ML060610395

E-mail Gucwa, Entergy, to Ennis, NRR, VY EPU Steam Dryer Monitoring

ML060610395
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	02/26/2006
From:	Gucwa L Entergy Nuclear Operations
To:	Richard Ennis Office of Nuclear Reactor Regulation
References
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Download: ML060610395 (30)

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Rick Ennis-EntergyVermontYankee letter BV 06-019 Page 1 From:

"Gucwa, Len" <LGUCW90@eritergy.com>

To:

"Rick Ennis" <RXE~nrc.gov>

Date:

2/26/06 5:22PM

Subject:

Entergy Vermont Yankee letter BVY 06-019

<<BVY 06-019 Attach. 1.pdf>> <<BVY 06-019 limit curves.doc>> <<BVY 06-019 cover.pclf>

Len T. Gucwa, P.E.

VY Licensing lgucw90@entergy.com 802/451-3193 CC:

"Nichols, Craig" <cnicholprod.entergy.com>, <tgsinrc.gov>, <ciwanrc.gov>

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Entergy Vermont Yankee letter BVY 06-019 2/26/06 5:22PM "Gucwa, Len" <LGUCW90(entergy.com>

LGUCW90@entergy.com Recipients nrc.gov owf4po.OWFNDO RXE (Rick Ennis) nrc.gov TWGWPOO2.HQGWDO01 TGS CC (Thomas Scarbrough) nrc.gov twf4_po.TWFNDO CIW CC (Carolyn Wingo) prod.entergy.com cnichol CC (Craig Nichols)

Post Office owf4_po.OWFNDO TWGWPOO2.HQGWDO01 twf4_po.TWFNDO Files MESSAGE TEXT.htm BVY 06-019 Attach. 1.pdf BVY 06-019 limit curves.doc BVY 06-019 cover.pdf Mime.822 Options Expiration Date:

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Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

Vermont Yankee P.O. Box 0500 185 Old Fery Road ntow Cl VBrattleboro, VT 05302-0500 Tel 802 257 5271 February 26, 2006 Docket No. 50-271 13VY 06-019 TAC No. MC0761 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Vermont Yankee Nuclear Power Station Extended Power Uprate - Regulatory Commitment Information Regarding Steam Dryer Monitoring and FIV Effects

References:

1) Entergy letter to U.S. Nuclear Regulatory Commission, 'Veriont Yankee Nuclear Power Station, License No. DPR-28 (Docket No. 50-271), Technical Specification Proposed Change No. 263, Extended Power Uprate," BVY 03-80, September 10, 2003

2) Entergy letter to U.S. Nuclear Regulatory Commission, uVermont Yankee Nuclear Power Station, Technical Specification Proposed Change No. 263 - Supplement No. 36, Extended Power Uprate -

Response to NRC's Letter re: License Conditions," BVY 05-096, October 17, 2005

3) Entergy letter to U.S. Nuclear Regulatory Commission, 'Vermont Yankee Nuclear Power Station, Technical Specification Proposed Change No. 263 - Supplement No. 33, Extended Power Uprato -

Response to Request for Additional Information," BW 05-084, September 14, 2005 This letter provides information pursuant to a regulatory commitment made in connection with the application by Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

(Entergy) for a license amendment (Referencs 1, as supplemented) to increase the maximum authorized power level of the Vermont Yankee Nuclear Power Station (VYNPS) from 1593 megawatts thermal (MWt) to 1912 MWt.

In Reference 2, Entergy proposed a license condition and made a regulatory commitment to provide information regarding potentially adverse flow effects on plant structures, systems, and components (SSCs) that might result from extended power uprate (EPU) operation.

The subject regulatory commitment relates to actions required prior to exceeding 1593 MWt, and states in relevant part:

BVY 06-019 Docket No. 50-271 Page 2 of 3 With regard to [proposed] License Condition 3.M, "Potential Adverse Flow Effects," Entergy will provide information on plant data, evaluations, walkdowns, inspections, and procedures associated with the individual requirements of that license condition to the NRC staff prior to increasing power above 1593 MWt or each specified hold point, as applicable... to this letter is the Steam Dryer Monitoring Plan (SDMP) that will be applicable during power ascension to full EPU conditions. The SDMP will remain in effect until proposed License Condition 3.M expires. The SDMP, together with the EPU Power Ascension Test Procedure (PATP) provide for monitoring, inspecting, evaluating, and prompt action in response to potential adverse flow effects on the steam dryer as a result of power uprate operation.

These actions provide assurance of the continued structural integrity of the steam dryer under EPU conditions.

Included in the SDMP are the "steam dryer stress limit curves."

These curveis establish operating limits in accordance with proposed License Condition 3.M (Reference 2). Continuous monitoring of pressure fluctuations from strain gage signals relative to the curves provides assurance of the structural Integrity of the steam dryer. If necessary, changes to the SDMP will be made in accordance with the provisions of License Condition 3.M. to this letter are those portions of the power ascension test procedure (PATP) for EPU that are applicable to flow-induced vibnation monitoring during power ascension testing for a representative power plateau. Any future changes to the PATP will be made in accordance with governing VYNPS change processes and will be available on-site to NRC inspectors. to this letter provides a description of the data acquisition system that will be used to collect and record signals indicative of pressure loads on the steam dryer. This description Is an update to the information provided In Reference 3.

The Information contained herewith is provided in accordance with the cited regulatory commitment and in anticipation of actions required to comply with proposed License Condition 3.M. There are no new regulatory commitments contained In this submittal.

