BVY 12-015, Proposed Change No. 300, Renewed Facility Operating License Condition 3.P and 3.Q Changes

Proposed Change No. 300, Renewed Facility Operating License Condition 3.P and 3.Q Changes

ML12068A110
Person / Time
Site:	Vermont Yankee
Issue date:	03/05/2012
From:	Wamser C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 12-015
Download: ML12068A110 (17)

Text

Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd Vernon, VT 05354 Tel 802 257 7711 Christopher J. Wamser Site Vice President BVY 12-015 March 5, 2012 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Proposed Change No. 300 Renewed Facility Operating License Condition 3.P and 3.Q Changes Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCE:

1. NUREG-1 907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station," Supplement 2, dated March 2011

Dear Sir or Madam:

In accordance with 10CFR50.90, Vermont Yankee (VY) is proposing an amendment to Renewed Facility Operating License DPR-28. The proposed amendment would revise VY Renewed Facility Operating License Condition (RFOLC) 3.P to clarify that the programs and activities described in the Updated Final Safety Analysis Report (UFSAR) supplement submitted pursuant to 10 CFR 54.21(d), as revised during the license renewal application process, may be changed without prior NRC approval provided the requirements of 10 CFR 50.59 have been previously satisfied.

Additionally, RFOLC 3.Q is revised to clarify that the programs and activities, identified in Appendix A of Supplement 2 to NUREG-1 907 and the UFSAR supplement, to be completed before the period of extended operation are completed on schedule and the NRC is to be notified upon completion of implementation of these activities.

VY has reviewed the proposed amendment in accordance with 10 CFR 50.92 and concludes it does not involve a significant hazards consideration. In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the State of Vermont, Department of Public Service. to this letter provides a detailed description and evaluation of the proposed change. contains a markup of the current VY Renewed Facility Operating License (RFOL) page. Attachment 3 contains the retyped RFOL page. Attachment 4 includes a new regulatory commitment.

A new regulatory commitment to include the list of License Renewal Commitments identified in Appendix A of Supplement 2 to NUREG-1 907 in the UFSAR supplement is included in this letter.

Although this change does not meet the requirements for an exigent review under 10 CFR 50.91 (a)(6), VY requests a timely review. Recent discussions with regional NRC staff indicate that an interpretation/clarification of the wording of our existing license condition is pending, vJ~iZ

BVY 12-015 / Page 2 of 2 and that interpretation would result in our inability to utilize the 10 CFR 50.59 regulatory process to evaluate and make changes to our license renewal commitments.

If you have any questions on this transmittal, please contact Mr. Robert Wanczyk at 802-451-3166.

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

Executed on March 5, 2012.

Sincerely,

[CJW/PLC]

Attachments

1. Description and Evaluation of the Proposed Changes

2. Markup of the Current Renewed Facility Operating License Pages

3. Retyped Renewed Facility Operating License Pages

4. List of Regulatory Commitments cc: Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Rd Vernon, Vermont 05354 Ms Elizabeth Miller, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 12-015 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Proposed Change 300 Description and Evaluation of Proposed Changes

BVY 12-015 / Attachment 1 / Page 1 of 5

1.

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Vermont Yankee (VY) hereby proposes to amend Renewed Facility Operating License (RFOL) DPR-28. Specifically;

" Renewed Facility Operating License Condition (RFOLC) 3.P is clarified to improve the understanding that changes to the programs and activities, including commitments, described in the Updated Final Safety Analysis Report (UFSAR) supplement can be evaluated under 10 CFR 50.59 to determine if prior NRC approval is required. A commitment to include the list of License Renewal Commitments, identified in Appendix A of Supplement 2 to NUREG-1 907 (Reference 6.a), in the UFSAR Supplement is included in this letter. This will ensure that all changes to commitments are evaluated under 10 CFR 50.59.

• RFOLC 3.Q is revised to clarify that the intent of the license condition is to ensure that the programs and activities, identified in Appendix A of Supplement 2 to NUREG-1907 and the UFSAR supplement, to be completed before the period of extended operation are completed no later than March 21, 2012 and the NRC is notified of completion.

• Add an amendment number tracking mechanism to the RFOL.

