BVY 15-022, Notification of Changes to Regulatory Commitments
| ML15091A381 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/27/2015 |
| From: | Wamser C Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY 15-022 | |
| Download: ML15091A381 (7) | |
Text
---Entergy Entergy Nuclear Oper iOios, Inc.
Vermont Yankee 320 Governor Hunt Rd
/
Vernon, VT 05354 7
Tel 802 257 7711 Christopher J. Wamser Site Vice President BVY 15-022 March 27, 2015 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Notification of Changes to Regulatory Commitments Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28
Dear Sir or Madam:
Pursuant to the guidance in Nuclear Energy Institute (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes," Revision 0, attached is a summary of recently changed commitments at Vermont Yankee Nuclear Power Station. These commitment changes were evaluated as not requiring prior NRC approval.
This letter provides NRC notification of these changes. Attachment 1 includes a summary of regulatory commitment changes and a basis for each change. No NRC action is requested on this issue.
This letter contains no new regulatory commitments.
Should you have any questions or require additional information concerning this submittal, please contact Mr. Coley Chappell at (802) 451-3374.
Sincerely,
[CJW/plc]
Attachments:
- 1. Summary Report of Regulatory Commitment Changes A u)!
(7 k1-7 ju-
BVY 15-022 / Page 2 of 2 cc:
Mr. Daniel H. Dorman, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 USNRC Resident Inspector Vermont Yankee Mr. Christopher Recchia, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601
BVY 15-022 Docket No. 50-271 Vermont Yankee Nuclear Power Station Summary Report of Regulatory Commitment Changes
BVY 15-022 1 Attachment 1 / Page 1 of 4 VERMONT YANKEE NUCLEAR POWER STATION COMMITMENT CHANGE
SUMMARY
REPORT COMMITMENT SOURCE(S)
ORIGINAL COMMITMENT(S)
PROPOSED CHANGE AND JUSTIFICATION NUMBERS 16829, 16830, Letters to NRC Revise applicable High Pressure Core Injection On January 12, 2015, Entergy docketed the 16831, 16907, dated October 14, (HPCI) procedure(s) to require dynamic venting certifications of permanent cessation of operations 16908, 16909, 2008 and October of HPCI discharge piping following any and permanent removal of fuel from the reactor 16949 22, 2009 maintenance activities that could drain the vessel for the Vermont Yankee Nuclear Power system. (16909)
Station (VYNPS). Generic Letter 2008-01 does not Install vents on HPCI suction and discharge apply to permanently defueled facilities. As a result, piping, Core Spray (CS) suction piping, these commitments were retired due to the Residual Heat Removal (RHR) suction piping permanent defueling of VYNPS.
and RHR Low Pressure Coolant Injection (LPCI) piping and revise applicable procedures to include periodic venting or Ultrasonic examination (UT). (16829, 16830, and 16949)
Revise existing procedures to capture the results of venting operations, on HPCI, CS and RHR systems. (16831 and 16908)
Implement performance based administrative controls to UT or vent HPCI, RHR and CS suction piping and CS discharge piping. (16907) 16759, 16760, Letter to NRC dated Enhance the guidance for manually starting the These commitments originated from VYNPS' 16761, 16762 January 11, 2007 Reactor Core Isolation Cooling (RCIC) System response to NRC Order EA-02-026, Section to provide provisions for monitoring Reactor II.B.5.b, which required Licensees to develop Pressure Vessel (RPV) level. (16759) mitigating strategies related to the key safety Develop guidance for depressurizing the RPV functions of core cooling, containment, and SFP using the safety relief valves (SRVs) and for cooling.
injection into the RPV with a portable pump.
(16760)
On January 12, 2015, Entergy docketed the Develop guidance for injection into the hotwell certifications of permanent cessation of operations and containment and makeup to the and permanent removal of fuel from the reactor Condensate Storage Tank (CST) using a vessel for the VYNPS. As a result, core damage is portable pump. (16761) no longer possible and primary containment no Develop guidance regarding manually opening longer performs a design function. Thus, the B.5.b a containment vent line. (16762) commitments associated with starting the RCIC system, utilizing the SRVs, injecting into the RPV,
BVY 15-022 / Attachment 1 / Page 2 of 4 VERMONT YANKEE NUCLEAR POWER STATION COMMITMENT CHANGE
SUMMARY
REPORT COMMITMENT SOURCE(S)
ORIGINAL COMMITMENT(S)
PROPOSED CHANGE AND JUSTIFICATION NUMBERS injection into the hotwell and containment, providing makeup to the CST, and opening a containment vent were retired and reclassified as historical, because the applicable systems, structures and components performance requirements regarding core cooling and primary containment were no longer required in the defueled state.
