BVY 14-030, Technical Specifications Proposed Change No. 309, Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition - Supplement 1

Technical Specifications Proposed Change No. 309, Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition - Supplement 1

ML14119A101
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/24/2014
From:	Wamser C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 14-030, TAC MF3714
Download: ML14119A101 (11)

Text

Entergy Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd Vernon, VT 05354 Tel 802 257 7711 Christopher J. Wamser Site Vice President BVY 14-030 April 24, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Technical Specifications Proposed Change No. 309, Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition - Supplement 1 (TAC No. MF3714)

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. 309, Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition," BVY 14-010, dated March 28, 2014 (TAC No.

MF3714)

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)

3.

Email from USNRC to VY, "Draft RAI - TS Proposed Change 307, License Condition N," dated March 28, 2014 (Security-Related)

4.

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 -

Supplement 1," BVY 14-028, dated April 24, 2014

Dear Sir or Madam:

By letter dated March 28, 2014 (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). The proposed amendment would revise the VY OL and Technical Specifications (TS) to be consistent with the expected permanently shutdown and defueled condition of VY. The markups to the OL and TS provided in Reference 1 reflected other proposed changes to the OL and TS that were submitted under separate requests, including those provided in Reference 2, which included a proposed elimination of the Mitigation Strategy License Condition (License Condition 3.N) from the VY OL.

Azu0(

BVY 14-030 / page 2 of 3 In Reference 3, the NRC provided VY with a draft Request for Additional Information (RAI) regarding the proposed elimination of License Condition 3.N. In response to the draft RAI (Reference 4), ENO withdrew the proposed elimination of the license condition. Attachments 1 and 2 of this letter provide a revised markup and retyped pages, respectively, of the VY OL to reflect this.

Additionally, in Reference 1 ENO provided proposed changes to current TS 3/4.8.D, "Liquid Holdup Tanks," that included renumbering the existing TS as new TS 3/4.1.A. The markups and retyped pages provided for those changes inadvertently omitted a renumbering of a TS 3.8.D.1 reference in current TS 3.8.D.2 and 4.8.D.1 to TS 3.1.A.1 in proposed TS 3.1.A.2 and 4.1.A.1. Attachments 1 and 2 provide a corrected markup and retyped page, respectively.

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.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on April 24, 2014.

Sincerely, Jg(Y (WA CJW/plc Attachments: 1.

Markup of Operating License and Technical Specification Pages

2.

Retyped Operating License and Technical Specification Pages 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 08D15 Washington, DC 20555

BVY 14-030 / page 3 of 3 cc list cont'd:

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 14-030 Docket 50-271 Vermont Yankee Nuclear Power Station Markup of Operating License and Technical Specification Pages Changes to other aspects of tho SDMP may be. made in accordance with the guidance of NEI 90 04.

1.5 l..

Dung each of the three scheduled refueli ng eutagcs (beginning with the spnng 2007 refueling outage), a visual inspection shall be conduited ot all accessible, susceptibieleeIoations of the steamA dryer, including flaws left "as fis" and moedifications.

e. The results of the visual inspections of the steam dyer cnducted dui the three scheduled refueling outages (beginning with the SPrin 2007 refueling outage) shall be Fepo~ted to the NRC staff within 60 day following Sta~tup fromn the rcspeetivc refueling outage. Th rensults of th mSlmIVmmmshalk besumite i

e the NRm stf on a

mIpel wg i

th

• llm in 6

i days following tho completion of all EPU power ascension testing.

7. The requirements of paragraph 4 above for meeting the SIDMPI shall be i mplemented upon issuance of the EPU license amendment and shall continue untol the completion of one full operating cyele at EPU. if an unacceptable Structural flaw (due to fatigue) is detected during the subsequent visual inspection of the steam dryer, the requiremnents oe paragraph 4 shall extend another full opera:ting cycle until the Visual inspietion standard of no new flaw!s/fl..aw gro.th based on visual

,nsp*,

,,,n is satisfied.

8. This lifence condition shall eXpire upon satisfaction of the reeuirements in pea~Fagphs f dFyeF does n

, 6, and proviaca tat a visual inspection 01 the steam et reveal any new unacceptable flaw or unacceptable flaw

!JF0.~tfl IflJl I~ UUC 10 KILIiIUC.

N.

Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a)

Fire fighting response strategy with the following elements:

1.

Pre-defined coordinated fire response strategy and guidance

2.

Assessment of mutual aid fire fighting assets

3.

