Vermont Yankee Presentation to VSNAP 7/9/12 VY/Entergy
Fukushima Response Bernard Buteau
Slide 2
Tonights Presentation Industry Actions Immediately Following
the accident at Fukushima Key Priorities for longer term responses
Industry response to INPO Event Report and NRC Orders Industry FLEX
approach VY Specific Response to INPO Event Report VY Schedule to
respond to NRC Orders Entergy Organizational Structure addressing
NRC Orders
Slide 3
Industry Starting Points NRC Near Term Task Force (NTTF)
established to identify Fukushima Lessons Learned NRC Management
established priorities to address Task Force Recommendations 3
Priorities established: Tiers 1, 2, and 3 Tier 1 Issues being
addressed now NRC Orders and 50.54(f) address Tier 1
Recommendations Tier 1 issue on Station Blackout (SBO) Rulemaking
intended to address gaps between current SBO regulations and loss
of power due to Beyond Design Basis Events Joint industry/Nuclear
Energy Institute (NEI) Task Forces working with NRC for all issues;
Entergy represented on all Task Forces Standardization
industry/fleet working through NEI to establish common guidance,
methods, and submittals; Entergy developing fleet solutions
Slide 4
Design Basis and Beyond Design Basis Design Basis information
identifies specific functions performed by a system, structure or
component as defined in the Vermont Yankee Updated Final Safety
Analysis Report (UFSAR) Design Basis Events incorporate realistic
worst case scenarios (e.g. Maximum Expected Flood conditions,
Seismic Events, etc) Beyond Design Basis Events postulate events
that are more severe than those considered as Design Basis
Events
Slide 5
Key Priorities Maintain Operational Safety Focus Create an
Entergy Fukushima response Organization Establish Points of Contact
Corporate Governance and Site Execution Brief Site Points of
Contact Select Vendors Develop work breakdown structure/project
scoping Establish plans, resource needs, and budgets Enhance
integration with and communications to sites
Slide 6
Tier 1 Recommendations Seismic/Flooding Reevaluation [Analyses]
Seismic/Flooding Inspections SBO/Extended Loss of AC Power
Rulemaking Mitigation of Beyond Design Basis Events Loss Of
Ultimate Heat Sink [LUHS] and Extended Loss of AC Power [ELAP]
Reassess Mark I Hardened Containment Vent Install new Spent Fuel
Pool Instrumentation Enhance Emergency Operating Procedures (EOPs)
Severe Accident Management Guidelines (SAMGs) and Extensive Damage
Management Guidelines (EDMGs) Reassess Emergency Plan (EP) Staffing
and Communications
Slide 7
NRC Orders and 50.54(f) Letter March 12, 2012 Three Orders
Hardened Containment Vents Spent Fuel Pool Instrumentation
Mitigation Strategies for Beyond Design Basis External Events
(Note: For VY the design basis river level is 252 feet normal river
level is around 219 feet. River level rose to a max of 223 feet
after Hurricane Irene) 50.54(f) Letter - (NRC Requests for
Information) Perform Seismic Reevaluation and Inspections to new
criteria Perform Flooding Reevaluation and Inspections to new
criteria Assess Emergency Plan Staffing and Communications to new
criteria
Slide 8
Order 1 - Mitigation Strategies for Beyond Design Basis (BDB)
External Events Strategies must maintain/restore core cooling,
containment, and Spent Fuel Pool cooling Response equipment must be
reasonably protected from external events Three phased approach to
severe events, including Extended Loss of all AC Power (ELAP) and
Loss of Ultimate Heat Sink (LUHS) Phase 1 relies on installed
equipment and resources to respond to severe event Phase 2 relies
on portable, onsite equipment to extend response capability Phase 3
relies on offsite resources for long term response Industry has
proposed FLEX system Interim Staff Guidance to be issued by NRC in
August 2012
Slide 9
Order 2 - Hardened Containment Vent Design Features: Requires
remote operation AND monitoring capability Sized to prevent
containment overpressure No spurious actuation Upgrades containment
vent in place since early 1990s Interim Staff Guidance scheduled to
be issued by NRC in August 2012
Slide 10
Order 3 - SFP Instrumentation Design Features: Independent
primary backup instruments to measure pool level Protected from
hazards Mounted to ensure functionality post-seismic event Can
withstand expected environment Interim Staff Guidance scheduled to
be issued by NRC in August 2012
Slide 11
The Industry FLEX Approach Industry response to Order on Beyond
Design Basis (BDB) Events Key Goals: Prevent fuel damage (Core and
Spent Fuel Pool) Provide diverse, redundant, flexible means to
restore and maintain core and fuel pool cooling and containment
Assumes Extended Loss of AC Power and Loss of Ultimate Heat Sink
N+1 Sets of Portable equipment for mitigation Interim Staff
Guidance scheduled to be issued by NRC in August 2012 First round
of equipment ordered for each site
Slide 12
NEI 12-06 Diverse and Flexible coping Strategies (FLEX)
Slide 13
NRC Orders Key Dates Mar 2012 NRC Orders issued Apr 2012Sites
acknowledge no hardship with the Orders; COMPLETE Aug 2012NRC to
issue Interim Staff Guidance Oct 2012Initial Status Reports due
from industry Feb 2013Overall Integrated Plans due (update every 6
