryer stress instrument uncertainty. This information will be report, and re-establish the steam included in the report to the NRC staff being made dryer monitoring plan (SDMP) limit in accordance with License Condition 3.M.1.e. curve with the updated ACM load (Reference PCRS tracking item WT-VTY-2006-definition and revised instrument 00000-00249) uncertainty, which will be provided to the NRC staff. Entergy Nuclear Operations, Inc. The revised SDMP provides long-term monitoring of shall revise the SDMP to' reflect steam dryer performance in accordance with GE long-term monitoring of plant 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 steam dryer inspection *program with General Electric Services Information Letter 644, Revision 1; and to identify the NRC Project Manager for the facility as the point of contact for providing SDMP information during power ascension. 0M"C

Page 12 of 19 Rev. 2 Requirement Implementing Actions Entergy Nuclear Operations, Inc. The final EPU steam dryer load definition will be shall submit the final extended included in the report provided to the NRC staff in power uprate (EPU) steam dryer accordance with License Conditions 3.M.1.e. and load definition for the facility to the 3.M.2.c. NRC upon completion of the power (Reference PCRS tracking item WT-VTY-2006-ascension test program. 00000-00251) 3vvrl"

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Page 13 of 19 Rev. 2 License Condition Requirement Implementinq Actions I I ILA 1~ 4 R-1 W4_ MW aaalp

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Page 14 of 19 Rev. 2 I 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-VYI-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 with the guidance of NEI 99-04. 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 15 of 19 Rev. 2 I 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 steamr 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 16 of 19 Rev. 2 MSL A Upper 1.0E+00 iGOE-01 1 .0E-02 1 .OE-03. E 1.0E-04 1 .0E-05 1.OE-06 0 50 100 150 200 250 Frequency, Hz

                     -LC02    AveMSLA_Upper                                 LCI Ave-MSL-A Upper Fiaure 1: Steam Dryer Stress Limit Curve               -  MSL 'A' Urper MSL A Lower 1.OE+00 1.OE-01 1.0E-02 1.OE-03 E

1.OE-04 1.0E-05 1.0E-06 0 50 100 150 200 250 Frequency, Hz

                 --    LC_2 Ave MSLA-Lower                            -LC_1   Ave MSL A Lower Figure 2: Steam Dryer Stress Limit Curve - MSL 'A' Lower

Page 17 of 19 Rev. 2 MSL B Upper 1.OE+00 t.OE-01 1.0E-02 z S.OE-O3 1.OE-04 1.00-05 1.OE-06 0 50 100 150 200 250 Frequency, Hz

                -LC_2    AveMSL-B-Upper                           -LC-1     Ave MSL-BUpper Figure 3: Steam Dryer Stress Limit Curve - MSL 'B' Upper MSL B Lower 1.OE+00 I .OE-01 I.OE-02 1.OE-03 i.0E-04 1.OE-05 i0E-06 0         50                 100                . 150                  200             250 Frequency, Hz
                --  LC_2 AveMSL-BLower                              -   LC_1 AveMSLB_Lower Figure 4: Steam Dryer Stress Limit Curve - MSL 'B' Lower

Page 18 of 19 Rev. 2 MSL C Upper 1.E+00 11.-01 1.E-02 w E 0< 1.E-03 1.E-04 1.E-05 1.E-06 0 50 100 150 200 250 Frequency, Hz

             *    -    LC_2 Ave_MSL-C!Upper .                          -   LC_1 Ave_MSLC-Upper Figure 5: Steam Dryer. Stress. Limit Curve - MSL 'C' Upper MSL C Lower 1.OE+00 1.0E-01 1.0E-02
 " 1.0E-03 E

1.00-04 1,0E-05 1.OE-06 0 50 100 150 200 250 Frequency, Hz

                   -LC_2     AveMSL-C_Lower                              -LCI    Ave MSLCLower Fiaure 6: Steam Dryer Stress Limit Curve - MSL 'C' Lower

Page 19 of 19 Rev. 2 MSL D Upper I.OE.0OO 1 CE-Ol 1.GE-02 E 1.0E-03 1.0E-04 1 0E-05 1.0E-06 0 50 100 150 200 250 Frequency, Hz

                       -LC_2   AveMSLDUpper                        -LC)1   AveMSL_DUpper Figure 7: Steam Dryer Stress Limit Curve - MSL 'D' Upper MSL D Lower 1.OE+00 1.0E-01 1.0E-02 E