Designated staging areas for equipment and materials

4.

Command and control

5.

Training ofresponse personnel (b)

Operations to mitigate fuel damage considering the following:

1.

Protection and use of personnel assets

2.

Communications

3.

Minimizing fire spread

4.

Procedures for implementing integrated fire response strategy

5.

Identification of readily-available pre-staged equipment Renewed Facility Operating License No. DPR-28

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c)

Actions to minimize release to include consideration of:

1. Water spray scrubbing Deleted

2. Dose to onsite responders

0. The

,,ieense shall implement and maintain all ActinS requi;cd by to NRC QOder EA 06 137, isued June 20, 2006, except the last aetien that reqUires ineprtenf the Strategies onto the site sccurity plan, contingeney plan, emergency plan andior guard training and qualification plan, as appropriate.

P. The information in the UFSAR supplement, submitted pursuant to 10 CRIF 54.21 (d), as revised during the license renewal application process, and as supplemented by Commitment Nos. 1-5, 6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 38, 39, 42, 43, and 45-55 of Appendix A of Supplement 2 of NUREG-1 907 shall be incorporated as part of the UFSAR which will be updated in accordance with 10 CER 50.71 (e).

As such, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. may make changes to the programs and activities described in the UFSAR supplement and Commitment Nos. 1-5, 6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 38, 39, 42, 43, and 45-55 of Appendix A of Supplement 2 of NUREG-1 907 provided Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

Q. This paragraph deleted by Amendment No. 256, April 17, 2013.

eee R.

Entergly Nuclear VeFrmont Yankoe, LLC and Entergly Nuclear Operatiens, Ic shall implement the moc~t recent staff approved vercion of the Boiling Wate Reacto*

Vessels and InternIall Project (BWRVIP) Integrated Surveillance Program- (ISP) a the method to dem.ntrate complianR e with the reguiraments of 10 CFR Part 60, Appendix H. An'; ehanges to the BWRVIP i16 eapsulc wIEunarawwal scule

• must he submmmm ror mv staff roview and approval. Any changes to the IBWRVIP ISP capsule withdrawal sehedule which affeets the timne of withdrawai of any surveillance capsules m~ust be incorporated into the Iicensing basis. if any surv.illanec eapsules are removed without the intent to test them, these capsules must be Stored i mnanner Which maintains them in a condition which would SUPPort re insertion into the reatort9 oreScuro-vessel,-1 if n.esea~y?

Renewed Facility Operating License No. DPR-28 Amendment M6

3.1 3.1 RADIOACTIVE 4--4 IMITING CONDITIONS FOR OPERATION RA...AT..VE EFFLUENTS Applicability:

Applies to the release of all radioactive effluents from the plant.

Objective:

To assure that radioactive effluents are kept "as low as is reasonably achievable" in accordance with 10CFR50, Appendix I and, in any event, are within the dose limits for Members of the Public specified in 10CFR20.

Specification:

Deleted C. ~ Iit tem~d 4.1 4-,:--& VEILLANCE REQUIREMENTS 4-.4 RADIOACTIVE EFFLUENTS Applicability:

Applies to the required surveillance of all radioactive effluents released from the plant.

Objective:

To ascertain that all radioactive effluents released from the plant are kept "as low as is reasonably achievable" in accordance with 10CFR50, Appendix I and, in any event, are within the dose limits for Members of the Public specified in 10CFR20.

Specification:

A-.

eleted C-Deleted

~j-~D.

Liquid Holdup Tanks

1. The quantity of radioactive material contained in any outside tank* shall be limited to less than or equal to 10 curies, excluding tritium and dissolved or entrained noble gases.

FA1z-D.

Liquid Holdup Tanks

1. The quantity of 3.1.A.1 radioactive material contained in each Off he liquid holdup tanks* shall be determined to be ithin the limits of Specification 3.8.D.I by analyzing a representative sample of the tank's contents within one week following the addition of radioactive materials to the tank.

One sample may cover multiple additions.

2.

With the quantity of 3.1.A.1 radioactive material i any outside tank*

exceeding the limit o Specification 3.8.D.!,

immediately take action to suspend all additions of radioactive material to the tank.

Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, reduce the tank contents to within the limit.

• NOTE:

Tanks included in this Specification are only those outdoor tanks that are not surrounded by liners, dikes, or walls capable of holding the tank's contents, or that do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system.

