Text

License Amendment, Issuance of Amendment Instrumentation Technical Specifications
	ML091410358
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	06/12/2009
From:	James Kim; Plant Licensing Branch 1
To:	; Entergy Nuclear Operations
	kim j
References
	TAC MD8111
	Download: ML091410358 (159)
	v • d • e

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 off!!

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i; June 12, 2009

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+0 Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354 SLlB~IECT:

VERMONT YANKEE NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: INSTRUMENTATION TECHNICAL SPECIFICATIONS (TAC NO. MD8111)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 236 to Facility Operating License DPR-28 for the Vermont Yankee Nuclear Power Station, in response to your application dated February 12, 2008, as supplemented by letters dated August 28,2008, September 15, 2008.

October 17, 2008, December 15, 2008, December 18, 2008 (two letters), April 9, 2009, and May 20,2009.

The amendment would revise Technical Specification (TS) Sections 2.1, "Limiting Safety System Setting," 3.1. "Reactor Protection System," 3.2, "Protective Instrument Systems," associated Surveillance Requirements. and other TS with similar requirements as these instrumentation TS t'

seCdons.

A sopy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, James Kim, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosures:

1. Amendment No. 236 to License No. DPR-28

2. Safety Evaluation CC 'N/ends: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY NUCLEAR VERMONT YANKEE, LLC AND ENTERGY NUCLEAR OPERATIONS, INC.

DOCKET NO. 50-271 VERMONT YANKEE NUCLEAR POWER STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 236 License No. DPR-28

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment filed by Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (the licensee) dated February 12, 2008, as supplemented by letters dated August 28, 2008, September 15, 2008, October 17,2008, December 15,2008, December 18,2008 (two letters),

April 9, 2009, and May 20, 2009, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

- 2

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Facility Operating License No. DPR-28 is hereby amended to read as follows:

(B)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 236, are hereby incorporated in the license. Entergy Nuclear Operations, Inc. shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION

~~,~ef a:~t ~i~nSing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: June 12, 2009

ATTACHMENT TO LICENSE AMENDMENT NO. 236 FACILITY OPERATING LICENSE NO. DPR-28 DOCKET NO. 50-271 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 3

3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert i

i 20a 21a 44a 44b 5

5 8

8 10 10 20 20 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47

- 2 Remove Insert 48 48 48a 49a 55a 71a 74a 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 59 59 60 60 61 61 62 62 63 63 64 64 65 65 66 66 67 67 68 68 69 69 70 70 71 71 72 72 73 73 74 74

- 3 E.

Entergy Nuclear Operations, Inc., pursuant to the Act and 10 CFR Parts.30 and 70, to possess, but not to separate, such byproduct and special nuclear material as may be produced by operation of the facility.

3. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20. Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A.

Maximum Power Level Entergy Nuclear Operations, Inc. is authorized to operate the facility at reactor core power levels not to exceed 1912 megawatts thermal in accordance with the Technical Specifications (Appendix A) appended hereto.

B.

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 236 are hereby incorporated in the license. Entergy Nuclear Operations, Inc. shall operate the facility in accordance with the Technical Specifications.

C.

Reports Entergy Nuclear Operations, Inc. shall make reports in accordance with the requirements of the Technical Specifications.

D.

This paragraph deleted by Amendment No. 226.

E.

Environmental Conditions Pursuant to the Initial Decision of the presiding Atomic Safety and Licensing Board issued February 27, 1973, the following conditions for the protection of the environment are incorporated herein:

Amendment No.--200, ~, ~, ~, ~, ~. ~, 233, 234, 235, 236

VYNPS TABLE OF CONTENTS Page No.

1.0 DEFINITIONS 1

SAFETY LIMITS LIM.ITING SAFETY SYSTEM SETTING 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

B.

Primary Containment Isolation 43 B

C.

Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation 50 C

D.

(Deleted) 54 D

E. Contio1 Rod Block Actuation 54 E

F. Mechanical Vacuum Pump Isolation Instrumentation 58 F

G.

Post-Accident Monitoring Instrumentation..

60 G

H.

(Deleted) 64 H

I. Recirculation Pump Trip Instrumentation 64 I

J.

(Deleted) 64 J

K.

Degraded Grid Protective System 68 K

L. Reactor Core Isolation Cooling System Actuation 72 L

BASES 75 3.3 CONTROL ROD SYSTEM 81 4.3 A.

Reactivity Limitations B1 A

B. Control Rods B2 B

C.

Scram Insertion Times 85 C

D.

Control Rod Accumulators

~

87 D

E. Reactivity Anomalies 88 E

BASES B9 Amendment No.~, -e:+, &3-, %, +/--64, ~, ~,

~,

~, 236

-i

VYNPS 1.0 DEFINITIONS Z.

Surveillance Interval - Relocated to Specification 4.0.1.

AA. Deleted BB. SourceCheck" channel sensor The qualitative is exposed to a assessment of channel radioactive source.

response when the CC. Dose Equivalent I-13l -

The dose equivalent I-131 shall be that concentration of I-13l (microcurie/gram) which alone would produce the same dose as the quantity and isotopic mixture of I-131, I-132, I-133, 1-134 and I-135 actually present.

The dose.conversion factors used for this calculation shall be those listed in Federal Guidance Report (FGR) 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," 1988; FGR 12, "External Exposure to Radionuclides In Air, Water, and Soil," 1993; or NRC Regulatory Guide 1.109, "Revision I, 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.

00. Reactor Protection System (RPS) Response Time -

RPS Response Time shall be the time from the opening of the sensor contact up to and including the.

opening of the scram solenoid relay.

" Amendment No. H, ~, 43, -+Q.,

~, ~, H-6-r +/-M, -+/--6S, ~, 8-3-, -+/--9-J., ~, ~,

236 5

VYNPS 2.1 LIMITING SAFETY SYSTEM SETTING 1.1 SAFETY LIMIT For no combination of loop recirculation flow rate. and core thermal power shall the APRM flux scram trip setting be allowed to exceed 120%*

of rated thermal power.

b. Flux Scram Trip Setting (Refuel or Startup!

Hot Standby Mode)

In accordance with Table 3.1.1, when the reactor mode switch is in the REFUEL position or the STARTUP/HOT STANDBY position, average power range monitor "(APRM) scram shall be set down to less than or equal to 15% of rated neutron flux.

The IRM flux scram setting shall be set at less than or equal to 120/125 of full scale.

B. Deleted

c. Reactor low water level scram setting shall be at least 127 inches above the top of the enriched fuel.

Amendment No. -+/--&,

~,

~, i!-+/-4, 236 8

VYNPS 1.1 SAFETY LIMIT 2.1 LIMITING SAFETY SYSTEM SETTING D. Reactor low-low water level Emergency Core Cooling System (ECCS) initiation shall be

~ 82.5 inches above the top of

. I the enriched fuel.

E. When operating at > 25% uf Rated Thermal Power, turbine stop valve scram shall be ~ 10% valve closure from full open.

F. When operating at > 25% of Rated Thermal Power, turbine control valve fast closure.

Scram shall be actuation of the turbine control valve fast closure relay.

G. Main stearn line isolation valve closure scram shall be ~ 10%

valve closure from full open.

H. Main stearn line low pressure initiation of main stearn line isolation valve closure shall be ~ 800 psig.

Amendment No. 8-" My +/--H, ~, 236 10

VYNPS 3.1 LIMITING CONDITIONS FOR OPERATION 3.1 REACTOR PROTECTION SYSTEM (RPS)

Applicability:

Applies to the operability of plant instrumentation and control systems required for reactor safety.

Objective:

To specify the limits imposed on plant operation by those instrument and control systems required for reactor safety.

Specification:

A.

The RPS instrumentation for each Trip Function in Table 3.1.1 shall be operable in accordance with Table 3.1.1.

4.1 SURVEILLANCE REQUIREMENTS 4.1 REACTOR PROTECTION SYSTEM (RPS)

Applicability:

Applies to the surveillance of the plant instrumentation and control systems required for reactor safety.

Specification:

A.1 RPS instrumentation shall be checked, functionally tested and calibrated as indicated in Table ~.l.1.

When an RPS channel is placed in an inoperable status solely for the performance of required surveillances, entry into associated Limiting Conditions for Operation and required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Trip Function maintains RPS trip capability.

2. Exercise -each automatic scram contactor once every week using the RPS channel test switches or by performing a Functional Test of any automatic RPS Trip Function.

3. Verify RPS Response Time is S 50 milliseconds for each automatic RPS Trip Function once every Operating Cycle.

Amendment No. 1-, ~, -l-&&, ~, ~, 236 20

VYNPS 3.1 LIMITING CONDITIONS OPERATION FOR 4.1 SURVEILLANCE REQUIREMENTS

4. Perform a Logic System Functional Test of RPS instrumentation Trip Functions once every Operating Cycle.

Amendment No.-1-64, 236 20a

VYNPS Table 3.1.1 (page 1 of 3)

Reactor Protection System Instrumentation ACTIONS WHEN REQUIRED REQUIRED ACTIONS APPLICABLE MODES CHANNELS CHANNELS REFERENCED OR OTHER SPECIFIED'

'PER TRIP ARE FROM ACTION TRIP TRIP FUNCTION CONDITIONS SYSTEM INOPERABLE NOTE 1 SETTING

1. Reactor Mode RUN, STARTUP/HOl 1

Note 1 Note 2.a NA Switch in STANDBY, Refuel a)

Shutdown Refuel (b) 1 Note 1 Note 2.d NA

2. Manual Scram RUN, STARTUP/HOl 1

Note 1 Note 2,. a NA STANDBY, Refuel a)

Refuel (b) 1 Note 1 Note 2.d NA

3. Intermediate Range Monitors (IRMs)

a. High Flux

'STARTUp/HOT STANDBY, Refuel (a) 2 Note 1 Note 2.a

~ 120/125 Refuel (b) 2 Note 1 Note 2.d

~ 120/125

b. Inop STARTUP1HOT STANDBY, Refuel (a) 2 Note 1 Note 2.a NA Refuel (b) 2' Note 1 Note 2.d NA (a)

With reactor coolant temperature> 2l2°F.

(b)

With reactor coolant temperature ~ 212°F and any control rod withdrawn from,a core cell containing one or more fuel assemblies.

Amendment No. ~, 236 21

VYNPS Table 3.1.1 (page 2 of 3)

Reactor Protection System Instrumentation ACTIONS W~EN REQUIRED REQUIRED ACTIONS APPLICABLE MODES

. CHANNELS CHANNELS REFERENCED OR OTHER SPECIFIED PER TRIP ARE FROM ACTION TRIP TRIP FUNCTION CONDITIONS S"(STEM INOPERABLE

.'NOTE 1 SETTING

4. Average Power.

Range Monitors (APRMs)

a. High Flux RUN 2

Note 1 Note 2.b (c)

(Flow Bias)

b. High Flux STARTUP/HOT 2

Note 1 Note 2.a

~ 15%

(Reduced)

STANDBY, Refuel (al

c. Inop RUN, STARTUP/HOT 2

Note 1 Note 2.a NA STANDBY, Refuel a)

(a)

With reactor coolant temperature> 212°F.

(c)

Two loop operation:

S~ 0.331'1+ 50.45% for 0% < 1'1

~ 30.9%

S~ 1.071'1+ 27.23% for 30.9% < 1'1

~ 66.7%

S~ 0.551'1+ 62.34% for 66.7% < 1'1

~ 99.0%

With a maximum of 117.0% power for W > 99.0%

Sinq1e loop operation:

S~ 0.331'1+ 48.00% for 0% < 1'1

~ 39.1%

S~ 1.07W+ 19.01% for 39.1% < 1'1

~ 61.7%

S~ 0.551'1+ 51.22% for 61.7% < 1'1

~ 119.4%

With a maximum of 117.0% power for 1'1 > 119.4%

Amendment No. -l-64, 236 21a

VYNPS Table 3.1.1 (page 3 of 3)

Reactor Protection System Instrumentation ACTIONS WHEN REQUIRED REQUIRED ACTIONS APPLICABLE MODES CHANNELS CHANNELS REFERENCED OR OTHER SPECIFIED PER TRIP ARE FROM ACTION TRIP TR1P FUNCTION CONDITIONS SYSTEM.

