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Category:Letter type:BVY
MONTHYEARBVY 24-005, Report of Investigation Pursuant to 10 CFR 20, Appendix G2024-01-30030 January 2024 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 24-004, Report of Investigation Pursuant to 10 CFR 20, Appendix G2024-01-23023 January 2024 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 24-003, Nuclear Onsite Property Damage Insurance2024-01-0404 January 2024 Nuclear Onsite Property Damage Insurance BVY 24-001, Pre-Notice of Disbursement from Decommissioning Trust2024-01-0202 January 2024 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-030, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-12-20020 December 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-029, Proof of Financial Protection2023-12-12012 December 2023 Proof of Financial Protection BVY 23-028, Pre-Notice of Disbursement from Decommissioning Trust2023-11-28028 November 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-027, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-11-21021 November 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-026, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-11-13013 November 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-025, Pre-Notice of Disbursement from Decommissioning Trust2023-11-0202 November 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-023, License Amendment Request Addition of License Condition 3.K, License Termination Plan; Proposed Change No. 3172023-10-10010 October 2023 License Amendment Request Addition of License Condition 3.K, License Termination Plan; Proposed Change No. 317 BVY 23-022, Pre-Notice of Disbursement from Decommissioning Trust2023-08-23023 August 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-020, Pre-Notice of Disbursement from Decommissioning Trust2023-08-0202 August 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-021, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-08-0202 August 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-019, Update to 2022 Radiological Effluent Release Report2023-07-24024 July 2023 Update to 2022 Radiological Effluent Release Report BVY 23-018, Update to Nuclear Onsite Property Damage Insurance2023-07-12012 July 2023 Update to Nuclear Onsite Property Damage Insurance BVY 23-017, Pre-Notice of Disbursement from Decommissioning Trust2023-06-29029 June 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-016, 10 CFR 72.48 Report2023-06-0505 June 2023 10 CFR 72.48 Report BVY 23-015, Report of Investigation Pursuant to 1O CFR 20, Appendix G2023-06-0505 June 2023 Report of Investigation Pursuant to 1O CFR 20, Appendix G BVY 23-014, Pre-Notice of Disbursement from Decommissioning Trust2023-05-31031 May 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-013, 2022 Radiological Environmental Operating Report2023-05-10010 May 2023 2022 Radiological Environmental Operating Report BVY 23-011, 2022 Radiological Effluent Release Report2023-05-10010 May 2023 2022 Radiological Effluent Release Report BVY 23-012, Pre-Notice of Disbursement from Decommissioning Trust2023-05-0202 May 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-009, 2022 Individual Monitoring NRC Form 5 Report2023-04-24024 April 2023 2022 Individual Monitoring NRC Form 5 Report BVY 23-008, Pre-Notice of Disbursement from Decommissioning Trust2023-04-0606 April 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-006, Status of Decommissioning and Spent Fuel Management Fund for Year Ending 20222023-03-29029 March 2023 Status of Decommissioning and Spent Fuel Management Fund for Year Ending 2022 BVY 23-007, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-03-29029 March 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-005, Nuclear Onsite Property Damage Insurance2023-03-13013 March 2023 Nuclear Onsite Property Damage Insurance BVY 23-004, Pre-Notice of Disbursement from Decommissioning Trust2023-03-0202 March 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-003, Pre-Notice of Disbursement from Decommissioning Trust2023-01-31031 January 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-030, Documentary