ML081820047
| ML081820047 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/15/2008 |
| From: | James Kim Plant Licensing Branch 1 |
| To: | Entergy Nuclear Operations |
| kim J, NRR/ADRO/DORL, 415-4125 | |
| References | |
| GL-08-001, TAC MD7891 | |
| Download: ML081820047 (9) | |
Text
September 15, 2008 Vice President, Operations Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION - RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NO. MD7891)
Dear Sir or Madam:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated April 10, 2008, Entergy Nuclear Operations, Inc. (the licensee) submitted a 3-month response to GL 2008-01 for Vermont Yankee Nuclear Power Station. The NRC staffs assessment of the responses for Vermont Yankee is contained in the enclosure to this letter.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for Vermont Yankee, with the exception of the clarifications and associated requests discussed in the enclosure, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the enclosure.
If you have any questions regarding this letter, please feel free to contact James Kim at (301) 415-4125.
Sincerely,
/RA/
James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
As stated cc w/encl: See next page
If you have any questions regarding this letter, please feel free to contact James Kim at (301) 415-4125.
Sincerely,
/RA/
James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
As stated cc w/encl: See next page Distribution:
PUBLIC RidsNrrDorlLpl1-1 RidsNrrPMJKim RidsOGCMailCenter LPL1-1 Reading File RidsNrrLASLittle RidsAcrsAcnw&mMailCenter RidsNrrDorlDpr RidsRgn1MailCenter JWermeil ADAMS Accession Number: ML081820047 OFFICE LPLI-1:PM LPLI-1:LA PGCB:BC DSS/DD LPLI-1/BC NAME JKim SLittle MMurphy JWermeil MKowal DATE 9/5/2008 9/11/2008 9/15/2008 9/15/2008 9/15/08 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 Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W.
Washington, DC 20037-1128 Mr. David O=Brien, Commissioner Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601 Mr. James Volz, 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 P.O. Box 250 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. Carla A. White, RRPT, CHP Radiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070 Ms. Charlene D. Faison Manager, Licensing Entery Nuclear Operations 440 Hamilton Avenue White Plains, NY 10601 Resident Inspector Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission P.O. Box 176 Vernon, VT 05354 Massachusetts Emergency Management Agency ATTN: John Giarrusso, Nuclear Preparedness Manager 400 Worcester Rd.
Framingham, MA 01702-5399 Jonathan M. Block, Esq.
Main Street P.O. Box 566 Putney, VT 05346-0566
Vermont Yankee Nuclear Power Station cc:
Senior Vice President Entergy Nuclear Operations, Inc.
P.O. Box 31955 Jackson, MS 39286-1995 Mr. Oscar Limpias Vice President, Engineering Entergy Nuclear Operations P.O. Box 31955 Jackson, MS 39286-1995 Mr. John A. Ventosa GM, Engineering Entergy Nuclear Operations 440 Hamilton Avenue White Plains, NY 10601 Mr. Joseph P. DeRoy VP, Operations Support Entergy Nuclear Operations, Inc.
P.O. Box 31955 Jackson, MS 39286-1995 Mr. John R. Dreyfuss Director, NSA Entergy Nuclear Operations Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354 Manager, Licensing Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354 Vice President Oversight Entergy Nuclear Operations, Inc.
P.O. Box 31955 Jackson, MS 39268-1995 Senior Manager, Nuclear Safety &
Licensing Entergy Nuclear Operations, Inc.
P.O. Box 31953 Jackson, MS 39286-1995 Senior Vice president and COO Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. James H. Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Garrett D. Edwards 814 Waverly Road Kennett Square, PA 19348
Vermont Yankee Nuclear Power Station cc:
Ms. Stacey M. Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue New Orleans, LA 70113 Mr. Norman L. Rademacher Director, NSA Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernont, VT 05354 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 Uldis Vanags State Nuclear Engineer Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601 Mr. Michael D. Lyster 5931 Barclay Lane Naples, FL 34110-7306
Enclosure NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271
- 1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
- 2. Licensees Proposed Alternative Course of Action By letter dated April 10, 2008, Entergy Nuclear Operations, Inc. (the licensee) submitted a 3-month response to GL 2008-01 for Vermont Yankee Nuclear Power Station. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because in-field inspection of some segments of piping within the GL subject systems, including the high-pressure coolant injection system, core spray system, and residual heat removal system (containment spray, low-pressure coolant injection and shutdown cooling modes cannot be completed for the following reasons: (1) portions of the GL subject systems are inaccessible; and, (2) portions of the GL subject systems are located in high dose areas during power operations.
The licensee also stated that the walkdowns and evaluations of the normally accessible portions of the GL subject systems will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete
the walkdowns of the inaccessible portions of the subject systems during the next refueling outage, which is presently scheduled for fall 2008. The licensees letter dated April 10, 2008, listed the following commitments for Vermont Yankee:
- 1. Submit an initial response to GL 2008-01 by October 11, 2008.
- 2. Submit a supplemental response to GL 2008-01 by January 30, 2009.
The licensee stated that the alternative course of action is acceptable based on the following:
- 1. Vermont Yankee will have the walkdowns and evaluations of the normally accessible portions of the systems completed by October 11, 2008.
- 2. Vermont Yankee will complete the walkdown of the inaccessible portions of the systems during the refueling outage (RFO) and Vermont Yankee 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.
Based on the above considerations, the licensee concluded that completing the walkdowns of the inaccessible portions of the subject systems outside of the requested 9-month timeframe is an acceptable alternative course of action.
- 3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable.
The NRC staff notes examples where the licensees 3-month submittal dated April 10, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, although the licensees 3-month submittal states that the walkdowns and evaluations of the normally accessible portions of the GL subject systems will be completed by October 11, 2008, the licensee does not state that this information will be included in the October 11, 2008, submittal. In addition, although the licensee commits to submit a supplemental response to GL 2008-01 by January 30, 2009, it is not clear whether it is possible that date could be greater than 90 days following startup from the Vermont Yankee fall 2008 RFO.
The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the Vermont Yankee fall 2008 RFO, provide all GL requested information to the NRC by October 11, 2008.
(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from the Vermont Yankee fall 2008 RFO but no later than January 30, 2009.
For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated April 10, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.