ML090860380

Audit Summary Regarding the Vermont Yankee Nuclear Power Station License Renewal Application

ML090860380
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/08/2009
From:	Rowley J License Renewal Projects Branch 2
To:	Kansler M Entergy Nuclear Operations
Rowley J, NRR/DLR/RLRB, 415-4053
References
Download: ML090860380 (12)

Text

May 8, 2009 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601-1839

SUBJECT:

AUDIT

SUMMARY

REGARDING THE VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION

Dear Mr. Kansler:

By letter dated January 25, 2006, Entergy Nuclear Operations, Inc., submitted an application for review by the U.S. Nuclear Regulatory Commission (NRC or the staff) pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) to renew the operating license for the Vermont Yankee Nuclear Power Station (VYNPS). On February 20, 2009, the staff completed an audit of the results of the confirmatory environmentally adjusted fatigue cumulative usage factor analyses for the core spray and recirculation outlet nozzles at the VYNPS. The audit summary is enclosed.

If you have any questions, please contact me at 301-415-4053 or by e-mail at Jonathan.Rowley@nrc.gov.

Sincerely,

/RA/

Jonathan Rowley, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulations Docket No. 50-271

Enclosure:

As stated cc w/encl: See next page

May 8, 2009 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601-1839

SUBJECT:

AUDIT

SUMMARY

REGARDING THE VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION

Dear Mr. Kansler:

By letter dated January 25, 2006, Entergy Nuclear Operations, Inc., submitted an application for review by the U.S. Nuclear Regulatory Commission (NRC or the staff) pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) to renew the operating license for the Vermont Yankee Nuclear Power Station (VYNPS). On February 20, 2009, the staff completed an audit of the results of the confirmatory environmentally adjusted fatigue cumulative usage factor analyses for the core spray and recirculation outlet nozzles at the VYNPS. The audit summary is enclosed.

If you have any questions, please contact me at 301-415-4053 or by e-mail at Jonathan.Rowley@nrc.gov.

Sincerely, Jonathan Rowley, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulations Docket No. 50-271

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION: See next page ADAMS Accession Number:

OFFCIE PM:RPB2:DLR LA:DLR BC:RPB1:DLR BC:RPB2:DLR OGC NAME JRowley YEdmonds JDozier DWrona LBS DATE 04/21/09 04/30/09 04/29/09 05/07/09 OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION (NRC)

OFFICE OF NUCLEAR REACTOR REGULATION - DIVISION OF LICENSE RENEWAL AUDIT

SUMMARY

REGARDING THE LICENSE RENEWAL APPLICATION FOR THE VERMONT YANKEE NUCLEAR POWER STATION (VYNPS)

Docket No: 50-271 License No: DPR-28 Licensee: Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC Location: NPOC Offices 11426 Rockville Pike, Suite 230 Rockville, MD 20852 Dates: February 18-20, 2009 NRC Staff: J. Rowley, Project Manager, Division of License Renewal (DLR)

B. Holian, Director, DLR D. Wrona, Branch Chief, DLR A. Hiser, Senior Technical Advisor, DLR J. Gavula, Mechanical Engineer, DLR C. Yang, Sr. Mechanical Engineer, DLR J. Fair, Sr. Mechanical Engineer, Division of Engineering (DE)

M. Hartzman, Sr. Mechanical Engineer, DE Licensee Staff: G. Young, License Renewal Manager, Entergy A. Cox, License Renewal Technical Manager, Entergy D. Mannai, Licensing Manager, VYNPS S. Goodwin, Engineering Supervisor, VYNPS G. Stevens, Senior Associate, Structural Integrity Associates J. Fitzpatrick, Engineering Supervisor, Areva Approved By: David Wrona, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Jerry Dozier, Chief Engineering Review Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation ENCLOSURE

Introduction On January 25, 2006, Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC (Entergy) submitted the license renewal application (LRA) for the Vermont Yankee Nuclear Power Station (VYNPS). In the Safety Evaluation Report of the Vermont Yankee LRA of May 2008 (NUREG-1907), the NRC staff proposed a license condition that would require Entergy to perform confirmatory analyses of the reactor core spray (CS) and reactor pressure vessel recirculation outlet (RO) nozzles two years prior to the period of extended operations and submit them to the NRC for review and approval. On January 15, 2009, Entergy submitted the results of its confirmatory environmentally adjusted fatigue cumulative usage factor (CUFen) analyses for the CS and RO nozzles at the VYNPS.

