ML052620055
| ML052620055 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/22/2005 |
| From: | Holden C NRC/NRR/DLPM/LPD1 |
| To: | Kansler M Entergy Nuclear Operations |
| Ennis R, NRR/DLPM, 415-1420 | |
| References | |
| TAC MB8714 | |
| Download: ML052620055 (5) | |
Text
September 22, 2005 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION - INSTRUMENTATION TECHNICAL SPECIFICATIONS (TAC NO. MB8714)
Dear Mr. Kansler:
By letter dated April 25, 2003, as supplemented on May 21, 2003, June 11, 2003, and June 30, 2005, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. submitted a proposed license amendment to the Nuclear Regulatory Commission (NRC or Commission) for the Vermont Yankee Nuclear Power Station (VYNPS). The proposed changes would have revised the VYNPS Technical Specifications (TSs) related to instrumentation to correct deficiencies in the TSs, reduce operator work-arounds, improve and correct confusing and ambiguous TS requirements, and allow for process enhancements. In a telephone conference call on August 30, 2005, we informed members of your staff that we would not be able to approve all of the requested changes as described in your application and its supplements.
You also informed us that you would not, at this time, re-submit your application by withdrawing the changes that were not sufficiently justified. As a result of this conference call and subsequent discussions with the Director of the Division of Licensing Project Management, Mr. Ledyard B. Marsh, you withdrew your amendment request by letter dated September 7, 2005. Members of your staff also stated that you intend to submit a revised amendment application in the future that would address the concerns raised by the NRC Staff. The purpose of this letter is to inform you of some of the problems we encountered with your amendment request.
Your proposed amendment would have revised portions of the VYNPS TSs, specifically, Sections 2.1, Limiting Safety System Setting; 3.1, Reactor Protection System; 3.2, Protective Instrument System; associated Surveillance Requirements; and other TSs with similar requirements as these instrumentation TS sections. You also stated that the Improved Standard Technical Specifications (ISTS), NUREG 1433, Revision 2, Standard Technical Specifications, General Electric Plants, BWR [boiling-water reactor]/4", dated April 30, 2001, was used as the guidance for developing your proposed changes. As stated in the preface to NUREG 1433, Licensees adopting portions of the ISTS to existing technical specifications should adopt all related requirements, as applicable, to achieve a high degree of standardization and consistency.
The NRC staff found in your application that when adopting portions of the ISTS, you did not in many instances adopt all related requirements including ISTS formatting and related surveillance requirements of the ISTS. This was specifically true for the changes that were noted as L Technical Changes or Less Restrictive. These are changes where requirements are relaxed, relocated, eliminated, or new flexibility is provided. For these less restrictive changes, the NRC staff expects that each change must have its own stand-alone justification, that is usually plant specific, regardless of whether it matches the corresponding ISTS requirement. The justification must support the conclusion that the revised requirement affords an adequate level of safety.
M. Kansler Simply referencing the ISTS is not sufficient for justification of less restrictive changes to your TSs. There is no safety evaluation or model plant that supports the ISTS. Each licensee must ensure that the selected ISTS will work and can be justified for their particular plant application.
If you decide to re-submit your application at a later date, you may want to meet with our technical staff to discuss your amendment request. You may also want to discuss with the NRC staff a complete conversion to the ISTS. The Commission continues to place the highest priority on requests for complete conversions to the ISTS. If you have any questions, please contact Mr. Richard B. Ennis, your NRC project manager, at (301) 415-1420.
Sincerely,
/RA by Richard J. Laufer for/
Cornelius F. Holden, Director Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271 cc: See next page
M. Kansler Simply referencing the ISTS is not sufficient for justification of less restrictive changes to your TSs. There is no safety evaluation or model plant that supports the ISTS. Each licensee must ensure that the selected ISTS will work and can be justified for their particular plant application.
If you decide to re-submit your application at a later date, you may want to meet with our technical staff to discuss your amendment request. You may also want to discuss with the NRC staff a complete conversion to the ISTS. The Commission continues to place the highest priority on requests for complete conversions to the ISTS. If you have any questions, please contact Mr. Richard B. Ennis, your NRC project manager, at (301) 415-1420.
Sincerely,
/RA by Richard J. Laufer for/
Cornelius F. Holden, Director Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271 cc: See next page DISTRIBUTION:
PUBLIC JBongarra, IROB-B PClifford, SRXB-A DLPM DPR PDI-2 Reading RLobel, SPSB-C RClark, IROB-A CHolden JLazevnick, EEIB-B STurk, OGC DRoberts SRhow, EEIB-A VBucci, OIG REnnis JCai, IROB-B VGoel, EEIB-B CAnderson, RGN-1 CRaynor ACRS ACCESSION NO.: ML052620055 OFFICE PDI-2/PM PDI-2/PM PDI-2/LA IROB-A/SC PDI-2/SC PDI-2/SC NAME JShea REnnis CRaynor TBoyce DRoberts RLaufer for CHolden DATE 9/20/05 9/20/05 9/20/05 9/22/05 9/22/05 9/22/05 OFFICIAL RECORD COPY
Vermont Yankee Nuclear Power Station cc:
Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. David R. Lewis Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.
Washington, DC 20037-1128 Ms. Christine S. Salembier, Commissioner Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601 Mr. Michael H. Dworkin, Chairman Public Service Board State of Vermont 112 State Street Montpelier, VT 05620-2701 Chairman, Board of Selectmen Town of Vernon P.O. Box 116 Vernon, VT 05354-0116 Operating Experience Coordinator Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 G. Dana Bisbee, Esq.
Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 Ms. Deborah B. Katz Box 83 Shelburne Falls, MA 01370 Ms. Carla A. White, RRPT, CHP Radiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070 Mr. James M. DeVincentis Manager, Licensing Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Resident Inspector Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission P.O. Box 176 Vernon, VT 05354 Director, Massachusetts Emergency Management Agency ATTN: James Muckerheide 400 Worcester Rd.
Framingham, MA 01702-5399 Jonathan M. Block, Esq.
Main Street P.O. Box 566 Putney, VT 05346-0566 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213
Vermont Yankee Nuclear Power Station cc:
Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Danny L. Pace Vice President, Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Brian OGrady Vice President, Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Jay K. Thayer Site Vice President Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. Kenneth L. Graesser 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Ronald Toole 1282 Valley of Lakes Box R-10 Hazelton, PA 18202 Ms. Stacey M. Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue New Orleans, LA 70113 Mr. Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, ME 04556 Mr. James P. Matteau Executive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301 Mr. William K. Sherman Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, VT 05620-2601