ML041810433

Vermont Yankee, 06/29/04 E-mail - Compliance with NRC Regulatory Compliance

ML041810433
Person / Time
Site:	Vermont Yankee
Issue date:	06/29/2004
From:	Richard Ennis NRC/NRR/DLPM/LPD1
To:	Blanch P - No Known Affiliation
Ennis R, NRR/DLPM, 415-1420
References
TAC MC0761
Download: ML041810433 (7)

Text

From: Rick Ennis To: Paul Blanch Date: 6/29/04 7:36AM

Subject:

RE: Compliance with NRC Regulatory compliance

Paul, As discussed in Section F.1 of the Appendix F of the VY UFSAR, the plant was designed and constructed based on the proposed (draft) GDC. Changes have been made to the facility over the life of the plant that may have invoked the final GDC.

I assume you are mostly concerned about the licensing bases related to the proposed EPU amendment. The specific regulatory requirements the NRC uses to review EPU amendments are shown in the template Safety Evaluation (SE) in Review Standard RS-001. For BWRs, the SE template is in RS-001, Section 3.2. The template is based on the final GDC in 10 CFR 50, Appendix A. However, since VY is a pre-GDC plant, we asked Entergy to revise the template to reflect the VY licensing bases. The revised template was provided in Attachment 4 to Entergys Supplement 4 dated 1/31/04 (ADAMS Accession No. ML040360118). You may also may want to look at Attachment 2 to Entergys Supplement 1, dated 10/1/03 (ADAMS Accession No. ML032810447) which provided a AEC/GDC matrix. The draft GDC can be found on pages 13 to 17 of ADAMS Accession No. ML003674711.

If your question regarding the VY licensing bases was intended to pertain to more than just the EPU, the licensing bases, for any plant, are located in many documents (e.g., FSAR, Tech Specs, license, orders, QA program, emergency plan, security plan, etc.). A good reference document for this issue is NRR Office instruction LIC-100, "Control of Licensing Bases for Operating Reactors," which is in ADAMS at Accession No. ML033530249.

Thanks, Rick 301-415-1420

>>> "Paul Blanch" <pmblanch@comcast.net> 06/25/04 08:54PM >>>

Rick:

Thanks for the response. I reviewed Appendix F of the USAR Revision 17 and I assume that VY is in compliance with the 70 draft GDCs unless specifically stated that they are taking exception to these criteria. Is this a proper assumption?

Could you please provide me with a copy of these 70 criteria which VY states it complies with, and is apparently a part of the plants current licensing bases?

Where can I find a copy of the current licensing bases?

---

Original Message-----

From: Rick Ennis [1]

Sent: Friday, June 25, 2004 3:37 PM

To: pmblanch@comcast.net Cc: shadis@ime.net; Anthony McMurtray; Allen Howe; Brian Holian; Cornelius Holden; Cliff Anderson; David Pelton; Donna Skay; Tad Marsh; Mohammed Shuaibi; Robert Kuntz; Stuart Richards; William Ruland; arniegundersen@sailchamplain.net; dlochbaum@ucsusa.org

Subject:

Re: Compliance with NRC Regulatory compliance

Paul, A response has not yet been sent to the 12/8/03 letter from Bill Sherman. Heres a response to your other questions:

1) Did the VY SAR originally or at any time address compliance with regulatory criteria as required by RG 1.70 Chapter 1?

The VY UFSAR, Appendix F, addresses conformance to the 70 AEC General Design Criteria (proposed GDCs).

2) Where can I locate the latest requirements for the content of an SAR?

(RG 1.70, NUREG 0800 or Harold Dentons letter to the Commission dated July 23, 1980)?

The requirements for the content of an SAR are contained in 10 CFR 50.34. RG 1.70 and NUREG 0800 do not contain requirements.

RGs are issued to describe and make available to the public such information as methods acceptable to the staff for implementing specific parts of the NRCs regulations, techniques used by the staff in evaluating specific problems or postulated accidents, and guidance to applicants. RGs are not substitutes for regulations, and compliance with RGs is not required. RG 1.70, Revision 3, provides guidance on the format and content of SARs.

The Standard Review Plan (SRP), NUREG-0800, provides guidance to the NRR staff reviewers in performing its safety reviews. Compliance with the SRP is not required.

3) How can I locate a copy of the original SAR Chapter 1 for VY?

I was unable to find it. Suggest you contact the PDR at 301-415-4737.

