ML101440239
| ML101440239 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 05/28/2010 |
| From: | Giitter J Division of Operating Reactor Licensing |
| To: | Vanderdoes P - No Known Affiliation |
| Kim J, NRR/ADRO/DORL/LPL1-1, 415-4125 | |
| Shared Package | |
| ML101440229 | List: |
| References | |
| G20100295, LTR-10-0216, SECY-2010-0265, TAC ME3908 | |
| Download: ML101440239 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 28,2010 Mr. Peter Van der Does P. O. Box 523 Brattleboro, VT 05302
Dear Mr. Van der Does:
On behalf of the Nuclear Regulatory Commission (NRC), I am responding to your letter dated April 22, 2010. In your letter, you questioned whether three safety upgrades related to license renewal at the Vermont Yankee Nuclear Power Station (Vermont Yankee) and referenced in NUREG-1437, Supplement 30, Appendix G, were implemented by Entergy, the company that owns Vermont Yankee. You also expressed concerns about NRC oversight of maintenance at Vermont Yankee.
Regarding your question concerning the three severe accident mitigation alternatives (SAMAs) referenced in NUREG-1437, Supplement 30, Appendix G, Entergy has not implemented those three SAMAs at Vermont Yankee.
The Commission's regulations for Title 10 of the Code of Federal Regulations (10 CFR) Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions" require that license renewal applicants consider alternatives to mitigate severe accidents if the NRC staff has not previously evaluated SAMAs for the applicant's plant in an environmental impact statement (EIS) or related supplement or in an environmental assessment.
The NRC staff reviewed Entergy's analysis and concluded that the Entergy's evaluation of SAMAs was performed correctly. The NRC reviewed areas in which risk can be further reduced in a cost-beneficial manner through the implementation of all or a subset of the identified, potentially cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff agrees that further evaluation of these SAMAs by Entergy is warranted. However, these SAMAs do not relate to adequately managing the effects of aging during the period of extended operation. Therefore, they need not be implemented as part of license renewal pursuant to the Commission's regulations for 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." Entergy has not agreed to implement the three SAMAs you refer to and the NRC staff is not requiring implementation.
The only changes that must be implemented by the applicant as part of the license renewal process are those that are identified as being cost-beneficial, that provide a significant reduction in total risk, and that are related to adequately managing the effects of aging during the period of extended operation. However, the SAMA evaluation may identify some plant enhancements that appear to be cost-beneficial but that are not related to adequately managing the effects of aging during the period of extended operation. Such enhancements are considered as current operating issues and are further evaluated as changes that might appropriately be made under the current operating license rather than as a license renewal issue.
P. Van der Does
- 2 You also expressed a concern relative to whether Entergy is doing an adequate job of reporting their scheduled maintenance to the NRC, since your observation is that Entergy seems to be lax in performing their scheduled maintenance. We rely on NRC's Reactor Oversight Process (ROP) to determine if nuclear power reactors, including Vermont Yankee, are operating safely and in accordance with applicable regulations. NRC onsite resident and regional inspectors conduct inspections of maintenance activities at each operating unit in accordance with the ROP. These inspections include document reviews as you referenced. In accordance with inspection procedures, onsite inspectors also directly observe maintenance activities. Guidance for completing inspection samples of maintenance and other activities is provided in a number of inspection procedures that include, but are not limited to, lVIaintenance Effectiveness, Maintenance Risk Assessments and Emergent Work Control, Plant Modifications, Post Maintenance Testing, Refueling and Other Outage Activities, and Surveillance Testing.
The ROP guidance for completing inspection samples of maintenance activities ensures that all risk-significant maintenance activities are inspected on a sampling basis. Our onsite resident inspectors evaluate the effectiveness of maintenance. If NRC inspectors identify a significant discrepancy, Entergy must resolve the discrepancy. NRC inspectors will then verify that the discrepancy has been resolved.
Entergy also evaluates the risk associated with removing equipment from service for maintenance. Inspection samples of maintenance risk assessments are conducted each calendar quarter. During this type of inspection sample, onsite inspectors verify the performance of risk assessments, the adequacy of risk assessments for maintenance-related activities, and the identification and resolution of problems.
Entergy may make modifications to risk significant structures, systems, and components (SSCs). Modifications to systems ranked high in risk are periodically inspected as they occur.
These inspection samples verify that modifications have not affected the safety functions of important safety systems, degraded the capability of risk significant SSCs, or placed the plant in an unsafe condition. Each quarter, onsite resident inspectors also complete inspection samples of post-maintenance testing activities and surveillance testing of risk significant SSCs. These inspection samples verify that procedures and test activities are adequate, and these inspection samples verify that these SSCs are capable of performing their intended safety functions.
The NRC assessment of maintenance activities continues during refueling and other outages.
These inspection samples evaluate licensee activities during high risk evolutions, verify that licensees consider risk in developing outage schedules, and assess whether licensees are adhering to their operating license and technical specification requirements that ensure defense-in-depth.
Maintenance issues identified by NRC inspectors are assessed for safety significance and are documented in accordance with the ROP in publicly available inspection reports. Through these ROP inspections, the NRC has reasonable assurance that maintenance activities conducted by Entergy at Vermont Yankee meet NRC requirements. Vermont Yankee is currently in the License Response column of the NRC's ROP Action Matrix, indicating performance at a level requiring no additional !\\IRC oversight beyond the baseline inspections.
P. Van der Does
- 3 If you have further questions related to Vermont Yankee, please contact James Kim at 301-415 4125. Thank you for your interest in these matters.
Sincerely, Joseph G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271 cc: Distribution via Listserv
P. Van der Does
- 3 If you have further questions related to Vermont Yankee, please contact James Kim at 301-415 4125. Thank you for your interest in these matters.
Sincerely,
/raJ (RNelson for)
Joseph G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271 cc: Distribution via Listserv DISTRIBUTION: G20100295/EDATS: SECY-201 0-0265/LTR-10-0216 PUBLIC LPL1-1 R/F RidsNrrDorl Resource RidsNrrDorlLpl1-1 Resource RidsNrrPMVermontYankee Resource RidsNrrLASLittle Resource RidsAcrsAcnw_MailCenter Resource RidsNrrMailCenter Resource RidsOgcRp Resource RidsEdoMailCenter Resource RidsOpaMail Resource RidsRgn1 MailCenter Resource RidsNrrOd Resource RidsSecyMailCenter Resource ADAMS Accession Nos.: Package/ML101440229; Incoming/ML101330422; Response: ML101440239
- Yia email OFFICE LPL1-1/PM LPL1/1/LA R1/BC DLR/BC LPL 1-1/BC DORLID NAME
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