ML13247A029
| ML13247A029 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/28/2013 |
| From: | Wamser C Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051 | |
| Download: ML13247A029 (8) | |
Text
En t le rgy Entergy Nuclear Operations, Inc.
320 Governor Hunt Road Vernon, Vermont 05354 Tel: (802) 257-7711 Christopher J. Wamser Site Vice President BVY 13-075 August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
REFERENCES:
Vermont Yankee's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28
- 1. NRC Order Number EA-1 2-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (ML12054A679)
- 2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012 (ML12221A339)
- 3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-1 2-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012 (ML12240A307)
- 4. Vermont Yankee's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), BVY 12-073, dated October 26, 2012 (ML12306A086)
- 5. Vermont Yankee's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),
BVY 13-015, dated February 28, 2013 (ML13064A301)
Dear Sir or Madam:
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to all power reactor licensees. Reference 1 was immediately effective and directs Entergy Nuclear Operations, Inc. (ENO) to install reliable spent fuel pool level instrumentation at the Vermont Yankee Nuclear Power Station. Specific requirements are outlined in Attachment 2 of Reference 1.
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BVY 13-075 Page 2 of 3 Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 1 also requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions. Reference 4 provided the Vermont Yankee initial status report regarding spent fuel pool instrumentation. Reference 5 provided the Vermont Yankee overall integrated plan for reliable spent fuel pool instrumentation.
The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.
On August 27, 2013, Entergy announced that it had decided to permanently cease power operations of Vermont Yankee Nuclear Power Station in the fourth quarter 2014.
This status report was prepared prior to that decision. Entergy is evaluating its responses to Reference 1 in order to determine the appropriate actions in alignment with the decision to permanently cease operations. Entergy requests the NRC terminate its review of the responses related to the Order until Entergy can submit changes to its integrated plan to reflect the impact of this decision.
Should you have any questions regarding this submittal, please contact Mr. Coley Chappell at (802) 451-3374.
This letter contains no new regulatory commitments.
I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2013.
Sincerely, CJW / JTM
Attachment:
Vermont Yankee's (VY) First Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation cc list: next page
BVY 13-075 Page 3 of 3 cc:
Mr. William M. Dean Regional Administrator, Region 1 U. S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Vermont Yankee U. S. Nuclear Regulatory Commission ATTN: Richard Guzman OWFN - Mail Stop 08C2 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Jessica A. Kratchman OWFN - Mail Stop 9 D2 11555 Rockville Pike Rockville, MD 20852-2378 Mr. Christopher Recchia, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601
BVY 13-075 Attachment Vermont Yankee's (VY) First Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation 1 Introduction VY developed an overall integrated plan (Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool level instrumentation (SFPI), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the overall integrated plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2 Milestone Accomplishments The following milestone(s) have been completed since the development of the overall integrated plan (Reference 1), and are current as of July 31, 2013.
Although not part of the original milestone schedule, NRC requests for additional information (RAIs) were received June 20, 2013 (Reference 3) and responded to on July 19, 2013 (Reference 4). The response to the RAIs was added to the milestone schedule. Any additional RAI responses will be provided in future six-month status reports as necessary. The status of individual RAIs is indicated in the VY RAI Status table below. The addition of this milestone and target completion date does not impact the Order implementation date.
3 Milestone Schedule Status The following provides an update to milestone schedule to support the overall integrated plan.
This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed.
Revised Target Milestone Target Completion Activity Status Completion DateDate Reliable SFPI Installed Fall 2014 Refueling In Progress Outage NRC RAIs (Reference 3)
See VY RAI July 19, 2013 Status Table Below Page 1 of 5
VY's First Six Month Status Report for the Implementation of SFPI 4 Changes to Compliance Method The current Level 2 elevation is now 342'-5" El. The previous Level 2 elevation was 10 ft. above the top of the spent fuel rack at 331'-3" El. This differs from the conceptual design VY initially submitted to the NRC. The Level 2 elevation is raised to 342'-5" to account for non-special nuclear material stored above 331'-3" in the Spent Fuel Pool.
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation VY expects to comply with the order implementation date and no relief/relaxation is required at this time.
6 Open Items from Overall Integrated Plan and Draft Safety Evaluation None.
7 Potential Draft Safety Evaluation Impacts The NRC has not yet issued a draft safety evaluation; therefore, there are no potential impacts to the draft safety evaluation identified at this time.