If you have any questions or require additional information, please contact Mr. James DeVincentis at (802) 2584236.

Sincerely, Norman L. Rademacher Director, Nuclear Safety Assurance Vermont Yankee Nuclear Power Station

BVY 06-019 Docket No. 50-271 Page 3 of 3 Attachments (3) cc:

Mr. Samuel J. Collins (w/o attachments)

Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Richard B. Ennis, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0 8 B1 Washington, DC 20555 USNRC Resident Inspector (wlo attachments)

Entergy Nuclear Vernont Yankee, LLC P.O. Box 157 Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

EWVY 06-019 Docket No. 50-271 Attachment I Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 263 Extended Power Uprate - Regulatory Commitment Information Regarding Steam Dryer Monitoring and FIV Effects Steam Dryer Monitoring Plan Total number of pages In Attachment I I(exuding his coversheer) Is 19.

STEAM DRYER MONITORING PLAN Vermont Yankee Nuclear Power Station Revision 0 Prepar r

er of C. J. Nichols Reviewer:

O Date:

Oa 'L 1,

0 Date:

e 2- / t-4N Approver:

Date:

?- zL-c6

VYNPS Steam Dryer Monitoring Plan Page 1 of 18 VERMONT YANKEE NUCLEAR POWER STATION STEAM DRYER MONITORING PLAN Introduction and Purpose The Vermont Yankee Steam Dryer Monitoring Plan (SDMP) describes the course of action for monitoring and evaluating the performance of the Vermont Yankee Nuclear Power Station (VYNPS) steam dryer during power ascension testing and operation above 100% of the original licensed thermal power (OLTP), i.e., 1593 MWt, to the full 120% extended power Uprate (EPU) condition of 1912 MWt to verify acceptable performance. The SDMP also addresses long-term actions necessary to implement proposed license Condition 3.M.

Through operating limits, periodic surveillances, and required actions, the Impact of potentially adverse flow ejects on the structural integrity of the steam dryer will be minimized.

Unacceptable steam dryer performance is a condition that could challenge steam dryer structural integrity and result in the generation of loose parts, cracks or tears in the steam dryer that result in excessive moisture carryover.

During reactor power operation, performance is demonstrated through the measurement of a combination of plant parameters.

Scope The SDMP is primarily an initial power ascension test plan designed to assess steam dryer performance from 100% OLTP (i.e., 1593 MV/t) to 120% OLTP (i.e., 1912 MWt) and to perform confirmatory inspections for a period of time following initial and continued operation at uprated power levels.

Power ascension to 120% OLTP will be achieved in a series of power step increases and holds at plateaus corresponding to 80 MWt increments above OLTP. Elements of this plan will be implemented before EPU power ascension testing, and others may continue after power ascension testing.

There are three main elements of the SDMP:

1. Slow and deliberate power ascension with defined hold points and durations, allowing time for monitoring and analysis;

2. A detailed power ascension monitoring and analysis program to trend steam dryer performance (primarily through the monitoring of steam dryer load signals and moisture carryover); and

3. A long term inspection program to verify steam dryer performance at EPU operating conditions.

Several elements of the SDMP also provide for completion of the necessary actions to satisfy the requirements of license conditions associated with the EPU license amendment.

A complete tabulation of the provisions of the license condition and the implementing strategy to complete them is contained in Table 3.

Power Ascension VYNPS procedure ERSTI-04-VYl-1409-000, "Power Ascension Test Procedure for Extended Power Conditions 1593 to 1912 MWth," (PATP) will provide controls during power ascension testing and confirm acceptable plant performance. Other procedures may be entered to conduct

VYNPS Steam Dryer Monitoring Plan Page 2 of 18 specialized testing, such as condensate and feedwater testing. The VYNPS power ascension will occur over an extended period with gradual increases in power, hold periods, and engineering analyses of monitored data that must be approved by station management.

Relevant data and evaluations will be transmitted to the NRC staff in accordance with the provisions of the license condition. The PATP includes:

1. Power ascension rate of 16 MWt/hr,

2. Hourly monitoring of steam dryer perfonnance during power ascension (required by License Condition 3.M);

3. Four hour holds at each 40 MWt; and

4. Minimum 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> holds at each 80 M'Nt power plateau to perform steam dryer analysis allowing for NRC review, as appropriate (required by License Condition 3.M).

Monitoring Plans Table I outlines the steam dryer surveillance requirements during reactor power ascension testing for EPU. The monitoring of moisture carryover and main steam line (MSL) pressure data provide measures for ensuring acceptable performance of the steam dryer. Frequent monitoring of these parameters will provide early detection capability of off-normal performance.

Proposed License Condition 3.M will require that steam dryer performance criteria are met and prompt action is taken if unacceptable performance Is detected. Entergy has established two performance levels (Level 1 criteria and Level 2 criteria) as described in Table 2 for evaluating steam dryer performance during EPU power ascension testing. The Level I criteria correspond to the limits specified in the proposed license condition, while the Level 2 criteria are operating action levels that may indicate reductions in margin.

The comparison of measured plant data against defined criteria, based on the steam dryer structural analysis of record, will provide predictive capabilities toward determining steam dryer structural integrity under EPU conditions.

