ML050110108
| ML050110108 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 01/21/2005 |
| From: | Richard Ennis NRC/NRR/DLPM/LPD1 |
| To: | Kansler M Entergy Nuclear Operations |
| Boska J, NRR, 301-415-2901 | |
| References | |
| TAC MB8714 | |
| Download: ML050110108 (13) | |
Text
January 21, 2005 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION -INSTRUMENTATION TECHNICAL SPECIFICATIONS, VERMONT YANKEE NUCLEAR POWER STATION (TAC NO. MB8714)
Dear Mr. Kansler:
By letter dated April 25, 2003, as supplemented on May 21 and June 11, 2003, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. submitted a proposed license amendment to the Nuclear Regulatory Commission (NRC) for the Vermont Yankee Nuclear Power Station (VYNPS). The proposed amendment, Technical Specification Proposed Change No. 259, Instrumentation Technical Specifications would revise the VYNPS Technical Specifications (TSs) related to instrumentation to correct deficiencies in the TSs, reduce operator work-arounds, improve and correct confusing and ambiguous TS requirements, and allow for process enhancements.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure.
We request that the additional information be provided by February 25, 2005. The response timeframe was discussed with Ms. Ronda Daflucas of your staff on December 17, 2004. If circumstances result in the need to revise your response date, or if you have any questions, please contact me at (301) 415-1420.
Sincerely,
/RA/
Richard B. Ennis, Senior Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
Request for Additional Information cc w/encl: See next page
January 21, 2005 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - INSTRUMENTATION TECHNICAL SPECIFICATIONS, VERMONT YANKEE NUCLEAR POWER STATION (TAC NO. MB8714)
Dear Mr. Kansler:
By letter dated April 25, 2003, as supplemented on May 21 and June 11, 2003, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. submitted a proposed license amendment to the Nuclear Regulatory Commission (NRC) for the Vermont Yankee Nuclear Power Station (VYNPS). The proposed amendment, Technical Specification Proposed Change No. 259, Instrumentation Technical Specifications would revise the VYNPS Technical Specifications (TSs) related to instrumentation to correct deficiencies in the TSs, reduce operator work-arounds, improve and correct confusing and ambiguous TS requirements, and allow for process enhancements.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure.
We request that the additional information be provided by February 25, 2005. The response timeframe was discussed with Ms. Ronda Daflucas of your staff on December 17, 2004. If circumstances result in the need to revise your response date, or if you have any questions, please contact me at (301) 415-1420.
Sincerely,
/RA/
Richard B. Ennis, Senior Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION:
PUBLIC JBongarra, IROB-B PClifford, SRXB-A PDI-2 Reading RLobel, SPSB-C CSchulten, IROB-A DRoberts JLazevnick, EEIB-B BPoole, OGC REnnis BMarcus, EEIB-A VBucci, OIG CAnderson, RGN-1 JCai, IROB-B VGoel, EEIB-B ACCESSION NO.: ML050110108 OFFICE PDI-2/PM PDI-2/PM PDI-2/LA PDI-2/SC NAME JBoska REnnis CRaynor DRoberts DATE 1/18/05 1/18/05 1/18/05 1/19/05 OFFICIAL RECORD COPY
Vermont Yankee Nuclear Power Station cc:
Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. David R. Lewis Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.
Washington, DC 20037-1128 Ms. Christine S. Salembier, Commissioner Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601 Mr. Michael H. Dworkin, Chairman Public Service Board State of Vermont 112 State Street Montpelier, VT 05620-2701 Chairman, Board of Selectmen Town of Vernon P.O. Box 116 Vernon, VT 05354-0116 Operating Experience Coordinator Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 G. Dana Bisbee, Esq.
Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 Ms. Deborah B. Katz Box 83 Shelburne Falls, MA 01370 Ms. Carla A. White, RRPT, CHP Radiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070 Mr. James M. DeVincentis Manager, Licensing Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Resident Inspector Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission P.O. Box 176 Vernon, VT 05354 Director, Massachusetts Emergency Management Agency ATTN: James Muckerheide 400 Worcester Rd.
Framingham, MA 01702-5399 Jonathan M. Block, Esq.