Evidence of Performance Bond2022-12-30030 December 2022 Documentary Evidence of Performance Bond BVY 22-028, Re Proof of Financial Protection2022-11-28028 November 2022 Re Proof of Financial Protection BVY 22-027, Bvy 22-027; Pre-Notice of Disbursement from Decommissioning Trust for Vermont Yankee Nuclear Power Station2022-11-11011 November 2022 Bvy 22-027; Pre-Notice of Disbursement from Decommissioning Trust for Vermont Yankee Nuclear Power Station BVY 22-026, Pre-Notice of Disbursement from Decommissioning Trust2022-10-31031 October 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-025, Pre-Notice of Disbursement from Decommissioning Trust2022-10-0404 October 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-023, Pre-Notice of Disbursement from Decommissioning Trust2022-09-0101 September 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-022, Report of Investigation Pursuant to 10 CFR 20, Appendix G2022-08-22022 August 2022 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 22-021, Report of Investigation Pursuant to 10 CFR 20, Appendix G2022-08-16016 August 2022 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 22-020, Pre-Notice of Disbursement from Decommissioning Trust2022-08-0101 August 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-019, Pre-Notice of Disbursement from Decommissioning Trust2022-07-0606 July 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-013, Notification of Revised Decommissioning Cost Estimate2022-06-17017 June 2022 Notification of Revised Decommissioning Cost Estimate BVY 22-018, Pre-Notice of Disbursement from Decommissioning Trust2022-06-0808 June 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-015, 2021 Radiological Environmental Operating Report2022-05-0505 May 2022 2021 Radiological Environmental Operating Report BVY 22-017, Pre-Notice of Disbursement from Decommissioning Trust2022-05-0505 May 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-014, 2021 Radiological Effluent Release Report2022-04-28028 April 2022 2021 Radiological Effluent Release Report BVY 22-012, Biennial Report for Quality Assurance Program Manual Changes Under 10 CFR 50.54(a)(3), 10 CFR 71.106, and 10 CFR 72.140(d)2022-04-12012 April 2022 Biennial Report for Quality Assurance Program Manual Changes Under 10 CFR 50.54(a)(3), 10 CFR 71.106, and 10 CFR 72.140(d) BVY 22-011, Pre-Notice of Disbursement from Decommissioning Trust2022-04-0404 April 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-009, Status of Decommissioning and Spent Fuel Management Fund for the Year Ending 20212022-03-23023 March 2022 Status of Decommissioning and Spent Fuel Management Fund for the Year Ending 2021 BVY 22-008, Pre-Notice of Disbursement from Decommissioning Trust2022-02-24024 February 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-005, ISFSI Decommissioning Funding Plan2022-02-24024 February 2022 ISFSI Decommissioning Funding Plan 2024-01-04
[Table view] Category:License-Application for Facility Operating License (Amend/Renewal) DKT 50
MONTHYEARBVY 23-023, License Amendment Request Addition of License Condition 3.K, License Termination Plan; Proposed Change No. 3172023-10-10010 October 2023 License Amendment Request Addition of License Condition 3.K, License Termination Plan; Proposed Change No. 317 3F1120-02, and Crystal River Nuclear Plant - Application for Order Approving Indirect Transfers of Control of Licenses in Connection with Internal Corporate Reorganization2020-11-19019 November 2020 and Crystal River Nuclear Plant - Application for Order Approving Indirect Transfers of Control of Licenses in Connection with Internal Corporate Reorganization BVY 17-004, Technical Specifications Proposed Change No. 313: Revision to License and Permanently Defueled Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool2017-07-20020 July 2017 Technical Specifications Proposed Change No. 313: Revision to License and Permanently Defueled Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool BVY 17-022, License Amendment Request - Cyber Security Plan License Condition Removal Proposed Change No. 3162017-07-13013 July 2017 License Amendment Request - Cyber