Main Steam Line Strain Gages o

During power ascension, steam dryer performance will be monitored hourly through the evaluation of pressure fluctuation data collected from strain gages instailed on the MSLs. Entergy has installed strain gages at eight locations on the MSLs in the primary containment and a data acquisition system (DAS) designed to reduce uncertainties in the evaluation of steam dryer loads.

o The strain gage data collected hourly during power ascension will be compared against the stress limit curve that is provided as Figures 1 - 8 of the SDMP and is based on Entergy Calculation VYC-3001. If any frequency peak from the MSL strain gage data exceeds the stress limit curve (Level 1), Entergy will reduce the reactor power to a level at which the stress limit curve is not exceeded.

o Additionally, Entergy will monitor data collected from accelerometers mounted to the main steam piping inside the drywell to provide additional insights into the strain gage signals.

VYNPS Steam Dryer Monitoring Plan Page 3 of 18 o During hold points at each 80 MWt power level above current licensed thermal power, the collected data, along with a comparison to the steam dryer limit curve, will be transmitted to the NRC staff.

o For any circumstance requiring a revision to the steam dryer limit curve, Entergy will resolve uncertainties in the steam dryer analysis and provide the results of that evaluation to the NRC staff prior to further increases in reactor power.

o Entergy will resolve uncertainties in the steam dryer analysis with the NRC staff within 90 days of Issuance of the EPU license amendment. If resolution is not made within this time interval, reactor operation will not exceed 1593 MWt. These planned actions are in compliance with proposed License Condition 3.M.

Moisture Carryover o

Moisture carryover trending provides an indicator of steam dryer integrity.

o At each 40 MWt step, moisture carryover data will be taken and compared to the predetermined acceptance criteria (Table 2).

Level 1 criteria (0.35%) Is based on the maximum analyzed value.

o The data taken at each 80 MWt plateau will be evaluated and documented in the assessment sent to the NRC for information.

• Other Monitoring o

Plant data that may be indicative of off-normal steam dryer performance will be monitored during power ascension (e.g., reactor water level, steam flow, feed flow, steam flow distribution between the individual steam lines). Plant data can, provide an early indication of unacceptable steam dryer performance. The enhanced monitoring of selected plant parameters will be controlled by the PATP and other plant procedures.

NRC Notifications o In accordance with proposed License Condition 3.M., at discrete power levels, and if the steam dryer stress limit curve (i.e., Level 1 criterion) is exceeded, Entergy will provide notifications to the NRC staff consisting of data and evaluations performed during EPU power ascension testing above 1593 MWt. Detailed discussions regarding new plant data, inspections, and evaluations will be held with NRC staff upon request.

The designated NRC point of contact for such information is the NRC Project Manager for the VYNPS EPU.

o The results of the SDMP will be submitted to the NRC staff in a report within 60 days following the completion of all EPU power ascension testing. In addition the final full EPU power performance criteria spectra (i.e., steam dryer stress limit curve) will be submitted to the NRC staff within 90 days of license amendment issuance.

Contemporary data and results from steam dryer monitoring will be availabls on-site for review by NRC inspectors as it becomes available. The written report on steam dryer

VYNPS Steam Dryer Monitoring Plan Page 4 of 18 performance during EPU power ascension testing will include evaluations or corrective actions that were required to obtain satisfactory steam dryer performance. The report will include relevant data collected at each power step, comparisons to performance criteria (design predictions), and evaluations performed in conjunction with steam dryer structural integrity monitoring.

Lona Term Monitoring The long-term monitoring of plant parameters potentially indicative of steam dryer failure will be conducted, as recommended by General Electric Service Information Letter 644, Rev. 1 and consistent with License Condition 3.M.

Moisture Carryover Per VYNPS station operating procedure OP-0631, "Radiochemistry," moisture carryover is periodically monitored for moisture carryover during normal plant operations. VYNPS off-normal procedure ON-3178, Increased Moisture Carryover," provides guidance to evaluate any elevated moisture carryover results including that resulting from potential vessel internals damage. This monitoring will also provide insight into changes in moisture carryover values during changing reactor core configurations (control rod patterns)

Strain Gage Monitoring As the strain gages will remain operational and can provide for future data collection, additional strain gage monitoring will be performed as determined appropriate during the remainder of the operating cycle following EPU implementation.

Inspections The VYNPS steam dryer will be inspected during the refueling outages scheduled for the Spring.

2007, Fall 2008, and Spring 2010. The inspections conducted after power uprate implementation will be comparable to the inspection conducted during the Spring 2004 refueling outages and will be in accordance with the guidance in SIL 644, Rev. 1.

Reporting to NRC Steam Dryer Visual Inspections: The results of the visual inspections of the steam dryer conducted during the next three refueling outages shall be reported to the NRC staff within 60 days following startup from the respective refueling outage.

VYNPS Steam Dryer Monitoring Plan Page 5 of 18 Table I Steam Dryer Surveillance Requirements During Reactor Power Operation Above a Previously Attained Power Level Parameter Surveillance Frequency

1. Moisture Carryover Every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Notes 1 and 2)

2. Main steam line pressure data Hourly when Initially increasing power above a from strain gages previously attained power level AND At least once at every 40 MWt (nominal) power step above 100% OLTP (Note 3)

3. Main steam line data from At least once at every 40 MWt (nominal) power step accelerometers above 100% OLTP (Note 3)

ANI)

Within one hour after achieving every 40 MVt (no ninal) power step above 100% OLTP Notes to Table 1:

1. If a determination of moisture carryover cannot be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of achieving an 80 MWt power plateau, an orderly power reduction shall be made within the subsequent 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to a power level at which moisture carryover was previously determined to be acceptable. For testing purposes, a power ascension step Is defined as each power increment of 40 MWt, i.e.,

at thermal power levels of approximately 102.5%, 105%, 107.5%, 110%, 112.5%, 115%,

117.5%, and 120% OLTP. Power level plateaus are nominally every 80 MWt.

