ML081430682

Letter to Atomic Safety and Licensing Board Corrected Affidavit of Kenneth Chang (Exhibit 2) and Missing Page 4-43 to Staff Exhibit 1

ML081430682
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/22/2008
From:	Subin L NRC/OGC
To:	Karlin A, Wendy Reed, Richard Wardwell Atomic Safety and Licensing Board Panel
SECY RAS
References
50-271-LR, ASLBP 06-849-03-LR, RAS M-63
Download: ML081430682 (8)

Text

May 22, 2008 Alex S. Karlin, Esq., Chair Dr. William H. Reed Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 1819 Edgewood Lane U.S. Nuclear Regulatory Commission Charlottesville, VA 22902 Washington, DC 20555-0001 Dr. Richard E. Wardwell Administrative Judge Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 In the Matter of ENTERGY NUCLEAR OPERATIONS, INC.

(Vermont Yankee Nuclear Power Station)

Docket No. 50-271-LR; ASLBP No. 06-849-03-LR

Dear Administrative Judges:

It has come to the Staffs attention that testimony provided in Affidavit of Kenneth C.

Chang Concerning NEC Contentions 2A & 2B (Metal Fatigue) (Staff Exh. 2) contained errors.

Enclosed are Affidavit of Kenneth C. Chang dated May 21, 2008 and replacement pages for Affidavit of Kenneth C. Chang Concerning NEC Contentions 2A & 2B.

It has also come to the Staffs attention that in Staff Exh. 1, the last page of Section 4.3 (page 4-43) was missing. Please find that page enclosed.

Sincerely,

/RA/

Lloyd B. Subin Counsel for NRC Staff

Enclosures:

As Stated cc: Attached Service List

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

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

)

(Vermont Yankee Nuclear Power Station) )

AFFIDAVIT OF KENNETH C. CHANG I, Kenneth C. Chang, do hereby declare under penalty of perjury as follows:

1. In A.4 on page 5, lines 11-12, of Affidavit of Kenneth C. Chang Concerning NEC Contentions 2A & 2B (Metal Fatigue) (Staff Exh. 2) I in inadvertently wrote that the FW nozzle is Vermont Yankees most FAC-susceptible nozzle. I intended to write that the FW nozzle is Vermont Yankees most limiting (i.e. nozzle with highest CUFen).

2. Therefore, in A.4 on page 5 in line 12, the words FAC-susceptible should be stricken and replaced with the words most limiting (i.e. nozzle with the highest CUFen).

3. The sentence in A.11 on page 10 lines 1-7 of Affidavit of Kenneth C. Chang Concerning NEC Contentions 2A &2B (Metal Fatigue) (Staff Exh. 2) is unclear and must be revised.

4. The existing sentence should be replaced with the following: Error analysis is not necessary because conservatism is built into the design fatigue curves for carbon steel/stainless steel in the light water environment. As stated in NUREG/CR-6583 and NUREG/CG-5704, these design curves have been adjusted for uncertainties that are associated with material and loading conditions.

application using the specific software could underestimate the CUF, and therefore, cannot be the analysis of record. However, the updated analysis, whether using the maximum Fen or appropriate Fen s, yields CUFs lower than the Code allowable. The staff concludes that this updated analysis are the analysis of record for the FW nozzle. Based on the above discussion, the staff concludes that similar analysis should be performed for the CS and the RR outlet nozzles and that these analyses will be documented as the analyses of record for these two nozzles.

On this basis, the staff finds that although the applicant has used a 2-dimensional axisymmetric model to handle thermal transient and pressure, it did consider the six stress components and use them to develop three principle stresses and the stress intensities. Therefore, the staff finds that for the updated analysis of the FW nozzle, the stress intensities and the CUFs are calculated in accordance with ASME Code requirements. The staff concluded that the updated FW analysis consistent with the rules of the ASME Code Section III yields lower EAF CUF values for the FW nozzle. In the letter dated February 21, 2008, the applicant stated that it considers the updated EAF analysis, submitted in the January 30, 2008 letter, as the analysis of record for the FW nozzle. The staffs concern expressed in RAI 4.3.3-2 is resolved. However, a license condition for performing the ASME Code analyses for the CS and the RR outlet nozzles will remain in effect until the applicant has completed and submitted those final analyses for NRC review and approval no later than two years prior to entering the PEO.

