BVY 14-019, Notification of Revised Regulatory Commitments Associated with Request for Information Per 10 CFR50.54(f) Regarding Recommendations 2.1, 2.3, & 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident ...

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Notification of Revised Regulatory Commitments Associated with Request for Information Per 10 CFR50.54(f) Regarding Recommendations 2.1, 2.3, & 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident ...
ML14079A025
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 03/12/2014
From: Wamser C
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 14-019
Download: ML14079A025 (12)
v • d • e


Text

Entergy Nuclear Operations, Inc.

Vermont Yankee vEntergy 320 Governor Hunt Road Vernon, Vermont 05354 Tel: (802) 257-7711 Christopher J. Wamser Site Vice President BVY 14-019 March 12, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Notification of Revised Regulatory Commitments Associated With Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCES:

1. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ML12053A340)
2. Notification Of Permanent Cessation Of Power Operations, BVY 13-079, dated September 23, 2013 (ML13273A204)

Dear Sir or Madam:

On March 12, 2012, the NRC issued "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" (Information Request) to all NRC power reactor licensees and holders of construction permits in active or deferred status (Reference 1).

By letter dated September 23, 2013, Entergy Nuclear Operations, Inc. (Entergy) notified the NRC that it had decided to permanently cease power operations of Vermont Yankee Nuclear Power Station (VY) at the end of the current operating cycle (Reference 2).

Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1), the 10 CFR Part 50 license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2). The recommendations in Reference 1 are intended for operating units. As Reference 1 indicates, "Operating power reactor licensees under 10 CFR Part 50 are required to respond to all of the information requests." The list of licenses to which Reference 1 applies does not include permanently shutdown units. Upon docketing of AWu 0

BVY 14-019 / Page 2 of 3 the certifications pursuant to 10 CFR 50.82(a)(1), Entergy will no longer be an operating power reactor licensee; therefore the requests and commitments associated with Reference 1 will no longer be applicable to VY. In the interim, Entergy has revised some of the commitment dates associated with Reference 1. Attachment 1 contains a listing and discussion of the revised commitments.

This letter contains revised regulatory commitments as listed in Attachment 2.

Should you have any questions regarding this submittal, please contact Mr. Coley Chappell at (802) 451-3374.

I declare under penalty of perjury that the foregoing is true and correct; executed on March 12, 2014.

Sincerely,

[CJW/JTM]

Attachment:

1. Revised Regulatory Commitments and Plans Associated With March 12, 2012 Information Request
2. List of Revised Regulatory Commitments cc: Mr. William M. Dean Regional Administrator, Region 1 U. S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Vermont Yankee U. S. Nuclear Regulatory Commission ATTN: Douglas V. Pickett OWFN - Mail Stop 08G9A 11555 Rockville Pike Rockville, MD 20852-2378

BVY 14-019 / Page 3 of 3 U. S. Nuclear Regulatory Commission ATTN: Jessica A. Kratchman OWFN - Mail Stop 9 D2 11555 Rockville Pike Rockville, MD 20852-2378 Mr. Christopher Recchia, Commissioner Vermont Department of Public service 112 State Street, Drawer 20 Montpelier, VT 05620-2601

BVY 14-019 Docket 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Revised Regulatory Commitments and Plans Associated With March 12, 2012 Information Request

BVY 14-019 / Attachment 1 / Page 1 of 5 Revised Regulatory Commitments and Plans Associated With March 12, 2012 Information Request On March 12, 2012, the NRC issued "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dai-ichi Accident" (Information Request) to all NRC power reactor licensees and holders of construction permits in active or deferred status (Reference 1). The 50.54(f) letter requests licensees to perform seismic and flooding walkdowns and hazard re-evaluations, and perform emergency preparedness communication and staffing evaluations for prolonged loss of power events.

By letter dated September 23, 2013, Entergy Nuclear Operations, Inc. (Entergy) notified the NRC that it had decided to permanently cease power operations of Vermont Yankee Nuclear Power Station (VY) at the end of the current operating cycle (Reference 2).

Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1), the 10 CFR Part 50 license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

The recommendations in Reference 1 are intended for operating units. As Reference 1 indicates, "Operating power reactor licensees under 10 CFR Part 50 are required to respond to all of the information requests." The list of licenses to which Reference 1 applies does not include permanently shutdown units. Upon docketing of the certifications pursuant to 10 CFR 50.82(a)(1), Entergy will no longer be an operating power reactor licensee; therefore the requests and commitments associated with Reference 1 will no longer be applicable to VY. While it is Entergy's intent to docket the required certifications at the end of the current operating cycle, the commitments associated with Reference 1 remain in effect until that action is complete. Entergy has evaluated the activities otherwise expected to occur in 2014 and prior to docketing of the required certifications and determined that changes in the due dates for the commitments will not have an adverse affect on safety. The results of that evaluation are discussed in this attachment.

A. SEISMIC WALKDOWNS AND HAZARDS REEVALUATIONS (2.1, 2.3)

Entergy has responded to Reference 1 information requests in References 5 and 6.

Recommendation 2.1 of Reference 1 requests further information which Entergy committed in Reference 4 to provide in 2014. Following the guidance in Reference 3, Entergy is revising the following seismic regulatory commitment dates to June 30, 2015:

  • Submit the remaining screening, prioritization and implementation details (SPID)

Section 4 information (7 months after endorsement of Updated Ground Motion Model) (due Mar 31, 2014)

  • Submit Expedited Seismic Evaluation Process (ESEP) reports (9 months after the SPID Section 4 information submittals) (due Dec 31, 2014)

BVY 14-019 / Attachment 1 / Page 2 of 5 These commitments support actions that will not occur until after VY plans to have permanently ceased operations and permanently removed the fuel from the reactor vessel. The impacted regulatory commitment dates do not impact Entergy's compliance with the current licensing basis for VY. Therefore, the changes in the due dates for the commitments will not have an adverse effect on safety.

B. FLOODING WALKDOWNS AND HAZARDS REEVALUATIONS (2.1, 2.3)

Entergy has responded to Reference 1 information requests in References 7, 8 and 9.

No revisions to the flooding regulatory commitment dates are being made at this time.

C. EMERGENCY PREPAREDNESS (9.3) [10 CFR 50.54(f) related]

Entergy responded to Reference 1 information requests in References 10, 11 and

12. In Reference 10 Entergy made the following regulatory commitment, to be implemented prior to start-up from Refueling Outage 31 Fall 2014:

"Enhancements identified within the assessment (Attachment 1) will be further developed as implementation progresses. Alternate approaches will be utilized if prudent (e.g., alternate/new technology, improved capability, cost savings, etc.).

These enhancement commitments are subject to change as a result of Diverse and Flexible Coping Strategies (FLEX) developments, advances in technology, and progress in the manner of addressing the need for these enhancements."

The regulatory commitment is credited in the NRC Staff Assessment (Reference 13).

Although Entergy is not revising the regulatory commitment at this time, it should be noted that the commitment date of "prior to start-up from Refueling Outage 31 Fall 2014," is not expected to occur due to the decision to permanently cease operations at VY (Reference 2). The following target activity dates included in References 10 and 11 (some of which were specifically discussed in Reference 13) are being revised to be consistent with the regulatory commitment date of "prior to start-up from Refueling Outage 31 Fall 2014:"

  • Complete engineering for identified enhancements (e.g., power supplies and structural upgrades) (due 4/11/2014).
  • Procure additional portable equipment (e.g., radios, satellite phones, batteries, generators), as required (due 7/11/2014)
  • Complete installation of engineered upgrades (due 11/5/2014)
  • Finalize storage location(s) of portable generators (due 7/11/2014)
  • Finalize training needs (due 4/11/2014)
  • Implement required training (due 11/5/2014)
  • Revise procedures to incorporate new equipment (due 11/5/2014)

Entergy committed in Reference 14 to perform Phase 2 staffing assessment activities related to NTTF Recommendation 4.2. In Reference 16 Entergy identified that it was evaluating its responses to the Mitigating Strategies Order (Reference 18; NTTF

BVY 14-019 / Attachment 1 / Page 3 of 5 Recommendation 4.2) in order to determine the appropriate actions in alignment with the decision to permanently cease operations. Reference 17 modified the final implementation date for VY implementation of the Mitigating Strategies order to December 31, 2016.