2. DETAILED DESCRIPTION License Condition 3.P currently states:

"The information in the UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), shall be incorporatedinto the next UFSAR no later than the next scheduled update required by 10 CFR 50.71(e), following the issuance of this renewed operating license. Until this update is complete, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations,Inc. may make changes to the information in the supplement without Commission approvalprovided that Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations,Inc., evaluates such changespursuant to the criteriain 10 CFR 50.59 and otherwise complies with the requirements of that section."

License Condition 3.P is proposed to be revised as follows:

"The information in the UFSAR supplement, submitted pursuant to 10 CFR 54.21(d), as' revised during the license renewal applicationprocess, is henceforth part of the UFSAR which will be updated in accordancewith 10 CFR 50.71(e). As such, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. may make changes to the programs and activities described in the supplement provided Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. evaluates such changespursuant to the criteriaset forth in 10 CFR 50.59 and otherwise complies with the requirementsin that section."

License Condition 3.Q currently states:

"The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), describes certain future activities to be completed prior to and/orduring the period of extended operation.Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations,Inc.

shall complete these activities in accordancewith Appendix A of Supplement 2 to NUREG-1907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee

BVY 12-015 / Attachment 1 / Page 2 of 5 Nuclear Power Station," issued March 2011 (excluding Commitment No. 37, which is supersededby the steam dryer license condition). Entergy Nuclear Vermont Yankee, LLC or Entergy Nuclear Operations,Inc. shall notify the NRC in writing when activities to be completed prior to the period of extended operationare complete and can be verified by NRC inspection."

License Condition 3.Q is proposed to be revised as follows:

"AppendixA of Supplement 2 to NUREG-1907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station," dated March 2011 (excluding Commitment No. 37, which is supersededby the steam dryer license condition), and the UFSAR supplement submitted pursuant to 10 CFR 54.21(d), as revised on February4, 2011, describes certain future programs and activities to be completed before the period of extended operation. Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations,Inc. shall complete these activities no later than March 21, 2012 and shall notify the NRC in writing when implementation of these activities is complete."

An amendment number tracking mechanism is added to the first page of the RFOL and the page containing License Conditions 3.P and 3.Q.

3. TECHNICAL EVALUATION VY received the RFOL in Reference 6.b. The following provides an evaluation of the proposed changes to RFOLC 3.P and 3.Q. These changes are administrative in nature and do not change any technical requirements.

RFOLC 3.P Changes The intent of RFOLC 3.P is to ensure that the UFSAR supplement, submitted pursuant to 10 CFR 54.21(d) and revised during the license renewal application process, is incorporated into the VY UFSAR no later than the next scheduled update in accordance with 10 CFR 50.71 (e). The license condition also allows changes to be made to the information in the supplement without prior NRC approval provided that the changes are evaluated under 10 CFR 50.59.

The current wording of RFOLC 3.P is clearly understood. However, the proposed changes to the wording ensure that there is consistency in the use of the terms "programs and activities" between the proposed new RFOLCs 3.P and 3.Q.

To ensure that the complete scope of information is contained in the UFSAR supplement, a regulatory commitment to include the list of License Renewal Commitments identified in Appendix A of Supplement 2 to NUREG-1907 in the UFSAR Supplement is included in this letter. The list will exclude Commitment No. 37, which was superseded by the steam dryer license condition, 3.S and include Commitment No. 55, which was not included in Appendix A but was evaluated in Supplement 2 to NUREG-1 907.

The reworded RFOLC ensures changes are adequately evaluated and the USFAR is updated as appropriate. This change is non-technical and provides for the control and evaluation of the UFSAR supplement information consistent with established processes for control of other information contained in the UFSAR.

I.

BVY 12-015 / Attachment 1 / Page 3 of 5 RFOLC 3.Q Changes The intent of RFOLC 3.Q is to ensure that activities scheduled to be completed before entering the period of extended operation (PEO) are completed in accordance with the schedule identified in Appendix A of Supplement 2 to NUREG-1 907, Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station, dated March 2011, and the UFSAR supplement submitted pursuant to 10 CFR 54.21 (d), as revised, and that NRC is notified in writing when implementation of these activities is complete.

