ML080310822
| ML080310822 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 02/21/2008 |
| From: | Kuo P T NRC/NRR/ADRO/DLR |
| To: | O'Brien D State of VT, Dept of Public Service |
| Rowley J, NRR/DLR/RLRB, 415-4053 | |
| Shared Package | |
| ML080310774 | List: |
| References | |
| TAC MD7992, Y020080024 | |
| Download: ML080310822 (7) | |
Text
February 21, 2008
David O'Brien, Commissioner Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, VT 05620-2601
Dear Mr. O'Brien:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter of December 17, 2007, regarding the final safety evaluation report (FSER) for the Vermont Yankee Nuclear Power Station (VYNPS). In your correspondence, you requested that I review the VYNPS FSER before it is issued to ensure that it addresses the issues discussed in the audit report from the Office of the Inspector General (OIG) issued on September 6, 2007 (OIG-07-A-15), regarding the NRC's license renewal program. With respect to this request, I can assure you that I and many other NRC staff and managers review all license renewal safety evaluation reports (SERs) before they are issued.
It is important to note that the OIG findings were specific to the documentation of the technical review, not the sufficiency of the technical review. OIG concluded that, "overall, the NRC has developed a comprehensive license renewal process to evaluate applications for extended periods of operation." However, OIG identified areas where improvements would enhance program operations. Specifically, OIG determined that a consistent evaluation of operating experience would improve NRC reviews.
The NRC has already implemented some improvements to address the OIG findings, and more are forthcoming. The agency updated the SER style guide, and project managers and audit team members took mandatory SER input documentation training. The staff implemented these improvements during its review of the VYNPS license renewal application (LRA).
In your letter, you requested assurance that the NRC independently verified the operating experience for VYNPS. We reviewed operating experience in two ways. In developing NUREG-1800, "Generic Aging Lessons Learned (GALL) Report," a staff technical guidance document, the staff reviewed industry-wide operating experience as an attribute of acceptable aging management programs. An applicant describes plant-specific operating experience in its LRA. The staff reviews the information in the application to verify that the applicant adequately considered the operating experience documented in the GALL Report as well as that which is specific to its facility during onsite audits. The staff documented the results of the audits related to VYNPS in an audit report, dated March 29, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML070860005).
The forthcoming FSER for VYNPS will include the results of the audit. In addition, t he NRC region-based inspectors performed a 2-week onsite inspection of the applicant's aging management programs, which included a thorough evaluation of the applicant's operating experience through a review of the corrective action database. The June 4, 2007, regional inspection report documents the results of the onsite review (ADAMS Accession No. ML071550330).
D. O'Brien
With respect to the independence of the NRC staff's review, the NRC independently verifies claims made by an applicant in its LRA. In a typical LRA review, the NRC asks approximately 400 questions during the audits and submits approximately 100 requests for additional information (RAIs). In its FSER, the NRC documents a technical basis for determining that answers to the audit questions and responses to the RAIs are acceptable. Experienced and knowledgeable NRC staff make t he determinations of acceptability based on staff review guidance, consistency with the GALL Report, and compliance with Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." The staff conducted its review of VYNPS in accordance with this established practice.
At the site, a regional team inspects the program descriptions and/or implementing procedures for the aging management programs and verifies the accuracy of the information contained in the application, independent of the safety review being performed by staff in the Office of Nuclear Reactor Regulation (NRR). The regional team makes a separate recommendation to the Director of NRR with regard to the implementation of the applicant's proposals on the basis of its inspections. In addition, the NRR staff and the regional team support each other by sharing issues identified during the review and inspections. This mutual support has resulted in additional technical reviews or inspections in the past.
If you have any additional questions regarding the license renewal process, please have your staff contact Mr. Jonathan Rowley of my staff at 301-415-4053.
