ML050800432

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TS Pages for Amendment 221 to License DPR-28, Relocating Current Definition of Surveillance Frequency to New Technical Specification (TS) Sections 4.0.2 and 4.0.3 and Revises Requirements for Missed Surveillance in TS Section 4.0.3
ML050800432
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 03/16/2005
From:
NRC/NRR/DLPM
To:
References
TAC MC0778
Download: ML050800432 (10)


Text

VYNPS TABLE OF CONTENTS LIMITING SAFETY Page No. SYSTEM SETTING SAFETY LIMITS 1.0 DEFINITIONS ................................... 1 1.1 FUEL CLADDING INTEGRITY 6

........................ 2.1 1.2 REACTOR COOLANT SYSTEM ........................ 18 ... 2.2 LIMITING CONDITIONS OF OPERATION Page No. SURVEILLANCE 3.0 LIMITING CONDITIONS OF OPERATION and SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ... 19a ... 4.0 BASES 19c 3.1 REACTOR PROTECTION SYSTEM ..................... 20 ... 4.1 BASES 29 3.2 PROTECTIVE INSTRUMENT SYSTEMS ................. 34 . .. 4.2 A. Emergency Core Cooling System ... 34 A..........

A B. Primary Containment Isolation ............. 34 ... B C. Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation ................................ 34 ... C D. Off-Gas System Isolation .................. 35 ... D E. Control Rod Block Actuation ............... 35 ... E F. Mechanical Vacuum Pump Isolation Instrumentation ..... .................... 35 ... F G. Post-Accident Instrumentation ............. 36 ... G H. Drywell to Torus AP Instrumentation ........

36 H I. Recirculation Pump Trip Instrumentation ........................... 37 ... I J. (Deleted) ................................ 37 ... J K. Degraded Grid Protective System .... ...... 37 ... K L. Reactor Core Isolation Cooling System Actuation ................................. 37 ... L BASES 75 3.3 CONTROL ROD SYSTEM ............................ 81 ... 4.3 A. Reactivity Limitations .................... 81i ... A B. Control Rods .............................. 82 ... B C. Scram Insertion Times ..................... 85 ... C D. Control Rod Accumulators .................. 87 ... D E. Reactivity Anomalies ...................... 88s ... E BASES 89 Amendment No. 4-, 47, 84, 9-s, , 214, 2-i4, 221 -i-

VYNPS 1.0 DEFINITIONS V. Shutdown - The reactor is in a shutdown condition when the reactor mode switch is in the shutdown mode position and no core alterations are being performed. When the mode switch is placed in the shutdown position a reactor scram is initiated, power to the control rod drives is removed, and the reactor protection system trip systems are de-energized.

1. Hot Shutdown means conditions as above with reactor coolant temperature greater that 212'F.
2. Cold Shutdown means conditions as above with reactor coolant temperature equal to or less than 212'F.
3. Shutdown means conditions as above such that the effective multiplication factor (Keff) of the core shall be less than 0.99.

W. Deleted X. Transition Boiling - Transition boiling means the boiling regime between nucleate and film boiling. Transition boiling is the regime in which both nucleate and film boiling occur intermittently with neither type being completely stable.

Y. Surveillance Frequency - Relocated to Specifications 4.0.2 and 4.0.3.

Amendment No. -4, 424t, 4Ai, 4-:74, a97-, 244, 221 4

VYNPS 1.0 DEFINITIONS Z. Surveillance Interval - Relocated to Specification 4.0.1.

I AA. Deleted BB. Source Check - The qualitative assessment of channel response when the channel sensor is exposed to a radioactive source.

CC. Dose Equivalent I-131 - The dose equivalent I-131 shall be that concentration of 1-131 (microcurie/gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134 and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in NRC Regulatory Guide 1.109, Revision 1, October 1977.

DD. Deleted EE. Deleted FF. Deleted GG. Deleted HH. Deleted II. Deleted JJ. Deleted KK. Deleted LL. Deleted MM. Deleted NN. Core Operating Limits Report - The Core Operating Limits Report is the unit-specific document that provides core operating limits for the current operating reload cycle. These cycle-specific core operating limits shall be determined for each reload cycle in accordance with Specification 6.6.C.

Plant operation within these operating limits is addressed in individual specifications.