INOPERABLE NOTE 1 SETTING

5. High Reactor RUN, STARTUP/HOr 2

Note 1 Note 2.a SlOSS Pressure STANDBY,. Refuel a) psig

6. High Drywei1 RUN, STARTUP/HOr 2

Note 1 Note 2.a S 2.5 Pressure STANDBY, Refuel a) psig'

7. Reactor Low Water RUN, STARTUP/HOr 2

Note 1 Note 2.a

? 127.0 Level STANDBY, Refuel a) inches

8. Scram Discharge RUN, STARTUP/HOr 2 per Note 1 Note 2.a

.S 21. 0 Volume High Level STANDBY, Refuel a) volume gallons Refuel (b) 2 per Note 1 Note 2.d S 21.0 volume gallons

9. Main Steam Line RUN 8

Note 1

'Note 2.b

~ 10%

Isolation Valve valve

. Closure closure

10. Turbine Control

.> 25% RATED 2

Note 1 Note 2.c (d)

Valve Fast THERMAL POWER Closure

11. Turbine Stop

> 25% RATED

'4 Note 1 Note 2.c

.~ 10%

Valve Closure THERMAL POWER valve closure (a)

With reactor coolant temperature> 212°F.

(b)

With reactor coolant temperature S 212°F and any control rod* withdrawn cell containing one or more fuel assemblies.

from a core (d)

Channel signals for the turbine control valve fast closure trip shall be derived from the same event or events which cause the control valve fast closure.

Amendment No. ~', 236 22

VYNPS Table 3.1.1 ACTION Notes

1. With one or more required Reactor Protection System channels inoperable, take all of the applicable Actions in.Notes 1.a, 1.b, and 1.c below.

a. With one or more Trip Functions with one or more required channels inoperable:

1) Place an inoperable channel for each Trip Function in trip within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; or

2) Place "the associated trip system in trip within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With one or more Trip Functions with one or more required channels inoperable in both trip systems:

1) Place an inoperable channel in one trip system in trip within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; or

2) Place one trip system in trip within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With one or more Trip Functions with Reactor Protection System trip capability not maintained:

1) Restore Reactor Protection System trip capability within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

If *any applicable *Action and associated completion time of Notes l.a, 1.b, or 1.c is not met, take the applicable Action of Note 2 below referenced in Table 3.1.1 for the channel.

2. a. Place the reactor in HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. Place the reactor in STARTUP/HOT STANDBY within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

c. Reduce reactor power to < 25% Rated Thermal Power within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

d. Immediately initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies.

Amendment No. ~, 236 23

VYNPS Table 4.1.1 (page lof 3)

Reactor Protection System.Instrumentation Tests and Frequencies TRIP FUNCTION CHECK FUNCTIONAL TEST CALIBRATION

1. Reactor Mode NA Each Refueling Outage NA Switch in Shutdown

2. Manual Scram NA Every 3 Months*

NA

3. Intermediate Range Monitors (IRMs)

a. High Flux*

Once/Day, (a)

Within 31 Days Before entering STARTUP/HOT STANDBY (b) and Once/Operating*

Cycle (b), Ie)

Every 31 Days During STARTUP/HOT STANDBY, Every 31 Days During Refueling

b. Inop NA Within 31 Days Before. entering STARTUP/HOT STANDBY (b) and NA Every 31 Days During STARTUP/HOT STANDBY, Every 31 Days During'Refueling

4. Average Power Range Monitors

. (APRMs)

a. High Flux (Flow Bias)

NA Every 3 Months Every 7 Days for Output Signal by Heat Balance ldl Every 3 Months (e)

Each Refueling Outage for Flow

Bias, Every 2000 MWD/T Average Core Exposure for LPRMs using TIP System (a)

IRM and Source Range Monitor channels shall be determined to overlap during each startup after entering. STARTUP/HOT STANDBY MODE and IRM and APRM channels shall be determined to overlap during each controlled shutdown, if not performed in the previous 7 days.

(b)

Not required to be completed when entering STARTUP/HOT STANDBY MODE from RUN MODE until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering STARTUP/HOT STANDBY MODE.

(c)

Neutron detectors are excluded.

(d)

Not required to b~ completed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor power is ~ 23%

Rated Thermal Power.

(e)

Trip unit calibration only.

Amendment No ~,.. 236 2'4

VYNPS Table 4.1.1 (page 2 of 3)

Reactor Protection System Instrumentation Tests and Frequen?ies TRIP FUNCTION CHECK FUNCTIONAL TEST CALIBRATION

4. APRMs (continued)

b. High Flux (Reduced)

c. Inop

5. High Reactor Pressure

6. High Drywell Pressure

7. Reactor Low Water Level

8. Scram Discharge Volume High Level

9. Main Steam Line.

Isolation Valve Closure IO.Turbine Control Valve Fast Clos~re

a. First Stage Turbine Pressure Permissive (a)

NA Once/Day NA Once/Day NA NA

. NA NA Within 7 Days Before entering STARTUP/HOT STANDBY (b) and Every 7 Days During STARTUP/HOT STANDBY, Every 7 Days During Refueling Every 3 Months Every 3 Months Every 3 Months

Every 3 Months Every 3 Months Every 3 Months Every 3* Months Every 6 Months Within 7 Days Before enterinq STARTUP/HOT STANDBY !b). (cl. (e) and Every 7 Days During STARTUP/

HOT STANDBY (c). (e)

Every 7 Days During Refueling(cl, (e)

NA Every 3 Months (e)

Once/Operating Cycle Every 3 Months(e)

Once/Operating Cycle Every 3 Months Ie)

Once/Operating Cycle Every 3 Months~)

Once/Operating Cycle Each Refueling Outage Every 3 Months Every 6 Months and prior to entering STARTUP/HOT STANDBY for plant startup after Ref~eling (a)

IRM and Source Range Moni~or channels shall be determined to overlap during each startup after entering STARTUP/HOT STANDBY MODE and IRM and APRM channels shall be determined to overlap during each controlled shutdo~n, if not performed in the previous 7 days.

(b)

Not required to be completed when entering STARTUP/HOT STANDBY MODE from RUN MODE until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering STARTUP/HOT STANDBY MODE.

(c)

Neutron detectors are excluded.

(e).

Trip unit calibration only.

Amendment No. ~, 236 25

VYNPS Table 4.1.1 !page 3 of 3)

Reactor Protection System Instrumentation Tests and Frequencies TRIP FUNCTION CHECK FUNCTIONAL TEST CALIBRATION 1l.Turbine Stop Valve Closure NA Every 3 Months Each Refueling Outage

a. First Stage Turbine Pressure Permissive NA Every 6 Months Every 6 Months and prior to entering STARTUP/HOT STANDBY for plant startup after Refueling 26 Amendment No. -H4, 236

VYNPS This page intentionally left blank Amendment No. 236 27

VYNPS This page intentionally left blank

(

Amendment No. 236 28

VYNPS 3.2 LIMITING CONDITIONS FOR 4.2 SURVEILLANCE REQUIREMENTS OPERATION 3.2 PROTECTIVE INSTRUMENT SYSTEMS

4.2 Applicability

Applies to the operational status of the plant instrumentation systems which initiate and control a protective function.

Objective:

To assure the operability of protective instrumentation systems.

Specification:

A.

Emergency Core Cooling System (ECCS)

The ECCS instrumentation for each Trip Function in Table 3.2.1 shall be operable in accordance with Table 3.2.1.

PROTECTIVE INSTRUMENT SYSTEMS Applicability:

Applies to the Surveillance*

requirements of the instrumentation systems which initiate and control a protective function.

Objective:

To verify the operability of protective instrumentation systems.

Specification :.

A.

Emergency Core Cooling System (ECCS)

1. ECCS instrumentation shall be checked, functionally tested and calibr~ted as indicated in Table 4.2.1.

When an ECCS instrumentation channel is placed in an inoperable status solely for performance of required surveillances, entry into associated Limiting Conditions for Operation and required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Trip Function 3.d; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Trip Functions other than 3.d provided the associated Trip Function or redundant Trip Function maintains ECCS initiation capability.

2. Perform a Logic System Functional Test of ECCS instrumentation Trip Functions once every Operating Cycle.

Amendment No.~, 236 34

VYNPS Table 3.2.1 (page 1 of 4)

Emergency Core Cooling System Instrumentation ACTIONS WHEN REQUIRED REQUIRED APPLICABLE MODES OR CHANNELS CHANNELS OTHER SPECIFIED PER TRIP ARE TRIP FUNCTION CONDITIONS SYSTEM INOPERABLE TRIP SETTING

1. Core Spray Sy,stem

a. High Drywell Pressure RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a). Ie) 2 Note 1

s; 2.5 psig

b. Low:-Low Reactor Vessel Water Level RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuella). (b), (e) 2 Note 1

~ 82.5 inches

c. Low Reactor Pressure (Initiation)

RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (ai, (b) 1 Note 2

~

s; 300 psig and 350 psig

d. Low Reactor Pressure (System Ready and Valve Permissive)

RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (e), (bl 2

Note 2

~ 300 psig and

S;*350 psig

e. Pump Time Start Delay RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel fa). (b) 1 Note 2

~

s; 8 seconds and 10 seconds

f. Pump Discharge Pressure RUN, STARTUP/HOT STANDBY (c), HOT SHUTDOWN (c), Refuel (c) 2 per pump Note 8

~ 100 psig

g. Auxiliary Power Monitor RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a). Ib) 1 Note 2 NA

h. Pump Bus Power Monitor RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a). (b) 1 Note 2 NA (a)

With reactor coolant temperature> 212 OF.

(b)

When associated ECCS subsystem is required to be oper-able per specification 3.5.

(c)

With reactor steam pressure> 150 psig.

(e)

Required to initiate the emergency diesel generators when core spray is required to be operable per specification 3.5.

Amendment No. +64, 236 35

VYNPS Table 3.2.1 (page 2 of 4)

Emergency Core Cooling System Instrumentation ACTIONS WHEN REQUIRED REQUIRED APPLICABLE MODES OR CHANNELS CHANNELS OTHER SPECIFIED PER TRIP ARE TRIP FUNCTION.

CONDITIONS SYSTEM INOPERABLE TRIP SETTING

2. Low Pressure Coolant Injection (LPCI)

System

a. Low Reactor

pressure (Initiation)

RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a)

, Ib) 1 Note 2

~

5 300 psig and 350 psig

b. High Drywell Pressure (Initiation)

RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a) 2 Note 1 S; 2.5 psig

c. Low-Low Reactor Vessel Water Level RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a), (b) 2 Note 1

~ 82.5 inches

d. Reactor Vessel Shroud Level RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a) 1 Note 3

~ 2/3 core height

e. LPCI Pump Time Band C Start Delay RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a), (b) 1 Note 2

~

S 3 seconds and 5 seconds

f. RHR Pump Discharge Pressure RUN, STARTUP/HOT STANDBY Ic), HOT SHUTDOWN Ic), Refuel lc )

2 per pump Note 8*

~ 100 psig

g. High Drywell Pressure (Containment Spray Permissive)

RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (S) 2 Note 3 S 2.5 psig

h. Low Reactor Pressure (System Ready and Valve Permissive)

RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a), (b) 2 Note 2

~

S; 300 psig and 350 psig (a)

(b)

(c)

With When 3.5.

