ML14202A206

Technical Specifications Proposed Change No. 307, Revision to Technical Specification Administrative Controls for Permanently Defueled Condition - Supplement 2

ML14202A206
Person / Time
Site:	Vermont Yankee
Issue date:	07/16/2014
From:	Wamser C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME2991
Download: ML14202A206 (9)

Text

Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd Entergy Vernon, VT 05354 Tel 802 257 7711 Christopher J. Wamser Site Vice President BVY 14-052 July 16, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Technical Specifications Proposed Change No. 307, Revision to Technical Specification Administrative Controls for Permanently Defueled Condition -

Supplement 2 (TAC No. MF2991)

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

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Technical Specifications Proposed Change No. 307, Revision to Mitigation Strategy License Condition and Technical Specification Administrative Controls for Permanently Defueled Condition," BVY 13-096, dated October 31, 2013 (ML13316A004) (TAC No. MF2991)

Dear Sir or Madam:

By letter dated October 31, 2013 (Reference 1), Entergy Nuclear Operations, Inc. (ENO) proposed an amendment to Renewed Facility Operating License (OL) DPR-28 for Vermont Yankee Nuclear Power Station (VY). This amendment request proposed changes to the staffing, training and programmatic requirements contained in Section 6.0, Administrative Controls, of the VY Technical Specifications (TS) to support the transition of the VY facility to a permanently defueled condition.

ENO has identified additional changes to Section 6.0 of the TS that are needed to allow VY the flexibility to adopt a stand-alone Quality Assurance Program Manual and to ensure that procedures focus on the safe storage of spent nuclear fuel. to this letter provides a detailed description and evaluation of the proposed changes. contains a markup of the current TS page that builds on the markups provided in Reference 1. Attachment 3 contains the retyped TS page incorporating the changes proposed in this supplement and those in Reference 1.

The conclusions of the no significant hazards consideration and the environmental considerations contained in Reference 1 are not affected by, and remain applicable to, this supplement.

There are no new regulatory commitments made in this letter.

If you have any questions on this transmittal, please contact Mr. Philip Couture at 802-451-3193.

BVY 14-052 / page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on July 16, 2014.

Sincerely, CJW/plc Attachments: 1. Description and Evaluation of Proposed Changes

2. Markup of Technical Specification Page

3. Retyped Technical Specification Page cc: Mr. William M. Dean Region 1 Administrator U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of. Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O8D15 Washington, DC 20555 USNRC Resident Inspector Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 Mr. Christopher Recchia, Commissioner VT Department of Public Service 112 State Street, Drawer 20 Montpelier, VT 05620-2601

BVY 14-052 Docket 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Proposed Change 307 - Supplement 2 Description and Evaluation of Proposed Changes

BVY 14-052 / Attachment 1 / Page 1 of 2

1.

SUMMARY

DESCRIPTION In Reference 1, Entergy Nuclear Operations, Inc. (ENO) provided notification of the intention to permanently cease power operations of Vermont Yankee Nuclear Power Station (VY) in accordance with 10 CFR 50.82(a)(1)(i) at the end of the current operating cycle.

In Reference 2, ENO submitted proposed changes that would revise and remove certain requirements contained within Section 6.0, Administrative Controls, of the VY Technical Specifications (TS) consistent with the planned transition to a permanently defueled facility.

Additional changes to Section 6.0 of the TS have been identified that are needed to allow VY the flexibility to adopt a stand-alone Quality Assurance Program Manual and to ensure that procedures focus on the safe storage of spent nuclear fuel.

2. DETAILED DESCRIPTION AND BASIS FOR THE CHANGES The following table identifies each section that is being changed, the proposed changes, and the basis for the changes:

Proposed Changes to VY Technical Specification Section 6.0, Administrative Controls 6.2 Organization Current TS 6.2.C, Unit Staff Qualifications Proposed TS 6.2.C, Unit Staff Qualifications

1. Each member of the unit staff shall meet 1. Each member of the unit staff shall or exceed the minimum qualifications of meet or exceed the minimum ANSI/ANS 3.1-1978 for comparable qualifications of ANSI/ANS 3.1-1978 for positions with exceptions specified in comparable positions with exceptions the Entergy Quality Assurance Program specified in the Quality Assurance Manual (QAPM). Program Manual (QAPM).

Basis TS 6.2.C.1 - This TS specifies the minimum qualifications for the VY staff. The proposed change to this TS revises the title of the QAPM by removing specific reference to the Entergy corporate QAPM. This change will allow VY to transition from the Entergy corporate QAPM to a site-specific QAPM during the decommissioning process. No change to the qualification standards or exceptions to the standards are proposed. Accordingly, this change is administrative only.

6.4 Procedures Current TS 6.4 Proposed TS 6.4 Written procedures shall be established, Written procedures shall be established, implemented, and maintained covering the implemented, and maintained covering the

BVY 14-052 / Attachment 1 / Page 2 of 2 following activities: following activities:

A. Normal startup, operation and shutdown A. Normal startup, operation and shutdown of systems and components of the of systems and components needed for facility, the safe storage of nuclear fuel.

C. Actions to be taken to correct specific C. Actions to be taken to correct specific and foreseen potential malfunctions of and foreseen potential malfunctions of systems or components, suspected systems or components needed for the Primary System leaks and abnormal safe storage of nuclear fuel.

reactivity changes.

