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Vermont Yankees Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
	ML14064A200
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	02/26/2014
From:	Wamser C; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BVY 14-015, EA-12-051
	Download: ML14064A200 (12)
	v • d • e

0-Entergy Entergy Nuclear Operations, Inc.

320 Governor Hunt Road Vernon, Vermont 05354 Tel: (802) 257-7711 Christopher J. Wamser Site Vice President BVY 14-015 February 26, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

REFERENCES:

Vermont Yankee's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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

1. NRC Order Number EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (ML12054A679)

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012 (ML12221A339)

3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012 (ML12240A307)

4. Letter, Entergy to NRC, Vermont Yankee's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), BVY 12-073, dated October 26, 2012 (ML12306A086)

5. Letter, Entergy to NRC, Vermont Yankee's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), BVY 13-015, dated February 28, 2013 (ML13064A301)

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 Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), BVY 13-075, dated August 28, 2013 (ML13247A029)

Aoc I

BVY 14-015/Page 2 of 3

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) issued an Order (Reference 1) to all power reactor licensees. Reference 1 was immediately effective and directs Entergy Nuclear Operations, Inc. (Entergy) to install reliable spent fuel pool level instrumentation at the Vermont Yankee Nuclear Power Station (VY). Specific requirements are outlined in Attachment 2 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 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 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions. Reference 4 provided the VY initial status report regarding spent fuel pool instrumentation. Reference 5 provided the VY overall integrated plan for reliable spent fuel pool instrumentation. Reference 6 provided the first VY six-month status report.

Reference 7 notified the NRC that Entergy had decided to permanently cease power operations of VY at the end of the current operating cycle (expected in the fourth quarter of 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 VY 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.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 26, 2014.

Sincerely,

[CJW/JTM]

BVY 14-015 / Page 3 of 3

Attachment:

Vermont Yankee's (VY) Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation 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, Vermont 05620-2601

Attachment to BVY 14-015 Vermont Yankee's (VY) Second Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation

VY's Second Six Month Status Report for the Implementation of SFPI BVY 14-015 Attachment Vermont Yankee's (VY) Second Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation

1. Introduction Vermont Yankee (VY) developed an overall integrated plan (OIP)(Reference 1 in Section 8),

documenting the requirements to install reliable spent fuel pool level instrumentation (SFPI), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, 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 has decided to permanently cease power operations at VY at the end of the current operating cycle (Reference 6). 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. A revised OIP for VY will be submitted with the August 2014 6-month status report reflecting the decision.

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 Although not part of the original milestone schedule, an Interim Staff Evaluation (ISE) for VY was received November 26, 2013 (Reference 7). The ISE also includes requests for additional information (RAIs) for NRC staff to complete its review. NRC staff clarified during the November 26, 2013 public meeting that the Interim Staff Evaluation questions supersede any previous requests for information issued by the staff concerning the spent fuel pool instrumentation (Reference 8). Therefore, the RAIs dated June 20, 2013 (Reference 3) are considered superseded by the RAIs contained in the ISE. The addition of this milestone and target completion date does not impact the Order implementation date.

3. Milestone Schedule Status The following provides an update to Attachment 2 of the OIP providing 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-12-051 (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. The OIP (Reference 1) stated that the installation Page 1 of 8

VY's Second Six Month Status Report for the Implementation of SFPI of reliable spent fuel pool level instrumentation was scheduled for completion prior to startup from the fall 2014 refueling outage. Since VY will permanently cease power operations at the end of the current operating cycle (estimated to be 4th quarter 2014), there will be no further refueling outages, startups from refueling outages, or refueling cycles. As a result, the full implementation date has been updated to reflect the December 31, 2016 implementation date specified in the order.

Revised Target Milestone Tr t

et Activity Status Completion Date Reliable SFPI Installed Fall 2014 Refueling In Progress December 2016 Outage Respond to NRC RAIs dated July 19, 2013 Complete June 20, 2013 (Reference 3)

Respond to NRC RAIs contained in Interim Staff See Section 6 June 2016 Evaluation

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

- - These RAI responses are being reassessed and will be addressed 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 the VY at the end of the current operating cycle (Reference 6). 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.

Entergy plans to submit, in the August 2014 6-month status report, 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 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 the August 2014 status report.

6. Open Items from Overall Integrated Plan and Interim Staff Evaluation As discussed in Section 2, Vermont Yankee has received an Interim Staff Evaluation that includes 18 RAIs. Responses to the RAIs were requested by March 31, 2014, based on a Fall 2014 implementation date; the target completion date for the RAI responses has been revised Page 2 of 8

VY's Second Six Month Status Report for the Implementation of SFPI as discussed in Section 3. The following table provides a status of any RAIs documented in the Interim Staff Evaluation.

RAI #

Response Status 1

To be evaluated with revised OIP 2

To be evaluated with revised OIP 3

To be evaluated with revised OIP 4

To be evaluated with revised OIP 5

To be evaluated with revised OIP 6

To be evaluated with revised OIP 7

To be evaluated with revised OIP 8

To be evaluated with revised OIP 9

To be evaluated with revised OIP 10 To be evaluated with revised OIP 11 To be evaluated with revised OIP 12 To be evaluated with revised OIP 13 To be evaluated with revised OIP 14 To be evaluated with revised OIP 15 To be evaluated with revised OIP 16 To be evaluated with revised OIP 17 To be evaluated with revised OIP 18 To be evaluated with revised OIP

7. Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

Page 3 of 8

VY's Second Six Month Status Report for the Implementation of SFPI

8. References The following references support the updates to the overall integrated plan described in this attachment.

I

1. Vermont Yankee's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), BVY 13-015, dated February 28, 2013. (ML13064A301)

2. NRC Order Number EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012. (ML12054A679)

3. Vermont Yankee Nuclear Power Station - Request for Additional Information RE: Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051) (TAC NO. MF0780), dated June 20, 2013. (ML13165A279)

4. Response to Request for Additional Information Re: Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), BVY 13-065, dated July 19, 2013.

(ML13204A386)

5. Vermont Yankee's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), BVY 13-075, dated August 28, 2013 (ML13247A029)

6. Notification Of Permanent Cessation Of Power Operations, BVY 13-079, dated September 23, 2013 (ML13273A204)

7. Vermont Yankee Nuclear Power Station -Interim Staff Evaluation And Request For Additional Information Regarding The Overall Integrated Plan For Implementation Of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0780), dated November 26, 2013 (ML13311B077)

8. "Summary of the November 26, 2013, Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation," dated December 26, 2013 (ML13347B030)

Page 4 of 8

VY's Second Six Month Status Report for the Implementation of SFPI

9. Responses to the Interim Staff Evaluation Requests for Additional Information RAI #1 Please provide the results of the calculation used to determine the water elevation necessary for the pump's required NPSH to confirm that Level 1 has been adequately identified.