Sincerely, /RA/ Pao-Tsin Kuo, Director Division of License Renewal Office of Nuclear Reactor Regulation
(Package) ML080310774; (Incoming) ML080320105; (Response) ML080310822 OFFICE LA:NRR:DLR PM:RPB2:DLR BC:RPB2:DLR TECH EDITOR*Region I* D:DLR NAME IKing JRowley RFranovich w/edits HChang MModes PTKuo DATE 02/07/08 02/05/08 02/11/08 02/06/08 02/20/08 02/21/08 OFFICE OGC NAME MBaty DATE 02/08/08 Letter to D. O'Brien from P.T. Kuo, dated February 21, 2008
DISTRIBUTION
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JRowley RLaufer JShea RPowell, RI DScrenci, RI MModes, RI DPelton, SRI MYoung RidsOpaMail Vermont Yankee Nuclear Power Station
cc:
Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415
Mr. David R. Lewis Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W.
Washington, DC 20037-1128
Mr. David O'Brien, Commissioner Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601
Mr. James Volz, Chairman Public Service Board State of Vermont 112 State Street Montpelier, VT 05620-2701
Chairman, Board of Selectmen Town of Vernon P.O. Box 116 Vernon, VT 05354-0116
Operating Experience Coordinator Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354
G. Dana Bisbee, Esq.
Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937
Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108
Ms. Carla A. White, RRPT, CHP Radiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070
Mr. David Mannai Manager, Licensing Entergy Nuclear Operations Vermont Yankee Nuclear Power Station P.O. Box 500 185 Old Ferry Road Brattleboro, VT 05302-0500
Resident Inspector Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission P.O. Box 176 Vernon, VT 05354
Director, Massachusetts Emergency Management Agency ATTN: James Muckerheide 400 Worcester Road Framingham, MA 01702-5399
Jonathan M. Block, Esq.
Main Street P.O. Box 566 Putney, VT 05346-0566
Mr. John F. McCann Director, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
Mr. John T. Herron Sr. Vice President Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213
Mr. Oscar Limpias Vice President, Engineering Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213
Vermont Yankee Nuclear Power Station
cc:
Mr. Christopher Schwartz Vice President, Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
Mr. William C. Dennis Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
Mr. Theodore Sullivan Site Vice President Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station P.O. Box 500 185 Old Ferry Road Brattleboro, VT 05302-0500
Mr. James H. Sniezek 5486 Nithsdale Drive Salisbury, MD 21801
Mr. Garrett D. Edwards 814 Waverly Road Kennett Square, PA 19348
Ms. Stacey M. Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue New Orleans, LA 70113
Mr. Norman L. Rademacher Director, NSA
Mr. Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, ME 04556
Mr. James P. Matteau Executive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301
Mr. William K. Sherman Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, VT 05620-2601
Mr. Michael D. Lyster 5931 Barclay Lane Naples, FL 34110-7306
Diane Curran, Esq.
Harmon, Curran, Spielberg &
Eisenberg, L.L.P 1726 M Street, NW, Suite 600 Washington, DC 20036
Ronald A. Shems, Esq.
Shems, Dunkiel, Kassel & Saunders, PLLC 91 College Street Burlington, VT 05401
Karen Tyler, Esq.
Shems, Dunkiel, Kassel & Saunders, PLLC 91 College Street Burlington, VT 05401
Sarah Hofmann, Esq.
Director of Public Advocacy Department of Public Service 112 State Street - Drawer 20 Montpelier, VT 05620-2601 PO Box 0500 Brattleboro, VT 05302-0500
Vermont Yankee Nuclear Power Station
cc:
Jennifer J. Patterson, Esq.
Office of the New Hampshire Attorney General 33 Capitol Street Concord, NH 03301
Matias F. Travieso-Diaz, Esq.
Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, NW Washington, DC 20037-1128
Matthew Brock, Esq.
Assistant Attorney General Office of the Massachusetts Attorney General Environmental Protection Division One Ashburton Place, Room 1813 Boston, MA 02108-1598
Anthony Z. Roisman, Esq.
National Legal Scholars Law Firm 84 East Thetford Road Lyme, NH 03768
John Sipos, Assistant Attorney General Office of the Attorney General The Capitol State Street Albany, NY 12224