ML050110210

RAI - Relief Request B-5

ML050110210
Person / Time
Site:	Vermont Yankee
Issue date:	01/19/2005
From:	Richard Ennis NRC/NRR/DLPM/LPD1
To:	Kansler M Entergy Nuclear Operations
Ennis R, NRR/DLPM, 415-1420
References
TAC MC0959
Download: ML050110210 (6)

Text

January 19, 2005 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - RELIEF REQUEST B-5 (TAC NO. MC0959)

Dear Mr. Kansler:

By letter dated October 1, 2003, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. submitted relief request B-5 for Vermont Yankee Nuclear Power Station. Your submittal requests relief for some weld examinations where the required essentially 100%

examination coverage is impractical due to physical obstructions and limitations imposed by design, geometry, and materials of construction of the subject components.

The Nuclear Regulatory Commission staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure.

We request that the additional information be provided by April 30, 2005. The response timeframe was discussed with Ms. Ronda Daflucas of your staff on December 21, 2004. If circumstances result in the need to revise your response date, or if you have any questions, please contact me at (301) 415-1420.

Sincerely,

/RA/

Richard B. Ennis, Senior Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosure:

Request for Additional Information cc w/encl: See next page

January 19, 2005 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - RELIEF REQUEST B-5 (TAC NO. MC0959)

Dear Mr. Kansler:

By letter dated October 1, 2003, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. submitted relief request B-5 for Vermont Yankee Nuclear Power Station. Your submittal requests relief for some weld examinations where the required essentially 100%

examination coverage is impractical due to physical obstructions and limitations imposed by design, geometry, and materials of construction of the subject components.

The Nuclear Regulatory Commission staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure.

We request that the additional information be provided by April 30, 2005. The response timeframe was discussed with Ms. Ronda Daflucas of your staff on December 21, 2004. If circumstances result in the need to revise your response date, or if you have any questions, please contact me at (301) 415-1420.

Sincerely,

/RA/

Richard B. Ennis, Senior Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION PUBLIC DRoberts AKeim PDI-2 Reading REnnis TChan VBucci, OIG BPoole JBoska ACCESSION NO.: ML050110210 OFFICE PDI-2/PM PDI-2/PM PDI-2/LA PDI-2/SC NAME JBoska REnnis CRaynor DRoberts DATE 1/18/05 1/18/05 1/18/05 1/18/05 OFFICIAL RECORD COPY

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 Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W. Mr. James M. DeVincentis Washington, DC 20037-1128 Manager, Licensing Vermont Yankee Nuclear Power Station Ms. Christine S. Salembier, 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. 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.

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, 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 Sr. VP and Chief Operating Officer 1282 Valley of Lakes Entergy Nuclear Operations, Inc. Box R-10 440 Hamilton Avenue Hazelton, PA 18202 White Plains, NY 10601 Ms. Stacey M. Lousteau Mr. Danny L. Pace Treasury Department Vice President, Engineering Entergy Services, Inc.

Entergy Nuclear Operations, Inc. 639 Loyola Avenue 440 Hamilton Avenue New Orleans, LA 70113 White Plains, NY 10601 Mr. Raymond Shadis Mr. Brian OGrady New England Coalition Vice President, Operations Support Post Office Box 98 Entergy Nuclear Operations, Inc. Edgecomb, ME 04556 440 Hamilton Avenue White Plains, NY 10601 Mr. James P. Matteau Executive Director Mr. Michael J. Colomb Windham Regional Commission Director of Oversight 139 Main Street, Suite 505 Entergy Nuclear Operations, Inc. Brattleboro, VT 05301 440 Hamilton Avenue White Plains, NY 10601 Mr. William K. Sherman Vermont Department of Public Service Mr. John M. Fulton 112 State Street Assistant General Counsel Drawer 20 Entergy Nuclear Operations, Inc. Montpelier, VT 05620-2601 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

REQUEST FOR ADDITIONAL INFORMATION RELATED TO RELIEF REQUEST B-5 VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271 By letter dated October 1, 2003, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted relief request B-5 for Vermont Yankee Nuclear Power Station (VYNPS). The licensee's submittal identifies 49 welds for which the licensee requested relief pursuant to Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.55a(g)(5)(iii) on the basis that the required "essentially 100%" coverage examination is impractical due to physical obstructions and limitations imposed by design, geometry, and materials of construction of the subject components. Most of the welds are associated with reactor vessel nozzles.

The Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed below.

Entergy has requested relief in accordance with 10 CFR 50.55a(g)(5)(iii), based upon the argument that the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) examinations are impractical at VYNPS. However, the licensee must present adequate information to support a determination that the required examinations are impractical (not simply inconvenient) to perform to the extent required by the ASME Code. This information should include drawings, or other physical descriptions, of the component examination areas, showing examination coverage(s), weld cross-sections, etc., necessary to support the request.

In addition, the licensee should submit argument(s) as to why the use of other methods would not reasonably increase the examination coverage(s).

For example, in Table RR-B-5 of the licensee's submittal (Attachment 2, pages 5 and 6 of 9),

the limitation for many reactor pressure vessel nozzle-to-vessel welds simply states that the reduced volumetric coverage (ranging from 42% to 65%) is due to Nozzle, radius blend, and weld configuration. This does not provide an adequate description of the physical limitation, or indicate whether other techniques such as different interrogation angles could have practically increased the coverage.

Similar issues exist with the remainder of all of the components listed in Table RR-B-5. No drawings have been provided by the licensee to determine the extent of actual scanning limitations. The licensee should provide the following information:

1. Provide a technical basis for each component listed in Table RR-B-5 describing in detail the examination limitation, and discuss whether other examinations may be used to increase or supplement the limited examinations. The technical basis should include a cross-sectional sketch of the weld indicating ultrasonic coverage(s) and details of the weld and base metal materials. The technical basis should confirm, where applicable, Enclosure

that the examinations that were performed were qualified under Appendix VIII of Section XI.

2. Indicate what degradation mechanism(s) is most likely to occur in this weld and a basis for whether the achieved examination coverage could reasonably be expected to detect this degradation.