4) Why have Sections 1 and 2 seemed to have vanished from NUREG 0800?

The sections still exist, however, Im not sure why they arent shown on the NRC webpage at:

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0800/

I asked the Project Manager who has been working on an office instruction related to the SRP process (Rob Kuntz) to look into this issue.

5) Where can I find the requirements for the SAR?

As stated above, the requirements for the content of an SAR are contained in 10 CFR 50.34. The requirements for SAR updates are contained in 10 CFR 50.71.

6) What design basis documentation and regulations will be used by the Engineering Assessment team?

The guidance for the team is contained in Temporary Instruction 2515/158 which is available in ADAMS at Accession No. ML041730177.

Thanks, Rick 301-415-1420

>>> "Paul Blanch" <pmblanch@comcast.net> 06/15/04 12:58PM >>>

Rick:

First of all do you know if a response has been sent to Bill Shermans letter of December 8, 2003?

The second questions relates to the compliance with regulatory requirements.

I noted the update to the Prairie Island SAR dated 1999. In Section 1 of this update, Prairie Island specifically addresses (Section 1.5) all 70 GDCs in effect at the time of the issuance of the license. Because VY and PI were licensed about the same time I would expect to find the same type of information contained within the VY SAR. This is addressed in Section 1.5 of the PI SAR.

I reviewed the most recent VY Amendment 18 to the VY SAR and found no comparable section addressing compliance with regulatory criteria.

I also note that the requirements published in RG 1.70 required that compliance with GDCs and Regulatory Guides be addressed.

The following is from From Reg Guide 1.70 obtained from ADAMS.

TABLE OF CONTENTS Page INTRODUCTION i Chapter 1 INTRODUCTION AND GENERAL DESCRIPTION OF PLANT 1.1 Introduction 1-1 1.2 General Plant Description 1-1 1.3 Comparison Tables 1-2

1.3.1 Comparisons with Similar Facility Designs1-2 1.3.2 Comparison of Final and Preliminary Information... 1-2 1.4 Identification of Agent~s and Contractors 1-2 1.5 Requirements for Further Technical Information 1-2 1.6 Material Incorporated by Reference 1.7 Drawings and Other Detailed Information 1-4

• 1.7.1 Electrical, Instrumentation, and Control Drawings 1-4 1.7.2 Piping and Instrumentation Diagrams 1-4 1.7.3 Other Detailed Information 1-4 1.8 Conformance to NRC Regulatory Guides 1-4 1.9 Standard Designs 1-4 1.9.1 Interfaces 1.9.2Exceptions ~l~44 VYs SAR does not seem to have a comparable section. 1.8 is titled summary of radiation effects.

I realize that RG 1.70 has been superceded by NUREG 0800 but when I access this in ADAMS, Sections 1 and 2 of this document are missing for some reason.

Would you be so kind as to provide answers to the following:

Did the VY SAR originally or at any time address compliance with regulatory criteria as required by RG 1.70 Chapter 1?

Where can I locate the latest requirements for the content of an SAR? (RG 1.70, NUREG 0800 or Harold Dentons letter to the Commission dated July 23, 1980)

How can I locate a copy of the original SAR Chapter 1 for VY?

Why have Sections 1 and 2 seemed to have vanished from NUREG 0800?

Where can I find the requirements for the SAR?

What design basis documentation and regulations will be used by the Engineering Assessment team?

A response to these questions would be greatly appreciated before the NRCs meeting with the State of Vermont to be held on June 28, 2004.

CC: Allen Howe; Anthony McMurtray; arniegundersen@sailchamplain.net; Brian Holian; Cliff Anderson; Cornelius Holden; David Pelton; dlochbaum@ucsusa.org; Donna Skay; shadis@ime.net; Stuart Richards; Tad Marsh; William Ruland

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RE: Compliance with NRC Regulatory compliance Creation Date: 6/29/04 7:36AM From: Rick Ennis Created By: RXE@nrc.gov Recipients Action Date & Time owf4_po.OWFN_DO Delivered 06/29/04 07:36AM WHR CC (William Ruland) comcast.net Transferred 06/29/04 07:37AM pmblanch (Paul Blanch) ime.net Transferred 06/29/04 07:37AM shadis CC (shadis@ime.net) nrc.gov kp1_po.KP_DO Delivered 06/29/04 07:37AM BEH CC (Brian Holian)

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