Text

Revision of Technical Specifications Bases Pages
	ML15322A053
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	11/16/2015
From:	Chappell C; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BVY 15-055
	Download: ML15322A053 (8)
	v • d • e

Entergy Nuclear Operations, Inc.

Vermont Yankee SEn tergy 320 Governor Hunt Rd Vernon, VT 05354 Tel 802 257 7711 Coley C. Chappell Licensing Manager BVY 15-055 November 16, 2015 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Revision of Technical Specifications Bases Pages Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCE:

Letter, USNRC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station - Issuance of Amendment for Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition (CAC NO. MF3714)," NVY 15-096, dated October 7, 2015 (ML15I117A551)

Dear Sir or Madam:

This letter provides revised Vermont Yankee Nuclear Power Station (VYNPS) Technical Specification (TS) Bases pages. The TS Bases were revised in conjunction with an Amendment to Renewed Facility Operating License DPR-28 issued in the referenced letter.

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 the VYNPS TS. 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 802-451-3374.

Sincerely, CCC/plc (

Attachment:

1. Attahmen:

Revised 1.

Technical Specifications Bases Pages (5 pages)

BVY 15-055 / Page 2 of 2 cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O8D15 Washington, DC 20555 Mr. ChristopherReca, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05602-2601

BVY 15-055 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Revised Technical Specifications Bases Pages (5 pages)

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 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 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.

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.

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 unit 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.

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 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

Amrendment No. 2634 4

VYNPS SR 4.0.3 Bases (Continued)

The basis for this delay period inciudes 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.

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 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. 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 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 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. 2635 5

VYNPS BASES:

3.1 RADIOACTIVE EFFLUENTS A. Liquid Holdup Tanks The tanks listed in this Specification include all outdoor tanks that contain radioactivity that are not surrounded by liners, dikes, or walls capable of holding the tank contents, or that do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system.

Restricting the quantity of radioactive material contained in the specified tanks provides assurance that in the event of an uncontrolled release of the tanks' contents, the resulting concentrations would be less than the limits of 10CFR Part 20.1001-20.2402, Appendix B, Table 2, Column 2, at the nearest potable water supply and in the nearest surface water supply in an Unrestricted Area.

Amendment No. 2637

VYNPS BASES:

3.2 & 4.2 SPENT FUEL STORAGE A. To assure that there is adequate water to shield and cool the irradiated fuel assemblies stored in the pooi, a minimum pooi water level is established. This minimum water level of 36 feet is established because it would be a significant change from the normal level, well above a level to assure adequate cooling (just above active fuel).

B. The Spent Fuel Pool Cooling System is designed to maintain the pool water temperature below 1250 F during normal operations. If the reactor core is completely discharged, the temperature of the pool water may increase to greater than 1250 F.

A~mendment No. 2639 9

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 10CFR50.67 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. 263 1 ii