1.0E-03 1.0E-04 1.0E-05 1.0E-06 50 . 100 .150 200 250 Frequency, Hz

                    -LC_2    Ave MSLD0Lower                          -LC_1  AveMSL_ DLower Figure 8: Steam Dryer Stress Limit Curve - MSL 'D' Lower

cr* 0.1.-* Entergy Nuclear Northeast Entergy Nuclear Operations, Inc. Vermont Yankee U % j~o. P.O. Box 0500 Entff,ý c.A £~:l~ 185 Old Ferry Road Brattleboro, VT 05302-0500 Tel 802 257 5271 LUuJ Cý/\ v 2-- ý Cý May 4, 2006 Docket No. 50-271 BVY 06-042 TAC No. MC0761 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Vermont Yankee Nuclear Power Station Revision 3 to Steam Dryer Monitoring Plan

References:

1) Entergy letter to U.S. Nuclear Regulatory Commission, "Vermont Yankee Nuclear Power Station, License No. DPR-28 (Docket No. 50-271), Technical Specification Proposed Change No. 263, Extended Power Uprate," BVY 03-80, September 10., 2003

2) Entergy letter to U.S. Nuclear Regulatory Commission, "Vermont Yankee Nuclear Power Station, Revision 2 to Steam Dryer Monitoring Plan,"

BVY 06-039, April 20, 2006 This letter provides updated information pursuant to a regulatory commitment made in connection with the application by Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Entergy) for a license amendment (Reference 1, as supplemented) to increase the maximum authorized power level of the Vermont Yankee Nuclear Power Station (VYNPS) from 1593 megawatts thermal (MWt) to 1912 MWt. -Attachment 1 includes a revision (Revision 3) to-the Steam Dryer Monitoring Plan (SDMP) that was previously provided in Reference 2. The SDMP will remain in effect until License Condition 3.M expires. The SDMP, together with the Extended Power Uprate (EPU) Power Ascension Test Procedure (PATP), provides for monitoring, inspecting, evaluating, and prompt action in response to potential adverse flow effects on the steam dryer as a result of power uprate operation. These actions provide assurance of the continued structural integrity of the steam dryer under EPU conditions. Attachment 2 provides the basis, consistent with License Condition 3.M.4, for why this change does not require prior NRC approval. Entergy has performed necessary calculations and evaluations to ensure for safe operation at the 1912 MWt power level. Docket No. 7195 Attachment 13-4 27 Pages

BVY 06-042 Docket No. 50-271 Page 2 of 2 There are no new regulatory commitments contained in this submittal. If you have any questions or require additional information, please contact Mr. James DeVincentis at (802) 258-4236.

              ~Sincerely, Site 4Vice President Vermont Yankee Nuclear Power Station Attachments (2) cc:    Mr. Samuel J. Collins (w/o attachments)

Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Richard B. Ennis, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8B1 Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer .20 Montpelier, Vermont 05620-2601

BVY 06-042 Attachment 1 Vermont Yankee Nuclear Power Station Steam Dryer Monitoring Plan Revision 3

Entergy Vermont Yankee Steam Dryer Monitoring Plan Revision 3 May 4, 2006 Prepared B y

            --raig J. Nichols            Date Reviewed By         _______
          ,nes       CallaýAan           Date Approved Bm_                    /ý Date
           .\J.phneyfuss U

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 1 Hz 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

Page 1 of 20 Rev. 3 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 20 Rev. 3 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. 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 hour 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 will provide early detection capability of off-normal performance. Proposed License Condition 3.M will require 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 provide a means to assess continued steam dryer structural integrity under EPU conditions. Main Steam Fluctuating Pressure Monitoring System (Details contained 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 20 Rev. 3 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 (<lHz) 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 1 Hz. 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 overall system uncertainty is based on the combination of the uncertainties of each of the elements. The uncertainty in the ACM loads is derived from the following sources: o Uncertainty of the ACM' to conservatively predict pressure response at the significant frequencies o Uncertainty introduced by differences in sensor locations between QC2 and VY o Uncertainty introduced as a result of the ability of the ACM or Structural Model to match load and structural frequencies o Uncertainty resulting from strain gage and measure uncertainties. These uncertainties will then be combined by the squa-re root sum of the squares (SRSS) method to assess the ACM load uncertainty. As calculated in VYC-3001 the overall system uncertainty is 43%. This value is used in the determination of the reduction of the limit curve factor resulting in the final limit curve, shown as Figures 1 through 8 of the SDMP. The contribution' of each of the factors noted above is as follows:

