ML15033A053

NRR E-mail Capture - VY RAI from Dss/Srxb for MF3714

ML15033A053
Person / Time
Site:	Vermont Yankee
Issue date:	01/30/2015
From:	James Kim Plant Licensing Branch IV
To:	Couture P Entergy Nuclear Operations
References
TAC MF3714
Download: ML15033A053 (4)

Text

NRR-PMDAPEm Resource From: Kim, James Sent: Friday, January 30, 2015 11:59 AM To: 'Couture III, Philip' (pcoutur@entergy.com)

Subject:

VY RAI from DSS/SRXB for MF3714 Mr. Couture, A RAI from the Reactor System Branch is shown below. Please provide the response by March 6, 2015.

Thanks, Jim Kim REQUEST FOR ADDITIONAL INFORMATION DEFUELED TECHNICAL SPECIFICATIONS AND REVISED LICENSE CONDITIONS FOR PERMANENTLY DEFUELED CONDITION VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO.: 50-271 By letter dated March 28, 2014, Entergy, the licensee for the Vermont Yankee Nuclear Power Station, provided a License Amendment Request in order to revise the Technical Specifications and License Conditions to support the permanently defueled condition of the Vermont Yankee Nuclear Power Station.

This Request for Additional Information intends to identify the Structures and Components (SCs) needed to maintain the spent fuel in a safe condition during the decommissioning period and describe what actions are in place to provide reasonable assurance that the SCs are capable of fulfilling their intended functions.

The provisions of 10 CFR 50.51(b) require licensees that have provided certifications for permanent cessation of power operations and permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.82(a)(1)(ii) to take actions necessary to decommission and decontaminate the facility and continue to maintain the facility in a safe condition. The SCs required to maintain the safe operation of the facility during the decommissioning period may remain operational beyond the normal licensed operating period of 40 years.

Under the provisions of 10 CFR 50.82, the licensee must complete decommissioning within 60 years of permanent cessation of operations.

The provisions of 10 CFR 50.51(b) state:

Each license for a facility that has permanently ceased operations, continues in effect beyond the expiration date to authorize ownership and possession of the production or utilization facility, until the Commission notifies the licensee in writing that the license is terminated. During such period of continued effectiveness the licensee shall--

(1) Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility, including, where applicable, the storage, control and maintenance of the spent fuel, in a safe condition, and The provisions of 10 CFR 50.65 require licensees to monitor performance or condition of Structures, Systems and Component (SSC) to ensure they are capable of fulfilling their intended function. The scope of the monitoring specified in 10 CFR 50.65(a)(1) applies to safety-related SSCs as stated in Section 50.65(b)(1) and 1

to nonsafety-related SSC whose failure could prevent safety-related SSCs from fulfilling their intended function as stated in Section 50.65(b)(2)(ii).

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The provisions of 10 CFR 50.65(a)(1) state:

Each holder of an operating license for a nuclear power plant shall monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components, as defined in paragraph (b) of this section, are capable of fulfilling their intended functions.

The provisions of 10 CFR 50.65(a)(1) also state:

For a nuclear power plant for which the licensee has submitted the certifications specified in § 50.82(a)(1) or 52.110(a)(1) of this chapter, as applicable, this section shall only apply to the extent that the licensee shall monitor the performance or condition of all structures, systems, or components associated with the storage, control, and maintenance of spent fuel in a safe condition, in a manner sufficient to provide reasonable assurance that these structures, systems, and components are capable of fulfilling their intended functions.

The treatment of passive, long-lived SCs under the monitoring program during the original period of operation is likely to involve minimal performance or condition monitoring to maintain functionality. Passive SCs generally have functions that do not have performance and condition characteristics that are as readily observable as SCs that perform active functions. Long-lived SCs may not be subjected to periodic replacement based on a qualified life or specified time period. The U.S. Nuclear Regulatory Commission (NRC) staff needs to determine whether the licensees programs are sufficient to adequately manage the degradation effects of passive, long-lived SCs to prevent the loss of intended function beyond the normal licensed operating period of 40 years. Licensees, under the provisions of 10 CFR 50.51(b) and 10 CFR 50.82, shall take actions necessary to decommission and decontaminate the facility and continue to maintain the facility, including, the Spent Fuel Pool (SFP), in a safe condition until license termination, which period in this case will extend beyond the normal licensed operating period of 40 years.

The licensee does not describe what actions it will take to maintain the SFP in a safe condition, i.e., how it intends to monitor and maintain the intended function of passive, long-lived SCs (e.g., the neutron absorbing materials) in the SFP, the fire protection system and the radiation protection system beyond the normal licensed operating period of 40 years. Accordingly, the staff requests that the licensee provide the following information:

1. Identify and list the long-lived, passive SCs (e.g., neutron absorbing materials) in the SFP, the fire protection system and the radiation protection system that are needed, pursuant to the provisions of 10 CFR 50.51(b), to provide reasonable assurance that safe condition of the spent fuel will be monitored and maintained during the decommissioning period.

2. Provide a summary description of actions that will be taken to monitor and maintain the performance or condition of long-lived, passive SCs, identified in the response to Request 1, to provide reasonable assurance that the long-lived, passive SCs are capable of fulfilling their intended functions during the decommissioning period.

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Hearing Identifier: NRR_PMDA Email Number: 1846 Mail Envelope Properties (James.Kim@nrc.gov20150130115800)

Subject:

VY RAI from DSS/SRXB for MF3714 Sent Date: 1/30/2015 11:58:57 AM Received Date: 1/30/2015 11:58:00 AM From: Kim, James Created By: James.Kim@nrc.gov Recipients:

"'Couture III, Philip' (pcoutur@entergy.com)" <pcoutur@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 6184 1/30/2015 11:58:00 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: