3-1-2013 Letter from VY to NRC Plan for Reliable ... - State of Vermont

AREVA NP Inc.ANP-3203Revision 0Vermont Yankee Nuclear Power Station’s Overall Integrated Plan in Response to March 12, 2012Commission Order Modifying Licenses with Regard to Requirements for Reliable HardenedContainment Vents (Order Number EA-12-050)Section 5:Procedures and TrainingRequirement 3.1- Develop, Implement, and Maintain ProceduresPage 25Licensees shall develop, implement and maintain procedures necessary for the safe operation of theHCVS, Procedures shall be established for system operations when normal and backup power is available,and during S8O conditions.l$G 3.1 Criteria:Procedures shall be developed describing when and how to place the HCVS in operation, the location ofsystem components, instrumentation available, normal and backup power supplies, directions for sustainedoperation, including the storage location of portable equipment training on operating the portableequipment, and testing of equipment. The procedures shall identify appropriate conditions and criteria foruse of the HCVS. The procedures shall clearly state the nexus between CAP and ECCS pumps during aOBLOCA and how an inadvertent opening of the vent valve could have an adverse impact on this nexus.The HCVS procedures shall be developed and implemented in the same manner as other plant proceduresnecessary to support the execution of the EOPs.Licensees shall establish provisions for out-of-service requirements of the HCVS and compensatorymeasures. These provisions shall be documented in the Technical Requirements Manual (TRM) or similardocument. The allowed unavailability time for the HCVS shall riot exceed 30 days during modes 1, 2 and 3.if the unavailability time exceeds 30 days. the TRM shall direct licensees to perform a cause assessmentand take the necessary actions to restore HCVS availability in a timely manner, consistent with plantprocedures and prevent future unavailability for similar causes.Response (ref. ISG Item 3.1):Procedures will be established for system operations when normal and backup power is available,and during prolonged SBO conditions.The HCVS procedures will be developed and implemented following the plants process forinitiating or revising procedures and contain the following details:• appropriate conditions and criteria for use of the HCVS• when and how to place the HCVS in operation,• the location of system components,• instrumentation available,• normal and backup power supplies,• directions for sustained operation(reference NEI 12-06), including the storagelocation of portable equipment,• training on operating the portable equipment, and• testing of portable equipmentThe procedures will state the impact on ECCS, RHR, and CS pumps NPSH (loss of CAP) duringa DBLOCA due to an inadvertent opening of the vent.Licensees will establish provisions for out-of-service requirements of the HCVS andcompensatory measures. The following provisions will be documented in the TechnicalRequirements Manual (TRM) or other controlled document:• The allowed unavailability time for the HCVS shall not exceed 30 days during modes 1, 2,and 3.• If the unavailability time exceeds 30 days