Amendment No. a4, G4, 44, m4, 4&, G3s, 4l6, 1-5l, 4-6C8, }7G, LEG, a9-, 221 5 t

VYNPS 3.0 LIMITING CONDITIONS FOR 4.0 SURVEILLANCE REQUIREMENT (SR)

OPERATION APPLICABILITY APPLICABILITY 3.0.1 RESERVED SR 4.0.1 SRs shall be met during the modes or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified frequency shall be failure to meet the LCO except as provided in SR 4.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 4.0.2 Unless otherwise stated in these specifications, periodic surveillance tests, checks, calibrations, and examinations shall be performed within the specified surveillance intervals. These intervals may be adjusted plus 25%. The operating cycle interval is considered to be 18 months and the tolerance stated above is applicable.

SR 4.0.3 If it is discovered that a surveillance was not performed within its specified frequency, declaring applicable Limiting Conditions for Operation (LCOs) not met may be delayed, from the time of discovery, up to 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the surveillance. A risk evaluation shall be performed for any Surveillance delayed greater thafi 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> and the risk impact shall be managed.

Amendment No. 221 39 a

VYNPS 3.0 LIMITING CONDITIONS FOR 4.0 SURVEILLANCE REQUIREMENT (SR)

OPERATION APPLICABILITY APPLICABILITY SR 4.0.3 (Continued)

If the surveillance is not performed within the delay period, applicable LCOs must immediately be declared not met, and applicable LCOs must be entered.

When the surveillance is performed within the delay period and the surveillance is not met (i.e., acceptance criteria are not satisfied),

applicable LCOs must immediately be declared not met, and applicable LCOs must be entered.

Amendment No. 221 19b 4

VYNPS BASES:

TS 3.0 Limiting Conditions for Operation Applicability Reserved.

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 which the 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. 221 19c i

VYNPS SR 4.0.2 Bases SR 4.0.2 permits a 25t 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 25t 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 hours1 days <br />0.143 weeks <br />0.0329 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 10CFRSO, 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.

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 hours1 days <br />0.143 weeks <br />0.0329 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 Amendment No. 221 19d

VYNPS SR 4.0.3 Bases (Continued) 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. 221 19e

VYNPS Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month/year) the change was implemented.

C. PRIMARY CONTAINMENT LEAK RATE TESTING PROGRAM A program shall be established to implement the leak rate testing of the primary containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B as modified by approved exemptions.

This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, entitled "Performance Based Containment Leak-Test Program," dated September 1995, as modified by the following exception to NEI 94-01, Rev. 0, "Industry Guideline for Implementing Performance-Based Option of 10CFR50, Appendix J":

Section 9.2.3: The first Type A test after the April 1995 Type A test shall be performed no later than November 2005.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 44 psig.

The maximum allowable primary containment leak rate, La, at Pa, shall be 0.8% of primary containment air weight per day.

Leak rate acceptance criteria are:

1. Primary containment leak rate acceptance criterion < 1.0 La.
2. The as-left primary containment integrated leak rate test (Type A test) acceptance criterion is < 0.75 La.
3. The combined local leak rate test (Type B and C tests) acceptance criterion is < 0.60 La, calculated on a maximum pathway basis, prior to entering a mode of operation where containment integrity is required.
4. The combined local leak rate test (Type B and C tests) acceptance criterion is < 0.60 La, calculated on a minimum pathway basis, at all times when primary containment integrity is required.
5. Airlock overall leak rate acceptance criterion is < 0.10 La when tested at > Pa.

The provision of SR 4.0.2 for Surveillance Frequency does not apply to the test frequencies specified in the Primary Containment Leak Rate Testing Program.

D. Radioactive Effluent Controls Program This program conforming to 10 CFR 50.36a provides for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably Amendment No. 52, 171, 2-l , 221 265

VYNPS

h. Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from the unit to areas at or beyond the site boundary, conforming to 10 CFR 50, Appendix I;
i. Limitations on the annual and quarterly doses to a member of the public from iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half lives greater than 8 days in gaseous effluents released from the unit to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; and
j. Limitations on the annual dose or dose commitment to any member of the public, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.

E. TECHNICAL SPECIFICATIONS (TS) BASES CONTROL PROGRAM This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:
1. A change in the TS incorporated in the license, or
2. A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.
d. Proposed changes that meet the criteria of Specification 6.7.E.b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

Amendment No. -171 , 221 267