Page 4 of 20 Rev. 3 Maximum Uncertainty of the ACA Methodology (per VYC 3001 Rev. 2) ACM ability to conservatively match peak response at the highest frequencies: 32% Difference in Sensor Locations from QC2 to VY 7% Ability of ACM or Structural Model to match response frequencies: 25% SG and DAS ability to measure pressure in Pipe .11% Uncertainty of Dryer Pressure data Measurements at QC2 3% Combined Uncertainty by Square Root Sum of the Squares 43% The uncertainty of the ACM to predict peak response at observed dryer acoustic frequencies is 'the largest contributor to overall ACA load uncertainty. The other uncertainties including the sensor location uncertainty, frequency uncertainty, pipe pressure measurement uncertainty, and QC2 dryer pressure measurement uncertainty are independent elements of uncertainty because they are derived from unrelated variables such as location, frequency, independent benchmark assessment, and detection equipment. Therefore the SRSS combination methodology is appropriate. " 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 + 4^2) = 16%.

System Monitoring Requirements

   " 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 20 Rev. 3 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 Monitoring 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 elevated moisture carryover results including that resulting from potential vessel internals

Page 6 of 20. Rev. 3 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.

Page 7 of 20 Rev. 3 Table 1 Steam Dryer Surveillance Requirements During Reactor Power Operation Above a Previously Attained Power Level Parameter Surveillance Frequency

1. Moisture Carryover Every 24 hours (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 hours of achieving an 80 MWt power plateau, an orderly power reduction shall be made within the subsequent 12 hours 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 8 of 20 Rev. 3 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 i Level 2: 1. Promptly suspend reactor power ascension until an engineering evaluation concludes that furtherpower 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 Spectra1 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 hours, 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 hours. 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 1011 cycles (i.e., 13.6 ksi).

Page 9 of 20 Rev. 3 Table 3 Steam Dryer License Conditions License Condition Requirement Implementing Actions 3,M.l.a Entergy shall monitor hourly the 32 During initial power ascension above 1593 MWt, main steam line (MSL) strain gages data from at least 32 strain gages will be collected during power ascension above 1593 and evaluated by Entergy's power ascension test MWt for increasing pressure team to verify that acoustic signals indicative of fluctuations in the steam lines. 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-VYI -1409-000) (Reference PCRS tracking item WT-VTY-2005-00000-01803)

Page 12 of 20 Rev. 3 License Condition Requirement Implementing Actions above OLTP Enteragy Nsuclear as oiation wut ther lenchharking of thesnew ACM MOperationsgae Inc. shabl evaluathe a fr specific,upa ent of the srs uVs erfortned and is contained in udt 3.M.2. Afe thstean Teahn .... 120% of OLP insh l.dsandre-estab fe etainty oletnsran gae daaa nppoiaely traerinit curve basn ( hS im Calculation VYCe 3001, Rev. 1. ie adfrequency-specific assessment of (Referece0 VYC43001 Rev. 1)

              'ACM urncertainty at the acoustic steam dryer flwidcdvbato                              re-establish eot        n         peiiae      th~ec strens         ofmithcre ACth sigonal frequency.,-..

3.M.2.c After reaching 120% of OLTP, After collecting strain gage data at approximately reprtanNuclear Entergy Operations,steam reesandishalle Inc. the EPU fullthpower includefdrenc 1o9te RCstfO will establish eporttI-4 level, Entergy bin md the gagemeasurements obtain strveaith shall upate ACMrlorm from the steam (Refre,,cedryer PCRS tracking vibration flow-induced temWT-TY-2006load fatigue MSL strain gages and establish the margin for the facility, update the steam dryer stress steam dryer flow-induced vibration report, and re-establish the stress limit curve with load fatigue margin for the facility, the updated ACM load definition and revised update the steam dryer stress instrument uncertainty. This information will be report, and re-establish the steam included in the report to the NRC staff being made dryer monitoring plan (SDMP) limit in paccordance with License Condition 3.M...e. curve with the updated ACM load (Reference PCRS tracking item WT-VTY-2006-definition and revised instrument 00000-00249) uncertainty, which will be provided to the NRC staff. 3 M.2l During-f powern asceipsion above COMPLETE -A paFrt ofithe evaluatovn perfoered OLTR if an engieeing evaluation at. 1673MWt Entergy Vermont Yan ompletedr is required in aewith the revisions torthe VY Steam Dryer model used in th