The NRC staff conducted a three-day audit of the results on February 18-20, 2009. The focus of the audit was determining if the confirmatory metal fatigue analyses appropriately utilized the American Society of Mechanical Engineers (ASME) Code Section III methodology rather than the Greens Function methodology, which was used in the original analyses, to demonstrate acceptable CUFen for 60 years of plant life for the CS and RO nozzles. The NRC staff also focused on determining if any significantly different technical or scientific judgments from those used in the VYNPS feedwater nozzle confirmatory analysis were used.

In performing this audit, the NRC staff examined the applicants calculations and related references for these calculations. The NRC staff also interviewed Entergy representatives and contractors to obtain additional clarification related to the calculations. This summary documents the NRC staff activities during this audit.

Reactor Core Spray Nozzle Confirmatory Analysis During its audit, the NRC staff reviewed the applicants confirmatory analysis and related references for the CS nozzle. The applicant indicated that the analysis is consistent with the methods in the ASME Code Section III and does not involve use of the Greens Function, as was done in the previous refined analysis. The applicant also indicated that the CS confirmatory analysis contains no significantly different technical or scientific judgments from those used in the VYNPS feedwater nozzle confirmatory analysis and that the CUFen is less than unity. The staff interviewed the applicant's technical staff and reviewed the documents listed below.

DOCUMENT TITLE REVISION Structural Integrity Design Inputs and Methodology for Revision 0 Associates Calculation ASME Code Fatigue Usage Analysis No. 0801038.301* of Reactor Core Spray Nozzle Structural Integrity Stress Analysis of Reactor Core Revision 0 Associates Calculation Spray Nozzle No. 0801038.302*

Structural Integrity Fatigue Analysis of Core Spray Revision 0 Associates Calculation Nozzle No. 0801038.303*

Structural Integrity Core Spray Nozzle Finite Element Revision 0 Associates Calculation Model No. VY-16Q-308**

Structural Integrity Core Spray Nozzle Greens Function Revision 1 Associates Calculation No. VY-16Q-309**

Structural Integrity Fatigue Analyses of Core Spray Revision 1 Associates Calculation Nozzle No. VY-16Q-310**

• Confirmatory analysis

• • Refined analysis The NRC staff compared the CS nozzle confirmatory analysis with the refined analysis. The NRC staff reviewed the calculations to determine whether the applicant used significantly different technical or scientific judgments from those used in the feedwater nozzle confirmatory analysis. The NRC staffs task also included determining:

1. If the confirmatory analysis is a detailed ASME Code Section III fatigue calculation,

2. If the same transient definitions and cycle counts were used,

3. If the same finite element model was used,

4. If the same number and severity of design transients were used,

5. If the same water chemistry inputs were used,

6. If the same limiting cross-section was evaluated,

7. and if appropriate stress ranges and correction factor were applied.

In response to the NRC staffs questions regarding variations in stress results between the refined and confirmatory analyses, Entergy informed the NRC staff that a different element type was used in the two finite element models. According to Entergy's contractor, the finite element software produced inconsistent stress results, wherein membrane plus bending stress intensities were reportedly greater than the total stress intensities. Since these results were inconsistent with the definition of total stress intensity, the contractor switched to a different element type in the confirmatory analyses to assure they obtained accurate stresses, and indicated they were independently pursuing the cause of the inconsistency with the software vendor. The NRC staff verified that the same element type was used in the confirmatory analyses for the feedwater, CS, and RO nozzles.

The NRC staff was unable to verify various results in the analysis using the numbers and references cited by the applicant. The NRC staff questioned the applicant on these matters. The applicant indicated that some editorial errors had been made. It was stated that the numbers used in the analysis were correct, that the calculations were correct, but some of the references were incorrect. The applicant provided the correct references to the NRC staff. Upon additional review using the corrected references, the NRC staff was able to verify the results. On preliminary review, the NRC staff could not find an effect the editorial errors had on the methodology, the calculations, or the results.

