BVY 08-020, Three Month Response to GL-08-001

Three Month Response to GL-08-001

ML081120227
Person / Time
Site:	Vermont Yankee
Issue date:	04/10/2008
From:	Ted Sullivan Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 08-020, GL-08-001
Download: ML081120227 (6)

Text

Entergy Nuclear Operations, Inc Vermont Yankee P.O. Box 250

-m E nter y Governor Hunt Road Vernon, VT 05354 Tel 802 257 7711 April 10, 2008 BVY 08-020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

NRC Generic Letter 2007-01, "Managing Gas Accumulation in EmergencyCore Cooling, Decay Heat Removal, and Containment Spray Systems," NVY 08-008, dated January 11, 2008

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

Vermont Yankee Three Month Response to Generic Letter 2008-01

Dear Sir or Madam:

The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 dated January 11, 2008, to address the issue of gas accumulation in emergency core cooling, decay heat removal, and containment spray systems.

The GL requested each licensee to submit a written response in accordance with 10 CFR 50.54(f) within nine months of the date of the GL to provide the following (summarized) information:

a. A description of the results of evaluations that were performed pursuant to the requested actions of the GL. This description should provide sufficient information to demonstrate that you are or will bein compliance with the quality assurance criteria in Sections III, V, XI, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license, as those requirements apply to the subject systems of the GL.

b. A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that were determined necessary to assure compliance with these regulations.

c. A statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

Additionally, the NRC requested that if a licensee cannot meet the requested nine month response date, the licensee provide a response within 3 months of the date of this GL. In the three month response, the licensee was requested to describe the alternative course of action that it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

BVY 08-020 / page 2 of 2 to this letter contains Vermont Yankee's three month response to NRC GL 2008-

01. Attachment 2 contains new regulatory commitments.

If you have any questions or require additional information, please contact Mr. David Mannai at 802-451-3304.

The requested information is being provided pursuant the requirements of 10 CFR 50.54(f).

I declare under the penalty of perjury that the foregoing information is true and correct.

Executed on April 10, 2008.

Sincerely,

/*d u!ý, ý Site Vice President Vermont Yankee Nuclear Power Station Attachments:

1. Vermont Yankee Three Month Response to NRC Generic Letter 2008-01

2. Regulatory Commitment List cc: Mr. Samuel J. Collins, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. James S. Kim, Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont 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

BVY 08-020 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Vermont Yankee Three Month Response to NRC Generic Letter 2008-01

BVY 08-020 / Attachment 1/ Page 1 of 1 Vermont Yankee Three Month Response to NRC Generic Letter 2008-01 This response to Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," addresses the three month response requested in NRC GL 2008-01, which was dated January 11, 2008.

This response discusses:

• The required evaluations that will not be complete by October 11, 2008 (nine months from the date of GL 2008-01).

• The alternative course of action planned.

• The basis for the acceptability of the alternative course of action.

For Vermont Yankee (VY), the following emergency core cooling systems and decay heat removal systems are considered within the scope of GL 2008-01:

• High Pressure Coolant Injection System

• Core Spray System

• Residual Heat Removal System (containment spray, low pressure coolant injection, and shut down cooling modes)

The information requested for the nine month response to GL 2008-01 includes a description of the results of evaluations that were performed pursuant to the requested actions of the GL, a description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that were determined necessary; the status of corrective actions, a schedule for completion of outstanding corrective actions, and the basis for that schedule. The requested evaluations are those necessary to ensure that the subject systems are sufficiently filled with water that they can reliably perform their intended functions.

The performance of an in-field inspection of the system piping is considered to be a necessary part of the VY evaluations. Since portions of the above systems are inaccessible or high dose areas during power operations, an outage is required to complete the response to the GL. VY has a refueling outage (RFO) during the Fall of 2008 and will finalize walkdowns and inspections during the RFO. Therefore, the full scope of the required evaluations and any resultant corrective actions will not be complete prior to the requested nine month GL response date.

VY Will have the walkdowns and evaluations of the normally accessible portions of the above systems completed by October 11, 2008. VY will complete the walkdown of the inaccessible portions of the systems during the RFO and VY will supplement the initial response to the GL by January 30, 2009. This will provide time following the RFO to evaluate the results of the outage inspections.

BVY 08-020 50-271 Docket No.

2 Attachment Power Station Yankee Nuclear Vermont List Commitment Regulatory

Regulatory Commitments Table This table identifies actions discussed in this letter for which Entergy commits to perform. Any other actions discussed in this submittal are described for the NRC's information and are not commitments.

Letter Number/Title: BVY 08-020, Vermont Yankee Three Month Response to Generic Letter 2008-01 TYPE SCHEDULED S(Check one) COMPLETION COMMITMENT DATE ONE-TIME CONTINUING (If Required)

ACTION COMPLIANCE Submit an initial response to Generic X October 11, 2008 Letter 2008-01.

Submit a supplemental response to x January 30, 2009 Generic Letter 2008-01.