Amendment No. 44, 9,

-4 1-7-a

BVY 14-030 Docket 50-271 Vermont Yankee Nuclear Power Station Retyped Operating License and Technical Specification Pages (iii)

Entergy Nuclear Vermont Yankee, LLC shall establish a standby trust to receive funds from the surety, if a surety is obtained, in the event that Entergy Nuclear Vermont Yankee, LLC defaults on its funding obligations for the decommissioning of Vermont Yankee.

The standby trust agreement must be in a form acceptable to the NRC, and shall conform with all conditions otherwise applicable to the decommissioning trust agreement.

(iv)

The surety agreement must provide that the agreement cannot be amended in any material respect, or terminated, without 30 days prior written notification to the Director of the Office of Nuclear Reactor Regulation.

Entergy Nuclear Vermont Yankee, LLC shall take all necessary steps to ensure that the decommissioning trust is maintained in accordance with the application for approval of the transfer of this license to Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc., and the requirements of the Order approving the transfer, and consistent with the safety evaluation supporting the Order.

Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. shall take no action to cause Entergy Global Investments, Inc., or Entergy International Holdings Ltd. LLC, or their parent companies to void, cancel, or modify the lines of credit to provide funding for Vermont Yankee as represented in the application without prior written consent of the Director of the Office of Nuclear Reactor Regulation.

K. This paragraph deleted by Amendment No. xxx.

L.

This paragraph deleted by Amendment No. xxx.

M. This paragraph deleted by Amendment No. xxx.

N.

Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a)

Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b)

Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications Renewed Facility Operating License No. DPR-28 Amendment xxx

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c)

Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders

0. This paragraph deleted by Amendment No. xxx.

P.

The information in the UFSAR supplement, submitted pursuant to 10 CRF 54.21(d), as revised during the license renewal application process, and as supplemented by Commitment Nos. 1-5, 6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 38, 39, 42, 43, and 45-55 of Appendix A of Supplement 2 of NUREG-1907 shall be incorporated as part of the UFSAR which will be updated in accordance with 10 CFR 50.71(e).

As such, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. may make changes to the programs and activities described in the UFSAR supplement and Commitment Nos. 1-5, 6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 38, 39, 42, 43, and 45-55 of Appendix A of Supplement 2 of NUREG-1907 provided Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

Q. This paragraph deleted by Amendment No. 256, April 17, 2013.

R.

This paragraph deleted by Amendment No. xxx.

S.

This paragraph deleted by Amendment No. xxx.

I 4.

This license is effective as of the date of issuance and is effective until the Commission notifies the licensee in writing that the license is terminated.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By Eric J. Leeds Eric J. Leeds, Director Office of Nuclear Reactor Regulation

Enclosures:

Appendix A - Technical Specifications Date of Issuance: March 21, 2011 Renewed Facility Operating License No. DPR-28 Amendment 262,2,%, xxx

VYNPS 3.1 LIMITING CONDITIONS FOR OPERATION 4.1 SURVEILLANCE REQUIREMENTS 3.1 RADIOACTIVE EFFLUENTS 4.1 RADIOACTIVE EFFLUENTS Applicability:

Applies to the release of all radioactive effluents from the plant.

Objective:

To assure that radioactive effluents are kept "as low as is reasonably achievable" in accordance with 10CFR50, Appendix I and, in any event, are within the dose limits for Members of the Public specified in 10CFR20.

Specification:

A.

Liquid Holdup Tanks

1. The quantity of radioactive material contained in any outside tank* shall be limited to less than or equal to 10 curies, excluding tritium and dissolved or entrained noble gases.

2.

With the quantity of radioactive material in any outside tank*

exceeding the limit of Specification 3.1.A.1, immediately take action to suspend all additions of radioactive material to the tank.

Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, reduce the tank contents to within the limit.

Applicability:

Applies to the required surveillance of all radioactive effluents released from the plant.

Objective:

To ascertain that all radioactive effluents released from the plant are kept "as low as is reasonably achievable" in accordance with 10CFR50, Appendix I and, in any event, are within the dose limits for Members of the Public specified in 10CFR20.

Specification:

A.

Liquid Holdup Tanks

1. The quantity of radioactive material contained in each of the liquid holdup tanks* shall be determined to be within the limits of Specification 3.1.A.1 by analyzing a representative sample of the tank's contents within one week following the addition of radioactive materials to the tank.

One sample may cover multiple additions.

• NOTE:

Tanks included in this Specification are only those outdoor tanks that are not surrounded by liners, dikes, or walls capable of holding the tank's contents, or that do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system.

Amendment No.

xxx 6