Basis TS 6.4.A - This TS is proposed to be revised to specify that procedures are required for normal startup, operation and shutdown of systems and components necessary to ensure the safe storage of nuclear fuel, rather than the facility, to be consistent with the planned transition to a permanently defueled facility. Once the certifications required by 10 CFR 50.82(a)(1) have been submitted to the NRC, operation of the reactor will be prohibited and the operational focus will be on the spent fuel pool and associated makeup and cooling systems.

(NOTE: Changes were proposed to TS 6.4.C in Reference 2. Additional changes are proposed to the TS in this supplement to clarify the applicability of the TS to systems and components needed for safe storage of nuclear fuel. The justification for the changes proposed in Reference 2 are reproduced for consistency)

TS 6.4.C - This TS is being revised to reflect that once the reactor is permanently defueled, reactivity changes in the reactor vessel will no longer be possible and the Primary Systems that provide reactor core cooling will no longer be required. Therefore, a requirement to have procedural direction to address reactivity changes or suspected Primary System leakage does not apply in the permanently defueled condition.

Since operation of the reactor will be prohibited and the operational focus will be on the spent fuel pool and associated makeup and cooling systems, the proposed change will require that procedures be in place to address malfunctions of systems or components needed for the safe storage of nuclear fuel to be consistent with the planned transition to a permanently defueled facility.

References

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Technical Specifications Proposed Change No. 307, Revision to Mitigation Strategy License Condition and Technical Specification Administrative Controls for Permanently Defueled Condition," BVY 13-096, dated October 31, 2013 (ML13316A004) (TAC No. MF2991)

BVY 14-052 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station Proposed Change 307 - Supplement 2 Markup of Technical Specification Page

VYNPS

-- An NRC approved training and 6.2 ORGANIZATION (Cont'd) retraining program for Certified C. Unit Staff Qualifications Fuel Handlers shall be maintained

1. Each member of the unit s aff shall meet or exceed the minimum qualifications of ANSI/A S 3.1-1978 for comparable positions with exceptions specifie in the E Quality Assurance Program Manual (QAPM).

2. - I I ý - __ I I A I _.- - - - - I - - - _'- __ - - - - ý Operator (SRO) and a liconsod Roactor.... Oporator (RO),. arc tho....

i*ndividuals who, in add-itin to meeting the reGuirementP of SpecificGation 6-2-Q-1, pcrform thop functins JQ oibe in 10- C FR. -5 0.5 4(m) .

6.3 ACTION TO BE TAKEN IF A SAFETY LIMIT IS EXCEEDED FD-ele tedl >

bo folIojcd in tho ovcnt a safoty limit is oxceeded.

If a .lmit safoty is eXocodod, tho reactor Shall beuo iPMmed-iatel#4; 1Y.

6.4 PROCEDURES needed for the safe Istoraqe of nuclear fuel Written procedures shall be estab ed, implemented, and maintained covering the following activi s:

A. Normal start operation and shutdown of systems and components Ih.a. iu needed for the safe B. Rcucine perations anda. storaqe of nuclear fuel C. Actions to be taken to correct specifi nd foreseen potential malfunctions of systems or componentsT SuSpected Primary System la.ks and aborm.al- reactivity changes.

D. Emergency conditions involving potential or actual release of radioactivity.

E. Preventive and corrective maintenance operations which could have an effect on the safety of the re*a-t-.

• -nuclear fuel F. Surveillance and testing requirements.

G. Fire protection program implementation.

H. Process Control Program in-plant implementation.

I. Off-Site Dose Calculation Manual implementation.

6.5 HIGH RADIATION AREA As provided in paragraph 20.1601(c) of 10 CFR 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraphs 20.1601(a) and 20.1601(b) of 10 CFR 20:

A. High Radiation Areas with dose rates greater than 0.1 rem/hour at 30 centimeters, but not exceeding 1.0 rem/hour at 30 centimeters from the radiation source or from any surface penetrated by the radiation:

Amendment No. -- , -44, -4, 4-3, 1-4, 4, 44--, 24-, 2-1-4, 2-4-1-, 242 257

BVY 14-052 Docket 50-271 Attachment 3 Vermont Yankee Nuclear Power Station Proposed Change 307 - Supplement 2 Retyped Technical Specification Page

VYNPS 6.2 ORGANIZATION (Cont'd)

C. Unit Staff Qualifications

1. Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Quality Assurance Program Manual (QAPM).

2. An NRC approved training and retraining program for Certified Fuel Handlers shall be maintained.

6.3 Deleted 6.4 PROCEDURES Written procedures shall be established, implemented, and maintained covering the following activities:

A. Normal startup, operation and shutdown of systems and components needed for the safe storage of nuclear fuel.

B. Fuel handling operations.

C. Actions to be taken to correct specific and foreseen potential malfunctions of systems or components needed for the safe storage of nuclear fuel.

D. Emergency conditions involving potential or actual release of radioactivity.

E. Preventive and corrective maintenance operations which could have an effect on the safety of the nuclear fuel.

F. Surveillance and testing requirements.

G. Fire protection program implementation.

H. Process Control Program in-plant implementation.

I. Off-Site Dose Calculation Manual implementation.

6.5 HIGH RADIATION AREA As provided in paragraph 20.1601(c) of 10 CFR 20, the following controls shall be applied to high radiation areas in place'of the controls required by paragraphs 20.1601(a) and 20.1601(b) of 10 CFR 20:

A. High Radiation Areas with dose rates greater than 0.1 rem/hour at 30 centimeters, but not exceeding 1.0 rem/hour at 30 centimeters from the radiation source or from any surface penetrated by the radiation:

Amendment No. -,-, 4-1, 4-3, .-4, 1§-, 4,-6-4, -1, 2-1-4, 2-44, 2-2-3 257