The UFSAR supplement was last revised during the license renewal application review process by VY letter dated February 4, 2011 (Reference 6.d).

The current wording needs to be clarified because it is not clear what the appropriate process is for making changes to the license renewal commitments listed in Appendix A of Supplement 2 to NUREG-1907. One interpretation of the current license condition wording is that prior NRC approval would be required under 10 CFR 50.90 in order to make any change to a license renewal commitment, whether it is included in the UFSAR supplement or not. Requiring the use of the 10 CFR 50.90 license amendment process to change license renewal commitments would create an unnecessary burden on both VY and the NRC staff. The proposed change to RFOLC 3.Q, in conjunction with the regulatory commitment to incorporate the list of license renewal commitments into the UFSAR supplement, would require that any changes to license renewal commitments be evaluated pursuant to 10 CFR 50.59.

The reworded RFOLC ensures that activities identified as needing to be completed prior to entering the PEO are completed on the appropriate schedule. This change is non-technical and provides NRC notification of completion of license renewal activities. It is also consistent with the description of the license condition in Section 1.7 of Volume I of NUREG-1907:

The second license condition requires future activities identified in the UFSAR supplement to be completed prior to the period of extended operation.

The proposed change also differentiates between programs and activities whereas the current wording specifies only activities. Differentiating between programs (i.e. aging management programs) and activities (i.e. one-time and/or periodic tests and inspections) provides further clarification of RFOLC 3.P and 3.Q.

Adding an amendment number tracking mechanism to the RFOL is an administrative change.

4. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Pursuant to 10 CFR 50.92, Vermont Yankee (VY) has reviewed the proposed change and concludes that the change does not involve a significant hazards consideration since the proposed change satisfies the criteria in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

BVY 12-015 / Attachment 1 / Page 4 of 5 The proposed amendment would revise VY Renewed Facility Operating License Condition (RFOLC) 3.P to clarify that the programs and activities described prior approval provided the requirements of 10 CFR 50.59 are satisfied. Additionally, RFOLC 3.Q is revised to note that certain activities are required to be completed prior to the period of extended operation and are to be completed in accordance with the schedule in Appendix A of Supplement 2 to NUREG-1907. An amendment number tracking mechanism is also added to the first page of the Renewed Facility Operating License and the page containing License Conditions 3.P and 3.Q.

The proposed change does not involve a significant hazards consideration because:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The amendment does not significantly increase the probability of an accident since it does not involve a change to any plant equipment that initiates a plant accident.

The change clarifies RFOLC 3.P and 3.Q. The license conditions deal with administrative controls over information contained in the Updated Final Safety Analysis Report (UFSAR) supplement. The proposed changes are administrative and the license conditions are not an initiator or mitigator of any previously evaluated accidents. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated since it does not involve any physical alteration of plant equipment and does not change the method by which any safety-related system performs its function. The license conditions deal with administrative controls over information contained in the UFSAR supplement. No new or different types of equipment will be installed and the basic operation of installed equipment is unchanged. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed amendment does not affect design codes or design margins. The change clarifies RFOLC 3.P and 3.Q, is administrative in nature and does not have the ability to affect analyzed safety margins. Therefore, operation of VY in accordance with the proposed amendment will not involve a significant reduction in the margin to safety.

Based on the above, Entergy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

BVY 12-015 / Attachment 1 / Page 5 of 5

5. ENVIRONMENTAL CONSIDERATIONS This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows:

(i) The amendment involves no significant hazards determination.

As described in Section 4 of this evaluation, the proposed change involves no significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The proposed amendment does not involve any physical alterations to the plant configuration that could lead to a change in the type or amount of effluent release off site.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed amendme.ytt does not involve a significant increase in individual or cumulative occupational radiation exposure.

Based on the above, VY concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

6. REFERENCES

a. NUREG-1907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station," Supplement 2, dated March 2011

b. Letter, USNRC to VYNPS, "Issuance of Renewed Facility Operating License No.