4.3.3.3 UFSAR Supplement The applicant provided a UFSAR Supplement summary description of its TLAA evaluation of effects of reactor water environment on fatigue life in LRA Section A.2.2.2.3.

The staff reviewed the applicants Commitment No. 27 and concludes that implementation of this commitment prior to period of extended operation will address environmentally assisted fatigue for the seven components which have not been addressed.

On the basis of its review of the UFSAR Supplement, the staff concludes that the summary description of the applicants actions to address effects of reactor water environment on fatigue life is adequate.

4.3.3.4 Conclusion On the basis of its review, and Commitment No. 27 as discussed above, the staff finds that the applicant has demonstrated that, as required by 10 CFR 54.21(c)(1)(iii), the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. The staff also concludes that the UFSAR Supplement contains an appropriate summary description of the TLAA evaluation, as required by 10 CFR 54.21(d).

4-43

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

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

OPERATIONS, INC. ) ASLBP No. 06-849-03-LR

)

(Vermont Yankee Nuclear Power Station) )

CERTIFICATE OF SERVICE I hereby certify that copies of the NRC Staff letter dated May 22, 2008, transmitting corrected testimony and missing exhibit pages in the above-captioned proceeding have been served on the following by electronic mail with copies by deposit in the NRCs internal mail system or, as indicated by an asterisk, by electronic mail, with copies by U.S. mail, first class, this 22nd day of May, 2008.

Alex S. Karlin, Chair Office of the Secretary Administrative Judge Attn: Rulemakings and Adjudications Staff Atomic Safety and Licensing Board Mail Stop: O-16G4 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: ask2@nrc.gov E-mail: hearingdocket@nrc.gov William H. Reed* Marcia Carpentier, Esq.

Administrative Judge Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Mail Stop: T-3F23 1819 Edgewood Lane U.S. Nuclear Regulatory Commission Charlottesville, VA 22902 Washington, DC 20555-0001 E-mail: whrcville@embarqmail.com E-mail: mxc7@nrc.gov Richard E. Wardwell Lauren Bregman, Law Clerk Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Mail Stop: T-3 F23 Washington, DC 20555-0001 Washington, D.C. 20555-0001 E-mail: rew@nrc.gov E-mail: Lauren.Bregman@nrc.gov Office of Commission Appellate Peter C.L. Roth, Esq*

Adjudication Office of the Attorney General Mail Stop: O-16G4 33 Capitol Street U.S. Nuclear Regulatory Commission Concord, NH 3301 Washington, DC 20555-0001 E-mail: peter.roth@doj.nh.gov E-mail: OCAAmail@nrc.gov

Ronald A. Shems, Esq.* Anthony Z. Roisman, Esq.*

Karen Tyler, Esq. National Legal Scholars Law Firm Shems Dunkiel Kassel & Saunders, PLLC 84 East Thetford Rd.

91 College Street Lyme, NH 03768 Burlington, VT 05401 E-mail: aroisman@nationallegalscholars.com E-mail: rshems@sdkslaw.com Ktyler@sdkslaw.com David R. Lewis, Esq.* Sarah Hofmann, Esq.*

Matias F. Travieso-Diaz, Esq Director of Public Advocacy Elina Teplinsky, Esq Department of Public Service Blake J. Nelson, Esq 112 State Street - Drawer 20 Pillsbury Winthrop Shaw Pittman LLP Montpelier, VT 05620-2601 2300 N Street, NW E-mail: sarah.hofmann@state.vt.us Washington, DC 20037-1128 E-mail: david.lewis@pillsburylaw.com matias.travieso-diaz@pillsburylaw.com elina.teplinsky@pillsburylaw.com blake.nelson@pillsburylaw.com Diane Curran* James R. Milkey*

Harmon, Curran, Spielberg, & Eisenberg, LLP Assistant Attorney General, Chief 1726 M Street N.W., Suite 600 Environmental Protection Division Washington, D.C. 20036 Office of the Attorney General E-mail: dcurran@harmoncurran.com One Ashburton Place, 18th Floor Boston, MA 02108 E-mail: jim.milkey@state.ma.us

/RA/

Lloyd B. Subin Counsel for NRC Staff