BVY 14-014, Vermont Yankee'S Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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Vermont Yankee'S Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
ML14064A195
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 02/26/2014
From: Wamser C
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 14-014, EA-12-049
Download: ML14064A195 (16)
v • d • e


Text

Entergy Nuclear Operations, Inc.

SEntergy Vermont Yankee 320 Governor Hunt Road Vernon, Vermont 05354 Tel: (802) 257-7711 Christopher J. Wamser Site Vice President BVY 14-014 February 26, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Vermont Yankee's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCES:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A736)
2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ML12229A174)
3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012 (ML12221A205)

4. Letter, Entergy to NRC, Vermont Yankee Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), BVY 12-071, dated October 26, 2012 (ML12306A084)
5. Letter, Entergy to NRC, Vermont Yankee Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), BVY 13-017, dated February 28, 2013 (ML13064A300)

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BVY 14-014 / Page 2 of 3

6. Letter, Entergy to NRC, Vermont Yankee's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), BVY 13-076, dated August 28, 2013 (ML13247A030)
7. Letter, Entergy to NRC, Notification Of Permanent Cessation of Power Operations, BVY 13-079, dated September 23, 2013 (ML13273A204)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an order (Reference 1) to Entergy. Reference 1 was immediately effective and directs Entergy to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1.

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 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the Vermont Yankee initial status report regarding mitigation strategies. Reference 5 provided the Vermont Yankee Overall Integrated Plan.

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 6 provided the first six-month status report.

Reference 7 notified the NRC that Entergy had decided to permanently cease power operations of Vermont Yankee Nuclear Power Station in the fourth quarter 2014. This status report reflects 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 power operations.

The purpose of this letter is to provide the second 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.

This letter contains no new regulatory commitments.

Should you have any questions regarding this submittal, please contact Mr. Coley Chappell at (802) 451-3374.

BVY 14-014 / Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct; executed on February 26, 2014.

Sincerely,

[CJW/JTM]

Attachment:

Vermont Yankee's Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (12 pages) 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: Douglas V. Pickett OWFN - Mail Stop 08G9A 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, VT 05620-2601

Attachment to BVY 14-014 Vermont Yankee's Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Vermont Yankee's Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction Entergy Nuclear Operations, Inc. (Entergy) developed an Overall Integrated Plan (OIP) for Vermont Yankee Nuclear Power Station (VY) (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the OIP, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

On September 23, 2013, Entergy notified the NRC that it had decided to permanently cease power operations of VY at the end of the current operating cycle (Reference 9). Entergy is evaluating its responses to Reference 2 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations at VY.

2. Milestone Accomplishments The following milestone(s) have been completed since July 31, 2013 and are current as of January 31, 2014.
  • First Six-Month Status Report - August 2013
3. Milestone Schedule Status The following provides an update to Attachment 2 of the OIP. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. Items that were changed are discussed below.

Order EA-12-049 (Reference 2) requires completion of full implementation no later than two (2) refueling cycles after submittal of the overall integrated plan, as required in Condition C.1 .a, or December 31, 2016, whichever comes first. Since VY will permanently cease power operations at the end of the current operating cycle, estimated to be 4th quarter 2014 (Reference 9), there will be no further refueling outages, startups, or refueling cycles. As a result, the full implementation date has been updated to reflect a December 31, 2016 implementation date.

Other milestone dates will be revised with submittal of a revised OIP in August 2014.

  • Purchase Equipment A new milestone target date will be provided with a revised OIP.

Page 1 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX

  • Validation Walk-throughs This new milestone target date reflects the revised Order implementation date.

e Perform Staffing Analysis The milestone target date has been revised to reflect the revised Order implementation date.

0 Submit Completion Report This new milestone target date reflects the revised Order implementation date.

Milestone Schedule Target Revised Milestone Completion Activity Status Target Date* Completion Date Submit 60 Day Status Report October 26, Complete 2012 Submit Overall Integrated February 28, Complete Implementation Plan 2013 Submit 6 Month Status Report August 28, 2013 Complete Develop Mods Fall 2013 In Progress** TBD**

Develop Strategies/Playbook with RRC Spring 2014 In Progress** TBD**

Purchase and Procure Equipment Spring 2014 In Progress** TBD**

Perform Staffing Analysis Summer 2014 Not Started August 2016 Issue FLEX Support Guidelines (FSGs) Summer 2014 Not Started TBD**

Submit 6 Month Status Report February 2014 Complete (with this submittal)

Create Maintenance Procedures Summer 2014 Not Started TBD**

Submit 6 Month Status Report including August 28, 2014 Not Started revised Overall Integrated Plan Procedure Changes Training Material Summer 2014 Not Started TBD**

Complete Develop Training Plan Spring 2014 Not Started TBD**

Implementation Outage Fall 2014 Not Started Not Applicable Page 2 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX Revised Target Target Milestone Completion Activity Status Completion Date* Date Fall 2014 Not Started December Implement Training 2016 Fall 2014 Not Started December Implement Mods 2016 Submit Completion Report February 2015 Not Started February 2017 NRC FLEX RAI's (Reference 3) July 17, 2013 See RAI Table TBD**

(Section 9)

Validation Walk-throughs Fall 2014 Not Started December 2016

- Target Completion Date is the last submitted date from either the OIP or previous six-month status report.

- These milestones are being reassessed and revised target completion dates will be determined and included with the revised 0IP.

4. Changes to Compliance Method On September 23, 2013, Entergy notified the NRC that it has decided to permanently cease power operations at VY at the end of the current operating cycle (Reference 9). Entergy is evaluating its responses to Reference 2 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations.

The FLEX strategies in the OIP rely on the current conceptual design of the reliable hardened vent (RHV) system that was developed in response to NRC Order EA-12-050 (Reference 5).

NRC Order EA-13-109 (Reference 6) dated June 6, 2013, rescinds the requirements of NRC Order EA-12-050. On November 22, 2013, Entergy requested rescission of NRC Order EA 109 upon docketing of the 10CFR50.82(a)(1) certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel (Reference 10).

Entergy plans to submit, in the August 2014 status update, a revised OIP reflecting the decommissioning plant conditions which will exist in December 2016.

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation VY expects to comply with the revised order implementation date and no relief/relaxation is required at this time. Relief/relaxation requests associated with the revised OIP are expected to be submitted in August 2014.

Page 3 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX

6. Open Items from Overall Integrated Plan and Draft Safety Evaluation Below are the open items from the integrated plan submitted on February 28, 2013.

Overall Integrated Plan Open Item Status OIP Section: General Integrated Plan Elements (PWR Started. The applicability of this

& BWR) - Seismic Hazard Assessment open item will be reassessed as Open Item: FLEX Storage locations have not been part of the revised OIP expected finalized, therefore, investigation of deployment routes to be submitted August 2014.

for possible impacts due to liquefaction have not been performed OIP Section: General Integrated Plan Elements (PWR Started. The applicability of this

& BWR) - Key Site assumptions to implement NEI open item will be reassessed as 12-06 strategies. part of the revised OIP expected Open Item: 1. Structure, content and details of the to be submitted August 2014.

Regional Response Center playbook will be determined.

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 OIP described in this attachment.
1. Vermont Yankee Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), BVY 13-017, dated February 28, 2013.
2. NRC Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.
3. NRC Request for Additional Information Regarding Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049) (TAC No. MF0779), dated June 17, 2013.

Page 4 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX

4. Response to Request for Additional Information Regarding Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049) - Vermont Yankee Nuclear Power Station, BVY 13-064, July 17, 2013.
5. NRC Order Number EA-12-050, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents, dated March 12, 2012.
6. NRC Order Number EA-13-109, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013.
7. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012.
8. Vermont Yankee's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), BVY 13-076, dated August 28, 2013 (ML13247A030)
9. Notification Of Permanent Cessation Of Power Operations, BVY 13-079, dated September 23, 2013 (ML13273A204)
10. Entergy's Request for Rescission of and Schedule Relief from Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109) , BVY 13-101, dated November 22, 2013 Page 5 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX

9. RAI Status Note: The below RAIs are included for completeness. They are associated with the original OIP submitted February 2013 (Reference 1). A revised OIP which considers the planned decommissioning state is expected to be submitted August 2014.