months thereafter) Full Compliance to all Orders must be achieved
by the sooner of December 31, 2016 or the 2 nd RFO from submittal
of the integrated plan
Slide 14
INPO and NRC Fukushima Orders INPO Requirements 3/15/11 INPO
Event Report (IER) 11-1* [All actions required complete by 4/16/11]
NRC Requirements 4/18/11 NRC issued Inspection Manual / Temp
Instructions 4/22/11 NRC Inspection of VY per Temp Instructions
{NRC Inspection / no findings} 5/11/11 NRC Bulletin 2011-11
Mitigating Strategies issued to obtain a comprehensive verification
that licensees' mitigating strategies maintain or restore core
cooling, spent fuel cooling, and containment following a large
explosion or fire 3/12/12 NRC issued Orders to modify licenses *
Tsunami occurred on 3/11/11
Slide 15
VY Immediate Response to INPO Event Report 11-1 Addressed
recommendations made in INPO Level 1 Event Report 11-1 by doing the
following: Verified plant staffs ability to mitigate conditions
that result from beyond design basis events (Security, Severe
Accident Management) Verified that emergency equipment is available
and functional Tested active equipment and walked down and
inspected passive equipment Verified that procedures to implement
needed strategies are in place and executable Verified
qualifications of operators and support staff who operate the
emergency equipment Verified that needed agreements and contracts
are in place to help mitigate consequences Above actions were
performed by March 23 rd, 2011
Slide 16
VY Immediate Response to INPO Event Report 11-1 Verified the
capability to mitigate Station Blackout (SBO) required by station
design is functional and valid Performed walk downs and inspections
to verify all required materials properly staged Demonstrated
through walk downs that procedures for response to SBO are
executable Completed walk downs and inspections by March 30 th,
2011
Slide 17
VY Immediate Response to INPO Event Report 11-1 Verified the
capability to mitigate internal and external flooding events meets
station design: Verified through walk downs and inspections that
required materials and equipment are adequate and properly staged
Verified that accessible doors and barriers are functional
Completed verification actions by April 6 th, 2011
Slide 18
VY Immediate response to INPO Event Report 11-1 Performed walk
downs and inspections of equipment needed to mitigate fire and
flood events to identify the potential that the equipments function
could be lost during a seismic event Identified mitigating
strategies for identified vulnerabilities Performed walk downs and
inspections of important equipment such as: Storage tanks Plant
water intake structure and Fire and flood response equipment to
develop mitigating strategies to cope with loss of important
functions These walk downs and inspections were completed by April
13 th, 2011
Slide 19
VY Immediate response to INPO Level 1 Event Report Results
Enhancement/Improvement recommendations included items such as:
Creation of new Preventive Maintenance activities to check air
pressure in vehicle tires, modify cooling tower panels to allow
faster access to deep basin, create test to check pump flow, etc
Replacement of small portable generator Enhancing procedures to add
or improve content Creating new or improved training modules Any
issues identified during the INPO walk downs were entered into the
VY Corrective Action Tracking system
Slide 20
VY Fukushima Projected Response Dates to NRC Orders
Slide 21
SR Vice President Fukushima Project Management Organization
Over 100 staff & Contract Personnel VP EngineeringVP Project
ManagementVP Project LicensingVP Fukushima Project Sr. Licensing
ManagerExecutive AssistantGeneral Manager Project Director
Engineering Lead Fleet Project Manager Licensing Lead Director
Project Mgt Fleet DE Leads Fleet Licensing Leads
Slide 22
Fukushima Project Design Engineering Organization Contractor
Lead Eng VP Engineering Lead Engineer SBO/FLEX Lead Seismic Lead
Flooding Lead Cont. Vent Lead SFP Instr. Lead EP Lead Entergy Site
Leads ANO - GGNS - IPEC - JAF - PLP - PNPS - RBS - VY- W3 - Entergy
Site Leads ANO - GGNS - IPEC - JAF - PLP - PNPS - RBS - VY- W3 -
Entergy Site Leads ANO - GGNS - IPEC - JAF - PLP - PNPS - RBS - VY-
W3 - Entergy Site Leads ANO - GGNS - IPEC - JAF - PLP - PNPS - RBS
- VY- W3 - Entergy Site Leads ANO - GGNS - IPEC - JAF - PLP - PNPS
- RBS - VY- W3 - Entergy Site Leads ANO - GGNS - IPEC - JAF - PLP -
PNPS - RBS - VY- W3 - VP Fukushima Project GM Engineering Seismic
Lead
Slide 23
Executive Sponsor Asst. Executive Sponsor PM Director Fleet PM
Assistant PM Manager of Projects (9 sites) Entergy Site PMs ANO -
GGNS - IPEC - JAF - PLP - PNPS - RBS - VY- W3 - Site Project Teams
Estimator Scheduler Cost Eng. Engineering Field Eng. Licensing EP
Support Operations Maintenance (Others as needed) Sr. Licensing Mgr
Licensing Engineer Site Licensing Mgrs (9 sites) EP Director Site
Licensing Leads ANO - GGNS - IPEC - JAF - PLP - PNPS - RBS - VY- W3
- EP Managers (9 sites) Site EP Staff Leads ANO - GGNS - IPEC - JAF
- PLP - PNPS - RBS - VY- W3 - Fukushima Project Project Team
Organization Corp. Project Team Scheduler Estimator Cost Eng. -
Communications - Corporate Positions DE Director