With reactor coolant temperature> 212 of.

associated ECCS subsystem.is required to be reactor steam pressure> 150 psig.

operable per specification Amendment No. ~, 236 36

VYNPS Table 3.2.1 (page 3 of 4)

Emergency Core Cooling System Instrumentation ACTIONS WHEN REQUIRED REQUIRED APPLICABLE MODES OR CHANNELS CHANNELS OTHER SPECIFIED PER TRIP ARE TRIP FUNCTION CONDITIONS SYSTEM INOPERABLE TRIP SETTING

2. LPCI System (Continued)

i. Auxiliary Power Monitor j.. Pump Bus Power Monitor

3. High Pressure Coolant Injection (HPCI)

System

a. Low-Low Reactor Vessel* Water Level

b. Low Condensate Storage Tank Water Level

c. High Drywell Pressure

d. High Reactor Vessel Water Level RUN, STARTUP/HOT 1

STANDBY, HOT SHUTDOWN, Refuel (aI, (bl RUN, STARTUP/HOT 1

STANDBY, HOT SHUTDOWN, Refuel lal, Ib' RUN, STARTUP/HOT 2

STANDBY (cl, HOT SHUTDOWN lcl, Refuel (c)

RUN, STARTUP/HOT 2

STANDBY lc), HOT SHUTDOWN (c,, Refuel lc)

RUN, STARTUP/HOT 2

STANDBy 1c), HOT SHUTDOWN(cl, Refuel lcl RUN, STARTUP/HOT 2

STANDBY lc), HOT SHUTDOWN lc), Refuel lc)

Note 2 NA Note 2 NA Note 4

~ 82.5 inches Notes 5,9;10 Note 4 S 2.5 psig Note 6.

S 177 inches (a)

With reactor coolant temperature> 212 of.

(b)

When associated ECCS subsystem is required to be operable per specification 3.5.

(c)

With reactor steam pressure> 150 psig.

(d)

Percent of instrument span.

Amendment No.-+/--64, 236 37

VYNPS Table 3.2.1 (page 4 of 4)

Emergency Core Cooling System Instrumentation ACTIONS WHEN REQUIRED REQUIRED APPLICABLE MODES OR CHANNELS CHANNELS OTHER SPECIFIED PER TRIP ARE TRIP FUNCTION CONDITIONS SYSTEM INOPERABLE TRIP SETTING

4. Automatic Depressurization

.System (ADS)

a. Low-Low Reactor*

Vessel Water Level

b. High Drywell, Pressure

c. Time Delay

d. Sustained Low-Low Reactor Vessel Water Level Time Delay RUN, STARTUP/HOT STANDBY (C), HOT SHUTDOWN(Cl, Refuel (e) 2 Note 7

~ 82.5 inches RUN, STARTUP/HOT STANDBY (e), HOT SHUTDOWN,e), Refuel (e) 2 Note 7

~ 2.5 psig.

RUN, STARTUP/HOT STANDBY (C), HOT SHUTDOWN (e), Refuel (e) 1 Note 8

~ 120 seconds RUN, STARTUP/HOT STANDBY (e), HOT SHUTDOWN(e), Refuel 'e) 2 Note 8

~ 8 minutes (c)

With ~eactor steam pressure> 150 psig.

Amendment No. ~, 236 38

VYNPS Table 3.2.1 ACTION Notes

1. With one or more channels inoperable for ECCS instrumentation Trip Functions l.a, l.b, 2.b and 2.c:

a. Declare the associated systems inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of initiation capability for feature(s) in both divisions; and

b. Place any inoperable channel in trip within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If any applicable Action and associated completion time of Note l.a or l.b is not met, immediately declare associated systems inoperable.

2. With one or more channels inoperable for ECeS'instrumentation Trip Functions Lc, Ld, Le~ Lg, Lh, 2.a" 2.e, 2.h, 2.1 and 2.j:

a. Declare the associated systems inoperable within l'hour from discovery of loss of initiation capability for feature(s) in both divisions; and

b. Restore any inoperable channel to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If any applicable Action and associated completion time of Note 2.a or 2.b is not met,' immediately declare associated systems inoperable.

3. With one or more channels inoperable for ECCS instrumentation Trip Functions 2.d and 2.g:

a. For Trip Function 2.g only, declare the associated system inoperable within, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of LPCI initiation capability; and

b. For Trip Function 2.g, place any inoperable channel in trip within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c. For Trip Function 2.d restore any inoperable channel to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If any applicable Action,and associated completion time of Note 3.a, 3.b or 3.c is not 'met, immediately declare associated' systems inoperable.

4. With one or more channels inoperable for ECCS instrumentation Trip Functions 3.a and 3.c:

a. Declare the HPCI System inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of HPCI System initiation capability; and

b. Place any inoperable channel in trip within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If any applicable Action and associated completion time of Note 4.a or 4.b is not met, immediately declare HPCI System inoperable.

5. With one or more channels inoperable for ECCS instrumentation Trip Function 3.b:

a. Declare the. HPCI System inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery' of loss of HPCI initiation capability when HPCI System suction is aligned to the Condensate Sto~age Tank; and

b. Place any inoperable channel in trip or align HPCI System suction to the suppression pool within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If any applicable Action and associated completion time of Note 5.a or 5.b is not met, immediately declare the HPCI System inoperable.

Amendment No. ~, 236

,39

VYNPS Table 3.2.1 ACTION Notes (Continued)

6. With one or more channels inoperable for ECCS instrumentation Trip Function 3.d:

a. Restore any inoperable channel to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If the Action and associated completion time of Note 6.a is"not met, immediately declare the HPCI System inoperable.

7. With one or more channels inoperable for ECCS instrumentation Trip Functions 4.a and 4.b:

a. Declare ADS inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems; and

b. Place any inoperable channel in trip within 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months from discovery of the inoperable channel concurrent with HPCI" System or RCIC System inoperable, and

c. Place any inoperable channel in trip within 8 days.

If any applicable Action and associated completion time of Note 7.a, 7.b or 7.c is not met, immediately declare ADS inoperable.

8. With one or more channels inoperable for ECCS instrumentation Trip Functions l.f, 2.f, 4.c and 4.d:

a. Declare ADS inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems; and

b. Restore any inoperable channel to operable status within 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months from discovery of the inoperable channel concurrent with HPCI System or RCIC System inoperable, and

c. Restore any inoperable channel to operable status within 8 days.

If any applicable Action and associated completion time of Note 8.a, 8.b or 8.c is not met, immediately declare ADS inoperable.

9. If the as-found channel setpoint *is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

10. The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

setpoints more conservative than the Limiting Trip Setpoint are acceptable provided that as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures to confirm channel performance.

The methodologies used to determine the as-found and the as-left tolerances are specified in the Vermont Yankee Setpoint Program Manual.

Amendment No. ~, 236 40

VYNPS Table 4.2.1 (page 1 of 2)

Emergency Core Cooling System Instrumentation Tests and Frequencies TRIP FUNCTION CHECK FUNCTIONAL TEST CALIBRATION

1. Core Spray System

a. High Drywell Once/Day Every 3 Months Every 3 Months la)

Pressure Once/Operating Cycle r

b. Low-Low Reactor Once/Day Every 3 Months Every 3 Months la)

Vessel Water Level Once/Operating Cycle

c. Low Reactor Pressure NA Every 3 Months*

Every 3 Months la)

(Initiation)

Once/Operating Cycle

d. Low Reactor Pressure NA Every 3 Months Every 3 Months la)

(System Ready and Once/Operating Cycle Valve Permissive)

e. Pump Start Time NA NA Once/Operating Cycle Delay

f. Pump Discharge NA Every 3 Months Every 3 Months Pressure

g. Auxiliary Power Once/Day Every 3 Months NA Monitor h.* Pump Bus Power Once/Day Every 3 Months NA Monitor

2. Low Pressure Coolant Injection (LPCI) System J

a. Low Reactor Pressure NA Every 3 Months Every 3 Months la)

(Initiation)

Once/Operating Cycle

b. High Drywell Once/Day Every 3 Months Every 3 Months la)

Pressure Once/Operating Cycle (Initiation)

c. Low-Low Reactor**

Once/Day Every 3 Months Every 3 Months la)

Vessel Water Level Once/Operating Cycle

d. Reactor Vessel NA Every 3 Months Every 3 Months lal Shroud Level Once/Operating Cycle

e. LPCI Band C Pump NA NA Once/Operating Cycle Start Time Delay

f. RHR.Pump Discharge NA Every 3 Months Every 3 Months Pressure

g. High Drywell NA Every 3 Months Every 3 Months la)

Pressure Once/Operating Cycle (Containment Spray Permissive)

(a)

Trip unit calibration only.

Amendment No. ~, 236 41

VYNPS Table 4.2.1 (page 2 of ?)

Emergency Core Cooling System Instrumentation Tests and Frequencies TRIP FUNCTION

'CHECK FUNCTIONAL TEST CALIBRATION

2. LPCI System (Continued)

h. Low Reactor Pressure (System Ready and Valve Permissive)

NA Every 3 Months Every 3 Months (a)

Once/Operating Cycle

i. Auxiliary Power Monitor Once/Day Every 3 Months NA

j. Pump Bus Monitor Power Once/Day Every 3 Months NA

3. High Pressure Coolant Injection (HPCI) System

a. Low-Low Reactor Vessel Water Level Once/Day Every 3 Months Every 3 Months (a)

Once/Operating Cycle

b. Low Condensate Storage Tank Water Level NA Every 3 Months Every 3 Montp,s,

c. High Drywell Pressure Once/Day Every 3 Months Every 3 Months la)

Once/Operating Cycle

d. High' Reactor Vessel Water Level NA Every 3 Months Every 3 Months~)

Onc~/Operating Cycle

4. Automatic Depressurization System (ADS)

a. Low-Low Reactor Vessel Water Level Once/Day Every 3 Months Ev!'!ry 3' Months (a)

Once}Operating Cycle

b. High Drywell Pressure Once/Day Every 3 Months Every '3 Months la)

Once/Operating 'Cycle

c. Time Delay NA NA Once/Operating Cycle

d. Sustained Low-Low Reactor Vessel Water Level Time Delay NA NA Once/Operating Cycle (a)

Trip unit calibration only.

Amendment No. -l-64 236 42

VYNPS 3.2 LIMITING CONDITIONS FOR OPERATION 3.2 PROTECTIVE INSTRUMENT SYSTEMS B.

Primary Containment Isolation The primary containment isolation instrumentation for

,each Trip Function in Table 3.2.Z shall be operable in accordance,with Table 3.2.2.

4.2 SURVEILLANCE REQUIREMENTS 4.2 PROTECTIVE INSTRUMENT SYSTEMS B.

Primary Containment Isolation

1. The primary containment isolation instrumentation shall be checked, functionally tested and calibrated as indicated in Table 4.2.2.

When a primary containment isolation channel, and/or the affected primary containment isolation valve, is placed in an inoperable status solely for performance of required instrumentation surveillances, entry into associated Limiting Conditions for Operation and required Actions may be delayed'for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Trip Function maintains isolation capability.

2. Perform a Logic System Functional Test of Primary Containment isolation instrumentation Trip Functions once every Operating Cycle.

Amendment No. ~" 236 43

VYNPS Table 3.2.2 (page 1 of 3)

Primary Containment Isolation Instrumentation ACTIONS WHEN ACTIONS APPLICABLE MODES REQUIRED REQUIRED REFERENCED OR OTHER CHANNELS CHANNELS FROM SPECIFIED PER TRIP ARE ACTION TRIP TRIP FUNCTION CONDITIONS SYSTEM INOPERABLE NOTE 1 SETTING

1. Main Steam Line Isolation a.Low-Low Reactor Vessel Water Level RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN', Refuel (a) 2 Note 1 Note 2.a

~ 82.5 inches b.High Main Steam Line Area

'Temperature RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a) 8 Note 1 Note 2.a s; 196 OF for channels monitoring outside steam tu'nne1 and S; 200 OF for channels monitoring inside steam tunnel c'. High Main Steam Line Flow RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel 1a) 2 per main steam line Note 1 Note 2.a s; 140% of.

rated flow d.Low Main Steam Line Pressure RUN 2

Note 1 Note 2.e

~ 800 psig e.High Main Steam Line Flow - Not in RUN STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a) 2 Note 1 Note 2.a s; 40% of rated flow

f. Condenser, Low.