2. Provided that the Level 2 performance criteria in Table 2 are not exceeded, when steady state operation at a given power exceeds 168 consecutive hours, moisture carryover monitoring frequency may be reduced to once per week.

3. The strain gage surveillance shall be perfonned hourly when increasing power above a level at which data was previously obtained. The surveillance of both the strain gage data and MSL pressure data is also required to be performed once at each 40 MWt power step above 1593 MWt and within one hour of achieving each 40 MWt step In power, i.e., at thermal power levels of approximately 102.5%, 105%, 107.5%, 110%, 112.5%, 115%, 117.5%, and 120% OLTP (i.e., 1593 MWt). If the surveillance is met at a given power level, additional surveillances do not need to be performed at a power level where data had previously been obtained.

If valid strain gage data cannot be recorded hourly or within one hour of initially reaching a 40 MWt power step from at least three of the four MSLs, an orderly power reduction shall be made to a lower power level at which data had previously been obtained. Any such power level reduction shall be completed within two hours of determining that valid data was not recorded.

VYNPS Steam Dryer Monitoring Plan Page 6 of 18 Trable 2 Steam Dryer Performance Criteria and Required Actions Performance Criteria Not to be Required Actions if Performance Criteria Exceeded and Required Exceeded Completion Times Level 2:

1. Promptly suspend reactor power ascension until an engineering Moisture carryover exceeds evaluation concludes that further power ascension is justified.

0.1%

2. Before resuming reactor power ascension, the steam dryer OR performance data shall be reviewed as part of an engineering evaluation to assess whether further power ascension can be made Moisture carryover exceeds without exceeding the Level I criteria.

0.1% and increases by

> 50% over the average of the three previous measurements taken at

> 1593 MWt OR Pressure data exceed Level 2 Spectral Level 1:

1. Promptly initiate a reactor power reduction and achieve a previously acceptable power level (i.e., reduce power to a previous step level)

Moisture carryover exceeds within two hours, unless an engineering evaluation concludes that 0.35%

continued power operation or power ascension is acceptable.

OR

2. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, re-measure moisture carryover and perform an Pressure data exceed Level engineering evaluation of steam dryer structural integrity. If the 1 Spectral results of the evaluation of steam dryer structural integrity do not support continued plant operation, the reactor shall be placed in a hot shutdown condition within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If the results of the engineering evaluation support continued power operation, implement steps 3 and 4 below.

3. If the results of the engineering evaluation support continued power operation, reduce further power ascension step and plateau levels to nominal Increases of 20 MWt and 40 MWt, respectively, for any additional power ascension.

4. Within 30 days, the transient pressure data shall be used to calculate the steam dryer fatigue usage to demonstrate that continued power operation is acceptable.

1 The EPU spectra shall be determined and documented In an engineering calculation or report. Acceptable Level 2 spectra shall be based on maintaining < 80% of the ASME allowable alternating stress (Se) value at 1011 cycles (i.e., 10.88 ksi). Acceptable Level i Spectra shall be based on maintaining the ASME Sa at 1011 cycles (i.e., 13.6 ksi).

VYNPS Steam Dryer Monitoring Plan Page 7 of 18 1 able 3 Steam Dryer License Conditions License Condition Requirement Implementing Actions 3.M.1.a Entergy shall monitor hourly the 32 During initial power ascension above 1593 MWt, main steam line (MSL) strain gages data from at least 32 strain gages will be collected during power ascension above 1593 and evaluated by Entergy's power ascension test MWt for increasing pressure team to verify that acoustic signals indicative of fluctuations in the steam lines.

increasing pressure fluctuations in the steam lines are not challenging the steam dryer stress limit curve. Monitoring will be conducted hourly during any power ascension above a previously attained power level.

(Reference ERSTI-04-VY1 -1409-000)

(Reference PCRS tracking item WT-VrY-2005-00000-01803) 3.M.1.b Entergy shall hold the facility for 24 The PATP has established test plateau increments hours at 105%, 110%, and 115% of of approximately 80 MWt (corresponding to 105%,

OLTP (i.e., 1593 MWt) to collect 110%, and 115% of 1593 MWt). Reactor power will data from the 32 MSL strain gages not be increased above the plateau for a minimum required by License Condition of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.

During the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of steady 3.M.1.a, conduct plant inspections state operation at each plateau, strain gage data and walkdowns, and evaluate steam will be collected from all available strain gages dryer performance based on these (minimum of 32) and evaluated to demonstrate data; shall provide the evaluation to acceptable steam dryer performance. Additionally, the NRC staff by facsimile or moisture carryover measurements will be made at electronic transmission to the NRC each plateau and every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during power project manager upon completion of ascension testing.

At the 80 MWt plateau hold the evaluation; and shall not points, Entergy will conduct plant walkdowns and increase power above each hold Inspections of plant equipment, including piping and point until 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after the NRC components Identified as potentially vulnerable to project manager confirms receipt of flow-induced vibration (FIV) in accordance with the the transmission.

PATP and other plant procedures.

Steam dryer performance will be evaluated based on these data.

The 24-hour period and the 96-hour period may overlap once the transmittal Is provided to the NRC staff.