Main Street P.O. Box 566 Putney, VT 05346-0566 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213
Vermont Yankee Nuclear Power Station cc:
Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Danny L. Pace Vice President, Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Brian OGrady Vice President, Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Jay K. Thayer Site Vice President Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. Kenneth L. Graesser 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Ronald Toole 1282 Valley of Lakes Box R-10 Hazelton, PA 18202 Ms. Stacey M. Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue New Orleans, LA 70113 Mr. Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, ME 04556 Mr. James P. Matteau Executive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301 Mr. William K. Sherman Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, VT 05620-2601
Enclosure REQUEST FOR ADDITIONAL INFORMATION (RAI)
REGARDING PROPOSED LICENSE AMENDMENT INSTRUMENTATION TECHNICAL SPECIFICATIONS VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271 By letter dated April 25, 2003, as supplemented on May 21 and June 11, 2003, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Entergy) submitted a proposed license amendment to the Nuclear Regulatory Commission (NRC) for the Vermont Yankee Nuclear Power Station (VYNPS). The proposed amendment, Technical Specification Proposed Change No. 259, Instrumentation Technical Specifications would revise the VYNPS Technical Specifications (TS) related to instrumentation to correct deficiencies in the TSs, reduce operator work-arounds, improve and correct confusing and ambiguous TS requirements, and allow for process enhancements.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed herein.
Technical Specifications Section (IROBA):
RAI G-1 The "Applicable Modes or other Specified Conditions" in Specification Tables are capitalized (e.g., "RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN"). Does capitalization of modes of reactor operation have a definition connotation?
RAI G-2 Provide a VYNPS license amendment citation to show that all topical reports listed in the proposed TS Bases for each revised limiting condition for operation (LCO) have been reviewed and approved for VYNPS by the NRC staff, or provide information to show that the topical report is applicable for VYNPS.
RAI G-3
Reference:
Table 3.2.1, ACTION Note Completion Time The Bases for the Table 3.2.1 ACTIONS Note completion time states:
it is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This completion time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."
This completion time discussion is taken from the Improved Standard Technical Specifications (ISTS). Show why this feature of ISTS Section 1.0, Use and Application, Section 1.3, Completion Times is an appropriate application for the VYNPS TSs without incorporating all the features of Section 1.3 of the ISTS. Additionally, explain the meaning of "ACTION Note Completion Time" as referenced to Table 3.2.1.
RAI G-4
Reference:
DOC A.4 (Reactor Protection System [RPS])
Current Technical Specifications (CTS) 3.1.B and 4.1.B, which provided requirements related to the average power range monitors (APRM) gain and power distribution, were deleted from the CTS by Amendment No. 219 after the currently proposed amendment was submitted. The CTS changes made by Amendment Nos. 219 and 220 should be reflected in the revised pages for this amendment to allow for proper review of the revised pages.
RAI G-5
Reference:
Instrumentation Definitions CTS definitions for channel functional tests are credited in 3.1/4.1 Discussion of Change (DOC)
LA.10 as ensuring the RPS instrumentation is maintained operable; therefore, the CTS details for performing instrument functional tests of the RPS functions can be relocated to the Bases.
However, the emergency core cooling systems (ECCS) instrumentation has a logic system functional test (4.2.A.2), while the proposed RPS instrumentation section does not. Note 7 to CTS Table 4.1.1 describes a logic system functional test of the RPS. Please add this requirement to the proposed TS (perhaps as 4.1.A.4) or justify its removal. Describe how logic system functional tests are handled for each instrumentation section.
SECTION 1 CTS 3.1/4.1, REACTOR PROTECTION SYSTEM RAI 1.0-3
Reference:
A.17 CTS Table 4.1.1 Note 4 and CTS Table 4.1.2 Note 2 state that tests are not required when systems are not required to be operable or are tripped and that if tests are missed, they shall be performed prior to returning the system to an operable status. The basic requirements of these notes are also in the CTS definition 1.0.Z, "Surveillance Interval," which states that these tests, unless otherwise stated in these specifications, may be waived when the instrument, component, or system is not required to be operable, but that these tests shall be performed on the instrument, component, or system prior to being required to be operable. However, the CTS also discusses requirements if the channel is tripped and if tests are missed. These deletions of CTS are not evaluated in DOC A.17. Provide additional analysis and discussion of change.
