ML081980525

2008/07/08-Joint Stipulation

ML081980525
Person / Time
Site:	Vermont Yankee
Issue date:	07/08/2008
From:	Doris Lewis, Bob Nelson, Travieso-Diaz M Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee, Pillsbury, Winthrop, Shaw, Pittman, LLP
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-271-LR, ASLBP 06-849-03-LR, RAS M-129
Download: ML081980525 (6)

Text

DOCKETED tIA 8 a USNRC July 14, 2008 (8:00am)

OFFICE OF SECRETARY July 8, 2008 RULEMAKINGS AND ADJUDICATIONS STAFF 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. ) ASLBP No. 06-849-03-LR

)

(Vermont Yankee Nuclear Power Station) )

JOINT STIPULATION Pursuant to para. 7 of the Atomic Safety and Licensing Board's ("Board") Initial Scheduling Order dated November 17, 2006, as modified by the Board during the prehearing telephone conference held on June 24, 2008 (Tr. 656-57), Applicants Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (collectively "Entergy"), the NRC Staff, and intervenor New England Coalition, Inc. ("NEC") hereby agree to stipulate to the following facts.

NEC CONTENTIONS 2A AND 2B

1. Section 4.3.3 of the License Renewal Application for VY ("Application") presents Entergy's initial assessment of the effects of the reactor coolant environment on fatigue life for nine plant-specific locations of six reactor components at VY selected in accordance NUREG/CR-6260 and the NRC Staff s "GALL Report".

2. The initial CUF s computed by Entergy for VY are tabulated in Table 4.3.3 of the en Application. As that Table shows, seven of the nine locations had CUF en s greater than unity, and therefore greater than the specified criterion of the ASME Code.

3. To address these results, the Application states (Application, Section 4.3.3 at 4.3-7) that, prior to entering the period of extended operation, for each location that may exceed a

CUF of 1.0 when considering environmental effects, VY will implement one of three possible courses of action, including "further refinement of the fatigue analyses to lower the predicted CUFs to less than 1.0."

4. Entergy engaged SIA to performn-refined analyses to calculate the CUFs, Fens and CUFen s for all nine locations of interest in accordance with the approach described in the GALL Report.

5. Final versions of fifteen refined calculations were issued in August and December 2007.

6. To resolve certain NRC Staff concerns, Entergy proposed, and the NRC Staff accepted, that Entergy perform a confirmatory CUF analysis of the feedwater nozzle using en methods that would be acceptable to the NRC.

7. The Staff imposed a license condition requiring similar confirmatory analyses for two other nozzles, the recirculation outlet nozzle and the core spray nozzle. Those confirmatory analyses will become the "analyses of record" for those two locations.

Entergy is to submit these analyses to the Staff no later than two years prior to the start of the period of extended operation, in March 2012.

NEC CONTENTION 3

8. In 2002, steam dryer cracking and damage to components and supports for the main steam and feedwater lines were observed at the Quad Cities Unit 2 nuclear power plant.

Loose parts were shed by the dryer due to metal fatigue failure of the dryer caused by flow-induced vibration.

9. The Quad Cities 2 experience raised a concern that a loss of physical integrity of the dryer could result in the release and migration of loose dryer sections or parts to other components and could thus have adverse impact on safety-related equipment.

10. The existence of cracks on the surface of a steam dryer needs to be identified and evaluated before the cracks progress to the point where they could cause a loss of physical integrity of the dryer, resulting in loose parts.

I

11. In its License Renewal Application, Entergy addresses aging management of the VY steam dryer as follows:

Cracking due to flow-induced vibration in the stainless steel steam dryers is managed by the BWR Vessel

- Internals Program. The BWR Vessel Internals Program currently incorporates the guidance of GE-SIL-644, Revision 1. VYNPS will evaluate BWRVIP-139 once it is approved by the staff and either include its recommendations in the VYNPS BWR Vessel Internals Program or inform the staff of VYNPS's exceptions to that document.

License Renewal Application, § 3.1.2.2.11 "Cracking due to Flow-Induced Vibration."-

13. GE-SIL-644 recommends that BWR licensees institute a program for the long term monitoring and inspection of their steam dryers. It provides inspection and monitoring guidelines.

14. The monitoring component of the proposed VY steam dryer management program consists of assessing the status of the steam dryer by the plant operators and VY's technical staff through the continuous monitoring of certain plant parameters.

