ML17332A084
| ML17332A084 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 11/27/2017 |
| From: | Tierney J State of VT, Dept of Public Service, Vermont Citizens Action Network |
| To: | Jack Parrott Division of Decommissioning, Uranium Recovery and Waste Programs |
| JParrott NRC NMSS DUWP | |
| References | |
| Download: ML17332A084 (5) | |
Text
,^q^.,VERMONT State of Vernont Departrrrent of Public Scrwice Iphonel 8oz-828-z8tt rr2 Statc Strcct I fax] 8oz-828-2342 Montpclicr, VT tl562tl-26cl1 Itdrl 8o<l-Zg+-8ggo http ://publicselvice.verrtront. gov November 27,2017 Jack D. Parrott, Senior Project Manager Office of Nuclear Material Safety & Safeguards Reactor Decommissioning Branch US Nuclear Regulatory Commission Mail Stop T-8F5 Washington, DC 20555 Re: Vermont Pubtic Service Department Comments on the Forthcoming Issuance of a License Amendment Regarding the Date of the Vermont Yankee Cyber Security Plan Milestone 8 Implementation Schedule
References:
- l. E-Mail from Jack D. Parrott of the Office of Nuclear Material Safety & Safeguards to Commissioner June E. Tierney of the Vermont Public Service Department (the "Department"), "Vermont Yankee Nuclear Power Station ("VYNPS") - Forthcoming Issuance of a License Amendment Regarding the Date of the VYNPS Cyber Security Plan Implementation Schedule Milestone 8," dated November 8,2017
- 2. Entergy Letter BVY l7-007 to USNRC, "License Amendment Request - Cyber Security Plan Implementation Schedule Proposed Change No. 314, Vermont Yankee Nuclear Power Station, Docket No. 50-271, License No. DPR-28," dated May l, 2017 (MLl7l24A429)
Dear Mr. Parrott:
In response to your electronic mailing sent November 8, 2017 (Reference l) requesting comments on the Nuclear Regulatory Commission's ("NRC's") draft Safety Evaluation Report ("SER") for Vermont Yankee's proposed change in schedule in implementing Cyber Security Plan Milestone 8 (Reference2),1directed Vermont Public Service Department staff to evaluate the draft SER enclosed with Reference l. The purpose of this letter is to provide you with the comments that resulted from this evaluation.
Overall, the Department has no technical objections to Vermont Yankee's requested delay in the I
Milestone implementation date. Vermont Yankee fully implemented Cyber Security Plan Milestones I through 7 prior to its cessation of Power Generating Operations in December 2014.
1
VT Public Service Commissioner Letter to USNRC November 27,2017 Page2 of2 Because Vermont's State Nuclear Engineer, Mr. Anthony Leshinskie, is stationed primarily at the Vermont Yankee site, the Department has frrst-hand knowledge on the Vermont Yankee Cyber Security plan's implementation, and more importantly, how seriously Vermont Yankee Staff takes Cyber Security concerns. The justifications made in Reference2 are similar to those made in pievious Vermont yankee Cyber Security Milestone 8 implementation date change requests.
h.r. justifications include that Vermont Yankee currently has far fewer active Critical Digital Assets than when the plant was still generating electricity. Additionally, Vermont Yankee maintains the ability to manually operate many of the plant systems critical to maintaining Spent Fuel pool integrity without relying upon digital assets. Based on this reasoning, delaying the final implementation date does not represent a significant safety concern.
please note that in evaluating the draft SER, Department staff observed several items that we request you consider prior to issuing the SER for this Vermont Yankee License Amendment Request. The observations are summarized in the comments contained in the enclosure to this lettr. euestions or further details regarding these items may be directed to my office or the Vermont State Nuclear Engineer, Mr. Anthony Leshinskie at 802-272-1714 or anthony. leshi nskicfg)verrnont. gov .
On behalf of the State of Vermont, I thank you for this opportunity to comment on this Vermont yankee License Amendment Request. I look forward to similar comment opportunities in the future.
V truly E.
