BVY 07-043, Revision of Technical Specification Bases Pages
| ML071800288 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/21/2007 |
| From: | Ted Sullivan Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY 07-043 | |
| Download: ML071800288 (11) | |
Text
Entergy Nuclear Operations, Inc.
Vermont Yankee P.O. Box 0500
--e-E185 Old Ferry Road SEn tergy Brattleboro. VT 05302-0500 Tel 802 257 5271 June 21, 2007 BVY 07-043 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Revision of Technical Specification Bases Pages This letter provides revised Technical Specification (TS) Bases pages.
Bases pages 19c through 19f have been revised to incorporate the Bases statements for LCO 3.0.8 into Section 3.0/4.0.
LCO 3.0.8 was incorporated into the TS by License Amendment No. 230.
The content changes are limited to those on page 19c; the content for the SR 4.0.1 through SR 4.0.3 Bases was displaced to pages 19d through 19f by this addition, with no changes in the wording.
These changes to the TS Bases have been determined not to require prior NRC approval in accordance with 10CFR50.59.
For your information and records, a marked-up copy of the Bases pages as well as a re-typed copy are included as Attachment 1 and 2.
There are no new regulatory commitments contained in this submittal.
Should you have any questions concerning this matter, please contact Mr. David Mannai at (802) 258-5422.
Sincerely, Si Vice P esideh-/
Vermon ankee Nuclear Power Station Attachments (2) cc listing (next page)
Aja.
BVY 07-043 Page 2 of 2 cc:
Mr. Samuel J. Collins Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. James Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601
BVY 07-043 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Revision of Technical Specification Bases Pages Marked-up Version of Bases Pages
VYNPS BASES:
TS 3.0 Limiting Conditions for Operation Applicability Reserved.
TS 4.0 Surveil Re r
n
) Applicability SR 4.0.1 Bases SR 4.0.1 establishes the requirement that SRs must be met during the modes or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs.
This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits.
Failure to meet a Surveillance within the specified frequency, in accordance with SR 4.0.2, constitutes a failure to meet an LCO.
Systems and components are assumed to be OPERABLE when the associated SRs have been met.
Nothing in this Specification,
- however, is to be construed as implying that systems or components are OPERABLE when either:
- a. The systems or components are known to be inoperable, although still meeting the SRs or
- b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.
Surveillances do not have to be performed when the unit is in a mode or other specified condition for which the r i pements..of the associated LCO are not applicable, unless otherwise specified.
Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR.
In this case, the unplanned event may be credited as fulfilling the performance of the SR.
This allowance includes those SRs whose performance is normally precluded in a given mode or other specified condition.
Surveillances do not have, to be performed on inoperable equipment because the LCOs define the remedial measures that apply.
Surveillances have to be met and performed in accordance with SR 4.0.2, prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE.
This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 4.0.2.
Post maintenance testing may not be possible in the current SR 4.0.1 mode or other specified conditions in the Applicability due to the necessary unit parameters not having been established.
In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function.
This will allow operation to proceed to a mode or other specified condition where other necessary post maintenance tests can be completed.
An example of this process is:
- a. High pressure coolant injection (HPCI) maintenance during shutdown that requires system functional tests at a
specified pressure.
Provided other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE.
This allows operation to reach the specified pressure to complete the necessary post maintenance testing.
Amendment No.
221 19c
INSERT 1 LCO 3.0.8 Bases LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s).
This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not being capable of performing their associated support function(s).
This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control.
The snubber requirements do not meet the criteria in 10 CFR 50.36(c) (2) (ii), and, as such, are appropriate for control by the licensee.
If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the conditions and required actions entered.
LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a siAgle train or subsystem supported system.
LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.
LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system.
LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.
INSERT 1 (continued)
LCO 3.0.8 Bases (Continued)
LCO 3.0.8 requires that risk be assessed and managed.
Industry and NRC guidance on the implementation of 10 CFR 50.65(a) (4)
(the Maintenance Rule) does not address seismic risk.
However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed.
The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.
BVY 06-07-043 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Revision of Technical Specification Bases Pages Retyped Version of Bases Pages
VYNPS BASES:
TS 3.0 Limiting Conditions for Operation Applicability LCO 3.0.8 Bases LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s).
This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not being capable of performing their associated support function(s).
This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control.
The snubber requirements do not meet the criteria in IOCFR5O.36(c) (2) (ii),
and as such, are appropriate for control by the licensee.
If the allowed time expires and the snubbers(s) are unable to perform their associated support function(s),
the affected supported system's LCO(s) must be declared not met and the conditions and required actions entered.
LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system.
LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.
LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system.
LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable.
The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.
LCO 3.0.8 requires that risk be assessed and managed.
Industry and NRC guidance on the implementation of 10CFR50.65(a) (4)
(the Maintenance Rule) does not address seismic risk.