Vermont Yankee FLEX OIP RAI Status RAI Number RAI Topic Status 049-RAI-VY-1 Identify LARs needed for FLEX mods Open 049-RAI-VY-2 Early containment venting - provide Open technical and regulatory basis Generic Industry Concern 049-RAI-VY-3 Timeline/time constraints - provide basis to Complete justify there being no margin in timing of actions 049-RAI-VY-4 Identify equipment needed for the SBO Complete coping duration that is being credited for ELAP during Phase 2 049-RAI-VY-5 Provide justification for long term Open habitability at temperatures over 110 OF in MCR 049-RAI-VY-6 Actions to protect operators in hot areas Open 049-RAI-VY-7 Security measures needed when doors or Complete equipment hatches are propped open for ventilation purposes 049-RAI-VY-8 Batteries and load shedding: a. Provide Open load profile and actions and impacts due to load shed, b. Identify components that change state when de-energized for load shed, c. Identify breakers for load shed, d.

Identify whether special markings will be applied to breakers selected for load shed 049-RAI-VY-9 Provide documentation of battery duration Open and qualification Generic Industry Concern Page 6 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX RAI Number RAI Topic Status 049-RAI-VY-10 Provide basis that time constraint of Complete connecting Phase 2 DG can be met 049-RAI-VY-1 1 Describe how FLEX DG and EDG are Closed isolated to prevent simultaneous operation on bus 049-RAI-VY-12 Provide minimum DC voltage for operation Complete of elect equipment 049-RAI-VY-13 Justify how load shed can be complete at Open the same time ELAP is declared 049-RAI-VY-14 Seismic capability of EDG fuel oil storage Complete and day tanks 049-RAI-VY-15 Describe power requirements for HCVS Open valves and indication or instrumentation Generic Industry and how power will be supplied Concern Related to Order EA-13-109 049-RAI-VY-16 Battery room hydrogen accumulation and Complete venting 049-RAI-VY-17 Strategy for venting hydrogen from battery Open rooms 049-RAI-VY-18 Provide additional information to address Open considerations 2 - 4 of Section 5.3.3 of NEI 12-06 regarding internal flood sources, power for mitigation of groundwater, and impact of non-seismic downstream dams 049-RAI-VY-19 Long duration persistent flooding - discuss Open plans to move equipment and restock supplies 049-RAI-VY-20 Regional Response Center (RRC) Complete contracts/agreements - discuss items 2-10 of NEI Section 12.2 Page 7 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX RAI Number RAI Topic Status 049-RAI-VY-21 Discuss portable lighting and Complete communication in plant for deployment strategies 049-RAI-VY-22 Unavailability control for Complete equipment/connections per NEI Sect 3.2.2