Vermont blic Department I l2 State Street, Second Floor Montpelier, VT 05620 -2601 Enclosure / State of Vermont Evaluation and Comments CC: DanielH. Dorman Doug Tifft Regional Administrator, Region I Regional State Liaison Officer, Region I US Nuclear Regulatory Commission US Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 2100 Renaissance Blvd., Suite 100 King of Prussia,PA 19406-2713 King of Prussia, PA 19406-2713 Anthony R. Leshinskie Vermont State Nuclear Engineer and Decommissioning Coordinator I l2 State Street, Third Floor Montpelier, VT 05620-260 I Anthony. Leshinsk ie@vermont. gov (802)272-t'n4
State of Vermont Evaluation and Comments on the License Amendment Request Regarding the Date of the Vermont Yankee Cyber Security Plan Milestone I Implementation Schedule
Summarv of Bvaluation: As part of the Vermont Public Service Department's (the "Department's") evaluation of the draft Safety Evaluation Report ("SER") included in Reference l, régarding Vermont Yankee's proposed change in the date for completing implementation of Cyber Security Milestone 8, Reference I and its parent License Amendment Request ("LAR")
contained in Referenc e2have been reviewed. Additionally, Vermont Yankee's separate LAR that propose changes to its Physical Security Plan contained in Reference 3 has been reviewed, since the References 2 and 3 LARs each modify existing language in Section 3.G in Vermont Yankee's Operating License.
The reviews of References I through 3 resulted in the following three comments:
L Reference 2, Attachment l, Page 3 refers to a prior Vermont Yankee evaluation of the Spent Fuel Zirconium-Water Reaction Fire event as a means of demonstrating that the overall accident risk at Vermont Yankee has reduced since the plant ceased power operations.
Vermont State Agencies have previously filed contentions with the NRC that the analysis of this Zirconium-Water Reaction Fire event is insufficient (Reference 4). Among other things, these contentions indicate Zirconium-Water Reaction Fire event analysis does not adequately consider spent fuel fires resulting from Hostile Actions. The NRC credited the contested Spent Fuel Zirconium-Water Reaction Fire event analysis as part of its justification for granting a License Exemption in which Vermont Yankee no longer needs to maintain an offsite Emergency Planning Zone and offsite emergency response capabilities. The Vermont State Agencies including in the Reference 4 filing still object to this License Exemption. However, thé State recognizes that a subsequent agreement between Entergy and the Vermont Department of Emergency Management and Homeland Security ("VT DEMHS") that funds a lesi formal offsite emergency response capability (through end of FY 2018) does mitigate the State's concern in this area. It is further noted that the Reference 2 evaluation does not credit that more than half of Vermont Yankee's Spent Fuel inventory has now been successfully moved from the onsite Spent Fuel Pool to Dry Cask Storage Systems. The State recognizes that this change mitigates, but does not eliminate, the concern regarding the adequacy of the Spent Fuel Zirconium-Water Reaction Fire event analysis.
- 2. The NRC needs to assure that the combined impact of the References 2 and 3 proposed changes to the text in Section 3.G of the Vermont Yankee Operating License are consistent.
Partiularly, in the last sentence of the second (and final) paragraph of Section 3.G, please confirm that the enumeration of the Vermont Yankee License Amendments that supplement License Amendment #247 is accurate.
- 3. In the Reference I Draft SER, the following typographical errors must be corrected:
- i. In Section 1.0, the correct Federal Register publication for the subject LAR is August 15 , 2017 (S2 FR 3 87 I 8) and not July I 8,2017 .
ii. In Section 3.5, the correct schedule completion date for the license commitment in the subject LAR is July 3 1,2019 and not July 3 l, 201 8.
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References:
- l. E-Mail from Jack D. Panott of the Offce of Nuclear Material Safety & Safeguards to Commissioner June E. Tierney of the Vermont Public Service Department (the "Department")
"Vermont Yankee Nuclear Power Station - Forthcoming Issuance of a License Amendment Regarding the Date of the VYNPS Cyber Security Plan Implementation Schedule Milestone 8," dated November 8,2017.
- 2. Entergy Letter BVY 17-007 to USNRC, "License Amendment Request - Cyber Security Plan Implementation Schedule Proposed Change No. 314, Vermont Yankee Nuclear Power Station, Docket No. 50-271, License No. DPR-28," dated May l, 2017 (MLl7l24A429).
- 3. Entergy Letter BVY l7-003 to USNRC, "Independent Spent Fuel Storage Installation Physical Security Plan, Revision 0 Proposed Change No. 315, Vermont Yankee Nuclear Power Station, Docket No. 50-271, License No. DPR-28,'dated May l, 2017 (MLl7l72A460).
- 4. Docket Number 50-271-LA-2, "State of Vermont Petition to Intervene Regarding Vermont Yankee Permanently Defueled Emergency Plan and Emergency Action Level Scheme License Amendment Request BVY 14-033," with supporting Declarations, dated February 9,2015 (ML I 5 040 A7 26, ML I 504047 24, MLI 5040 A7 28, & ML I 504 0 A729).
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