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:DLRBC: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

ENCLOSURE 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 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 (CUF en) 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 Green's Function methodology, which was used in the original analyses, to demonstrate acceptable CUF en 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 applicant's 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 applicant's 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 Green's 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 CUF en is less than unity. The staff interviewed the applicant's technical staff and reviewed the documents listed below.

DOCUMENT T ITLE R EVISION Structural Integrity Associates Calculation No. 0801038.301* Design Inputs and Methodology for ASME Code Fatigue Usage Analysis of Reactor Core Spray Nozzle Revision 0 Structural Integrity Associates Calculation No. 0801038.302* Stress Analysis of Reactor Core Spray Nozzle Revision 0 Structural Integrity Associates Calculation No. 0801038.303* Fatigue Analysis of Core Spray Nozzle Revision 0 Structural Integrity Associates Calculation No. VY-16Q-308** Core Spray Nozzle Finite Element Model Revision 0 Structural Integrity Associates Calculation No. VY-16Q-309** Core Spray Nozzle Green's Function Revision 1 Structural Integrity Associates Calculation No. VY-16Q-310** Fatigue Analyses of Core Spray Nozzle Revision 1

• 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 staff's 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 staff's 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 team's question and concerns. The NRC staff's 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 applicant's 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 Green's 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 CUF en 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 Calculation No. 0801038.304* Design Inputs and Methodology for ASME Code Fatigue Usage Analysis of Reactor Recirculation Outlet Nozzle Revision 0 Structural Integrity Associates Calculation No. 0801038.305* Stress Analysis of Reactor Recirculation Outlet Nozzle Revision 0 Structural Integrity Associates Calculation No. 0801038.306* Fatigue Analysis of Recirculation Outlet Nozzle Revision 0 Structural Integrity Associates Calculation No. VY-16Q-304** Recirculation Outlet Nozzle Finite Element Model Revision 0 Structural Integrity Associates Calculation No. VY-16Q-305** Recirculation Outlet Nozzle Stress History Development for Nozzle Green Function Revision 0 Structural Integrity Associates Calculation No. VY-16Q-306** Fatigue Analysis of Recirculation outlet Nozzle Revision 0

• 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 team's 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 (K e) 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 K e for the RO confirmatory analysis. The RO confirmatory analysis incorporated the allowable design stress intensity value (S m) for Alloy 600 instead of stainless steel. The CUF en value for the RO nozzle will be different when using the stainless steel S m in the calculation. The applicant plans to update their calculation and submit the corrected CUF en 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 staff's 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 Entergy's contractor was being independently pursued with the software vendor.

The applicant provided adequate responses to all of the project team's question and concerns, excluding the concerns mentioned above. The NRC staff's 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

SUBJECT:

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Vermont Yankee Nuclear Power Station cc: Regional Administrator, Region I U.S. Nuclear Regulatory Commission

475 Allendale Road King of Prussia, PA 19406-1415 Mr. David R. Lewis Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W. Washington, DC 20037-1128 Mr. David O'Brien, Commissioner Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601

Mr. James Volz, Chairman Public Service Board State of Vermont 112 State Street Montpelier, VT 05620-2701 Chairman, Board of Selectmen Town of Vernon P.O. Box 116 Vernon, VT 05354-0116 Operating Experience Coordinator Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 G. Dana Bisbee, Esq. Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108

Ms. Carla A. White, RRPT, CHP Radiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070

Mr. David Mannai Manager, Licensing Entergy Nuclear Operations Vermont Yankee Nuclear Power Station P.O. Box 500 185 Old Ferry Road Brattleboro, VT 05302-0500

Resident Inspector Vermont Yankee Nuclear Power Station U.S. Nuclear Regulatory Commission P.O. Box 176 Vernon, VT 05354 Director, Massachusetts Emergency Management Agency ATTN: James Muckerheide 400 Worcester Road Framingham, MA 01702-5399 Mr. John F. McCann Director, Licensing Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601 Mr. John T. Herron Sr. Vice President Entergy Nuclear Operations, Inc. 1340 Echelon Parkway Jackson, MS 39213

Vermont Yankee Nuclear Power Station cc: Mr. Oscar Limpias Vice President, Engineering Entergy Nuclear Operations, Inc. 1340 Echelon Parkway Jackson, MS 39213 Mr. Christopher Schwartz Vice President, Operations Support Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601 Mr. William C. Dennis Assistant General Counsel Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601

Mr. Theodore Sullivan Site Vice President Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station P.O. Box 500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. James H. Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Garrett D. Edwards 814 Waverly Road Kennett Square, PA 19348 Ms. Stacey M. Lousteau Treasury Department Entergy Services, Inc. 639 Loyola Avenue New Orleans, LA 70113 Mr. Norman L. Rademacher Director, NSA Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500

Mr. Raymond Shadis New England Coalition P.O. Box 98 Edgecomb, ME 04556 Mr. James P. Matteau Executive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301 Mr. William K. Sherman Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, VT 05620-2601

Mr. Michael D. Lyster 5931 Barclay Lane Naples, FL 34110-7306 Diane Curran, Esq.

Harmon, Curran, Spielberg & Eisenberg, L.L.P 1726 M Street, NW, Suite 600 Washington, DC 20036

Ronald A. Shems, Esq. Shems, Dunkiel, Kassel & Saunders, PLLC 91 College Street Burlington, VT 05401 Karen Tyler, Esq. Shems, Dunkiel, Kassel & Saunders, PLLC 91 College Street Burlington, VT 05401

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