Security Plan License Condition Removal Proposed Change No. 316 BVY 17-005, Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment and Notification of Amendment to Decommissioning Trust Agreement2017-02-0909 February 2017 Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment and Notification of Amendment to Decommissioning Trust Agreement BVY 15-040, License Amendment Request - Revised Cyber Security Plan Implementation Schedule - Proposed Change No. 3112015-06-24024 June 2015 License Amendment Request - Revised Cyber Security Plan Implementation Schedule - Proposed Change No. 311 BVY 14-083, Technical Specifications Proposed Change No. 307, Revision to Technical Specification Administrative Controls for Permanently Defueled Condition - Supplement 32014-12-0505 December 2014 Technical Specifications Proposed Change No. 307, Revision to Technical Specification Administrative Controls for Permanently Defueled Condition - Supplement 3 BVY 14-062, Proposed Change No. 310 - Deletion of Renewed Facility Operating License Conditions Related to Decommissioning Trust Provisions2014-09-0404 September 2014 Proposed Change No. 310 - Deletion of Renewed Facility Operating License Conditions Related to Decommissioning Trust Provisions BVY 13-109, Cyber Security Plan Implementation Schedule, Proposed Change No. 3082013-12-19019 December 2013 Cyber Security Plan Implementation Schedule, Proposed Change No. 308 BVY 13-097, Proposed Change 306, Areva Document No. 32-9145461-001, Vynpp - Re-analysis of Ast/Fha Radiological Consequences with Open Containment2013-11-14014 November 2013 Proposed Change 306, Areva Document No. 32-9145461-001, Vynpp - Re-analysis of Ast/Fha Radiological Consequences with Open Containment ML13323A5182013-11-14014 November 2013 Technical Specifications Proposed Change No. 306 Eliminate Certain ESF Requirements During Movement of Irradiated Fuel BVY 12-084, License Amendment Request; Changes to 10CFR50.63 Licensing Basis2012-12-21021 December 2012 License Amendment Request; Changes to 10CFR50.63 Licensing Basis BVY 12-085, Technical Specifications Proposed Change No. 302 Inoperable Control Rods2012-12-17017 December 2012 Technical Specifications Proposed Change No. 302 Inoperable Control Rods BVY 12-018, Technical Specifications Proposed Change No. 299 Recirculation System Discharge Bypass Valve Change2012-04-17017 April 2012 Technical Specifications Proposed Change No. 299 Recirculation System Discharge Bypass Valve Change BVY 12-016, License Amendment Request to Revise License Renewal Commitments2012-03-12012 March 2012 License Amendment Request to Revise License Renewal Commitments BVY 12-006, Technical Specifications Proposed Change No. 298, Rod Worth Minimizer Bypass Allowance2012-02-0101 February 2012 Technical Specifications Proposed Change No. 298, Rod Worth Minimizer Bypass Allowance BVY 12-005, Technical Specifications Proposed Change No. 297, Suppression Chamber-Drywell Leak Rate Test Surveillance Frequency Change2012-02-0101 February 2012 Technical Specifications Proposed Change No. 297, Suppression Chamber-Drywell Leak Rate Test Surveillance Frequency Change BVY 11-085, Proposed Change No. 296, Steam Dryer License Condition Change2011-12-22022 December 2011 Proposed Change No. 296, Steam Dryer License Condition Change BVY 11-069, Technical Specifications Proposed Change No. 295 Proposed Emergency License Amendment for Single Loop Operation2011-09-29029 September 2011 Technical Specifications Proposed Change No. 295 Proposed Emergency License Amendment for Single Loop Operation BVY 10-059, Technical Specifications Proposed Change No. 294, Elimination of Provisions Allowing HPCI and RCIC Suctions to Be Aligned to the Suppression Pool2010-11-0808 November 2010 Technical Specifications Proposed Change No. 294, Elimination of Provisions Allowing HPCI and RCIC Suctions to Be Aligned to the Suppression Pool BVY 10-045, Technical Specifications Proposed Change No. 289 Suppression Chamber-Drywell Vacuum Breakers and Differential Pressure2010-08-19019 August 2010 Technical Specifications Proposed Change No. 289 Suppression Chamber-Drywell Vacuum Breakers and Differential