Vacuum RUN, STARTUP/HOT STANDBY Ibl, HOT SHUTDOWN (b),

Refuel (al * (b) 2 Note 1 Note 2.a s; 12 inches Hg absolute

2. Primary Containment Isolation a.Low Reactor Vessel Water Level RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a) 2 Note 1 Note 2.b

~ 127.0 inches

b. High Drywell Pressure RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (al 2

Note 1 Note 2.b s; 2.5 psig (a)

With reactor coolant temperature> 212 OF.

(b)

With any turbine stop valve or turbine bypass valve not closed.

Amendment No. ~, 236 44

VYNPS Table 3.2.2 (page 2 of 3)

Primary Containment Isolation Instrumentation ACTIONS WHEN ACTIONS APPLICABLE MODES REQUIRED REQUIRED REFERENCED OR OTHER CHANNELS CHANNELS FROM SPECIFIED PER TRIP ARE ACTION TRIP TRIP FUNCTION CONDITIONS SYSTEM INOPERABLE NOTE 1 SETTING

3. High Pressure Coolant Injection (HPCI) System Isolation a.High Steam Line Space Temperature RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (0) 6 Note 1 Note 2.d b.High Steam Line dip (Steam Line Break)

RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (al 1

Note 1 Note 2.d s; 195 inches of water c.Low Steam Supply Pressure RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (0) 4 Note.1 Note 2.d

~ 70 psig d.High Main Steam Line Tunnel Temperature RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (al 2

Note 1 Note 2.d e.High Main Stea~

Line Tunnel Temperature Time Delay RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (0) 1 Note 1 Note 2.d s; 35 minutes

4. Reactor Core Isolation Cooling (RCIC) System Isolation a.High Main Steam Line Tunnel Temperature RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (0) 2 Note 1 Note 2.d b.High Main Steam Line Tunnel Temperature Time Delay RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (0) 1 Note '1 Note 2.d s; 35 minutes c.High Steam Line Space Temperature RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (0) 6 Note 1 Note 2.d (a)

With reactor cool~nt temperature> 212 of.

Amendment No. ~, 236 45

VYNPS Table 3.2.2 (page 3 of 3)

Primary Containment Isolation Instrumentation ACTIONS WHEN ACTIONS APPLICABLE MODES REQUIRED REQUIRED REFERENCED

'OR OTHER CHANNELS CHANNELS FROM SPECIFIED PER TRIP ARE ACTION TRIP TRIP FUNCTION CONDITIONS SYSTEM INOPERABLE NOTE 1 SETTING

4. RCIC System Isolation (Continued) d.High Steam Line dIp (Steam Line Break) e.High Steam Line dIp Time Delay f.Low Steam Supply Pressure

5. Residual Heat Removal Shutdown Cooling Isolation a.High Reactor Pressure RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a) 1 Note 1 Note 2.d

s; 195 inches of water RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a' 1

Note 1 Note 2.d

~ 3 seconds, and'

s; 7'seconds RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a) 4 Note 1 Note 2'.d

~ 50 psig RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a' 1

Note 1 Note 2.d

s; 150 psig (a)

With reactor coolant temperature> 212 OF.

Amendment No. -H4, 236 46

VYNPS '

Table 3.2.2 ACTION Notes

1.

With one or more required Primary Containment Isolation Instrumentation channels inoperable,,take all of the 'applicable Actions in Notes 1.a and l.b below.

a. With one or more Trip Functions with one or more required channels' inoperable:

1)

For Trip Functions 2.a and 2.b, place any inoperable channel in trip within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; and

2)

For Trip Functions 3.e, 4.b, and 4'.e, restore any inoperable channel to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; and

3)

For all other Trip Functions, place any inoperable channel in trip within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. With one or more Trip Functions with isolation capability not maintained:

1)

Restore isolation capability within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Penetration flow' paths, isolated as a result of complying with the above Actions, may be unisolated intermittently under administrative controls.

If any applicable and associated completion time of Note l.a or l.b is not met, take the appli~able Actions of Note 2 below and referenced in Table 3.2.2 for the channel.

2'. a. Isolate the associated Main Steam Line within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (penetration flow paths may be unisolated intermittently under administrative control); or Place the reactor in HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 'and place the reactor in COLD SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. Place the reactor in COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c.Place the reactor in STARTUP/HOT STANDBY within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

d. Isolate the affected penetration flow path within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and comply with specificati9ns 3.5 and 3.7 (penetration flow paths may be unisolated intermittently under administrative control).

Amendment No.~

236 47

VYNPS Table 4.2.2 (page 1 of 2)

Primary Contalnment Isolation Instrumentation Tests and Frequencies TRIP FUNCTION CHECK FUNCTIONAL TEST CALIBRATION

1. Main Steam Line

Isolation

a. Low-Low Reactor Vessel Water Level Once/Day Every 3 Months Every 3 Months (a)

Once/Operating Cycle

b. High Main Steam Line Area Temperature NA Every 3 Months Each Refueling Outage

c. High Main Flow Steam Line Once/Day Every 3 Months Every.3 Months (a)

Once/Operating Cycle

d. Low Main Pressure Steam Line NA Every 3 Months Every 3 Months

e. High Main Steam Line Flow - Not in RUN Once/Day Every 3 Months Every 3* Months (a)

Once/Operating Cycle

f. Condenser Low Vacuum NA Every 3 Months Every 3 Months

2. Primary Containment Isolation

a. Low Reactor Vessel Water Level NA Every 3 Months Every 3 Months (a)

Once/Operating Cycle

b. High Drywell Pressure Once/Day Every 3 Months Every 3 Months (a)

Once/Operating Cycle

3. High Pressure Coolant Injection (HPCI) System Isolation

a. High Steam Line Space Temperature NA Every 3 Months Each Refueling Outage

b. High Steam Line dip (Steam Line Break)

NA Every 3 Months Every 3 Months

c. Low Steam Supply Pressure NA Every 3 Months Every 3 Months

d. High Main Steam Line Tunnel Temperature NA Every 3 Months Each Refueling Outage

e. High Main Steam Line Tunnel Temperature Time Delay NA NA Once/Operating Cycle (a)

Trip unit calibration only.

AInendment No. -+/--64 2"36 48

VYNPS Table 4.2.2 (page 2 of 2)

~rimary Containment Isolation Instrumentation Tests and Frequencies TRIP FUNCTION CHECK FUNCTIONAL TEST CALIBRATION

4. Reactor Core Isolation Cooling (RCIC) System Isolation

a. High Main Steam Line Tunnel Temperature NA Every 3 Months Each Refueling Outage

b. High Main Steam Line Tunnel Temperature Time Delay NA

. NA Once/Operating Cycle

c. High Steam Line Space Temperature NA Every 3 Months Each Refueling Outage

d. High Steam Line dip (Steam Line Break)

NA Every 3 Months Every 3 Months

e. High Steam Line dip (Steam Line Break)'

Time Delay NA Every 3 Months.

Every 3 Months

f. Low Steam Supply Pressure NA Every 3 Months Every 3 Months

5. Residual Heat Removal Shutdown Cooling Isolation

a. High Reactor Pressure NA Every 3 Months Every 3 Months Amendment No. ~, 236 49

3.2 LIMITING CONDITIONS FOR OPERATION 3.2 PROTECTIVE INSTRUMENT SYSTEMS C. Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation The reactor building ventilation isolation and Standby Gas Treatment System initiation instrumentation for each Trip Function in Table 3.2.3 shall be operable in accordance with

Table 3.2.3.

VYNPS 4.2 SURVEILLANCE REQUIREMENTS 4.2 PROTECTIVE INSTRUMENT SYSTEMS C. Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation

1. The reactor building ventilation isolation and Standby Gas Treatment System initiation instrumentation shall be checked, functionally tested and calibrated as indicated in Table 4.2.3.

When a channel is placed in an inoperable status solely for performance of required instrumentation surveillances, entry* into the associated Limiting Conditions for Operation and required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Trip Function maintains reactor building ventilation isolation capability'and Standby Gas Treatment System initiation.

capability.

2. Perform a Logic System Functional Test of reactor building venti~ation isolation and Standby Gas rreatment

'System initiation instrumentation Trip Functions once every Operating Cycle.

Amendment No. ~, 236.

50

VYNPS Table 3.2.3 (page 1 of 1)

Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation Instrumentation TRIP FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER TRIP SYSTEM ACTIONS WHEN REQUIRED CHANNELS ARE INOPERABLE TRIP SETTING

l. Low Reactor Vessel Water Level RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel la). (b) 2 Note 1

~127.0 inches

2. High Drywell Pressure RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel 1al 2

Note 1

~ 2.5 psig

3. High Reactor Building Ventilation Radiation RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel la). (bl, (e). (d) 1 Note 1

~14 mR/hr

4. High Refueling Floor Zone Radiation RUN, STARTUP/HOT STANDBY, HOT SHUTDOWN, Refuel (a); (b), (e), (d) 1 Note 1

~ 100 mR/hr (a)

With reactor coolant temperature> 212 OF.

(b)

During operations with potential for draining the reactor vessel.

(c)

During movement of irradiated fuel assemblies or fuel cask in secondary containment.

(d)

During Alteration of the Reactor Core.

Amendment No. ~, 236 51

VYNPS Table 3.2.3 ACTION Note

1. With one or more required Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation Instrumentation channels inoperable, take all of the applicable Actions in Notes 1.a and 1.b below.

a. With one or more Trip Functions with one or more required channels inoperabl'e:

1) For Trip Functions 1 and 2, place any inoperable channel in trip within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; and

2) For Trip Functions 3 and 4, place any inoperable.channel in trip within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. With one or more'Trip Functibns with isolation or initiation papabi1ity not maintained:

1) Restore isolation and initiation capability within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

If any applicable Action and associated completion time of Note l.a or 1.b is not met, isolate the Reactor Building Ventilation System and place the Standby Gas Treatment System in operation within I hour.

Amendment' No. ~, 236 52

VYNPS Table 4.2.3 (page 1 of 1)'

Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation Instrumentation Tests.and.Frequencies TRIP FUNCTION CHECK FUNCTIONAL TEST CALIBRATION

1. Low Reactor Vessel Water Level NA Every 3 Months Every 3 1"1onths (s)

Once/Operating Cycle

2. High Drywell Pressure NA Every 3 Months Every 3 Months (s)

Once/Operating Cycle

3. High Reactor Building Ventilation Radiation Once/Day Every 3 Months Every 3 Months

4. High Refueling Floor Zone Radiation Once/Day During Refueling Every 3 Months Every 3 Months (a)

Trip unit calibration only.

Amendment No.-+/--64, 236 53

VYNPS 3.2 LIMITING CONDITIONS FOR OPERATION D.

Deleted.

E.

Control Rod Block Actuation The control rod block instrumentation for each Trip Function in Table 3.2.5 shall be operable in accordance with Table 3.2.5.

4.2 SURVEILLANCE REQUIREMENTS D.

Deleted.

E.

Control Rod Block Actuation

1. The control rod block instrumentation shall be functionally tested and calibrated as indicated in Table 4.2.5.'

When a Rod Block Monitor channel is placed in an inoperable status solely for performance of required surveillances, entry into associated Limiting Conditions for Operation and required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Trip Function maintains control rod block initiation capability.

Amendment No. ~, ~, 236 54

VYNPS Table 3.2.5 (page 1 of 1)

Control Rod Block Instrumentation TRIP FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER TRIP FUNCTION ACTIONS WHEN REQUIRED CHANNELS ARE INOPERABLE lI'RIP SETTING

l. Rod Block Monitor

a. Upscale (Flow Bias)

> 30% RATED THERMAL POWER 2

Note 1 SO. 66 (W) +N with a maximum as defined in the COLR 1b)

b. Downscale

> 30% RATED THERMAL POWER 2

Note 1

~ 2/125 scale full

c. Inop

> 30% RATED THERMAL POWER 2

Note 1 NA

2. Reactor Mode Switch Shutdown Position (a) 2 Note 2 NA (a)

When reactor mode switch is in the shutdown position.