& 11.5 049-RAI-VY-23 Access to and protection of N2 bottles Complete 049-RAI-VY-24 N2 bottle capacity to meet the required Complete SRV operations 049-RAI-VY-25 Securing of large portable equipment to Open protect the plant during a seismic event and evaluation of stored equipment for seismic interaction 049-RAI-VY-26 The effects of AC power loss on access to Open protected area and internal locked areas via security doors and gates when power is lost 049-RAI-VY-27 Access to FLEX valves via seismically Open protected buildings and paths 049-RAI-VY-28 Protection of tow vehicles Open 049-RAI-VY-29 Provide procedure / reference that Open describes how to take local readings of instruments 049-RAI-VY-30 What debris removal equipment is Open available for use prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 049-RAI-VY-31 Provide information on how snow & ice will Open be removed if necessary 049-RAI-VY-32 Discuss impact on portable equipment of Complete high temperatures in area where it is deployed Page 8 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX RAI Number RAI Topic Status 049-RAI-VY-33 Provide analytical results to support the Open conclusions of MAAP which will indicate Generic Industry they are consistent with expected plant Concern behavior and that core cooling is maintained 049-RAI-VY-34 Provide technical basis to support the Open conclusion that capability of MAAP code is Generic Industry sufficient to predict the adequacy of Concern mitigating strategies to cool the core during an ELAP event 049-RAI-VY-35 MAAP - provide summary of techniques, Open assumptions, and boundary conditions Generic Industry Concern 049-RAI-VY-36 QA process for MAAP Complete 049-RAI-VY-37 Provide justification for assumptions made Open regarding primary system leakage from recirculation pump seals and other sources 049-RAI-VY-38 Clarify whether the use of HPCI instead of Complete RCIC would affect the analysis 049-RAI-VY-39 Stability of SP water level with long term Open injection of outside water sources Generic Industry Concern Related to Order EA-13-109 049-RAI-VY-40 Will equipment protection features Complete interfere with operation of RCIC 049-RAI-VY-41 Discuss time frame for staging and Complete implementing Phase 2 FLEX pump operation 049-RAI-VY-42 Clarify how determination to place ADS Complete inhibit will be used and justify how the planned 'monitoring' approach is acceptable to prevent system actuation Page 9 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX RAI Number RAI Topic Status 049-RAI-VY-43 CST Standpipe mod - provide reference or Complete analysis that concludes that raising the standpipe adds 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of RCIC operation 049-RAI-VY-44 Add discussion to describe the need and Complete action of depressurization when implementing injection with FLEX pump 049-RAI-VY-45 What hydraulic analyses of FLEX Complete pump/strategy were done or are planned to confirm the required flow 049-RAI-VY-46 Discuss impact regarding water quality for Open injection with west deep basin on Connecticut River on fuel assemblies 049-RAI-VY-47 Develop timeline for startup of RCIC Open during cold shutdown conditions Generic Industry Concern 049-RAI-VY-48 Time to boil when in mode 5, and vessel Open level below the head flange Generic Industry Concern 049-RAI-VY-49 Explain the inconsistency between Complete guidance of EOPs to vent containment and the actions in the mitigating strategies for venting containment 049-RAI-VY-50 Early containment venting - confirm that Open maintenance of containment integrity is intended to demonstrate the ability to quickly restore containment integrity in the future while supporting decay heat removal in the meantime 049-RAI-VY-51 Provide clarification at to what is limiting Complete factor for early containment venting 049-RAI-VY-52 Submittal report contains no Complete instrumentation for measuring D/W temperature Page 10 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX RAI Number RAI Topic Status 049-RAI-VY-53 Containment integrity while at high Complete containment temperatures 049-RAI-VY-54 Provide range of plant states that require Complete containment venting - describe information used to make decision to vent 049-RAI-VY-55 What reliance was placed on BWR Complete roadmap and what plant specific analysis was performed 049-RAI-VY-56 Provide site analysis commensurate with Open the BWR roadmap 049-RAI-VY-57 Explain why two different MAAP reports Complete are referenced in the submittal 049-RAI-VY-58 Confirm HCVS does not rely on additional Open consumable support (air/nitrogen, power, Generic Industry etc.) Concern Related to Order EA-13-109 049-RAI-VY-59 Clarify intent of statement regarding use of Open portable equipment for HCVS Generic Industry Concern Related to Order EA-13-109 049-RAI-VY-60 Discuss impact on time-to-boil from Complete sloshing in the SFP 049-RAI-VY-61 Discuss venting the reactor building and Open impact to strategy without an adequate vent path 049-RAI-VY-62 Discuss/provide analysis for use of FLEX Open pump for filling CST and SFP concurrently 049-RAI-VY-63 Discuss/provide analysis for use of FLEX Complete pump for spraying SFP and vessel injection concurrently 049-RAI-VY-64 Discuss timing of SFP cooling initiation Complete during full core offload Page 11 of 12

Vermont Yankee's Second Six Month Status Report for the Implementation of FLEX RAI Number RAI Topic Status 049-RAI-VY-65 Discuss fueling provisions for portable Open equipment, time constraints, and protection of fuel cart 049-RAI-VY-66 Discuss instrumentation used to monitor Complete portable FLEX electrical power equipment 049-RAI-VY-67 Discuss maintenance and testing of Open electrical FLEX equipment Generic Industry Concern 049-RAI-VY-68 Severe accident condition impact to FLEX Complete strategies 049-RAI-VY-69 Severe accident condition impact to Complete equipment transport, and response times 049-RAI-VY-70 Discuss additional FLEX Complete equipment/actions needed for drywell flooding in severe accident conditions Page 12 of 12

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