The applicant provided adequate responses to all the project teams question and concerns.

The NRC staffs conclusion on CS nozzle confirmatory analysis will be documented in a separate staff safety evaluation.

Reactor Pressure Vessel Recirculation Outlet Nozzle Confirmatory Analysis During its audit, the NRC staff reviewed the applicants confirmatory analysis and related references for the RO nozzle. The applicant indicated that the analysis is consistent with the methods in the ASME Code Section III and does not involve use of the Greens Function, as was done in the previous analysis. The applicant also indicated that the RO confirmatory analysis contains no significantly different technical or scientific judgments from those used in the VYNPS feedwater nozzle confirmatory analysis and that the CUFen is less than unity. The NRC staff interviewed the applicant's technical staff and audited the documents listed below.

DOCUMENT TITLE REVISION Structural Integrity Associates Design Inputs and Methodology for Revision 0 Calculation ASME Code Fatigue Usage Analysis of No. 0801038.304* Reactor Recirculation Outlet Nozzle Structural Integrity Associates Stress Analysis of Reactor Recirculation Revision 0 Calculation Outlet Nozzle No. 0801038.305*

Structural Integrity Associates Fatigue Analysis of Recirculation Outlet Revision 0 Calculation Nozzle No. 0801038.306*

Structural Integrity Associates Recirculation Outlet Nozzle Finite Revision 0 Calculation Element Model No. VY-16Q-304**

Structural Integrity Associates Recirculation Outlet Nozzle Stress Revision 0 Calculation History Development for Nozzle Green No. VY-16Q-305** Function Structural Integrity Associates Fatigue Analysis of Recirculation outlet Revision 0 Calculation Nozzle No. VY-16Q-306**

• Confirmatory analysis

• • Refined analysis The NRC staff compared the RO nozzle confirmatory analysis with the previous analysis. The NRC staff reviewed the calculations to determine whether the applicant used significantly different technical or scientific judgments from those used in the feedwater nozzle confirmatory analysis. The project teams task also included determining:

1. If the confirmatory analysis is a detailed ASME Code Section III fatigue calculation,

2. If the same transient definitions and cycle counts were used,

3. If the same finite element model was used,

4. If the same number and severity of design transients were used,

5. If the same water chemistry inputs were used,

6. If the same limiting cross-section was evaluated,

7. and if appropriate stress ranges and correction factor were applied.

While reviewing the results, the NRC staff was unable to reproduce an elastic-plastic correction factor (Ke) found in the RO confirmatory analysis. The applicant, based on a question from the NRC staff, discovered that an incorrect material property was used to calculate the Ke for the RO confirmatory analysis. The RO confirmatory analysis incorporated the allowable design stress intensity value (Sm) for Alloy 600 instead of stainless steel. The CUFen value for the RO nozzle will be different when using the stainless steel Sm in the calculation. The applicant plans to update their calculation and submit the corrected CUFen value for the RO nozzle to the NRC.

The NRC staff also noted that there were several minor differences in the specified timing and temperature for one of the transients used in the RO confirmatory analysis when compared with the refined analysis. The applicant, prompted by the NRC staffs question, plans to modify the definition of this transient to match that of the refined analysis when the calculation is updated.

As noted above for the CS confirmatory analysis, Entergy informed the NRC staff that the RO confirmatory analysis similarly used a different element type in the finite element model. The cause of the inconsistent results identified by Entergys contractor was being independently pursued with the software vendor.

The applicant provided adequate responses to all of the project teams question and concerns, excluding the concerns mentioned above. The NRC staffs conclusion on the RO nozzle confirmatory analysis will be documented in a separate staff safety evaluation.