• The evaluations of steam dryer performance, based on the data collected during each of the 80 MWt plateaus, as well as the results of walikdowns and other measurements of FIV for various piping and plant components, will be provided to the NRC staff.

Arrangements have been made for electronic transmission through email and/or uploading to a

VYNPS Steam Dryer Monitoring Plan Page 8 of 18 License Condition Requirement Implementing Actions designated website.

Upon the NRC Project Manager confirming receipt of the steam dryer data and performance evaluation, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of hold time will commence. Power will not be increased above each of the 80 MWt hold points until the expiration of the 96-hour hold.

If during the hold periods, or at any other time, the NRC staff requests a discussion or requires clarification of the engineering evaluations provided in fulfillment of this requirement, Entergy will promptly arrange for such discussions. Entergy will maintain a power ascension control

center, including management oversight, available 24/7 on-site during power increases to previously unattained power levels.

(Reference ERSTI-04-VY1 -1 409-000)

(Reference PCRS tracking item WT-VTY-2005-00000-01803) 3.M.1.c If any frequency peak from the MSL The steam dryer stress limit curve provided strain gage data exceeds the limit herewith contains Level 1 and Level.2 criteria. If curve established by Entergy frequency peaks from MSL strain gage data exceed Nuclear Operations, Inc.

and either Level I or Level 2 criteria, prompt action will submitted to the NRC staff prior to be taken In response to the potential adverse flow operation above OLTP, Entergy effects that might result. Similar actions will occur if Nuclear Operations, Inc. shall return moisture carryover is excessive and previously the facility to a power level at which established Level 1 or Level 2 criteria are the limit curve is not exceeded. exceeded.

The Level 2 criteria represent a Entergy Nuclear Operations, Inc.

conservative action level for evaluation and close shall resolve the uncertainties in the monitoring of steam dryer performance-not a limit.

steam dryer analysis, document the The Level 1 criteria represent analytical limits and continued structural integrity of the additional actions may be warranted.

steam

dryer, and provide that documentation to the NRC staff by If any frequency peak from the MSL strain gage facsimile or electronic transmission data exceeds the Level 1 steam dryer stress limit to the NRC project manager prior to curve, Entergy will reduce reactor power to a power further Increases in reactor power.

level at which the limit curve is not exceeded.

(Reference ERSTI-04-VY1-1409-000)

Prior to any further increase in power above the reduced power level, Entergy will (1) resolve the uncertainties in the steam dryer analysis, (2) evaluate and document the adequate structural integrity of the steam dryer, and (3) provide that documentation to the NRC staff. Any revision to the

VYNPS Steam Dryer Monitoring Plan Page 9 of 18 License Condition Requirement Implementing Actions limit curve based on this evaluation will be provided to the NRC staff.

(Reference PCRS tracking item WT-VTY-2005-00000-01803) 3.M.1.d In addition to evaluating the MSL Accelerometers mounted on MSL piping will be strain gage data, Entergy Nuclear monitored on an hourly basis during power Operations, Inc.

shall monitor ascension testing to identify if resonances are reactor pressure vessel water level increasing above nominal levels in proportion to instrumentation or MSL piping MSL strain gage data.

If abnormally increasing accelerometers on an hourly basis resonant frequencies are

detected, power during power ascension above ascension will be halted.

Prior to any further OLTP. If resonance frequencies are increase in power, Entergy will (1) evaluate and Identified as increasing above document the adequate structural integrity of the nominal levels in proportion to strain steam dryer, and (2) provide that documentation to gage instrumentation data, Entergy the NRC staff.

Nuclear Operations, Inc. shall stop (Reference ERSTI-04-VY1-1409-000) power ascension, document the (Reference PCRS tracking item WT-VrY-2005-continued structural integrity of the 00000-01803) steam

dryer, and provide that documentation to the NRC staff by facsimile or electronic transmission to the NRC project manager prior to further increases in reactor power.

3.M.1.e Following start-up testing, Entergy After collecting strain gage data at approximately Nuclear Operations, Inc.

shall the EPU full power level, Entergy will resolve the resolve the uncertainties in the uncertainties in the steam dryer analysis and steam dryer analysis and provide provide documentation of the resolution to the NRC that resolution to the NRC staff by staff. If these actions cannot be achieved within 90 facsimile or electronic transmission days of issuance of the license amendment, reactor to the NRC project manager. If the power will be limited to 1593 MWt. This uncertainty uncertainties are not resolved within evaluation may be prepared and provided to the 90 days of issuance of the license NRC prior to reaching EPU full power levels amendment authorizing operation at associated with any proposed revision to the steam 1912

MWt, Entergy Nuclear dryer limit curve.

Operations, Inc. shall return the (Reference PCRS tracking item WT-VTY-2005-facility to OLTP.

00000-01803) 3.M.2.a Prior to operation above OLTP, To enhance performance and improve the accuracy Entergy Nuclear Operations, Inc. of the steam dryer measurement system, Entergy shall install 32 additional strain has installed 48 strain gages on MSL piping and will gages on the main steam piping and maintain a minimum of 32 operable strain gages shall enhance the data acquisition during power ascension testing.

The data system in order to reduce the acquisition system (DAS) was upgraded to reduce measurement uncertainty the uncertainty associated with the ACMI.

VYNPS Steam Dryer Monitoring Plan Page 10 of 18 License Condition Requirement Implementing Actions associated with the acoustic circuit (Reference Entergy VYNPS Temporary Alteration model (ACM).