DPR-28 for the Vermont Yankee Nuclear Power Station," NVY 11-031, dated March 21, 2011

c. NUREG-1 907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station," Volume 1, dated February 2008

d. Letter VYNPS to USNRC, "License Renewal Application Supplemental Information,"

BVY 11-010, dated February 4, 2011

7. PRECEDENCE The renewed facility operating licenses issued for Salem Nuclear Generating Station, Units 1 and 2, (ML11136A064) and Hope Creek Generating Station (ML11116A148) contain license condition wording similar to that proposed in this change.

BVY 12-015 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station Proposed Change 300 Markup of the Current Facility Operating License Pages

Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

(Vermont Yankee Nuclear Power Station)

Docket No. 50-271 Renewed Facility Operating License Renewed Operating License No. DPR-28

ýArndentNo.

The U.S. Nuclear Regulatory Commission (NRC or the Commission), having previously made the findings set forth in Facility Operating License No. DPR-28, dated February 28, 1973, has now found that:

a. Construction of the Vermont Yankee Nuclear Power Station (the facility) has been substantially completed in conformity with the application, as amended, the Provisional Construction Permit No. CPPR-36, the provisions of the Atomic Energy Act of 1954, as amended (the Act), and the rules and regulations of the Commission as set forth in Title 10 of the Code of FederalRegulations (CFR)

Chapter 1,: and

b. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; and

c. There is reasonable assurance (1) that the activities authorized by this renewed operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the rules and regulations of the Commission; and

d. Entergy Nuclear Vermont Yankee, LLC is financially qualified and Entergy Nuclear Operations, Inc. is technically and financially qualified to engage in the activities authorized by this renewed operating license, in accordance with the rules and regulations of the Commission; and

e. Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

have satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements" of the Commission's regulations; and

f. The issuance of this renewed operating license will not be inimical to the common defense and security or to the health and safety of the public; and

g. After weighing the environmental, economic, technical and other benefits of the facility against environmental costs and considering available alternatives, the issuance of this renewed operating license (subject to the conditions for Renewed Operating License No. DPR-28

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders

0. The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

P. .The.iformationin the UFSAR supplement, as revised, submitted pursuan+/ 10 CFR . d), shall be incorporated into the next UFSAR no next scheduled u required by 10 CFR 50.71 (e), fo, g the issuance of this renewed operating e. Until this u tis complete, Entergy Nuclear Vermont Yankee, LLC an uclear Operations, Inc. may make changes to the informa~-iIthe sup nt without Commission approval provided th-ergy Nuclear Vermont Ya LLC and Entergy Nuclear 0 ns, Inc., evaluates such changes pursuant critieria in 10O 0.59 and otherwise complies with the requirements of that n.

Q. describe% SAR supplement, as revised, submitted pursuant to 1m0 CFR N4.27,

-taein future activities to be completed prior to and/or gJ,the period of esuenrse beration. Entergy Nuclear Ve mont Y) , LLC and Entergy Nuclear Oper slnc. shall complete the ctivities in accordance with Appendix A suElement2.r NuREG907, "Safety Evaluation Report Related to the Lic '*denewal of Vermont Yankee Nuclear Power Station," issue r h 201 l~euding Commitment No. 37, which is suesddb sIteam dryer license co in) neg Nuclear Vermont Yanke or Entergy Nuclear Operations, Inc. 11notify the NRC in -g when activities to be completed prior to the perio ended o ion are complete and can be verified by NRC inspection.

R. Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

shall implement the most recent staff-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance Program (ISP) as the method to demonstrate compliance with the requirements of 10 CFR Part 50, Appendix H. Any changes to the BWRVIP ISP capsule withdrawal schedule must be submitted for NRC staff review and approval. Any changes to the BWRVIP ISP capsule withdrawal schedule which affects the time of withdrawal of any surveillance capsules must be incorporated into the licensing basis. If any surveillance capsules are removed without the intent to test them, these capsules must be stored in a manner which maintains them in a condition which would support re-insertion into the reactor pressure vessel, if necessary.

Renewed Facility Operating License No. DPR-28 Aendent No.