Following the guidance in Reference 3, Entergy is revising the following emergency preparedness regulatory commitment dates from Reference 14 to June 30, 2015:

  • Provide onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2 (due June 11,2014)
  • Conduct the onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2 (due May 11, 2014)
  • Provide a schedule of the time needed to implement changes associated with the Phase 2 staffing assessment (due June 11, 2014)

" Identify changes that have been made or will be made to the emergency plan regarding the on-shift or augmented staffing changes associated with the Phase 2 staffing assessment (due June 11, 2014)

Reference 11 and 12 provided interim actions taken to enhance existing communications systems until the communications assessment and the resulting actions are complete. The communication enhancement actions targeted in Reference 12 for 2013 have been completed. The staffing assessment commitments are related to actions which will not occur until after VY plans to have permanently ceased operations and permanently removed the fuel from the reactor vessel. The impacted regulatory commitment dates do not impact Entergy's compliance with the current licensing basis for VY. Once permanently defueled, potential spent fuel pool beyond design basis accident scenarios do not require the enhanced communication and staffing that may be necessary for the reactor-centered events the 50.54(f) letter addresses. Therefore, the changes in the due dates for the commitments will not have an adverse effect on safety.

D. EMERGENCY PREPAREDNESS (9.3) [Other]

Entergy committed in Reference 19 to implement a new computer program at VY that has the capability to perform a multi-source dose consequence analysis. Following the guidance in Reference 3, Entergy is revising the following emergency preparedness regulatory commitment date from Reference 19 to June 30, 2015:

  • Entergy Nuclear Operations, Inc. plans to implement a new computer program at VY that has the capability to perform a multi-source dose consequence analysis (due date December 31, 2014)

Following permanent removal of the fuel from the reactor vessel, VY will no longer have the possibility of emergency scenarios with multiple release points. Therefore, the change in the due date for the commitment will not have an adverse effect on safety.

BVY 14-019 / Attachment 1 / Page 4 of 5 E.

REFERENCES:

1. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ML12053A340)
2. Letter, Entergy to NRC, Notification Of Permanent Cessation Of Power Operations, BVY 13-079, dated September 23, 2013 (ML13273A204)
3. NEI 99-04, Guidelines for Managing NRC Commitment Changes
4. Letter, Entergy to NRC, Entergy's Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, BVY 13-037, dated April 29, 2013
5. Letter, Entergy to NRC, Entergy's Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendations 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - 1.5 Year Response for CEUS Sites, BVY 13-081, dated September 12, 2013
6. Letter, Entergy to NRC, Seismic Walkdown Report - Entergy's Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendations 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, BVY 12-080, dated November 27, 2012
7. Letter, Entergy to NRC, Flooding Walkdown Report - Entergy's Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendations 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, BVY 12-081, dated November 21, 2012
8. Letter, Entergy to NRC, Required Response 2 for NTTF Recommendation 2.1:

Flooding - Hazard Reevaluation Report, BVY 13-021, dated March 12, 2013

9. Letter, Entergy to NRC, Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendations 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, BVY 13-077, dated August 30, 2013
10. Letter, Entergy to NRC, Entergy's Response to the March 12, 2012, Information Request, Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 for Completing Emergency Communication Assessments, BVY 12-075, dated October 31, 2012

