BVY 09-021, Submittal of Revision of Technical Specification Bases Pages

Submittal of Revision of Technical Specification Bases Pages

ML090970283
Person / Time
Site:	Vermont Yankee
Issue date:	03/31/2009
From:	Mannai D Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 09-021
Download: ML090970283 (5)

Text

Entergy Nuclear Operations, Inc.

Vermont Yankee P.O. Box 0250 výEn te gy 320 Governor Hunt Road Vernon, VT 05354 Tel 802 257 7711 March 31, 2009 BVY 09-021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

(1) Letter, USNRC to Entergy, "Issuance of Amendment, Battery Systems (TAC No. MD9724)," NVY 09-012, dated February 11, 2009 (2) Letter, USNRC to Entergy, Issuance of Amendment, Sale or Lease of Property Within the Exclusion Boundary (TAC No.

MD9600)," NVY 09-014, dated February 26, 2009

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

Revision of Technical Specification Bases Pages

Dear Sir or Madam,

This letter provides revised Vermont Yankee Technical Specification (TS) Bases pages.

'The Vermont Yankee TS Bases were revised to conform with approved License Amendments 234 and 235 (References 1 and 2) and revise the description of the main station battery capacity.

These changes, processed in accordance with our Technical Specification Bases Control Program (TS 6.7.E), were determined not to require prior NRC approval. The revised Bases pages are provided for your information and for updating and inclusion with your copy of Vermont Yankee Technical Specifications. No NRC action is required in conjunction with this submittal.

There are no new regulatory commitments being made in this submittal.

Should you have any questions concerning this submittal, please contact me at (802) 451-3304.

Sincerelv Licensing Manager Vermont Yankee Nuclear Power Station Attachment (TS Bases pages 221 b, 223, 254a) 4LAX.I/ I cc listing (next page)

BVY 09-021 Page 2 of 2 cc: Mr. Samuel J. Collins, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. James S. Kim, Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0 8 C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee P.O. Box 157 320 Governor Hunt Road Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620

VYNPS BASES: 3.10 (Cont'd) the operable diesel generator are inoperable, the redundant required feature(s) with no off-site power available and the redundant required feature(s) supported by the inoperable diesel generator are required to be immediately declared inoperable and the applicable Technical Specification action(s) taken. These provisional requirements ensure that, during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time, a loss of off-site power does .not result in a loss of safety function of critical systems.

Required features are systems, subsystems, trains, components and devices supported by the off-site power sources and diesel generators and are required to be operable by the Technical Specifications in the existing plant mode or condition.

Either of the two main station batteries has sufficient capacity to energize the vital buses and supply d-c power to the associated emergency equipment for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without being recharged.

Due to the high reliability of battery systems, one of the two batteries may be out of service for up to three days provided all required systems, subsystems, trains, components and devices supported by the operable 125 volt Station Battery System are operable. The provisional requirement ensures that, during the three day allowed outage time, a loss of safety function of critical systems does not exist. Required systems, subsystems, trains, components and devices are.those supported by 125 volt Station Battery System and are required to be operable by the Technical Specifications in the existing plant mode or condition. This minimizes the probability of unwarranted shutdown by providing adequate time for reasonable repairs. A station battery or an Uninterruptible Power System battery is considered inoperable if one cell is out of service. A cell will be considered out of service if its float voltage is below 2.13 volts and the specific gravity is below 1.190 at 77°F.

The Battery Room is ventilated to prevent accumulation of hydrogen gas.

With a complete loss of the ventilation system, the accumulation of hydrogen would not exceed 4 percent concehtration in 2 1/2 days.

Therefore, on loss of Battery Room ventilation, the use of portable ventilation equipment and daily sampling provide assurance that potentially hazardous quantities of hydrogen gas will not accumulate.

C. The minimum diesel fuel supply of 36,000 gallons will supply one diesel generator for a minimum of seven days of operation at its continuous duty rating of 2750kW. Additional fuel can be obtained and delivered to the site from nearby sources within the seven-day period.