(b)

Trip Setting S 0.66 (W-6W)+N for single loop operation.

Amendment No. ~, 236 55

VYNPS Table 3.2.5. ACTION Notes 1.. With one or two RBM channels inoperable, take all of the applicable Actions in Notes l.a and l.b below.

a. If one RBM channei is inoperable, restore the inoperable channel to*

operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. If the required Action and associated completion time of Note l.a above is not met~ or if two RBM channels are inoperable, place one RBM channel in trip within the *next hour.

2. With one or more Reactor Mode Switch - Shutdown Position channels inoperable, immediately suspend control rod withdrawal and immediately

.initiate actions to fully insert all insertable control rods in core cells containing one or more fuel assemblies.

Amendment No. ~, 236 56

VYNPS Table 4.2.5 (page 1 of 1)

Control Rod Block Instrumentation Tests and.Frequencies TRIP FUNCTION FUNCTIONAL TEST CALIBRATION

1. Rod Block Monitor (RBM)

a. Upscale (Flow Bias)

b. Downscale

c. Inop Every 3 Months Every 3 Months Every 3 Months Every 3 Months (b). (e)

Every 3 Months(~

NA

2. Reactor Mode Switch Shutdown Position

Every Refueling Outage 1al NA (a)

Required to be completed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after the reactor mode switch is placed in the shutdown position.

(b)

Neutron detectors are excluded.

(c)

Includes calibration of the RBM Reference Downscale function (Le., RBM upscale function is not bypassed when >30% Rated Thermal Power).

Amendment No. -+/--64, 236 57

VYNPS 3.2 LIMITING CONDITIONS FOR OPERATION F. Mechanical Vacuum Pump Isolation Instrumentation

1. When the reactor is in the RUN or STARTUP/HOT STANDBY Mode and the mechanical vacuum pump is in service, 4 channels of the High Main Steam Line Radiation Trip Function for mechanical vacuum pump isolation shall be operable.

4.2 SURVEILLANCE REQUIREMENTS F. Mechanical Vacuum Pump Isolation Instrumentation

1. The High Main Steam Line Radiation Trip Function for mecpanical vacuum pump isolation shall be checked, functionally tested and calibrated as indicated in Surveillance Requirements 4.2.F.1.a, b, c, d and e.

When a channel is placed in an inoperable status solely for performance of required surveillances, entry into associated Limiting Conditions for Operation and required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Trip Function maintains mechanical vacuum pump isolation capability.

a. Perform an Instrument Check once each day.

b. Perform an Instrument Functional Test once every 3 months.

c. Perform an Instrument Calibration, except for radiation detectors, using a current source once every 3 months.

The Trip Setting shall be < 3.0 X background at rated thermal power.

d. Perform an Instrument Calibration using a' radiation source once each Refueling Outage.

e. Perform a Logic System Functional Test, including mechanical vacuum pump isolation valve, once every Operating Cycle.

Amendment No. -+/--64, ~, 236 58

VYNPS 3.2 LIMITING CONDITIONS FOR 4.2 SURVEILLANCE REQUIREMENTS OPERATION

2. If Specification 3.2.F.l is not met, take all.of the applicable Actions in Specifications 3.2.F.2.a and 2.b below.

a. With one or more channels inoperable:

1) Restore any inoperable channel to operable status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; or

2) Place'any inoperable channel or associated trip system in the trip condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (not applicable if the inoperable channel is the result of an inoperable mechanical vacuum pump isolation valve).

b. If the required Action and associated completion time of Specification 3.2.F.2.a above is not met~ or if mechanical vacuum pump isolation capability is not maintained:

1) Isolate the mechanical vacuum pump within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; or

2) Isolate the main steam lines within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; or

3) Place the reactor in the SHUTDOWN Mode within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Amendment No.l-#, ~, 236 59

VYNPS 3.2 LIMITING CONDITIONS FOR OPERATION G.

Post-Accident Monitoring Instrumentation The post-accident monitoring instrumentation for each Function in Table 3.2.6 shall be operable in accordance with Table 3.2.6.

4.2 SURVEILLANCE REQUIREMENTS G.

Post-Accident Monitoring Instrumentation

1. The post-accident monitoring instrumentation shall be checked and calibrated in accordance with Table 4.2.6.

When a channel is placed in an inoperable status solely for performance of required surveillances, entry into associated Limiting Conditions for J*

d Operatlon and requlre Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Amendment No. %, -+/--64, 236 60

VYNPS Table 3.2.6 (page 1 of 1)

Post-Accident Monitoring Instrumentation.

FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION ACTIONS WHEN REQUIRED CHANNELS ARE INOPERABLE

l.

Drywell Atmospheric Temperature RUN, STARTUP/HOT STANDBY 2

Note 1

2.

Drywe11 Pressure RUN, STARTUP/HOT STANDBY 2

Note 1

3.

Torus Pressure RUN, STARTUP/HOT STANDBY 2

Note 1

4.

Torus Water Level RUN, STARTUP/HOT STANDBY

2 Note 1

5.

Torus Water Temperature RUN, STARTUP/HOT STANDBY 2

Note 1

6.

Reactor Pressure RUN, STARTUP/HOT STANDBY 2

Note 1

7.

Reactor Vessel Level Water RUN, STARTUP/HOT STANDBY 2

Note 1

8.

Torus Air Temperature RUN, STARTUP/HOT STANDBY 2

Note 1

9.

Containment High Range Radiation Monitor RUN, STARTUP/HOT STANDBY 2

Note 2 Amendment No. ~, ~, 236 61

VYNPS Table 3.2.6 ACTION Notes

1. With, one or more Post-Accident Monitoring instrumentation channels, for Functions other than Function 9, inoperable, take ail of the applicabl~

Actions in Notes l.a and l.b below.

a. With one or more Functions with one channel inoperable:

1) Restore channel to operable status within 30 days; or

2) Prepare and submit a special report to the Commission within the next 14 days, outlining the Action taken, the cause of the inoperability, and the plans and schedule for restoring the channel to operable status.'

b. With one or more Function~ with two channels inoperable:

1) Restore one required channel to operable status with~n 7 days; or

2) Place the, reactor in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

2. With one or more Post - Accident Monitoring instrumentation Function 9 channels inoperable, take all of the applicable Actions in Notes 2.a and 2.b below.

a. With one channel inoperable:

1) Restore channel to operable status within 30 days; or

2) Prepare and submit a special report to the Commission within the next 14 days, outlining the Action taken, the cause of the inoperabi+ity, and the plans and schedule for restoring the channel to operable status.

b. With two channels inoperable:

1) Restore one channel to operable status within 7 days; or

2) Prepare and submit a special report to the Commission within the next 14 days, outlining the Action taken, the cause of the inoperability, and the plans and schedule for res~oring the channels to operable status.

Amendment No. -%0, ~, 236 62

VYNPS.

Table 4.2.6 (page 1 of 1)

Post-Accident Monitoring Instrumentation Tests and Frequencies FUNCTION CHECK CALIBRATION

1.

Drywell Atmospheric Once/Day Every 6 Months Temperature

2.

Drywell Pressure Once/Day Once/Operating Cycle

3.

Torus Pressure Once/Day Once/Operating Cycle

4.

Torus Water Level Once/Day Once/Operating Cycle

5.

Torus Water Once/Day Every 6 Months Temperature

6.

Reactor Pressure Once/Day Once/Operating

'Cycle

7.

Reactor Vessel Water Once/Day Once/Operating Level Cycle

8.

Torus Air Temperature Once/Day Every 6 Months

9.

Containment High Once/Day Once/Operating Range Radiation Cycle Monitor Amendment No. %, ~, 236 63

VYNPS 3.2 LIMITING CONDITIONS FOR OPERATION*

H.

Deleted.

I. Recirculation Pump Trip Instrumentation The recirculation pump trip instrumentation for each Trip Function in Table 3.2.7 shall be operable in accordance with Table 3.2.7.

J. Deleted.

4.2 SURVEILLANCE REQUIREMENTS H.

Deleted.

L Recirculation Pump Trip Instrumentation

1. The recirculation pump trip instrumentation *shall be checked, functionally tested and calibrated in accordance with Table 4.2.7.

When a channel is placed in an inoperable status solely. for performance of required surveillances, entry into associated Limiting Conditions for Operations and required Actions may be delayed for up to.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Trip Function maintains recirculation pump trip capability.

2. Perform a Logic System Functional Test, including recirculation pump trip breaker actuation, of recirculation pump.trip instrumentation Trip Functions once every Operating Cycle.

J. Deleted Amendment No..§.eo,

.§.eo, ~, ~, 236 64

VYNPS Table" 3.2.7 (page 1 of +)

Recirculation Pump Trip Instrumentation TRIP FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER TRIP SYSTEM ACTIONS WHEN REQUIRED CHANNELS ARE INOPERABLE TRIP SETTING

l. Low-Low Reactor Vessel Water Level RUN 2

Note 1

~ 82.5 inches

2. Time Delay RUN 2

Note 1

10 seconds

3. High Reactor Pressure RUN 2

Note 1

1150 psig Amendment No. ~, +64-, 236 65

VYNPS Table 3.2.7 ACTION Notes

1. With one or more recirculation pump trip instrumentation channels inoperable, take all of the applicable Actions in Notes l.a, l.b and I.c below.

a. With one or more Trip Functions with one or more channels inoperable:

1) Restore any inoperable channel to operable status within 14 days; or

2) Place any inoperable channel in trip within 14 days (not'applicable for Trip Function, 2 cha'nnels and not applicable if the inoperable channel is the result of an inoperable recirculation pump trip breaker).

b. With Trip Functions 1 and 2 with recirculation pump trip capability ~ot maintained or with Trip Function 3 with recirculation pump trip capability not maintained:

1) Restore recirculation pump trip capability within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

c. With Trip Functions 1, 2 and 3 with recirculation pump trip capability not maintained:

1) Restore recirculation pump trip capability for all but one Trip Function within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

If any applicable Action and associated completion time of Note 1.a, 1.b or 1.c is not met, immediately take the applicable Action of Note 2.a or 2.b.

2. a. Remove affected recirculation pump from service within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; or

b. Place the plant in STARTUP/HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Amendment No. ~, 64, 236 66

VYNPS Table 4.2.7 (page 1 of 1)

Recirculation Pump Trip Instrumentation Tests and Frequencies TRIP FUNCTION CHECK FUNCTIONAL TEST CALIBRATION

1. Low-Low Reactor Vessel Once/Day Every 3 Months Every 3 Months (a)

Water Level Once/Operating Cycle

2. Time Delay NA NA Every 3 Months

3. High Reactor Pressure Once/Day Every 3 Months Every 3 Months (a) once/Operating Cycle (a) Trip unit calibration only.

Amendment No. 58-, -i-64, 236 67

VYNPS 3.2 LIMITING CONDITIONS FOR OPERATION K.

Degraded Grid Protective S:istem The emergency bus undervoltage instrumentation for each Trip Function in Table 3.2.8 shall be operabie in accordance with Table 3.2.8.

4.2 SURVEILLANCE REQUIREMENTS K.

Degraded Grid Protective S:istem The emergency bus undervoltage instrumentation shall be functionally tested and calibrated in accordance with Table 4.2.8.