16872, 16766, Letters to the NRC Update Generic Letter (GL) 89-13 Program The purpose of the GL 89-13 Program was to 16767, 16768, dated January 22, document(s) to require inspection and cleaning ensure the service water system could perform its 16974, 16975, 1990, December 11, of the RHR heat exchangers and eliminate required safety functions. On January 12, 2015, 16977, 16978, 2001, January 25, periodic testing. (16872)
Entergy docketed the certifications of permanent 16980, 16981, 2007, and Perform inspection and cleaning of the Spent cessation of operations and permanent removal of 16982 November 12, 2014 Fuel Pool Cooling (SFPC) heat exchangers fuel from the reactor vessel for the VYNPS and has every 3 years with an allowed +/- 25%
implemented Amendment 262 to the Renewed tolerance. (16766)
Facility Operating License, which relaxed the Perform eddy current testing of the SFPC heat requirements for when secondary containment is exchangers every 6 years with an allowed +
required to be operable. As a result of these 25% tolerance. (16767) changes, the components cooled by service water no longer serve a safety related function including Perform monitoring of the Residual Heat that performed by the SFPC heat exchangers.
Removal Service Water (RHRSW) pump motor Therefore, the GL 89-13 program will no longer be coolers quarterly with an allowed +/- 25%
maintained including periodic inspection and testing tolerance. (16768) of the SFPC heat exchangers and piping. The GL Perform water and substrate sampling annually 89-13 Program will no longer be maintained. Thus, to detect the presence of both asiatic clams and these commitments were retired and reclassified as zebra mussels. If sampling detects their historic.
presence, system chlorination or an equally effective treatment program will be instituted.
(16974)
Add the four reactor recirculation units and the four RHRSW motor coolers to existing equipment monitoring programs. (16975)
Perform cleaning and inspection of Reactor Building Closed Cooling Water heat exchangers
BVY 15-022 / Attachment 1 / Page 3 of 4 VERMONT YANKEE NUCLEAR POWER STATION COMMITMENT CHANGE
SUMMARY
REPORT COMMITMENT SOURCE(S)
ORIGINAL COMMITMENT(S)
PROPOSED CHANGE AND JUSTIFICATION NUMBERS once per cycle. (16977)
Perform cleaning and inspection of Emergency Diesel Generator (EDG) jacket, lube oil and after coolers as necessary when a preventive maintenance overhaul is performed on the EDGs. (16978)
Perform heat transfer performance testing of Reactor Recirculation Unit (RRU) 7 and RRU 8.
Not to exceed once every three years. (16980)
Maintain the service water valve inspection program. (16981)
Identify locations in the service water system that may be susceptible to erosion and silting.
Perform appropriate inspection of these locations so that corrective action can be taken.
(16982) 16844,16845, Letters to the NRC Review exceptions to the applicable Joint On January 12, 2015, VYNPS docketed the 16865, 16867, dated November 15, Owners Group (JOG) Phase 2 and 3 results, in certifications of permanent cessation of operations 16956,16957 1996, March 13, accordance with VYNPS' Program for managing and permanent removal of fuel from the reactor 1997, May 27, 1999, regulatory commitments. (16844) vessel. The purpose of the MOV Program was to and November 14, Implement the results of the JOG Program perform periodic verification of the capability of 2000 Phases 2 and 3. (16845) safety-related MOVs to perform their safety Revise the Motor-Operated Valve (MOV) functions consistent with the current licensing bases Program Procedure to: (1) Establish a of VYNPS. No MOVs are required to perform a requirement to complete operability evaluations safety function in the defueled state. Thus, these reqireentto ompeteopeabiityevauatonscommitments were retired and reclassified as prior to returning components back to service following maintenance or testing activities, (2) historic.
Establish the criteria for the initial evaluations and a time frame for completing formal calculations and (3) Establish the method for tracking completion of revised MOV calculations. (16865)
Revise applicable MOV calculations to
BVY 15-022 / Attachment 1 / Page 4 of 4 VERMONT YANKEE NUCLEAR POWER STATION COMMITMENT CHANGE
SUMMARY
REPORT COMMITMENT SOURCE(S)
ORIGINAL COMMITMENT(S)
PROPOSED CHANGE AND JUSTIFICATION NUMBERS incorporate an application factor of 0.9 per Limitorque Technical Update 98-01. (16867)
Implement NRC GL 96-05 MOV Periodic Verification Program. (16956)