RAI 1.0-4
Reference:
LA.3, LA.4 and M.6 CTS Table 3.1.1 Note 2 becomes proposed Table 3.1.1 Note 1. These notes provide the actions to be taken when inoperable channels are discovered. From the NRC staff review of the documentation, there is a mismatch between the proposed TS Actions and the changes to CTS in that all TS changes are not identified and discussed. Revise the markup of CTS and the discussion of changes (DOCs) as necessary to cite the changes needed to CTS for adopting Table 3.1.1 Actions Note 1 requirements for one or more protection channels inoperable, Action Note 1.a requirements for one or more trip functions with one or more required channels inoperable, Action Note 1.b requirements for one or more Trip Functions with one or more required channels inoperable in both trip systems, and Action Note 1.c requirements for one or more trip functions with RPS trip capability not maintained.
RAI 1.0-7
Reference:
Bases Retype page 30 The RPS is required to be operable in RUN, STARTUP/HOT STANDBY and REFUEL with reactor coolant temperature > 212 EF. The REFUEL applicability with reactor coolant temperatures >212 EF is a departure from the ISTS. Explain the safety analysis that this applicability requirement is derived from. Revise the proposed TS Bases in sufficient detail to ensure adequate basis is provided as required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36.
RAI 1.0-8
Reference:
Bases Retype page 33, 4.a. APRM High Flux (Flow Bias)
Clarify the Bases statement that the APRM flow bias trip monitors neutron flux "relative" to the reactor coolant. What design basis is implied by "relative to reactor coolant"? Should this say reactor coolant flow?
RAI 1.0-9
Reference:
Bases Retype page 33, 4.a. APRM High Flux (Flow Biased)
Bases Retype page 33b, 4.b. APRM High Flux CTS allow an exception to having at least two local power range monitors (LPRM) inputs from each of the levels at which the LPRMs are located, which is "except that Channels A, C, D and F may lose all APRM inputs from the companion APRM cabinets plus one additional LPRM input and still be considered operable." This is proposed to be moved to the Bases. To relocate details such as this to the Bases, a Bases Control Program must be established in TS Section 6.
SECTION 2 CTS 3.2.A/4.2.A, EMERGENCY CORE COOLING SYSTEM RAI 2.0-1 DOC
Reference:
A.2 The proposed CTS applicability is to use table entries containing a reference to an "Applicable Mode or other specified conditions" for each ECCS required TS trip function as a replacement for "When the system(s) it initiates or controls is required in accordance with Specification 3.5."
The level of detail provided in discussion of change A.2 is insufficient for the NRC staff to discern what, if any, changes are being made to the CTS applicability for trip functions contained in Table 3.2.1. Show by a markup of the CTS applicability how the applicability requirements are changing for each Table 3.2.1 trip function. Justify changes as appropriate.
RAI 2.0-3 DOC
Reference:
L.1 and L.4 Show by marking up the CTS that, when compared to proposed Table 3.2.1 Applicability Requirements, the resulting applicability based on Modes is a less restrictive change to the current TS as derived from the Updated Final Safety Analysis Report (UFSAR).
RAI 2.0-4
Reference:
Table 3.2.1, Trip Function 1.c, Low Reactor Pressure (Initiation)
For this function, the required channels per trip system entry is "1." On Bases page 75a, the discussion explains the low pressure signals are initiated for two pressure transmitters that sense reactor pressure. Each of the transmitters provide an input to both low pressure ECCS logic trains with the contacts arranged in one-out-of-two logic. With two inputs to each train logic, it appears Table 3.2.1 should specify "2" required channels of low reactor pressure. (The staff notes that Table 3.2.1 Trip Function 1.d, "Low Reactor Pressure (System Ready and Valve Permissive)" requires two channels per trip system and has identical trip settings, 300 psig and 350 psig.)
RAI 2.0-5
Reference:
Table 3.2.1, Trip Function 1.f, Pump Discharge Pressure For the required channels per trip system trip function 1.f specifies "2 per pump." The "per pump" requirement represents a difference from current TSs, but was not evaluated. Provide an appropriate discussion of change.