Letter to M. Kansler from J. Rowley, dated May 08, 2009 DISTRIBUTION:

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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. David Mannai Washington, DC 20037-1128 Manager, Licensing Entergy Nuclear Operations Mr. David OBrien, Commissioner Vermont Yankee Nuclear Power Station Vermont Department of Public Service P.O. Box 500 112 State Street 185 Old Ferry Road Montpelier, VT 05620-2601 Brattleboro, VT 05302-0500 Mr. James Volz, Chairman Resident Inspector Public Service Board Vermont Yankee Nuclear Power Station State of Vermont U.S. Nuclear Regulatory Commission 112 State Street P.O. Box 176 Montpelier, VT 05620-2701 Vernon, VT 05354 Chairman, Board of Selectmen Director, Massachusetts Emergency Town of Vernon Management Agency P.O. Box 116 ATTN: James Muckerheide Vernon, VT 05354-0116 400 Worcester Road Framingham, MA 01702-5399 Operating Experience Coordinator Vermont Yankee Nuclear Power Station Mr. John F. McCann 320 Governor Hunt Road Director, Licensing Vernon, VT 05354 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue G. Dana Bisbee, Esq. White Plains, NY 10601 Deputy Attorney General 33 Capitol Street Mr. John T. Herron Concord, NH 03301-6937 Sr. Vice President Entergy Nuclear Operations, Inc.

Chief, Safety Unit 1340 Echelon Parkway Office of the Attorney General Jackson, MS 39213 One Ashburton Place, 19th Floor Boston, MA 02108

Vermont Yankee Nuclear Power Station cc:

Mr. Oscar Limpias Mr. Norman L. Rademacher Vice President, Engineering Director, NSA Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station 1340 Echelon Parkway P.O. Box 0500 Jackson, MS 39213 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. Christopher Schwartz Vice President, Operations Support Mr. Raymond Shadis Entergy Nuclear Operations, Inc. New England Coalition 440 Hamilton Avenue P.O. Box 98 White Plains, NY 10601 Edgecomb, ME 04556 Mr. Michael J. Colomb Mr. James P. Matteau Director of Oversight Executive Director Entergy Nuclear Operations, Inc. Windham Regional Commission 440 Hamilton Avenue 139 Main Street, Suite 505 White Plains, NY 10601 Brattleboro, VT 05301 Mr. William C. Dennis Mr. William K. Sherman Assistant General Counsel Vermont Department of Public Service Entergy Nuclear Operations, Inc. 112 State Street 440 Hamilton Avenue Drawer 20 White Plains, NY 10601 Montpelier, VT 05620-2601 Mr. Theodore Sullivan Mr. Michael D. Lyster Site Vice President 5931 Barclay Lane Entergy Nuclear Operations, Inc. Naples, FL 34110-7306 Vermont Yankee Nuclear Power Station P.O. Box 500 Diane Curran, Esq.

185 Old Ferry Road Harmon, Curran, Spielberg &

Brattleboro, VT 05302-0500 Eisenberg, L.L.P 1726 M Street, NW, Suite 600 Mr. James H. Sniezek Washington, DC 20036 5486 Nithsdale Drive Salisbury, MD 21801 Ronald A. Shems, Esq.

Shems, Dunkiel, Kassel & Saunders, PLLC Mr. Garrett D. Edwards 91 College Street 814 Waverly Road Burlington, VT 05401 Kennett Square, PA 19348 Karen Tyler, Esq.

Ms. Stacey M. Lousteau Shems, Dunkiel, Kassel & Saunders, PLLC Treasury Department 91 College Street Entergy Services, Inc. Burlington, VT 05401 639 Loyola Avenue New Orleans, LA 70113

Vermont Yankee Nuclear Power Station cc:

Sarah Hofmann, Esq.

Director of Public Advocacy Department of Public Service 112 State Street - Drawer 20 Montpelier, VT 05620-2601 Jennifer J. Patterson, Esq.

Office of the New Hampshire Attorney General 33 Capitol Street Concord, NH 03301 Matias F. Travieso-Diaz, Esq.

Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, NW Washington, DC 20037-1128 Matthew Brock, Esq.

Assistant Attorney General Office of the Massachusetts Attorney General Environmental Protection Division One Ashburton Place, Room 1813 Boston, MA 02108-1598 Anthony Z. Roisman, Esq.

National Legal Scholars Law Firm 84 East Thetford Road Lyme, NH 03768 John Sipos, Assistant Attorney General Office of the Attorney General The Capitol State Street Albany, NY 12224