Pressure BVY 10-036, Technical Specifications Proposed Change No. 292, License Amendment Withdrawal and Request - Cyber Security Plan2010-07-16016 July 2010 Technical Specifications Proposed Change No. 292, License Amendment Withdrawal and Request - Cyber Security Plan BVY 09-068, Technical Specifications Proposed Change No. 288 Scram Discharge Volume Vent and Drain Valves2009-12-0303 December 2009 Technical Specifications Proposed Change No. 288 Scram Discharge Volume Vent and Drain Valves BVY 09-063, Technical Specification Proposed Change No. 287 Safety Limit Minimum Critical Power Ratio Change2009-10-27027 October 2009 Technical Specification Proposed Change No. 287 Safety Limit Minimum Critical Power Ratio Change BVY 09-052, Technical Specifications Proposed Change No. 284 Change to Requirements for Inoperable Containment Isolation Valves2009-09-16016 September 2009 Technical Specifications Proposed Change No. 284 Change to Requirements for Inoperable Containment Isolation Valves BVY 09-051, Technical Specifications Proposed Change No. 285 Revision of High Radiation Area Controls2009-08-26026 August 2009 Technical Specifications Proposed Change No. 285 Revision of High Radiation Area Controls ML0912001622009-05-31031 May 2009 Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station Supplement 1 BVY 09-029, Technical Specifications Proposed Change No. 283 Change to Requirements for Performing 10 CFR 50, Appendix J, Type a Test2009-05-0505 May 2009 Technical Specifications Proposed Change No. 283 Change to Requirements for Performing 10 CFR 50, Appendix J, Type a Test BVY 09-012, Submittal of Proposed License Amendment for Technical Specifications No. 282, Revision of Drywell Vacuum Breaker Surveillance Requirements2009-02-24024 February 2009 Submittal of Proposed License Amendment for Technical Specifications No. 282, Revision of Drywell Vacuum Breaker Surveillance Requirements BVY 08-079, Technical Specifications Proposed Change No. 280, Supplement 1 Relocation of Reactor Building Crane Technical Specifications2008-10-31031 October 2008 Technical Specifications Proposed Change No. 280, Supplement 1 Relocation of Reactor Building Crane Technical Specifications BVY 08-055, Technical Specifications Proposed Change No. 277, License Amendment Request Application for Licensee Name Changes2008-09-30030 September 2008 Technical Specifications Proposed Change No. 277, License Amendment Request Application for Licensee Name Changes BVY 08-059, Technical Specifications Proposed Change No. 280 Relocation of Reactor Building Crane Technical Specifications2008-09-22022 September 2008 Technical Specifications Proposed Change No. 280 Relocation of Reactor Building Crane Technical Specifications BVY 08-052, Technical Specifications Proposed Change No. 278, Changes to Main Steam Isolation Valve Surveillance Requirements2008-09-22022 September 2008 Technical Specifications Proposed Change No. 278, Changes to Main Steam Isolation Valve Surveillance Requirements BVY 08-053, Technical Specifications Proposed Change No. 279 Sale or Lease of Property within the Exclusion Boundary2008-09-0404 September 2008 Technical Specifications Proposed Change No. 279 Sale or Lease of Property within the Exclusion Boundary BVY 08-001, Technical Specifications Proposed Change No. 273 Instrumentation Technical Specifications2008-02-12012 February 2008 Technical Specifications Proposed Change No. 273 Instrumentation Technical Specifications ML0806602032008-02-12012 February 2008 Vermont Yankee, Technical Specifications Proposed Change No. 273, Instrumentation Technical Specifications BVY 08-007, Technical Specification Proposed Change No. 276 Revision to TS Sections 3.3/4.3 for Control Rod System2008-02-0606 February 2008 Technical Specification Proposed Change No. 276 Revision to TS Sections 3.3/4.3 for Control Rod System ML0804202202008-02-0505 February 2008 Vermont Yankee - License Renewal Application, Amendment 35 ML0736502282007-12-11011 December 2007 (PA-LR) VY Response to RAI 4.3.3-2 BVY 07-056, Technical Specification Proposed Change No. 274, Changes to Technical Specifications for Emergency Diesel Generator