RAI 2.0-6
Reference:
Bases Table 3.2.1 ACTIONS Note 3 (page 75r, 3rd paragraph)
The proposed Bases state that the basis for an allowed out-of-service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore an inoperable channel of reactor vessel shroud level (trip function 2.d) or high drywell pressure (containment spray permissive; trip function 2.g) is the redundancy of the ECCS design as justified in topical report NEDC-30936-P-A (Bases reference 3). Thus, the current VYNPS license basis is NEDC-30936 and this is not proposed to be changed. However, the proposed "restore" action is a change to the CTS "place the channel in trip" action for trip function 2.g. Thus, if the current licensing basis document (NEDC-30936) has not changed, then a discussion is needed to show how NEDC-30936 addresses both the trip and repair options for the same 24-hour period. Otherwise, provide a discussion to justify the change to the trip function 2.g action requirement. Revise the Bases on page 75r accordingly and change to a less restrictive DOC writeup.
SECTION 3 CTS 3.2.B/4.2.B, PRIMARY CONTAINMENT ISOLATION RAI 3.0-1 DOC
Reference:
A.9 The discussion of change A.9 does not discuss Table 4.2.2 Notes 10 and 11 that are shown to be changed by DOC A.9 in the CTS markup.
RAI 3.0-3 The proposed TS Bases page 76m has a list of functions requiring an instrument check which does not match the proposed TS page 48. Correct the discrepancy.
SECTION 4 CTS 3.2.C/4.2.C, REACTOR BUILDING VENTILATION ISOLATION AND STANDBY GAS TREATMENT SYSTEM INITIATION INSTRUMENTATION RAI 4.0-1 DOC
Reference:
A.5 Note 3 to CTS Table 3.2.3 provides actions when the minimum number of channels per trip system requirement is not met. The proposed TS adds a column, "ACTIONS WHEN REQUIRED CHANNELS ARE INOPERABLE" to Table 3.2.3 which provides actions for inoperable channels. The new table column refers to actions listed in the table notes, which are located on the page following the table. Table 3.2.3 also includes footnotes for specifying applicability requirements. Having applicability footnotes and table action notes which are only differentiated by (1) for footnotes vice "1" for actions may lead to a misunderstanding during control room operations. Clarify the use of table notes and footnotes. The NRC staff recommends annotating the actions note with "Table 3.2.3" to read "Table 3.2.3 Note 1."
Consider using lowercase letters for footnotes.
RAI 4.0-2 DOC
Reference:
L.1 The applicability of the low reactor vessel water level trip function of CTS Table 3.2.3 is revised to delete requirements for "during movement of irradiated fuel assemblies or the fuel cask in secondary containment, and during alteration of the reactor core." These changes to the applicability are not evaluated. Additionally, the proposed applicabilities are not, as stated, consistent with the ISTS. Provide a safety analysis discussion of all changes with a conclusion as to why the change is acceptable.
Editorial comment: The correct reference in the 2nd to last sentence of DOC L.1 is "Function 1."
RAI 4.0-3 DOC
Reference:
L.2 The applicability of the high drywell trip function of CTS Table 3.2.3 is revised to delete requirements for "during movement of irradiated fuel assemblies or fuel cask in secondary containment, and during alteration of the reactor core." These changes to the applicability are not evaluated. Provide a safety analysis discussion of all changes. Additionally, the proposed applicabilities are not, as stated, consistent with the ISTS. Add a conclusion statement to explain why the change is acceptable.
SECTION 5 CTS 3.2.D/4.2.D, OFF-GAS SYSTEM ISOLATION INSTRUMENTATION RAI 5.0-1 DOC
References:
A.1 and A.2 Revise the submittal to delete both DOCs A.1 and A.2. These changes are not applicable to off-gas system isolation TS relocations which are evaluated using DOC R.1.
SECTION 6 CTS 3.2.E/4.2.E, CONTROL ROD BLOCK ACTUATION INSTRUMENTATION RAI 6.0-4 DOC
Reference:
LA.4 CTS Table 4.2.5 and associated Note 13, describing details of the performance of instrument calibrations of the rod block monitor (RBM) upscale (flow biased) trip function, are proposed to be relocated to the Bases. The calibration note states: "Includes calibration of the RBM Reference Downscale Function (i.e., RBM upscale function is not bypassed when >30% Rated Thermal Power)." This surveillance requirement (SR) is equivalent to NUREG-1433 SR 3.3.2.1.4.a to verify RBM is not bypassed for the upscale function. The calibration can not check the bypass function, so the bypass function must be a separate surveillance. Revise the proposed TS SRs to include the current TS Table 4.2.5 Note 13 testing requirements.