Inserts

1. The information in the UFSAR supplement, submitted pursuant to 10 CFR 54.21 (d), as revised during the license renewal application process, is henceforth part of the UFSAR which will be updated in accordance with 10 CFR 50.71(e). As such, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. may make changes to the programs and activities described in the supplement provided Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

2. Appendix A of Supplement 2 to NUREG-1 907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station," dated March 2011 (excluding Commitment No. 37, which is superseded by the steam dryer license condition), and the UFSAR supplement submitted pursuant to 10 CFR 54.21 (d), as revised on February 4, 2011, describes certain future programs and activities to be completed before the period of extended operation. Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. shall complete these activities no later than March 21, 2012 and shall notify the NRC in writing when implementation of these activities is complete.

BVY 12-015 Docket 50-271 Attachment 3 Vermont Yankee Nuclear Power Station Proposed Change 300 Retyped Facility Operating License Pages

Enterav Nuclear Vermont Yankee, LLC and Enterav Nuclear Or)erations, Inc.

(Vermont Yankee Nuclear Power Station)

Docket No. 50-271 Renewed Facility Operatina License Renewed Operating License No. DPR-28 Amendment No.

The U.S. Nuclear Regulatory Commission (NRC or the Commission), having previously made the findings set forth in Facility Operating License No. DPR-28, dated February 28, 1973, has now found that:

a. Construction of the Vermont Yankee Nuclear Power Station (the facility) has been substantially completed in conformity with the appl!cation, as amended, the Provisional Construction Permit No. CPPR-36, the provisions of the Atomic Energy Act of 1954, as amended (the Act), and the rules and regulations of the Commission as set forth in Title 10 of the Code of FederalRegulations (CFR)

Chapter 1,: and

b. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; and

c. There is reasonable assurance (1) that the activities authorized by this renewed operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the rules and regulations of the Commission; and

d. Entergy Nuclear Vermont Yankee, LLC is financially qualified and Entergy Nuclear Operations, Inc. is technically and financially qualified to engage in the activities authorized by this renewed operating license, in accordance with the rules and regulations of the Commission; and

e. Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

have satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements" of the Commission's regulations; and

f. The issuance of this renewed operating license will not be inimical to the common defense and security or to the health and safety of the public; and

g. After weighing the environmental, economic, technical and other benefits of the facility against environmental costs and considering available alternatives, the issuance of this renewed operating license (subject to the conditions for Renewed Operating License No. DPR-28

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders

0. The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

P. The information in the UFSAR supplement, submitted pursuant to 10 CFR 54.21(d), as revised during the license renewal application process, is henceforth part of the UFSAR which will be updated in accordance with 10 CFR 50.71(e). As such, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. may make changes to the programs and activities described in the supplement provided Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

Q. Appendix A of Supplement 2 to NUREG-1907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station,"

dated March 2011 (excluding Commitment No. 37, which is superseded by the steam dryer license condition), and the UFSAR supplement submitted pursuant to 10 CFR 54.21(d), as revised on February 4, 2011, describes certain future programs and activities to be completed before the period of extended operation. Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. shall complete these activities no later than March 21, 2012 and shall notify the NRC in writing when implementation of these activities is complete.

R. Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

shall implement the most recent staff-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance Program (ISP) as the method to demonstrate compliance with the requirements of 10 CFR Part 50, Appendix H. Any changes to the BWRVIP ISP capsule withdrawal schedule must be submitted for NRC staff review and approval. Any changes to the BWRVIP ISP capsule withdrawal schedule which affects the time of withdrawal of any surveillance capsules must be incorporated into the licensing basis. If any surveillance capsules are removed without the intent to test them, these capsules must be stored in a manner which maintains them in a condition which would support re-insertion into the reactor pressure vessel, if necessary.

Renewed Facility Operating License No. DPR-28 Amendment No.

BVY 12-015 Docket 50-271 Attachment 4 Vermont Yankee Nuclear Power Station Proposed Change 300 List of Regulatory Commitments

BVY 12-015 / Attachment 4 / page 1 of 1 List of Regulatory Commitments 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.

TYPE (Check one) SCHEDULED ONE-TIME CONTINUING COMPLETION DATE COMMITMENT ACTION COMPLIANCE (If Required)

Vermont Yankee will include the list of x Next scheduled License Renewal Commitments identified in update required by Appendix A of Supplement 2 to NUREG- 10 CFR 50.71 (e) 1907 (excluding Commitment No. 37 and including Commitment No. 55) in the UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21.