Fuel Oil and Reactor Building Crane Surveillance Requirements2007-10-18018 October 2007 Technical Specification Proposed Change No. 274, Changes to Technical Specifications for Emergency Diesel Generator Fuel Oil and Reactor Building Crane Surveillance Requirements BVY 07-063, Technical Specifications Proposed Change No. 275 Primary Containment Oxygen Concentration and Drywell-to-Suppression Chamber Differential Pressure Limits2007-10-18018 October 2007 Technical Specifications Proposed Change No. 275 Primary Containment Oxygen Concentration and Drywell-to-Suppression Chamber Differential Pressure Limits BVY 07-018, License Renewal Application, Amendment 262007-03-23023 March 2007 License Renewal Application, Amendment 26 ML0702402042007-01-10010 January 2007 Email: (PA-LR) Other Word File ML0701105042007-01-0404 January 2007 Vermont Yankee - License Renewal Application, Amendment 23 ML0634201782006-12-0404 December 2006 2006/12/04-Vermont Yankee Nuclear Power Station, License Renewal Application, Amendment 22, Clarification of Aging Management Program and Environmental Report Items ML0634004532006-11-0909 November 2006 2006/11/09-E-Mail: (NPA-PD-LR) VYNPS License Renewal Application Am. 20, Vermont Yankee BVY 06-097, 2006/10/31-Vermont Yankee License Renewal Application, Amendment 192006-10-31031 October 2006 2006/10/31-Vermont Yankee License Renewal Application, Amendment 19 ML0627801222006-10-12012 October 2006 Summary of a Telephone Conference Call Held on September 19, 2006, Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc ML0626800342006-09-19019 September 2006 2006/09/19-Vermont Yankee License Renewal Application, Amendment 13 ML0625504392006-09-0505 September 2006 License Renewal Application, Amendment 12 2023-10-10
[Table view] |
Text
Entergy Nuclear Operations, Inc.
Vermont Yankee P.O. Box 1250 Governor Hunt Road SEntergy Vernon, VT 05354 Tel 802 257 7711 October 31, 2008 BVY 08-079 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Reference:
(a) Letter, VYNPS to USNRC, "Technical Specification Proposed Change No. 280 Relocation of Reactor Building Crane Technical Specifications," BVY 08-059, dated September 22, 2008
Subject:
Vermont Yankee Nuclear Power Station Docket No. 50-271, License No. DPR-28 Technical Specifications Proposed Change No. 280, Supplement 1 Relocation of Reactor Building Crane Technical Specifications
Dear Sir or Madam,
In Reference (a), Entergy Nuclear Operations, Inc. (Entergy) proposed to amend Operating License DPR-28 for Vermont Yankee Nuclear Power Station (VY) to relocate Technical Specification requirements to the Technical Requirements Manual. During the acceptance review, the NRC staff requested additional information related to how the change satisfied the requirements of 10CFR50.36(d)(2)(ii)(B) Criterion 2 and on the proposed administrative controls. provides the requested information.
This supplement to the original license amendment request does not change the scope or conclusions in the original application, nor does it change the Entergy's determination of no significant hazards consideration There are no new regulatory commitments made in this letter.
If you have any questions on this transmittal, please contact Mr. David Mannai at (802) 452-3304.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on October 31, 2008.
Sincerely, Micael J. C Site Vice President Vermont Yankee Nuclear Power Station Attachment cc listing (next page) 1 ._
BVY 08-079 / page 2 of 2 cc: Mr. Samuel J. Collins (w/o attachments)
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 P.O. Box 157 Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601
.4 BVY 08-079 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Proposed Change 280 Supplement 1 Response to Request for Additional Information
BVY 08-079 / Attachment 1 / Page 1 of 2 Vermont Yankee Nuclear Power Station Proposed Change 280, Supplement 1 Response to Request for Add itional Information Requested Information:
Provide additional justification for how the proposed change satisfies the requirements of 10CFR50.36(d)(2)(ii)(B) Criterion 2 and why the proposed administrative controls are adequate.
