ML14239A029

Comment (1) of Anthony Leshinskie on Behalf of State of VT, Dept of Public Service, on Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations

ML14239A029
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	08/21/2014
From:	Leshinakie A R State of VT, Dept of Public Service
To:	Rules, Announcements, and Directives Branch
SECY RAS
References
79FR42539 00001, NRC-2014-0169
Download: ML14239A029 (4)

Text

PUBLIC SUBMISSION 6Page 1 of 1As of: August 22, 2014Received:

August 21, 2014Status: PendingPost Tracking No. ljy-8dxa-nioi Comments Due: August 21, 2014Submission Type: WebDocket: NRC-2014-0169 Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations Comment On: NRC-2014-0169-0001 Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations Document:

NRC-2014-0169-DRAFT-0001 Comment on FR Doc # 2014-17257 Submitter Information Name: Anthony Leshinskie Address:State of Vermont, Public Service Department 112 State StreetMontpelier, VT, 05620-2601 Email: Anthony.Leshinskie

@state.vt.us

~17ýTnDNJNJ"-'1m:,General CommentSee attached PDF for comments.

Attachments ENVY BVY 14-018 Public Period Comments PSD-ARL to NRCSUNSI Review CompleteTemplate

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08/22/2014 4V142?P.V VERMONTState of VermontDepartment of Public Service [phone] 802-828-2811 112 State Street [fax] 802-828-2342 Drawer 20 [tty] 800-734-8390 Montpelier, VT 05620-2601 http://www.publicservice.vermont.gov August 21, 2014Docket ID NRC-2014-0169 Comments from the Vermont Public Service Department regarding the following License Amendment Request published in the Federal Register on July 22, 2014:ENTERGY NUCLEAR VERMONT YANKEE, LLC & ENTERGY NUCLEAR OPERATIONS, INC.,DOCKET NO. 50-271, VERMONT YANKEE NUCLEAR POWER STATION, VERNON, VT.Date of amendment request:

March 24, 2014. A publicly available version is in ADAMS underAccession No. ML14085A257.

Description of amendment request:

The proposed amendment would revise the site emergency plan for the permanently defueled condition to reflect changes in the on-shift staffing andEmergency Response Organization staffing.

Gentlemen:

The subject Vermont Yankee License Amendment Request (LAR) has been reviewed by the StateNuclear Engineer and Decommissioning Coordinator on behalf of the State of Vermont and its PublicService Department.

Comments from this review are summarized in the table included in this letter andare respectfully submitted for Nuclear Regulatory Commission consideration as it examines the merits ofthis LAR as part of the Safety Evaluation Report process for Vermont Yankee.Please note that this review of the LAR was made with regard only to the interactions of the PublicService Department with Vermont Yankee On-Shift and Emergency Response Organization staff duringan Emergency Response Condition.

It is likely that other State of Vermont Agencies (e.g. the Division ofEmergency Management and Homeland Security or the Department of Health) that also interact with theVermont Yankee On-Shift and Emergency Response Organization staff will provide their own commentson this LAR.The Public Service Department comments on the LAR (ADAMS Accession No. ML14085A257) are asfollows:A Comment Attachment Section # /# # Description Comment1 1 5.2.4.2 In justifying elimination of the Technical Support Center(TSC) Reactor Engineer

position, the first Analysis paragraph implies that the Reactor Engineer's function can beperformed by the Shift Technical Advisor (STA). The STAposition is also being eliminated (per Section 5.2.4.1).

Eliminating the Reactor Engineer position should not rely onanother ERO or On-Shift Staffing position that is also beingeliminated.

Provide an alternate justification or reinstate theTSC Reactor Engineer position.

2 1 1 The discussion that identifies the post-shutdown on-shift staffpositions describes a total of 6 positions.

Subsequent discussion in Sections I & II of Attachment 4 (&Figure 8.1 ofAttachment

3) indicates that the minimum post-shutdown number of staff is 7 or 8, depending upon whether 1 of 2 FireBrigade positions is assigned to Radiation Protection Technician.

Attachment 1 makes no mention of the 2required Fire Brigade positions in its on-shift staff summary.To avoid confusion on the minimum staff requirements, eithermention these positions in the Attachment 1 summary or atleast note that additional minimum required positions arediscussed in Attachments 3 & 4. (This comment also appliesto Attachment 2, Pages 4 & 6 text and Attachment 3, Section8.1 text.)3 2 Table 8.4 -Do the 2 Fire Brigade positions noted in Comment #2 need toPage 2 of 2 be noted here?text4 4 Sections While the Station Blackout (SBO) rule clearly applies toIV.C.1 & VI operating power reactors, a brief statement indicating that theControl Room and Spent Fuel Pool-related systems at thepermanently shut down Vermont Yankee station will have ameans to receive electric power in the event of a loss ofoffsite electric power is still necessary.

This statement shouldindicate what on-site systems will remain available to supplythis back-up power source (e.g. the SBO Diesel Generator).

Alternatively, indicate what subsequent documentation willdiscuss back-up power sources.5 4 Sections While I concur that the described Control Room fire is theIV.C.2 & VI limiting scenario for this type of design basis accident, somediscussion is necessary to demonstrate that fire protection remains in place for the entire Vermont Yankee site to assurethat the Spent Fuel Pool and its associated support systemsare not compromised in the event of a fire anywhere on-site.Alternatively, indicate what subsequent documentation willdiscuss on-site fire protection.

.oJ ERMor Comment Attachment Section # /# # Description Comment6 4 I1.C.9 & The Time Motion Studies (TMS) included in this Attachment Subsequent assume that Vermont Yankee's Emergency Response DataE-Plan System (ERDS) link to the NRC will not be operational in theTables permanently shut down and defueled condition.

ERDS isspecifically identified in Vermont's Radiological Emergency Response Plan (RERP) as the means for the Public ServiceCoordinator, located at the State Emergency Operations Center (SEOC) during an emergency response condition, toassess Vermont Yankee conditions as part of Vermont's protective action decision-making process.

While it isrecognized that many of the ERDS parameters (e.g. thoserelated to the Reactor Coolant System and Safety Injection) are meaningless once Vermont Yankee is in a permanently shut down and defueled condition, the ERDS Radiation Monitoring System, Meteorological Data and Containment parameters related to the Spent Fuel Pool will still providemeaningful information.

As a result, the State of Vermontrequires that either 1) the ERDS link to the NRC be retainedduring Vermont Yankee's permanently shut down anddefueled period or 2) an alternate means similar to ERDS ismade available to provide equivalent Radiation Monitoring System, Meteorological information and Containment parameters relevant to the Spent Fuel Pool conditions for aslong as fuel remains within the Spent Fuel Pool.NRC or Vermont Yankee questions regarding these comments may be directed to the Vermont StateNuclear Engineer and Decommissioning Coordinator via the contact information included with theelectronic signature below.Regards,Is/ Anthony R. Leshinskie Anthony R. Leshinskie State Nuclear Engineer

& Decommissioning Coordinator State of VermontPublic Service Department 112 State StreetMontpelier, VT 05620-2601 Anthony.

Leshinskie@state.vt.us JIIII'1,V

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