RAI 6.0-5 DOC
Reference:
L.1 CTS requirements such as CTS 3.3.B.6, CTS 4.3.B.6, and CTS 4.11.C were deleted or modified in amendment 219. As noted in RAI G-4 previously, please revise the new TS pages to reflect the effect of Amendment No. 219.
RAI 6.0-6 Reference Table 3.2.5 Action Note 2 The editorial change to capitalize "action" is incorrect. The intent of this usage in ISTS is to instruct the operator to "take" the specified action, i.e., to do something.
SECTION 8 CTS 3.2.G/4.2.G, POST-ACCIDENT MONITORING INSTRUMENTATION RAI 8.0-1 DOC
Reference:
NA CTS 3.2.G is revised by deleting descriptive information regarding the design, location and analysis assumptions of post accident monitoring parameters. This change is not evaluated by any safety analysis discussion of change. Provide appropriate documentation for this change.
RAI 8.0-2 DOC
Reference:
NA CTS Table 3.2.6 parameter nomenclature for containment pressure (item 2 in the table) is revised by replacing "Containment" with "Drywell." This change is not evaluated by any safety analysis discussion of change. Provide appropriate documentation for this change.
RAI 8.0-3 DOC
Reference:
R.1 Evaluate CTS 3.2.G/4.2.G relocating requirements (LCOs, actions and surveillances) for the safety relief valve position indication (both pressure transmitter and acoustic monitor) and for stack noble gas effluent monitors to the Technical Requirements Manual (TRM) by performing an analysis using 10 CFR 50.36.(c)(2)(ii), or add a L-DOC justification for removal from CTS if the 10 CFR 50.36 criteria do not apply.
SECTION 9 CTS 3.2.H/4.2.H, DRYWELL TO TORUS DELTA-PRESSURE INSTRUMENTATION RAI 9.0-1 DOC
Reference:
LC.1 Evaluate CTS 3.2.H/4.2.H relocating requirements (LCOs, actions and surveillances) for the drywell to torus delta-pressure instrumentation to the TRM by performing an analysis using 10 CFR 50.36.(c)(2)(ii). This must be an R-DOC discussion since CTS 3.7 (p.151) currently has an LCO on the delta-pressure.
SECTION 10 CTS 3.2.I/4.2.I, RECIRCULATION PUMP TRIP INSTRUMENTATION RAI 10.0-2 DOC
Reference:
M.2 (editorial)
Insert "or" after "channels" and before "if" in the 3rd sentence.
SECTION 11 CTS 3.2.K/4.2.K, DEGRADED GRID PROTECTIVE SYSTEM INSTRUMENTATION RAI 11.0-2 DOC
Reference:
LC.1 CTS Table 3.2.8, Degraded Bus Voltage - Time Delay requires two operable instruments per bus. The proposed TS requires only one operable instrument channel per bus. DOC LC.1 does not evaluate this proposed change. Provide safety analysis justification to support the change or retain CTS requirements. Also see Tech Branch RAI 11.0-5.
RAI 11.0-4 DOC
Reference:
None Bases for applicable safety analyses, LCO and applicability states that the degraded grid protective system instrumentation is required for engineered safety features to function in any accident with a degradation or loss of offsite power." From this basis, it is clear that the VYNPS licensing basis should require the loss of power instrumentation to be operable.
Provide the appropriate loss of power TS instrumentation in Table 3.2.8.
SECTION 12 CTS 3.2.L/4.2.L, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM ACTUATION RAI 12.0-2 DOC
Reference:
LA.2 CTS 3.2.L Table 3.2.9 includes column "Minimum Number of Operable Instrument Channels per Trip System" with notes to each function that describe the trip system arrangements including the number of channels per trip system. The trip system design requirements are relocated to the Bases. The proposed Table 3.2.9 specifies "Required Channels per Trip System." The ISTS specifies the "Total Channels per Function." Revise Table 3.2.9 to adopt the ISTS column "Total Channels per Function" and revise Function 1 to specify four required channels.