             ~SDMP, Entergy Nula                        prtos            iieEeetModel (FEM). Additionalanlsso Inc. shall    performr          thj&    structural. the' FEM ouitpuit was ,performed- to assess the:

analysis. to- address§. frequency. ~freqenqy,- uncertainties. The results, of this

unc~ertainties- p to --10 ajý~ass essmeint<6-e -ontained in: Ca:lculation VYC7 vwithinf. this? uncertainty, band are- (Reference-ERSTI-04-VY1 -1409-0Ob)

   -.  .i    addressed.                    *   ,.    .-                  ~9                           ~~

3.M.2.e Entergy Nuclear Operations, Inc. The revised SDMP provides long-term monitoring of shall revise the SDMP to reflect steam dryer performance in accordance with GE. long-term monitoring of plant '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 steam 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; 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-VY1-1409-000) of contact for providing SDMP information dluring power ascension. COMPLETE - For moisture carryover, procedures OP-0631 and ON-3178 provide for long-term monitoring and controls.

Page 13 of 20 Rev. 3 License Condition Requirement Implementing Actions 3.M.2.f Entergy Nuclear Operations, Inc. The final EPU steam dryer load definition will be shall submit the final extended included in the report provided to the NRC staff in power uprate (EPU) steam dryer accordance with License Conditions 3.M.l.e. and load definition for the facility to the 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 BV..0601.9iforwards, shall.: submit: _thei6ý iflow-induced the FIV-related portionS of:.., the.::,EPU' pWerp. vibration related portions of the EPU ascension test.. procedure. to: the'& NRC.:%. (Refe]rence startup test procedure to the NRC; ERSTI-04-VY1-.1409-000) including methodolog for updating the limiit 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. Co.* lctrepresentative.data from 32 strainngages at eightWlMSL l ions.: -

2(t UsPiLng

                                                                  . l. .        -Speific ACM, anald.draio age dsotapto determine steam dryer            . strne*l 7i          h      :        :3.            .Input        ACM. loadsinto a-finite1element model to-determine dryer stresses.

4. Perform an updated uncertainty evaluation' revised steam dryerstress limit

                                                                                                       .Generate
                               *e*6i;:man~e.L                     curve(Is).      o.cclcltin                             .
                                                           .(Reference, PCIRS tracking item WT-VTY-2006-00000-00252) 3.'M.3(a)        Entergy shall prepare the EPU               COMPLETE -ATheisteam dryerac          stre limit curve to startup test procedure to include the       be applied for va fig te                     P       ormance stress limit cur~ve to be applied for .durnng power ascension is 'provided herewith.                 The limit curve wa-vlpdo                       the basis of evaluating           steam,         dryer                      wa devlpdo....

performance.. .calculation VYC-3,001, which is incorporated byý

                                                           -reference into the EPU PATP;<

(Reference ERSTI-04-VY1 -1 409-000) 3.M.3(b) Entergy shall prepare the EPU COMPLETE - Specific hold points and*durations are startup test. procedure.,1 t:o include. specified~in the PATP.

specific hold points and their (Reference ERSTI-04-VY1-140,9-000) -

duration during EPU power ascension.

3.M. 33(c) Entergy shall prepare the EPU 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) _______ hold points.I

Page 14 of 20

                                                                                                           . Rev.-3 License Condition                      Requirement                                  Implementing Actions 3.3M..3(d)       En.tpgy shalprepare, the EPU             COMPLETE. Plant parameterseto:be :monitored arel, startup test: procedure to include       specified in Attachment9to the PATP.

plant parameters to be monitored. (Reference ERSTI-04-VY1 '-1 409-000). 3.M.3(e) Entergy shall. prepare, the EPU COMPLETE-- Inspections and walkdowns to be

          *startup        test pr'oceduire: to .include. conducted for steam, feedwater, and' conde'nsate.**

inspections "and alkdowns to, b-e . systemis and comnpe*nents during hold points..- are. conduicted for steam, feedwater, specified in Attachmeint 0 to the PATR. adcondensate~ systems7 and (Reference~ ERSTIkO4-VY1 -1409-000)

compon~ents during the hold points.