TA-2005-15 RI) 3.M.2.b In the event that acoustic signals If acoustic signals indicative of increasing pressure are identified that challenge the limit fluctuations in the steam lines are identified as curve during power ascension challenging the steam dryer stress limit curve (i.e.,

above

OLTP, Entergy Nuclear Level 1 criterion), in addition to reducing reactor Operations, Inc.

shall evaluate power to a previously acceptable power level, steam dryer loads and re-establish Entergy will conduct an evaluation arid re-establish the limit curve based on the new the limit curve based on the latest strain gage data.

strain gage data, and shall perform As part of the redevelopment of the limit curve, a frequency-specific assessment of Entergy will prepare a

frequency-specific ACM uncertainty at the acoustic assessment of ACM uncertainty at the acoustic signal frequency.

signal frequency.

This uncertainty evaluation may be prepared and provided to the NRC in advance of this condition being met.

(Reference ERSTI-04-VY1-1409-000) 3.M.2.c After reaching 120% of OLTP, After collecting strain gage data at approximately Entergy Nuclear Operations, Inc. the EPU full power level, Entergy will establish the shall obtain measurements from the steam dryer flow-induced vibration load fatigue MSL strain gages and establish the margin for the facility, update the steam dryer stress steam dryer flow-induced vibration report, and re-establish the stress limit curve with load fatigue margin for the facility, the updated ACM load definition and revised update the steam dryer stress Instrument uncertainty.

This information will be report, and re-establish the steam included in the report to the NRC staif being made dryer monitoring plan (SDMP) limit in accordance with License Condition 3.M.1.e.

curve with the updated ACM load (Reference PCRS tracking item WT-VrY-2006-definition and revised instrument 00000-00249) uncertainty, which will be provided to the NRC staff.

3.M.2.d During power ascension above If an evaluation or analysis of the structural integrity OLTP, if an engineering evaluation of the steam dryer is required because acoustic is required in accordance with the signals indicative of increasing pressure fluctuations SDMP, Entergy Nuclear Operations, in the steam lines are identified as potentially Inc. shall perform the structural challenging the steam dryer stress limit curve (i.e.,

analysis to address frequency Level 1 criterion), Entergy will address frequency uncertainties up to 10%

and uncertainties up to + 10% and assure that peak assure that peak responses that fall responses that fall within this uncertainty band are within this uncertainty band are addressed.

This uncertainty evaluation may be addressed.

prepared and provided to the NRC in advance of this condition being met.

(Reference ERSTI-04-VYI-1409-000)

VYNPS Steam Dryer Monitoring Plan Page 11 of 18 License Condition Requirement Implementing Actions 3.M.2.e Entergy Nuclear Operations, Inc. The revised SDMP provides long-term monitoring of shall revise the SDMP to reflect steam dryer performance in accordance with GE long-term monitoring of plant SIL 644 Rev. 1.

parameters potentially indicative of (Reference PCRS tracking item WAT-VTY-2006-steam dryer failure; to reflect 00000-00250) consistency of the facility's steam dryer inspection program with The SDMP and the PATP identify the NRC Project General Electric Services Manager for the VYNPS EPU as the point of Information Letter 644, Revision 1; contact for providing SDMP information during and to identify the NRC Project power ascension.

Manager for the facility as the point (Reference ERSTI-04-VYI-1409-000) of contact for providing SDMP information during power ascension.

For moisture carryover, procedures OP-0631 and ON-3178 provide for long-term monitoring and controls.

3.M.2.f Entergy Nuclear Operations, Inc. The final EPU steam dryer load definition will be shall submit the final extended included in the report provided to the NRC staff in power uprate (EPU) steam dryer accordance with License Conditions 3.M.1.e. and load definition for the facility to the 3.M.2.c.

NRC upon completion of the power (Reference PCRS tracking item WT-VTY-2006-ascension test program.

00000-00251) 3.M.2.g Entergy Nuclear Operations, Inc. Entergy letter BVY 06-019 forwards the FlV-related shall submit the flow-induced portions of the EPU power ascension test vibration related portions of the EPU procedure to the NRC. (Reference EFRSTI-04-VY-startup test procedure to the NRC, 1409-000) including methodology for updating the limit curve, prior to initial power The methodology for updating the steam dryer ascension above OLTP.

stress limit curve is as follows:

Prerequisite: Generate report resolving uncertainties in the steam dryer analysis.

1. Collect representative data from 32 strain gages at eight MSL locations.

2. Using a plant-specific ACM, analyze strain gage data to determine steam dryer loads.

3. Input ACM loads into a finite element model to determine dryer stresses.

4. Perform an updated uncertainty evaluation.

5. Generate revised steam dryer stress limit curve(s).

(Reference PCRS tracking item WT-V1Y-2006-00000-00252)

VYNPS Steam Dryer Monitoring Plan Page 12 of 18 License Condition Requirement Implementing Actions 3.M.3(a)

Entergy shall prepare the EPU The steam dryer stress limit curve to be applied for startup test procedure to include the evaluating steam dryer performance during power stress limit curve to be applied for ascension is provided herewith. The lmlrnit curve was evaluating steam dryer developed on the basis of calculation VYC-3001, performance.

which is incorporated by reference into the EPU PATP.

(Reference ERSTI-04-VY1 -1409-000) 3.M.3(b)

Entergy shall prepare the EPU Specific hold points and durations are specified in startup test procedure to include the PATP.

specific hold points and their (Reference ERSTI-04-VY1 -1 409-000) duration during EPU power ascension.