Amendment No. ~, ~,. 236 68

VYNPS Table 3.2.8 (page 1 of 1)

Degraded Grid Protective System Instrumentation TRIP FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER'-BUS ACTIONS WHEN' REQUIRED CHANNELS ARE INOPERABLE TRIP SETTING

l. Degraded Bus Voltage a,. Voltage Trip (b)

(a) 2 Note'l

'~ 3660 volts and S 3740 volts

b. Time Delay 'Trip (b)

(a) 1 Note 2

~ 9 seconds and S 11 *seconds

c. Voltage Alarm (c)

(a) 2 Note 3

~ 3660'volts and

~ 3740 volts

d. Alarm Time Delay (c)

(a) 1 Note 3

~9 seconds and S 11 seconds (a)

When. the associated diesel generator is required to be operable per specifications 3.5, 3.7 and 3.10.

(b)

LOCA condition.

(c)

Non-LOCA condition.

Amendment No. %, '}-64, 236 69

VYNPS Table 3.2.8 ACTION Notes

1. With one or more r~quired Degraded Bus Voltage - Voltage Trip Function channels inoperable:

a. Place any inoperable channel in trip within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

If the Action and associated completion time of Note 1.a are not met, immediately declare the associated diesel generator inoperable.

2. With one or more required Degraded Bus Voltage - Time Delay Trip Function channels inoperable:

a. Restore any inoperable channel to operable status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

If the Action and associated completion time of Note 2.a are not met, immediately declare the associated diesel generator inoperable.

3. With one or more required Degraded Bus Voltage - Voltage Alarm and/or Alarm Time Delay Trip Function channels inoperable, take all of the applicable Actions in Notes 3.a and 3.b:

a. With one or more buses with alarm capability not maintained, restore alarm capability within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ; and

b. Restore any inoperable channel to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If the Action and associated completion time of Note 3.a or 3.b are not met, immediately initiate increased voltage monitoring of the associated 4.16kV emergency busIes) to twice per shift.

Amendment No. ~, ~, 236 70

VYNPS Table 4.2.8 (page 1. of 1)

Degraded Grid Protective System Instrumentation Tests and Frequencies TRIP FUNCTION FUNCTIONAL TEST CALIBRATION

1. Degraded Bus Voltage

a. Voltage Trip (a)

Once/Operating Cycle

b. Time Delay Trip (a)

Once/Operating Cycle

c. Voltage Alarm (a)

Once/Operating Cycle

d. Alarm Time Delay (a)

Once/Operating Cycle (a). Separate Functional Tests are not required for this Trip Function. Trip Function operability is demonstrated during Trip Function Calibration and integrated ECCS tests performed once per Operating Cycle.

Amendment No. -%, ~, 236 71

VYNPS 3.2 LIMITING CONDITIONS FOR OPERATION L. Reactor Core Isolation Cooling (RCIC) System Actuation The RCIC System instrumentation for each Trip..

Function in Table 3.2.9 shall be operable in accordance with Table 3.2.9.

4.2 SURVEILLANCE REQUIREMENTS L. Reactor Core Isolation Cooling (RCIC) System Actuation

1. The RCIC System instrumentation shall be checked, functionally tested and calibrated as indicated in Table 4.2.9.

When a channel is placed in an inoperable status solely for performance of required surveillances, entry into associated Limiting Conditions for Operation and required Actions may be delayed as follows:

(a) for u~ to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Trip Function 3; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Trip Functions 1 and 2 provided the associated Trip Function maintains RCIC initiation capability.

2. Perform a Logic System Functional Test of RCIC System instrumentation Trip Functions once every Operating Cycle.

An\\endment No. -+/--H, ~, 23"6 72

VYNPS Table 3.2.9 (page 1 of 1)

Reactor Core Isolation Cooling System Instrumentation ACTIONS WHEN REQUIRED REQUIRED APPLICABLE MODES OR CHANNELS CHANNELS OTHER SPECIFIED PER ARE TRIP FUNCTION CONDITIONS FUNCTION INOPERABLE TRIP SETTING

l. Low-Low Reactor RUN, STARTUP/HOT 4

Note 1

~ 82.5 inches Vessel water STANDBY (a), HOT Level SHUTDOWN (a), Refuel (a)

2. Low Condensate RUN, STARTUP/HOT 2

Note 2

~ 3. SH lb)

Storage Tank water Level STANDBY (a), HOT SHUTDOWN (a), Refuel (a)

3. High Reactor RUN, STARTUP/HOT 2

Note 3

~ 177.0 inches

. Vessel Water*

STANDBY (a), HOT Level SHUTDOWN (a), Refuel (a)

(a) with reactor stearn pressure> 150 psig.

(b)

Percent of instrument span.

Amendment No. -H-+/--, -+/--64, 236 73

VYNPS Table 3.2.9 ACTION Notes

1. With one or more RCIC System instrumentation Trip Function 1 channels inoperable:

a. Declare the RCIC System inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of RCIC initiation capability; and

b. Place any inoperable'channel in trip within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If any applicable 'Action and associated completion time of Note 1.a or 1.b is not met, immediately declare the RCIC System inoperable.

2. With one or more RCIC System instrumentation Trip Function 2 channeis inoperable:

a. Declare the RCIC System inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of RCIC initiatio~ capability when RCIC System suction is aligned to the Condehsate Storage Tank; and

b. Place ariy inoperable channel in trip or align RCIC System suction to the suppression.p091 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If any applicable Action and associated completion time of Note 2.a or 2.b is not met, immediatel.y declare the RCIC System inoperable.

3. With one or more RCIC System instrumentation Trip Function 3 channels inoperable:

a. Restore any inoperable channel to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If the Action and associated completion time of Note 3.a is not met, immediately declare the RCIC System inoperable.

Amendment No. -H+, ~, 236 74

VYNPS Table 4.2.9 (page 1 of 1)

Reactor Core Isolation COOling System Instrumentation Tests and Frequencies TRIP FUNCTION CHECK FUNCTIONAL TEST CALIBRATION

l. Low-Low Reactor Vessel Once/Day Every 3 Months Every 3 Months (a)

Water Level Once/Operating Cycle

2. Low Condensate Storage NA Every 3 Months Every 3 Months (a)

Tank Water Level Once/Operating Cycle

3. High Reactor 'Vessel NA Every 3 Months Every 3 Months (a)

Water Level Once/Operating Cycle (a)

Trip unit calibration only.

Amendment No. -H:-+/--, ~, 236 74a

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

.RELATED TO AMENDMENT NO. 236 TO FACILITY OPERATING LICENSE NO. DPR-28 ENTERGY NUCLEAR VERMONT YANKEE, LLC AND ENTERGY NUCLEAR OPERATIONS, INC.

VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271

1.0 INTRODUCTION

By application dated February 12, 2008 (Accession No. ML080660458), as supplemented by letters dated August 28,2008 (ML082490165), September 15, 2008 (ML082660371),

October 17, 2008 (ML082970191), December 15, 2008 (ML083540188), December 18, 2008 (two letters, ML083640317 and ML083650006), April 9, 2009 (ML091110498), and May 20, 2009 (ML091470321), Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (the licensee) submitted a request to amend the Vermont Yankee Nuclear Power Station (VY) Technical Specifications (TSs). The proposed amendment would revise TS Sections 2.1, "Limiting Safety System Setting," 3.1, "Reactor Protection System," 3.2, "Protective Instrument Systems." associated Surveillance Requirements (SRs), and other TS with similar requirements as these instrumentation TS sections. The supplemental letters dated August 28, 2008, September 15, 2008, October 17,2008, December 15,2008, December 18,2008 (two letters), April 9, 2009, and May 20,2009, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on April 22, 2008 (73 FR 21659).

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act requires that applicants for nuclear power plant operating licenses will provide:

[S]uch technical specifications, including information of the amount, kind, and source of special nuclear material required, the place of the use, the specific characteristics of the facility, and such other information as the Commission may, by rule or regulation, deem necessary in order to enable it to find that the utilization... of special nuclear material will be in accord with the common defense and security and will provide adequate protection to the health and safety of the public. Such technical specifications shall be a part of any hcense issued.

-2 In Title 10 of the Code of Federal Regulations (10 CFR) 50.36, the Commission established its regulatory requirements related to the content of TS. In doing so, the Commission placed emphasis on those matters related to the prevention of accidents and the mitigation of accident consequences. As recorded in the Statements of Consideration, "Technical Specifications for Facility Licenses; Safety Analysis Reports" (33 FR 18610, December 17, 1968), the Commission noted that applicants were expected to incorporate into their TS "those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity."

Pursuant to 10 CFR 50.36, TS are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plant's TS.

On July 22, 1993, the Commission issued its Final Policy Statement, expressing the view that satisfying the guidance in the policy statement also satisfies Section 182a of the Act and 10 CFR 50.36. The Final Policy Statement described the safety benefits of the Improved Standard Technical Specifications (ISTS, i.e. NUREGs 1430-1434) and encouraged licensees to use the ISTS as the basis for plant-specific TS amendments and for complete conversions based on the ISTS. In addition, the Final Policy Statement gave guidance for evaluating the required scope of the TS and defined the guidance criteria to be used in determining which of the LCOs and associated SR should remain in the TSs. The Commission noted that, in allowing certain items to be relocated to licensee-controlled documents while requiring that other items be retained in the TSs, it was adopting the qualitative standard enunciated by the Atomic Safety and Licensing Appeal Board in Portland General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979). There, the Appeal Board observed:

[T]here is neither a statutory nor a regulatory requirement that every operational detail set forth in an applicant's safety analysis report (or equivalent) be subject to a technical specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with specific Commission approval. Rather, as best we can discern it, the contemplation of both the Act and the regulations is that technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety. [...]

By this approach, existing LCO requirements that fall within or satisfy any of the criteria in the Final Policy Statement should be retained in the TS; those LCO requirements that do not fall within or satisfy these criteria may be relocated to licensee-controlled documents. The Commission codified the four criteria in 10 CFR 50.36 (60 FR 36953, July 19, 1995). The four criteria are stated as follows:

Criterion 1 Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2 A process variable, design feature, or operating restriction that is an initial condition of a design basis accident (DBA) or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

- 3 Criterion 3 A structure, system, or component [SSG] that is part of the primary success path and which functions or actuates to mitigate a [DBA]

or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4 An [SSG] which operating experience or probabilistic risk assessment [PRA] has shown to be significant to public health and safety.

Part 3.0 of this safety evaluation (SE) explains the NRC staff's determination that the use of the ISTS as the basis for VYs plant-specific TS amendment is consistent with the VY current licensing basis (CLB), the requirements and guidance of the Final Policy Statement, and 10 CFR 50.36.

The construction permit for VY was issued by the Atomic Energy Commission (AEC) on December 11, 1967. The plant was designed and constructed based on the proposed General Design Criteria (GDC) published by the AEC in the Federal Register (32 FR 10213) on July 11, 1967 (hereafter referred to as "draft GDG"). The AEC published the final rule that added Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear power Plants," in the Federal Register (36 FR 32555) on February 20, 1971 (hereinafter referred to as "final GDG").

Differences between the draft GDC and final GDC included a consolidation from 70 to 64 criteria. As discussed in the NRC staff Requirements memorandum for SECY-92-223, dated September 18, 1992 (ML003763736), the Commission decided not to apply the final GDC to plants with construction permits issued prior to May 21, 1971. At the time of promulgation of Appendix A to 10 CFR Part 50, the Commission stressed that the final GDC were not new requirements and were promulgated to more clearly articulate the licensing requirements and practice in effect at that time. Each plant licensed before the final GDC were formally adopted was evaluated on a plant-specific basis, determined to be safe, and licensed by the Commission.

As discussed in Appendix F of the VY Updated Final Safety Analysis Report (UFSAR), the licensees for VY have made changes to the facility over the life of the plant that may have invoked the final GDC. The extent to which the final GDC have been invoked can be found in specific sections of the UFSAR and other VY design and licensing basis documentation.

Although the final GDC quoted below are not directly applicable to VY, VY has similar requirements in their UFSAR.

GDC 10, "Reactor Design," of Appendix A, "General Design Criteria for Nuclear Plants, to 10 CFR Part 50, requires In part that protection systems be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences (AOOs).