Response
10CFR50.36(a)(2)(ii)(B) Criterion 2, requires Technical Specifications (TS) for "A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier."
Accidents that can result in the release of radioactive materials to the containment, when the drywell is open, are documented in.the Vermont Yankee Updated Final Safety Analysis (UFSAR). The UFSAR states that greatest potential for release occurs when the drywell head and reactor head have been removed. The UFSAR states that the only accident that could result in the release of significant quantities of fission products is the accidental dropping of a fuel bundle onto the top of the core.
The design basis Fuel Handling Accident (FHA) is described in UFSAR Section 14.6.4. The FHA assumes an irradiated fuel assembly is dropped onto the reactor core from the maximum height allowed by the fuel handling equipment. The analysis assumes that the entire amount of potential energy is available for appliation to the fuel assemblies involved in the accident.
Also, none of the energy associated with the dropped fuel assembly is absorbed by the fuel material. The FHA is assumed to bound other credible fuel handling accidents.
The fuel handling equipment used to transport irradiated fuel from the fuel pool to the reactor core is the refueling platform and associated components (e.g., mast, grapple, controls). The refueling platform is independent of the reactor building crane. The reactor building crane is not used to move irradiated fuel from the fuel pool to the reactor core.
The TS related to reactor building !crane operability (TS 3.12.G and TS 4.12.G) were established by License Amendment' No. 29 to Facility Operating License No. DPR-28 (Reference 1). License Amendment No. 29 established requirements to ensure that the reactor building crane would be inspected and tested before use to lift a spent fuel cask and established requirements that would prohibit the movement of a spent fuel cask over irradiated fuel assemblies within the spent fuel pool.
BVY 08-079 / Attachment 1 / Page 2 of 2 Entergy has also made commitments related to the control of heavy loads. The reactor building crane was identified as within the scope of NUREG-0612 and a number of improvements were implemented. For example, the reactor building crane was modified in 1976 by replacing the original trolley with one that has a dual load path on the main hoist when used for cask handling operations. The design of the new trolley satisfies the criteria for dual load path or "single-failure-proof" cranes.
In addition to the hardware improvements implemented to satisfy commitments made to NUREG 0612 a number of administrative improvements were committed to. Examples include:
" Maintenance procedures were revised to define safe load paths for major loads.
- Procedures were revised to include training and qualification requirements for crane operators, sling selection criteria, crane inspections prior to use and supervisory oversight of heavy lift operations.
" Special lifting devices were identified and obtained and periodic non-destructive examination was scheduled to monitor the condition of lifting devices.
Entergy's position is that the combination of hardware improvements and crane safety design features, commitments to establish safe load paths and the other commitments discussed above provide a level of assurance such that TS level administrative controls are not necessary to assure safety.
Entergy's proposal to relocate the current crane operability and surveillance requirements to the Technical Requirements Manual (TRM) is acceptable for the following reasons:
- Commitments made in response to NUREG 0612 are managed in accordance with NEI 99-04 "Guidelines for Managing NRC Commitment Changes", Revision 0, dated July 1999. This ensures a safety review of commitment changes is performed and the NRC notified of changes to regulatory commitments as required.
- Additionally, the TRM is "included by reference" in the UFSAR. As such changes to the TRM are evaluated in accordance with 10CFR50.59. This provides requirements that future changes to the operability and surveillance requirements will be evaluated to ensure that they do not create the possibility of an accident that is different than or that has greater consequences that the design basis FHA without prior NRC approval.
Changes made under 10CFR50.59 are reported to the NRC as required.
" Finally, the industry and NRC have worked to establish the expected scope and content of the TS to ensure compliance with 10CFR 50.36 requirements. For a General Electric Boiling Water Reactor (BWR), NUREG-1433 Revision 3, establishes the current expectations. Reactor Building Crane operability and surveillance requirements are not within the scope of NUREG-1433.
Reference:
- 1. Letter, USNRC to YAEC, dated January 28, 1977