3.M.3(c)

Entergy shall prepare the EPU Activities to be accomplished during hold points are startup test procedure to include [specified in the PATP.

activities to be accomplished during (Reference ERSTI-04-VYI-1409-000) hold points.

3.M.3(d)

Entergy shall prepare the EPU Plant parameters to be monitored are specified in startup test procedure to include Attachment 9 to the PATP.

plant parameters to be monitored.

(Reference ERSTI-04-VYl-1409-000) 3.M.3(e)

Entergy shall prepare the EPU Inspections and walkdowns to be conducted for startup test procedure to include steam, feedwater, and condensate systems and inspections and walkdowns to be components during hold points are specified in conducted for steam, feedwater, Attachment 9 to the PATP.

and condensate systems and (Reference ERSTI-04-VYI-1409-000) components during the hold points.

3.M.3(f)

Entergy shall prepare the EPU Methods to be used to trend plant parameters are startup test procedure to include specified in Attachment 9 to the PATP.

methods to be used to trend plant (Reference ERSTI-04-VYI-1409-000) parameters.

3.M.3(g)

Entergy shall prepare the EPU Acceptance criteria for monitoring end trending startup test procedure to include plant parameters, and conducting the walkdowns acceptance criteria for monitoring and inspections are specified in Attachment 9 to the and trending plant parameters, and PATP. (Reference ERSTI-04-VYI-1409-000) conducting the walkdowns and inspections.

3.M.3(h)

Entergy shall prepare the EPU Actions to be taken if acceptance criteria are not startup test procedure to include satisfied are specified in the PATP.

actions to be taken if acceptance (Reference ERSTI-04-VYI-1409-000) criteria are not satisfied.

VYNPS Steam Dryer Monitoring Plan Fage 13 of 18 License Condition Requirement Implementing Actions 3.M.3(i)

Entergy shall prepare the EPU Verification of the completion of commitments and startup test procedure to include planned actions specified in the license amendment verification of the completion of application and all supplements to the application in commitments and planned actions support of the EPU license amendment request specified in the license amendment pertaining to the steam dryer is specified in the application and all supplements to PATP.

the application In support of the (Reference ERSTI-04-VY1-1409-000)

EPU license amendment request pertaining to the steam dryer.

3.M.4 When operating above OLTP, the These restrictions are provided in the PATP and/or operating limits, required actions, the SDMP.

and surveillances specified in the (Reference ERSTI-04-VYI-1409-000)

SDMP shall be met. The following key attributes of the SDMP shall not be made less restrictive without prior NRC approval:

a. During initial power ascension testing above OLTP, each test plateau increment shall be approximately 80 MWt;

b. Level 1 performance criteria; and

c. The methodology for establishing the stress spectra used for the Level I and Level 2 performance criteria.

Changes to other aspects of the SDMP may be made in accordance with the guidance of NEI 99-04.

3.M.5 During each of the three scheduled The VYNPS steam dryer will be inspected during refueling outages (beginning with the refueling outages scheduled for the Spring the spring 2007 refueling outage),

2007, Fall 2008, and Spring 2010. The inspections a visual inspection shall be conducted after power uprate implementation will conducted of all accessible, be comparable to the inspections conducted during susceptible locations of the steam the Spring 2004 and Fall 2005 refueling outages dryer, including flaws left "as is" and will be in accordance with the guidance in SIL and modifications.

644, Rev. 1.

(Reference PCRS tracking Item WT-VTY-2006-00000-00253)

(Reference PCRS tracking item Wr-VTY-2006-00000-00254)

VYNPS Steam Dryer Monitoring Plan Page 14 of 18 License Condition Requirement Implementing Actions (Reference PCRS tracking Item VT-VTY-2006-00000-00255) 3.M.6 The results of the visual The VYNPS steam dryer will be inspected during inspections of the steam dryer the refueling outages scheduled for the Spring conducted during the three 2007, Fall 2008, and Spring 2010. The inspectons scheduled refueling outages conducted after power uprate implementation will (beginning with the spring 2007 be comparable to the inspections conducted during refueling outage) shall be reported the Spring 2004 and Fall 2005 refueling outages to the NRC staff within 60 days and will be in accordance with the guidance in SIL following startup from the 644, Rev. 1. The results will be documented in a respective refueling outage. The report and submitted to the NRC within 60 days results of the SDMP shall be following completion of all EPU power ascension submitted to the NRC staff In a i testing.

report within 60 days following the (Reference PCRS tracking item WT-VTY-2006-completion of all EPU power 00000-00256) ascension testing.

(Reference PCRS tracking item WT-VTY-2006-00000-00257)

(Reference PCRS tracking item WT-VTY-2006-00000-00258) 3.M.7 The requirements of paragraph When operating above 1593 MWt, the operating 3.M.4 above for meeting the SDMP limits, required actions, and surveillances specified shall be implemented upon In the SDMP will be met. Those key attributes of issuance of the EPU license the SDMP specified in License Condition 3.M.4 will amendment and shall continue not be made less restrictive without prior NRC until the completion of one full approval.

operating cycle at EPU. If an (Reference PCRS tracking item WT-VTY-2006-unacceptable structural flaw (due 00000-00259) to fatigue) is detected during the subsequent visual inspection of the steam dryer, the requirements of paragraph 4 shall extend another full operating cycle until the visual inspection standard of no new flaws/flaw growth based on visual inspection is satisfied.

3.M.8 This license condition shall expire (Reference PCRS tracking item Wr-VTY-2006-upon satisfaction of the 00000-00260) requirements in paragraphs 5, 6, and 7 provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw or unacceptable flaw growth that is due to fatigue.