3.M.33(f);- Entergy shall. prepare the EPU COMPLETE Methods-, to be used to trend plant. startup test procedure to include paramieters are spcfe in Attachm~ent *'9 'to the.,

meth'ods 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 mnitrin startup. test procedure toe include and trendin plantparameters and conucting.the.. acceptance criteria for monitoring' .:'aarid' ndi:nspetions 'are ..-. 'specified- in% and Attachment 9 to.the PATP. (Reference ERSTI-04-"i, eanditrending plant parameters, e conducting the walkdowins andt VY 1 1409-000) inspections.2 3,M. 3(h) iEntergy shall prepare :the.,EPU COMPLETE -Actions' to be' takenifacpne startup test *procedure. to .include criteria are not satisfied are spfifd in atce p'ta. actions to be taken. if acceptance (Reference ERSTI-04-VY1-1409-000) criteria ar'e 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 speciiedi thePAhP 'in the verification', of -'the completion of license amendment' application and all supplements commitments, and planne.d: actons to the application 'in, support of the EPU :license specified' in.the licenseý amendment amend mentl request pertainingý to the steam dcryer. is: aplication. and. all, supplements -to' specified in the PATP'. the application in support ýof the '(Reference ERSTI-04-VY1 -1400-000) EP icense amendment request

pertaining to the steam dryer.

Page 15 of 20 Rev. 3 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. Thefollowing key attributes of the SDMP shall not be made less restrictive without prior NRC approval:

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

b. Level 1 performance criteria; and

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

Changes to other aspects of the SDMP.may be made in accordance with the Quidance of NEI 99-04. 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 16 of 20 Rev. 3 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/f law 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 17 of 20 Rev. 3 1.OE+00 1.0E-01 1.0E-02 E I.0E-03 1.0E-04 1.oE-05 1.0E 0 50 100 150 200 250 Frequency, Hz

             -LC2_AveMSL_A    Upper                               -LC1  Ave MSLAUpper.

Figure 1: Steam Dryer Stress Limit Curve - MSL 'A' Upper 1.0E+00 1.OE-01 1.OE-02 1.0E-03 E 1.OE-04 1.0E-05 1.0E-06 0 50 100 150 200 250 Frequency, Hz

            -LC2_Ave    MSLALower                               -LC1   Ave MSLALower Figure 2: Steam Dryer Stress Limit Curve - MSL 'A' Lower

Page 18 of 20 Rev. 3 1.0E00 1.OE-01 I.OE-02 a 1.OE-03 1.OE-04 1.0E-05 1.0E-06 0 50 100 150 200 250 Frequency, Hz

                  -LC20AveMSLBUpper                          -LCIAveMSLB-Upper Figure 3: Steam Dryer Stress Limit Curve - MSL 'B' Upper 1 0E+00 1.05-01 I.DE Z   1.OE-03 I.OE     1 .OE-06 50              100                150              200              250 Frequency, Hz
                -    LC2_AveMSLBLower                        -   LC1 AveMSLBLower Fioure 4: Steam Dryer Stress Limit Curve - MSL 'B' Lower

Page 19 of 20 Rev. 3 1.E.00 1 .E-01 1.E-02 i .E-03 1.E-04 1.E-05 1.E-06 0 50 100 150 200 250 Frequency, Hz

                 -  LC2_AveMSLC_ Upper                        -     LC1_AveMSL_CUpper.

Fiqure 5: Steam Dryer Stress Limit Curve - MSL 'C' Upper 1.0E+00 1,0E-01 1.OE-02 .ES1.OE-03 1.OE-04 1.OE-05 1.0E-06 0 50 100 150 200 250 Frequency, Hz

                --  LC2_AveMSL _C_Lower                        -LC1     _AveMSL_CLbwer Figure 6: Steam Dryer Stress Limit Curve - MSL 'C' Lower

Page 20 of 20 Rev. 3 1.0E+00 1.0E-01 1.0E-02 1.02-03 E 1.0E-04 1.0E-05 1,OE-06 0 50 100 150 200 250 Frequencyý Hz

                    -  LC2_AveMSL_DUpper                         -LCIAveMSLDUpper Fiqure 7: Steam Dryer Stress Limit Curve - MSL'D' Unper 1.0E+00 1.OE-01 1.0E-02 1.0E-03 E

1.OE-04 1.0E-05 1.0E-06 50 100 150 200 250 Frequency, Hz

                    -- LC2_AveMSLDLower                        -    LClAveMSLDLower Ficure 8: Steam Dryer Stress Limit Curve - MSL 'D' Lower}}

ML063170200

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Dear John and Nancy:

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Dear Mr. Chairmnan:

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Dear Mr. Kansler:

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Dear Mr. Kansler:

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Background

NRC Staff Evaluation

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NRC Staff Evaluation

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NRC Staff Evaluation

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