Amendment No. BVY --01 4-O-, 213, BVY 06 905, 24;4, BVY 09-021 221b

VYNPS BASES: 4.10 (Cont'd) for the associated batteries. The results of these tests will be logged and compared with the manufacturer's recommendations of acceptability.

The Service Discharge Test, (4.10.A.2.c) is a test of the batteries ability to satisfy the design requirements of the associated dc system. This test will be performed using simulated or actual loads at the rates and for the durations specified in the design load profile (battery duty cycle).

Assurance that the diesels will meet their intended function is obtained by periodic surveillance testing and the results obtained from the pump and valve testing performed in accordance with the requirements of Specification 4.6.E. Specification 4.10.B.l.a provides an allowance to avoid unnecessary testing of the operable emergency diesel generator (EDG). If it can be determined that the cause of the inoperable EDG (e.g., removal from service to perform routine maintenance or testing) does not exist on the operable EDG, demonstration of operability of the remaining EDG does not have to be performed. If the cause of inoperability exists on the remaining EDG, it is declared inoperable upon discovery, and Limiting Condition for Operation 3.10.B.1 requires reactor shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.. Once the failure is repaired, and the common cause failure no longer exists, Specification 4.10.B.l.a is satisfied. If the cause of the initial inoperable EDG cannot be confirmed not to exist on the remaining EDG, performance of Surveillance Requirement (SR) 4.10.B.l.b suffices to provide assurance of continued operability of that EDG.

In the event the inoperable EDG is restored to operable status prior to completing either SR 4.10.B.l.a or SR 4.10.B.l.b, the plant corrective action program will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in the condition of SR 4.10.B.1 or SR 4.10.B.3.b.2.

According to NRC Generic Letter 84-15, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable time to confirm that the operable EDG is not affected by the same problem as the inoperable EDG.

Verification of operability of an off-site power source within one hour and once per eight hours thereafter as required by 4.10.B.3.b.l may be performed as an administrative check by examining logs and other information to determine that required equipment is available and not out of service for maintenance or other reasons. It does not require performing the surveillance needed to demonstrate the operability of the equipment.

C. Logging the diesel fuel supply weekly and after each operation assures that the minimum fuel supply requirements will be maintained.

During the monthly test for quality of the diesel fuel oil, a viscosity test and water and sediment test will be performed as described in ASTM D975-02. The quality of the diesel fuel oil will be acceptable if the results of the tests are within the limiting requirements for diesel fuel oils shown on Table 1 of ASTM D975-02.

Amendment No. 4-2-&, 4--, BVY 01 40, 244O, 2-i-, 2-i-4, 2-2-i, BVY 096 985, 234 223

VYNPS BASES:

5.1 SITE Exclusion area means that area surrounding the reactor, as measured from the reactor center line, in which the reactor licensee has the authority to determine all activities including exclusion or removal of personnel and property from the area. This area may be traversed by a highway, railroad, or waterway, provided those are not so close to the facility as to interfere with normal operations of the facility and provided appropriate and effective arrangements are made to control traffic on the highway, railroad, or waterway, in case of an emergency, to protect the public health and safety.

Contract provisions for property agreements in the exclusion area will ensure that the licensee retains sufficient control of all activities in the exclusion area including the authority to exclude or remove personnel and property, thereby (1) maintaining compliance with IOCFR50.67 radiological limits for the exclusion area, and (2) ensuring that any and all activities, now or in the future, in the exclusion area would not negatively affect nuclear safety, safe plant operation or violate current plant design or licensing basis.

Any property transaction in the exclusion area, as is the case for any activity which has the potential to adversely affect nuclear safety or safe plant operation,. requires a review in accordance with IOCFR50.59. Additionally, any property transaction would be required to comply with other regulatory requirements (e.g., IOCFR50.83) as applicable.

Amendment No. 235 254a