RAI 12.0-4 DOC
Reference:
LCO Retype Proposed TS Table 3.2.9, Action Notes 1.b, 2.b and 3.a refers to "Place [Restore] inoperable channel....." Revise these statements to "Place [Restore] inoperable channels...
RAI 12.0-5 DOC
Reference:
Bases Retype pages 80l and 80m The Actions basis for Table 3.2.9, Action Note 1 and Action Note 2 refer to the completion time as allowing an exception to the normal "time zero" for beginning the allowed outage time "clock." Show that the current TSs contain a "Use and Application Completion Times" discussion equivalent to NUREG-1433, Section 1.3. If not, discuss how "time zero" clocks can be interpreted with respect to the format and content of current TS. Also, on page 80m, correct the reference in the middle of the "Table 3.2.9 ACTION Note 2" paragraph to 2.a from 1.a.
Technical Branch RAIs CTS 3.1/4.1, REACTOR PROTECTION SYSTEM RAI 1.0-12 DOC
Reference:
M.12 The trip setting for the turbine control valve fast closure trip function is specified in CTS Table 3.1.1 Note 9 as "Channel signals for the turbine control valve fast closure scram shall be derived from the same event or events that cause the control valve fast closure," and CTS 2.1.F as, "Turbine control valve fast closure scram shall trip upon actuation of the turbine control valve fast closure relay." In proposed Table 3.1.1 (trip function 10) and TS 2.1.F, the trip setting is specified as > 150 psig acceleration relay oil pressure. Provide a technical basis to justify this change. In particular, verify this will comply with the statement in UFSAR 14.5.1.1.1 that control rod motion starts within 0.28 seconds after turbine control valves start to close. The NRC staff believes it is incorrect to state (in M.12 or the Bases, p. 33f) that the actual operating point for the associated trip function is not assumed in any transient or accident analysis, as the analysis in UFSAR 14.5.1.1.1 obviously assumes an operating point that will allow control rod insertion at the stated time.
SECTION 2 CTS 3.2.A/4.2.A, EMERGENCY CORE COOLING SYSTEM RAI 2.0-7 DOC
Reference:
M.6 CTS Table 3.2.1 specifies for the low condensate storage tank water level trip function that the Trip Setting be 3%. In proposed Table 3.2.1, the trip setting for the low condensate storage tank water level trip function (trip function 3.b) has been increased to 4.24% to account for the additional water level needed to preclude vortex formation. Provide the calculations for staff review of the setpoint methodology for this TS change.
SECTION 3 CTS 3.2.B/4.2.B, PRIMARY CONTAINMENT ISOLATION RAI 3.0-4 DOC
Reference:
M.7 Proposed TS Table 3.2.2, Function 1.b, 3.a, 3.d, 4.a, and 4.c, have trip setting changes from current TS which are justified by DOC M.7. Provide the setpoint calculations for staff review of the setpoint methodology for these TS changes.
SECTION 11 CTS 3.2.K/4.2.K, DEGRADED GRID PROTECTIVE SYSTEM INSTRUMENTATION RAI 11.0-5 DOC
Reference:
LC.1 The proposed change to Table 3.2.8 Degraded Bus Voltage - Time Delay trip function deletes the alarm function from TSs. The alarm function is necessary to alert operators to a degraded grid bus voltage condition in order for operators to take timely actions to mitigate a degraded bus voltage situation. VYNPS's licensing and design basis does not provide for automatic disconnect of a degraded bus, absent a loss-of-coolant-accident signal, which differs from NRC Branch Technical Position 1 (PSB-1). VYNPS committed, in a letter dated July 24, 1980, that operator action will be credited for the protection of safety equipment under these circumstances. Therefore, the alarm function is required for operator action for emergency bus realignment and should remain in the TSs. Table 3.2.8 should have an alarm function with an appropriate action for an inoperable instrument.
SECTION 12 CTS 3.2.L/4.2.L, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM ACTUATION RAI 12.0-3 DOC
Reference:
M.2 The CTS trip setting for low condensate storage tank water level trip function is revised from "3%" to "3.81%" to account for the additional water level needed to preclude the potential for vortex formation which corresponds to the process limit used in the associated setpoint calculation. Provide the calculations for NRC staff review of the setpoint methodology for this TS change.