GDC 13, "Instrumentation and Control," of Appendix A to 10 CFR Part 50, requires in part that instrumentation be provided to monitor variables and systems and that controls be provided to maintain these variables and systems within prescribed operating ranges during normal operation, AOOs, and for accident conditions. Specifically, the NRC staff reviewed the proposed

- 4 TS changes and the affected instrument setpoint calculations to ensure proper operation of the High-Pressure Coolant Injection (HPCI) System, Reactor Core Isolation Cooling (RCIC) System, and Primary Containment Isolation instruments.

GDC 20, "Protective System Functions," of Appendix A to 10 CFR Part 50, requires in part that the protection system be designed to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of AOOs. The NRC staff evaluated the license amendment request (LAR) to ensure that the proposed TS changes will still protect the fuel design limits and plant safety limits (SLs) and that these SLs will not be exceeded under plant transient, AOOs, and accident conditions.

3.0 TECHNICAL EVALUATION

In its review of the VY application, the NRC staff evaluated five kinds of current TS changes as defined by the licensee. The NRC staff's review also included an evaluation of whether existing regulatory requirements are adequate for controlling future changes to requirements that are removed from the current TS and placed in licensee-controlled documents. The following are the five types of current TS changes:

A Administrative - Changes to the current TS that do not result in new requirements or change operational restrictions and flexibility.

M More Restrictive - Changes to the current TS that result in added restrictions or reduced flexibility.

L Less Restrictive - Changes to the current TS that result in reduced restrictions or added flexibility.

LA Removed Details - Changes to the current TS that eliminate detail and relocate the detail to a licensee-controlled document. Typically, this involves details of system design and system description including design limits, description of system operation, procedural details for meeting TS requirements or reporting requirements, and cycle-specific parameter limits and TS requirements redundantly located in other licensee-controlled documents.

R Relocated Specifications - Changes to the current TS that relocate the requirements that do not meet the selection criteria of 10 CFR 50.36(c)(2)(ii).

The application included a justification for each proposed change to the current TS in a numbered discussion of change (DOC), using the above letter designations as appropriate.

The changes to the current TS, as presented in the application, are listed and described in the following five tables (for each TS section) provided as Attachments 1 through 5 to this SE:

Table A - Administrative Changes Table M - More Restrictive Changes Table L-Less Restrictive Changes Table LA - Removed Detail Changes Table R - Relocated Specifications

- 5 These tables provide a summary description of the proposed changes to the current TS. Further DOC justifications are provided in the licensee's application and supplemental letters. The information was provided in the licensee's application, as modified by supplemental letters, and was found to be acceptable by the NRC staff.

The NRC staff's evaluation and additional description of the kinds of changes to the current TS requirements listed in Tables A, M, L, LA, and R attached to this SE are presented in Sections A through E below, as follows:

Section A - Administrative Changes

Section B - More Restrictive Changes

Section C - Less Restrictive Changes

Section D - Removed Details

Section E - Relocated Specifications A.

Administrative Changes to the Current TS Administrative changes are intended to incorporate human factors principles into the form and structure of the proposed TS so that plant operations personnel can use them more easily.

These changes are editorial in nature or involve the reorganization or reformatting of current TS requirements without affecting technical content or operational restrictions. Every section of the application reflects this type of change. Among the changes proposed by the licensee and found acceptable by the NRC staff are:

Identifying plant-specific wording for system names, etc.;

Splitting up requirements currently grouped under a single current specification and moving them to more appropriate locations in two or more specifications of the proposed TS;

Combining related requirements currently presented in separate specifications of the current TS into a single specification of the proposed TS;

Presentation changes that involve rewording or reformatting for clarity (including moving an existing requirement to another location within the TS) but that do not involve a change in requirements;

Wording changes and additions that are consistent with current TS interpretation and practice and that more clearly or explicitly state existing requirements;

Deletion of TS that no longer apply;

Deletion of details that are strictly informational and have no regulatory basis; and,

Deletion of redundant TS requirements that exist elsewhere in the TS.

Table A attached to this SE lists the administrative changes being made in the VY application.

Table A is organized in proposed TS order by each A-type DOC to the current TS and provides a summary description of the administrative change that was made. The NRC staff reviewed all of the administrative and editorial changes proposed by the licensee and finds them acceptable because they do not result in any change in operating requirements, and are consistent with the Commission's regulations.

B.

More Restrictive Changes to the Current TS The licensee proposed a number of requirements that are more restrictive than those in the current TS. The changes in this category include requirements that are either new, more conservative than corresponding requirements in the current TS, or have additional restrictions that are not in the current TSs, but are in the ISTSs. Examples of more restrictive requirements

- 6 are placement of an LCO on plant equipment that is not required by the current TS, more restrictive requirements to restore inoperable equipment, and more restrictive SRs.

Table M attached to this SE lists the more restrictive changes being made in the VY application.

Table M is organized in proposed TS order by each M-type DOC to the current TS and provides a summary description of each more restrictive change that was adopted. The NRC staff reviewed each M-type DOC and found the changes to be acceptable because these changes provide additional restrictions on plant operation that enhance safety.

C.

Less Restrictive Changes to the TS Less restrictive requirements include deletions of and relaxations to portions of the current TS requirements that are being retained in the proposed TS. When requirements have been shown to give little or no safety benefit, their relaxation or removal from the TS may be appropriate. In most cases, relaxations-previously granted to individual plants on a plant-specific basis were the result of (1) generic NRC actions, (2) new NRC staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the Owners Groups' comments on ISTSs. The NRC staff reviewed generic relaxations contained in the ISTSs and found them acceptable because they are consistent with current licensing practices and the Commission's regulations. The VY design was also reviewed to determine if the specific design basis and licensing basis are consistent with the technical basis for the model requirements in the ISTSs and thus provide a basis for adoption.

The changes to the current TS involved deletions of and relaxations to portions of current TS requirements that may be grouped in the following categories:

Category 1 - Relaxation of LCO Requirement Category 2 - Relaxation of Applicability Category 3 - Relaxation of Completion Time Category 4 - Relaxation of Required Action Category 5 - Deletion of SR Category 6 - Relaxation of SR Acceptance Criteria Category 7 - Relaxation of Surveillance Frequency The following discussion addresses why these categories of less restrictive changes are acceptable:

Category 1 - Relaxation of LCO Requirement Certain current TS LCOs specify limits on operational and system parameters beyond those necessary to ensure meeting safety analysis assumptions and, therefore, are considered overly restrictive. The current TS also contain operating limits that have been shown to give little or no safety benefit to the operation of the plant. The proposed TS, consistent with the guidance in the ISTSs, would delete or revise such operating limits. Current TS LCO changes of this type may include: (1) redefining operating modes, including mode title changes; (2) deleting or revising operational limits to establish requirements consistent with applicable safety analyses; (3) deleting requirements for equipment or systems that establish system capability beyond that assumed to function by the applicable safety analyses, or that are implicit to the proposed TS requirement for systems, components, and devices to be operable; and (4) adding allowances to use administrative controls on plant devices and equipment during times when automatic control is required, or to establish temporary administrative limits, as appropriate, to allow time for systems to establish equilibrium operation. TS changes represented by this type allow operators

- 7 to more clearly focus on issues important to safety. The resultant proposed TS LCOs maintain an adequate degree of protection consistent with the safety analysis. They also improve focus on issues important to safety and provide reasonable operational flexibility without adversely affecting the safe operation of the plant. Changes involving the relaxation of LCOs are consistent with the guidance established by the ISTSs taking into consideration the VY CLB.

Therefore, based on the above, these categorical changes are acceptable.

Category 2 - Relaxation of Applicability The current TS require compliance with the LCO during the applicable Mode(s) or other conditions specified in the Specification's Applicability statement. When current TS Applicability requirements are inconsistent with the applicable accident analyses assumptions for a system, subsystem, or component specified in the LCO, the licensee proposed to change the LCO to establish a consistent set of requirements in the proposed TS. These modifications or deletions are acceptable because, during the operational or other conditions specified in the proposed TS applicability requirements, the LCOs are consistent with the applicable safety analyses.

Changes involving relaxation of applicability requirements are consistent with the guidance established by the ISTSs, taking into consideration the VY CLB. Therefore, based on the above, these categorical changes are acceptable.

Category 3 - Relaxation of Completion Time Upon discovery of a failure to meet an LCO, the TS specify time limits for completing Required Actions of the associated TS Conditions. Required Actions establish remedial measures that must be taken within specified Completion Times. Completion Times specify limits on the duration of plant operation in a degraded condition. Incorporating longer Completion Times is acceptable because such Completion Times will continue to be based on the operability status of redundant TSs required features, the capacity and capability of remaining TS-required features, provision of a reasonable time for repairs or replacement of required features, vendor developed standard repair times, and the low probability of a DBA occurring during the repair period. Changes involving relaxation of Completion Times are consistent with the guidance established by the ISTSs, taking into consideration the VY CLB. Therefore, based on the above, these categorical changes are acceptable.

Category 4 - Relaxation of Required Action LCOs specify the lowest functional capability or performance level of equipment that is deemed adequate to ensure safe operation of the facility. When an LCO is not met, the current TS specify actions to restore the equipment to its required capability or performance level, or to implement remedial measures providing an equivalent level of protection. Compared to current TS required actions, certain proposed TS actions would result in extending the time period during which the licensee may continue to operate the plant with specified equipment inoperable. Upon expiration of this time period, further action, which may include shutting down the plant, is required. Changes of this type include providing an option to (1) isolate a system, (2) place equipment in the state assumed by the safety analysis, (3) satisfy alternate criteria, (4) take manual actions in place of automatic actions, (5) "restore to operable status" within a specified time frame, (6) place alternate equipment into service, or (7) use more conservative TS instrumentation actuation setpoints. The resulting proposed TS actions provide measures that adequately compensate for the inoperable equipment, and are commensurate with the safety importance of the inoperable equipment, plant design, and industry practice. Therefore, these action requirements will continue to ensure safe operation of the plant. Changes involving relaxations of action requirements are consistent with the guidance established by the ISTS,

- 8 taking into consideration the VY CLB. Therefore, based on the above, these categorical changes are acceptable.

Category 5 - Deletion of Surveillance Requirement The current TS require maintaining LCO specified SSCs operable by meeting SR in accordance with specified SR frequencies. This includes conducting tests to demonstrate that such SSCs are operable and that LCO specified parameters are within specified limits. When the test acceptance criteria and any specified conditions for the conduct of the test are met, the equipment is deemed operable. The changes of this category relate to deletion of current TS SR, including deletion of an SR in its entirety, deletion of acceptance criteria, and deletion of the conditions required for performing the SR.

Deleting the SR, including acceptance criteria and/or conditions for performing the SR, for these items provides operational flexibility, consistent with the objective of the ISTS, without reducing confidence that the equipment is operable. For example, the current TS contain SR that are not included in the ISTS for a variety of reasons. This includes deletion of SR for measuring values and parameters that are not necessary to meet ISTS LCO requirements. Also, the ISTS may not include reference to specific acceptance criteria contained in the current TS, because these acceptance criteria are not necessary to meet ISTS LCO requirements, or are defined in other licensee controlled documents. The changes to SR acceptance criteria are acceptable because appropriate testing standards are retained for determining that the LCO required features are operable as defined by the ISTS.

Deleting conditions for performing SR includes not requiring testing of deenergized equipment (e.g., instrumentation channel checks) or equipment that is already performing its intended safety function (e.g., position verification of valves locked in their safety actuation position).

Waiving performance of a surveillance under these conditions is acceptable because the equipment is already performing its intended safety function.

The deletion of these current TS SR optimizes test requirements for the affected safety systems and increases operational flexibility. Changes involving relaxations of SR, as described, are consistent with the guidance established by the ISTS, taking into consideration the VY CLB.

Therefore, based on the above, these categorical changes are acceptable.