BVY 14-019 / Attachment 1 / Page 5 of 5

11. Letter, Entergy to NRC, Entergy Response to NRC Technical Issues for Resolution Regarding Licensee Communication Submittals Associated with Near-Term Task Force Recommendation 9.3 (TAC No. ME7951), BVY 13-014, dated February 21, 2013
12. Letter, Entergy to NRC, Entergy's 90-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments, BVY 12-037, dated June 11, 2012
13. Letter, Entergy to NRC, Vermont Yankee Nuclear Power Station - Staff Assessment in Response to Recommendation 9.3 of the Near-Term Task Force Related to the Fukushima Dai-ichi Nuclear Power Plant Accident, dated May 21, 2013
14. Letter, Entergy to NRC, Entergy's 60-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments, BVY 12-032, dated May 11, 2012
15. Letter, NRC to Entergy, Vermont Yankee Nuclear Power Station - Staff Assessment in Response to Recommendation 9.3 of the Near-Term Task Force Related to the Fukushima Dai-ichi Nuclear Power Plant Accident, dated May 21, 2013
16. Letter, Entergy to NRC, Vermont Yankee's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events (Order Number EA-12-049), BVY 13-076, dated August 28, 2013
17. Letter, Entergy to NRC, Vermont Yankee's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), BVY 14-014, dated February 26, 2014
18. NRC Order EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012
19. Letter, Entergy to NRC, Commitment for Implementation of Multi-source Dose Assessment Capability, BVY 13-059, dated June 26, 2013

BVY 14-019 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station List of Revised Regulatory Commitments

BVY 14-019 / Attachment 2 / Page 1 of 2 List of Revised 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.

Original Original Source of Original Revised Commitment Commitment Commitment Commitment Date Date ENO intends to respond On the schedule Entergy's Response to SPID Information -

to Enclosure 1 of NRC specified in the NRC Request for June 30, 2015 letter, Request for April 9, 2013, NEI Information Pursuant Information Pursuantto Letter: [see below] to 10 CFR 50.54(f) ESEP report - June Title 10 of the Code of Regarding the 30, 2015 FederalRegulations Plants submit the Seismic Aspects of 50.54(f) Regarding remaining SPID Recommendations 2.1 Recommendations 2.1, Section 4 of the Near-Term 2.3, and 9.3, of the Near- information (7 Task Force Review of Term Task Force Review months after Insights from the of Insights from the endorsement of Fukushima Dai-ichi Fukushima Dai-ichi Updated Ground Accident, BVY 13-037, Accident, dated March Motion Model) (due dated April 29, 2013 12, 2012, by following Mar 31, 2014) the approach described in Nuclear Energy Plants submit Institute letter to NRC, Expedited Seismic ProposedPath Forward Evaluation Process for NTTF (ESEP) reports (9 Recommendation 2. 1: months after the Seismic Reevaluations, SPID Section 4 dated April 9, 2013. information submittals) (due Dec 31, 2014)

Provide onsite and June 11, 2014 Entergy's 60-Day June 30, 2015 augmented staffing Response to the assessment considering March 12, 2012, functions related to Information Request, NTTF Recommendation Action Plan for 4.2 Completing Conduct the onsite and May 11, 2014 Emergency June 30, 2015 augmented staffing Communication and assessment considering Staffing Assessments, functions related to BVY 12-032, dated NTTF Recommendation May 11, 2012 4.2 Provide a schedule of June 11,2014 June 30, 2015 the time needed to implement changes associated with the Phase 2 staffing assessment.

BVY 14-019 / Attachment 2 / Page 2 of 2 Identify changes that June 11,2014 June 30, 2015 have been made or will be made to the emergency plan regarding the on-shift or augmented staffing changes associated with the Phase 2 staffing assessment.

Entergy Nuclear December 31, 2014 Commitment for June 30, 2015 Operations, Inc. plans to Implementation of implement a new Multi-source Dose computer program at VY Assessment that has the capability to Capability, BVY 13-perform a multi-source 059, dated June 26, dose consequence 2013 analysis

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