8 References The following references support the updates to the overall integrated plan described in this attachment.
- 1. Vermont Yankee's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), BVY 13-015, dated February 28, 2013. (ML13064A301)
- 2. NRC Order Number EA-1 2-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012. (ML12054A679)
- 3. Vermont Yankee Nuclear Power Station - Request for Additional Information RE: Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051) (TAC NO.
MF0780), dated June 20, 2013. (ML13165A279)
- 4. Response to Request for Additional Information Re: Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), BVY 13-065, dated July 19, 2013.
Page 2 of 5
VY's First Six Month Status Report for the Implementation of SFPI VY RAI Status RAI Nme RAI Topic RAI Status Number For level 1, specify how the identified location RAI-1.a represents the higher of the two points described in Open NEI 12-02 guidance for this level.
Provide sketch depicting the elevation view of the proposed typical mounting arrangements for RAI-1.b portions of the instrument channel consisting of Completed permanent measurement channel equipment.
Indicate datum values and points related to Level 1,2, and 3.
RAI-1.c Describe how level 2 will be adjusted to other than Completed the elevation provided in section 2.
RAI-1.d Provide drawings G-191173 Sht 1, Rev 40 and Completed 5920-12795, Rev 0.
Provide a clearly labeled sketch or marked-up plant drawing of the plan-view of the SFP area, depicting
RAI-2
the SFP inside dimensions, the planned locations/placement of primary and back-up SFP Open level sensors and the proposed routing of the cables.
Provide Design Criteria that will be used to RAI-3.a estimate total loading on mounting devices. Also Completed describe methodology used to estimate total loading.
Provide description of the manner in which the RAI-3.b level sensor will be attached to the refueling roof or Completed other support structures.
Provide a description of the manner by which the RAI-3.c mechanical connections will attach the level Completed instrument to permanent SFP structures.
Address how other hardware stored in the SFP will RAI-3.d not create adverse interaction with the fixed Completed instrument location(s).
Provide a description of the method(s) intended to RAI-4.a be applied to demonstrate of the permanently Completed installed equipment.
Provide a description of the testing and/or analyses that will be conducted to provide assurance that RAI-4.b the equipment will perform reliably under the worst-Completed case credible design basis loading at the location where the equipment will be mounted.
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VY's First Six Month Status Report for the Implementation of SFPI Provide a description of the specific method or RAI-4.c combination of methods that will confirm the reliability of the permanently installed equipment Completed following seismic conditions.
Provide a description of how the two channels of the proposed level measurement system meet this RAI-5.a requirement so that the potential for a common Completed cause event to adversely affect both channels is minimized to the extent practicable.
Provide further information on how each level RAI-5.b measurement system will be designed and Completed installed to address independence.
Provide the design criteria that will be applied to size the battery in a manner that ensures, with
RAI-6
margin, that the channel will be available to run Completed reliably and continuously following the onset of the DBD event.
RAI-7.a Provide an estimate of the instrument channel Completed RA___-7.a__
accuracy performance.
Provide a description of the methodology RAI-7.b determining the maximum allowed deviation from Completed the instrument channel design.
Provide a description of the capability and RAI-8.a provisions the proposed level sensing equipment Completed will have to enable periodic testing and calibration.
Provide a description of how such testing and RAI-8.b calibration will enable the conduct of regular Completed channel checks.
Provide a description of how functional checks will RAI-8.c be performed and the frequency of which they will Completed be conducted.
Provide a description of what preventative maintenance tasks are required to be performed Completed RAI-8.d during normal operation and the planned maximum surveillance interval.
Provide a description of the standards, guidelines, and/or criteria that will be utilized to develop
RAI-9
procedures for inspection, maintenance, repair, Completed operation, abnormal response, and administrative controls.
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VY's First Six Month Status Report for the Implementation of SFPI Provide further information describing the maintenance and testing program the licensee will RAI-10.a establish and implement to ensure that regular Completed testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.
Provide a description of how the guidance in NEI RAI-1O.b 12-02 Section 4.3 regarding compensatory actions Completed for one or both non-functioning channels will be addressed.
Provide a description of the compensatory actions RAI-10.c to be taken in the event that one of the instrument Completed channels cannot be restored to functional status within 90 days.
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