VYNPS Steam Dryer Monitoring Plan Page 15 of 18 MiSL A Upper 1.OE+OO 1.OE-01 1.0E-02 E 1.0E-03 1.0E-04 1.0E-05 1.0E-08 0

50 100 150 200 Frequency, Hz I-LC_2Ave_MSLA Upper

-LCL AveMSLAI 250 1

Upper I

Figure 1: Steam Dryer Stress Limit Curve - MSL 'A' Upper MSIL A Lower 1.OE+O0 1.OE-01 1.OE-02 t 1.0E03 1.OE-04 1.0E-06 50 100 150 200 250 Frequency. Hz

-LC_2 Ave_MSLALcwer

-LCj AveMSLA Lower Figure 2: Steam Drver Stress Limit Curve - MSL 'A' Lower

VYNPS Steam Dryer Monitoring Plan Page 16 of 18 MEL B Upper 1.0E+OO t.OE-01 1.OE020 N

A 1.OE-04 1.OE-05 t.OE46s 1.OE+OOl 1.0E-01 1.E-02 T 1.0E-03 I

1.0E-04 1.0E-05 1.OE-06 50 100 150 200 250 Frequency, Hz

-LC_2 AveMSL.B_Upper

-LCLI AveyMSLBjUpper

]

Figure 3: Steam Dryer Stress Limit Curve - MSL 'B' Upper USL. B Lower 50 100 150 200 250 Frequency. Hz LC2 Ave MSLBLower

-LC_1 AveMSL0 Lower

]

Figure 4: Steam Dryer 'tress Limit Curve - MSL 'B' Lower

VYNPS Steam Dryer Monitoring Plan Page 17 of 18 M SL C Upper tz z

E 0

50 100 150 200 250 Frequency. Hz l-LC_2Ave_USL..CUpper

-LC_1 Ave_MSL_C_Upper

]

Fiaure 5: Steam Dryer Stress Limit Curve - MSL 'C' UDner MSL. C Lower I.OE-0i 1.OE-02 1.w 1(E-O 6.

0 so 100 150 200 2fi Frequency, Hz

-LC 2AveMSLCLrower

-LCI AveMSLCLcwer

]

Figure 6: Steam Dryer Stress Limit Curve - MSL 'C' Lower

VYNPS Steam Dryer Monitoring Plan Page 18 of 18 WISL D Upper 1.OE+oo 1.OEO1 1i.OE042 1.0E42 M.OE-0 1.0E*06 1.0E0OO I.0OE-I.OE 02 1.0006 1.OE.00 I.0E.01 1.0E-03 aT I.OE-04 I.CE-06 i.OE-06 I

0 50 10r 150 200 Frquency, Hz I -LC2 AvejMSL__Upper

-LCJ Ave MSLOupper I

Figure 7: Steam Drver Stress Limit Curve - MSL 'D' UDDer 250 MSL D Lower a

50 100 150 200 250 Frequency. Hz

-LC_2 AveMSl<D-Lws

-LC1 Ave MSL_D Lower Figure 8: Steam Dryer Stress Limit Curve - MSL 'D' Lower

VYNPS Steam Dryer Monitoring Plan M.3L A Upper 1.OE-01 1.OE-02 1.0E-03 0

50 100 150 200 Frequency, Hz 250

-LC_2Ave MSLAUpper

-LC1 AveMSLAUpper Figure 1: Steam Dryer Stress Limit Curve - MSL 'A' UDper MSL A Lower I:t 0

50 100 150 200 250 Frequency, Hz

-LC_2Ave_MSLALower

-LC_1 Ave~_MSLkALower Figure 2: Steam Dryer Stress Limit Curve - MSL 'A' Lower

VYNPS Steam Dryer Monitoring Plan MSL B Upper I0 0

50 100 150 200 250 Frequency, Hz l -LC_2 Ave MSL.BUpper

-LCI AveMSLUpper X

Figure 3: Steam Drver Stress Limit Curve - MSL 'B' Uoper MSL B Lower 50 100 150 200 250 Frequency, Hz LC_2 Ave MSLBLower

-LC_1 Ave_MSL_B_Lower X

Figure 4: Steam Drver Stress Limit Curve - MSL 'B' Lower

VYNPS Steam Dryer Monitoring Plan MSL C Upper 0a 0

50

10) 150 200 250 Frequency, Hz LC_2 AveMSLCUpper

_MSL_C_Upper

-LC_1 Ave-MSL.C~_Upper Figure 5: Steam Dryer Stress Limit Curve - MSL 'C' Urper MSL C Lower N

I 0

50 10C 150 200 250 Frequency, Hz

-LC_2 AveMSL_C_Lower

-LC_L AveMSL.C_Lower Figure 6: Steam Dryer Stress Limit Curve - MSL 'C' Lower

VYNPS Steam Dryer Monitoring Plan MSL D Upper 1.OE+00 ZN 0

50 10N 150 200 Frequency, Hz LC2 Ave MSL.DUpper

-LCI AveMSL_DUpper 9 Figure 7: Steam Dryer Stress Limit Curve - MSL 'D' Upper 250 MSL D Lower N

1.OE-03 0

50 100 150 200 250 Frequency, Hz I-LC_2 Ave_MSL_D_Lower

-LC_1 AveMSLDLower Figure 8: Steam Dryer Stress Limit Curve - MSL 'D' Lower