15. With respect to dryer inspections during plant refueling outages, the details of the visual inspection program to be implemented are set forth in the section of GE-SIL-644 devoted to BWR-3 steam dryers, which is Appendix C, pp. 15-16. The dryer inspections are to be performed in accordance with the VY BWRVIP Program Plan, VY-RPT-06-00006 (Exhibit E3-12) and GE-SIL-644, Revision 1.

NEC CONTENTION 4

16. The FAC Program that Entergy proposes to implement during the license renewal period includes the following activities: (a) conducting an analysis to determine critical locations; (b) performing baseline inspections to determine the extent of thinning at these 2

locations; and (c) performing follow-up inspections to confirm the predictions, or repairing or replacing components as necessary.

17. Section B. 1.13 of the License Renewal Application for VY ("Application") indicates that

-theVY program for addressing flow accelerated corrosion ("FAC") of steel piping and components is comparable to the program described in the NRC guidance document "Generic Aging Lessons Learned (GALL) Report -- Tabulation of Results," NUREG-1801, Vol. 2, Rev. 1 (Sep. 2005) ("NUREG-1801"),Section XI.M17, Flow Accelerated Corrosion. Application at B-47.

Entergy has been authorized by the NRC Staff and NEC to submit this Joint Stipulation on its own behalf as well as theirs.

Respectfully Submitted, DAi Mat4K. Travie /-Diaz Blake J. Nelson PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, NW Washington, DC 20037-1122 Tel. (202) 663-8000 Counsel for Entergy Dated: July 8, 2008 3

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. ) ASLBP No. 06-849-03-LR

)

(Vermont Yankee Nuclear Power Station) )

CERTIFICATE OF SERVICE I hereby certify that copies of "Joint Stipulation" were served on the persons listed below by deposit in the U.S. Mail, first class, postage prepaid, and where indicated by an asterisk by electronic mail, this 8th day of July, 2008.

• Administrative Judge *Administrative Judge Alex S. Karlin, Esq., Chairman Dr. Richard E. Wardwell Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 ask2@(dnrc.gov rew(dnrc.gov

• Administrative Judge *Secretary William H. Reed Att'n: Rulemakings and Adjudications Staff 1819 Edgewood Lane Mail Stop 0-16 C I Charlottesville, VA 22902 U.S. Nuclear Regulatory Commission whrcvillea~embarcimail.com Washington, D.C. 20555-0001 secy@nrc.gov, hearingdocket@ldnrc. gov

• Office of Commission Appellate Adjudication Atomic Safety and Licensing Board Mail Stop 0-16 C I Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 OCAAmailgi-nrc.gov

• Lloyd Subin, Esq. *Sarah Hofmann, Esq.

• Mary Baty, Esq. Director of Public Advocacy

• Jessica A. Bielecki, Esq. Department of Public Service

• Susan L. Uttal, Esq. 112 State Street - Drawer 20 Office of the General Counsel Montpelier, VT 05620-2601 Mail Stop O-15-D21 Sarah.hofinann& state.vt.us U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 LBS3@nrc.gov; mcbl @nrc.gov; jessica.bielecki(Ziýnrc.gov; susan.uttalgnrc.gov

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

National Legal Scholars Law Firm *Karen Tyler, Esq.

84 East Thetford Road Shems, Dunkiel, Kassel & Saunders, PLLC Lyme, NH 03768 9 College Street aroisman(~nationallegalscholars.com Burlington, VT 05401 rshems@sdkslaw. corn ktyler@sdkslaw.com

• Peter L. Roth, Esq. *Marcia Carpenter, Esq.

Office of the New Hampshire Attorney General Atomic Safety and Licensing Board Panel 33 Capitol Street Mail Stop T-3 F23 Concord, NH 03301 U.S. Nuclear Regulatory Commission Peter.rothgdoj.nh.gov Washington, D.C. 20555-0001 mxc7@(nrc.gov

• Lauren Bregman, Law Clerk *Diane Curran, Esq.

Atomic Safety and Licensing Board Harmon, Curran, Spielberg, & Eisenberg, U.S. Nuclear Regulatory Commission L.L.P.

Mail Stop: T-3 F23 1726 M Street N.W., Suite 600 Washington, D.C. 20555-0001 Washington, D.C. 20036 Lauren. Bregmangnrc. gov dcurrana~harmoncurran.com

• Matthew Brock Assistant Attorney General Office of the Attorney General One Ashburton Place, 1 8 th Floor Boston, MA 02108 Matthew.BrockOistate.ma.us B J. Nelso~n 2