- However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed.
The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more
,snubbers are not able to perform their associated support function.
Amendment No.
-214, BVY 07-043 19c
VYNPS TS 4.0 Surveillance Requirement (SR) Applicability SR 4.0.1 Bases SR 4.0.1 establishes the requirement that SRs must be met during the modes or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs.
This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits.
Failure to meet a Surveillance within the specified frequency, in accordance with SR 4.0.2, constitutes a failure to meet an LCO.
Systems and components are assumed to be OPERABLE when the associated SRs have been met.
Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when either:
- a. The systems or components are known to be inoperable, although still meeting the SRs or
- b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.
Surveillances do not have to be performed when the unit is in a mode or other specified condition for whichthe requirements of the associated LCO are not applicable, unless otherwise specified.
Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR.
In this case, the unplanned event may be credited as fulfilling the performance of the SR.
This allowance includes those SRs whose performance is normally precluded in a given mode or other specified condition.
Surveillances do not have to be performed on inoperable equipment because the LCOs define the remedial measures that apply.
Surveillances have to be met and performed in accordance with SR 4.0.2, prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE.
This includes ensuring applicable Surveillances are not failed and their most recent performance.is in accordance with SR 4.0.2.
Post maintenance testing may not be possible in the current SR 4.0.1 mode or other specified conditions in the Applicability due to the necessary unit parameters not having been established.
In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function.
This will allow operation to proceed to a mode or other specified condition where other necessary post maintenance tests can be completed.
An example of this process is:
- a.
High pressure coolant injection (HPCI) maintenance during shutdown that requires system functional tests at a specified pressure.
Provided other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE.
This allows operation to reach the specified pressure to complete the necessary post maintenance testing.
Amendment No.
2-24=, BVY 07-043 19d
VYNPS SR 4.0.2 Bases SR 4.0.2 permits a 25% extension of the interval specified in the Frequency.
This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).
The 25% extension does not significantly degrade the reliability that results from performing the surveillance at its specified frequency.
This is based on the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the SRs.
The exceptions to SR 4.0.2 are those Surveillances for which the 25%
extension of the interval specified in the frequency does not apply.
These exceptions are stated in the individual Specifications.
The requirements of regulations take precedence over the TS.
An example of where SR 4.0.2 does not apply is in the Primary Containment Leakage Rate Testing Program.
This program establishes testing requirements and frequencies in accordance with the requirements of regulations.
The TS cannot in and of themselves extend a test interval specified in the regulations.
The provisions of SR 4.0.2 are not intended to be used repeatedly merely as an operational convenience to extend surveillance intervals (other than those consistent with refueling intervals).
SR 4.0.3 Bases SR 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a surveillance has not been completed within the specified frequency.
A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater, applies from the point in time that it is discovered that the surveillance has not been performed in accordance with SR 4.0.2, and not at the time that the specified Frequency was not met.
This delay period provides adequate time to complete surveillances that have been missed.
This delay period permits the completion of a surveillance before complying with action statements or other remedial measures that might preclude completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the surveillance, the safety significance of the delay in completing the required surveillance, and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the requirements.
When a surveillance with a frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering Run Mode after each fuel loading, or in accordance with 10CFR50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 4.0.3 allows for the full delay period of up to the specified frequency to perform the surveillance.
- However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 4.0.3 provides a time limit for, and allowances for the performance of, surveillances that become applicable as a consequence of Mode changes imposed by Action Statements.
Amendment No.
92-2-,
BVY 07-043 19e
VYNPS SR 4.0.3 Bases (Continued)
Failure to comply with specified surveillance frequencies is expected to be an infrequent occurrence.
Use of the delay period established by SR 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals.
While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified frequency is provided to perform the missed surveillance, it is expected that the missed surveillance will be performed at the first reasonable opportunity.
The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the surveillance as well as any plant configuration changes required or shutting the plant down to perform the surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the surveillance.
This risk impact should be managed through the program in place to implement 10 CFR 50.65(a) (4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."
This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown.
The missed surveillance should be treated as an emergent condition as discussed in the Regulatory Guide.
The risk evaluation may use quantitative, qualitative, or blended methods.
The degree of depth and rigor of the evaluation should be commensurate with the importance of the component.
Missed surveillances for important components should be analyzed quantitatively.
If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action.
All missed surveillances will be placed in the licensee's Corrective Action Program.
If a surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the completion times of the Action Statements for the applicable LCO Conditions begin immediately upon expiration of the delay period.
If a surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the completion times of the Action Statements for the applicable LCO Conditions begin immediately upon the failure of the surveillance.
Completion of the surveillance within the delay period allowed by this Specification, or within the completion time of the ACTIONS, restores compliance with SR 4.0.1.
Amendment No.
BVY 07-043 19f