Category 6-Relaxation of Surveillance Requirement Acceptance Criteria Prior to placing the plant in a specified operational Mode or other condition stated in the applicability of an LCO, and in accordance with the specified SR time interval thereafter, the current TS require establishing the operability of each LCO-required component by meeting the SR associated with the LCO. This usually entails performance of testing to demonstrate the operability of the LCO-required components, or the verification that specified parameters are within LCO limits. A successful demonstration of operability requires meeting the specified acceptance criteria, as well as any specified conditions, for the conduct of the test. Relaxations of current TS SR would include relaxing both the acceptance criteria and the conditions of performance. Also, the proposed TS would permit the use of an actual, as well as a simulated, actuation signal to satisfy SR for automatically actuated systems. This is acceptable because TS-required features cannot distinguish between an "actual" signal and a "test" signal. These relaxations of current TS SR optimize test requirements for the affected safety systems and increase operational flexibility. These current TS SR relaxations are consistent with the guidance established by the ISTS in consideration of the VY CLB.

- 9 Category 7 - Relaxation of Surveillance Frequency Prior to placing the plant in a specified operational Mode or other condition stated in the applicability of an LCO, and in accordance with the specified SR time interval (frequency) thereafter, the current TS require establishing the operability of each LCO required component by meeting the SR associated with the LCO. This usually entails performance of testing to demonstrate the operability of the LCO-required components, or the verification that specified parameters are within LCO limits. A successful demonstration of operability requires meeting the specified acceptance criteria, as well as any specified conditions, for the conduct of the test, at a specified frequency based on the reliability and availability of the LCO-required components.

Relaxations of current TS SR would include extending the interval between the SR. These relaxations of current TS SR frequencies optimize test requirements for the affected safety systems and increase operational flexibility. These current TS SR frequency relaxations are consistent with the guidance established by the ISTS in consideration of the VY CLB.

For the reasons presented above, the proposed less restrictive changes to the current TS are acceptable because they will not adversely impact safe operation of the facility. The proposed TS requirements are consistent with the CLB, operating experience, and plant accident and transient analyses, and provide reasonable assurance that public health and safety will be protected.

Table L attached to this SE lists the less restrictive changes being made in the VY application.

Table L, which is organized in proposed TS order by each L-type DOC to the current TSs, provides a summary description of the less restrictive change that was made.

D.

Removed Details When requirements have been shown to give little or no safety benefit, their removal from the TS may be appropriate. In most cases, relaxations previously granted to individual plants on a plant-specific basis were the result of (1) generic NRC actions, (2) new NRC staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the owners groups' comments on the ISTS. The NRC staff reviewed generic relaxations contained in the ISTS and found them acceptable because they are consistent with current licensing practices and the Commission's regulations. The VY design was also reviewed to determine if the specific design basis and licensing basis are consistent with the technical basis for the model requirements in the ISTS and thus provide a basis for the proposed TS. All of the changes to the current TS involving the removal of specific requirements and detailed information from individual specifications are described below:

Type 1 - Removing Details of System Design and System Description, Including Design Limits The design of the facility is required to be described in the USAR by 10 CFR 50.34. The regulation at 10 CFR 50.59 specifies controls for changing the facility as described in the USAR.

The TRM is a general reference in the USAR and changes to it are accordingly subject to 10 CFR 50.59. The TS Bases also contain descriptions of system design. TS 6.7.E specifies controls for changing the Bases. Removing details of system design is acceptable because the associated current TS requirements being retained without these details are adequate to ensure safe operation of the facility. In addition, retaining such details in TS is unnecessary to ensure proper control of changes. Therefore, it is acceptable to remove these details from the current TS and place them in licensee-controlled documents.

- 10 Type 2 - Removing Descriptions of System Operation The plans for normal and emergency operation of the facility are required to be described in the USAR by 10 CFR 50.34. TS 6.4 requires written procedures to be established, implemented, and maintained for plant operating procedures. The proposed TS Bases also contain descriptions of system operation. Controls specified in 10 CFR 50.59 apply to changes in procedures as described in the USAR and TRM. TS 6.7.E specifies controls for changing the Bases. Removing details of system operation is acceptable because the associated current TS requirements being retained without these details are adequate to ensure safe operation of the facility. In addition, retaining such details in TS is unnecessary to ensure proper control of changes. Therefore, it is acceptable to remove these details from the current TS and place them in licensee-controlled documents.

Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements Details for performing TS SR or for regulatory reporting are more appropriately specified in the plant procedures. Prescriptive procedural information in a TS requirement is unlikely to contain all procedural considerations necessary for the plant operators to comply with TS and all regulatory reporting requirements, and referral to plant procedures is, therefore, required in any event. Changes to procedural details include those associated with limits retained in the proposed TS. Therefore, it is acceptable to remove these details from the current TS and place them in licensee-controlled documents.

Type 4 - Removal of an LCO, a SR, or other TS Requirement to the TRM or USAR Certain current TS administrative requirements are redundant with respect to current regulations and thus are relocated to the USAR or other appropriate licensee-controlled documents, including the TRM. The Final Policy Statement allows licensees to relocate to licensee controlled documents current TS requirements that do not meet any of the criteria for mandatory inclusion in the TS. Changes to the facility or to procedures as described in the USAR are made in accordance with 10 CFR 50.59. Changes made in accordance with the provisions of other licensee-controlled documents are subject to the specific requirements of those documents.

Therefore, it is acceptable to remove these details from current TS and place them in Iicensee controlled documents.

Table LA attached to this SE lists the less restrictive removal of detail changes being made in the VY application. Table LA is organized in proposed TS order by each LA-type DOC to the current TSs, and provides a summary description of the less restrictive removal of detail change that was made.

The NRC staff has concluded that these types of detailed information and specific requirements do not need to be included in the proposed TS to ensure the effectiveness of the proposed TS to adequately protect the health and safety of the public. Accordingly, these requirements may be moved to one of the following licensee-controlled documents for which changes are adequately governed by a regulatory or TS requirement:

Bases controlled in accordance with TS 6.7.E, "Technical Specifications (TS) Bases Control Program."

Updated Final Safety Analysis Report (which references the Technical Requirements Manual) controlled by 10 CFR 50.59.

Programmatic documents required by TS Section 6.4.

- 11 To the extent that information has been relocated to licensee-controlled documents, such information is not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to public health and safety. Further, where such information is contained in LCOs and associated requirements in the current TS, the NRC staff has concluded that they do not fall within any of the four criteria set forth in 10 CFR 50.36(c)(2)(ii) and discussed in the Final Policy Statement (see Section 2.0 of this SE). Accordingly, existing detailed information, such as generally described above, may be removed from the current TS and not included in the proposed TS.

E.

Relocated Specifications The Final Policy Statement states that LCOs and associated requirements that do not satisfy or fall within any of the four specified criteria (now contained in 10 CFR 50.36(c)(2)(ii)) may be relocated from existing TS (an NRC-controlled document) to appropriate licensee-controlled documents as noted in Section D above.

This section discusses the relocation of entire specifications from the current TS to Iicensee controlled documents. These specifications generally would include LCOs, Action Statements (Le., Actions), and associated SRs. In its application and supplements, the licensee proposed relocating such specifications from the current TS to a licensee-controlled document such as the USAR or the TRM. The NRC staff has reviewed the licensee's submittals and finds that relocation of these requirements is acceptable in that the LCOs and associated requirements were found not to fall within the scope of 10 CFR 50.36(c)(2)(ii) and changes to Iicensee controlled documents will be adequately controlled by 10 CFR 50.59, as applicable. These provisions will continue to be implemented by appropriate station procedures (Le., operating procedures, maintenance procedures, surveillance and testing procedures, and work control procedures).

Table R attached to this SE lists all specifications that are being relocated from the current TS to licensee controlled documents. The specifications relocated from the current TS are not required to be in the TS because they do not fall within the criteria for mandatory inclusion in the TS as stated in 10 CFR 50.36(c)(2)(ii). These specifications are not needed to obviate the possibility that an abnormal situation or event will give rise to an immediate threat to the public health and safety. The NRC staff concludes that appropriate controls have been established for all of the current specifications and information being moved to the Technical Requirements Manual. Until incorporated in licensee controlled documents, changes to these specifications and information will be controlled in accordance with the current applicable procedures and regulations.

F.

Control of Specifications. Requirements. and Information Relocated from the Current TS In the VY application, the licensee proposes to relocate specifications, requirements, and detailed information from the current TS to licensee-controlled documents. This is discussed in Sections 3.D and 3.E of this SE. The facility and procedures described in the USAR and TRM can be revised in accordance with the provisions of 10 CFR 50.59, to ensure that records are maintained and appropriate controls are established over those requirements removed from the current TS and future changes to the requirements.

- 12 G.

Setpoint Changes G.1 Proposed Setpoint Changes The LAR proposed setpoint changes to resolve non-conservative TS issues currently being addressed by administrative controls. Specifically, the licensee proposed the following setpoint changes:

(1)

In Table 3.2.1, "Emergency Core Cooling System (ECCS) Instrumentation," Trip Setpoint 3.b, "HPCI System, Low Condensate Storage Tank Water Level," increase the setpoint from "~ 3%" to "~ 4.24%."

(2)

In TS Table 3.2.9, "RCIC System Instrumentation," Trip Setpoint 2, "Low Condensate Storage Tank Water Level," increase the setpoint from "~ 3%" to"~ 3.81 %."

(3)

In TS Table 3.2.2, "Primary Containment Isolation Instrumentation," Trip Setpoint 1.b, "Main Steam Line Isolation, High Main Steam Line Area Temperature," decrease the setpoint from "s; 212°F" to "s; 196°F" for channels monitoring outside the steam tunnel and to "s; 200°F" for channels monitoring inside the steam tunnel.

(4)

In TS Table 3.2.2, "Primary Containment Isolation Instrumentation," Trip Setpoint 3.a, "HPCI System Isolation, High Steam Line Space Temperature," decrease the setpoint from "s; 212°F" to "s; 196°F."

(5)

In TS Table 3.2.2, "Primary Containment Isolation Instrumentation," Trip Setpoint 3.d, "HPCI System Isolation, High Main Steam Line Tunnel Temperature," decrease the setpoint from "s; 212°F" to "s; 200°F."

(6)

In TS Table 3.2.2, "Primary Containment Isolation Instrumentation," Trip Setpoint 4.a, "RCIC System Isolation, High Main Steam Line Tunnel Temperature," decrease the setpoint from liS; 212°F" to "s; 200°F."

(7)

In TS Table 3.2.2, "Primary Containment Isolation Instrumentation," Trip Setpoint 4.c, "RCIC System Isolation, High Steam Line Space Temperature," decrease the setpoint from liS; 212°F" to "s; 196°F."

HPCI System and RCIC System Low Condensate Storage Tank Water Level Setpoints In the LAR, the licensee proposed changes to the setpoints for the low condensate storage tank water level functions for the operation of the HPCI System and RCIC System in TS Tables 3.2.1 and 3.2.9, respectively. The licensee proposed to increase the setpoints for (1) HPCI System Low Condensate Storage Tank Water Level in TS Table 3.2.1, Trip Setpoint 3.b, from "~ 3%" to

"~ 4.24%," and (2) for the RCIC System Low Condensate Storage Tank Water Level in TS Table 3.2.9, Trip Setpoint 2, from "~ 3%" to..~ 3.81 %."

These are the setpoints for the automatic transfer of the HPCI and RCIC suction flow paths from the condensate storage tank to the suppression pool when the level in the condensate storage tank is no longer sufficient to support adequate HPCI and RCIC pump suction head. The current setpoints have been determined to be insufficient to ensure that transfer of the HPCI System and RCIC System suction from the condensate storage tank to the suppression pool occurs prior to potential vortex formation at the HPCI and RCIC suction inlets in the condensate storage tank. The proposed setpoints for HPCI System Low Condensate Storage Tank Water

- 13 Level and RCIC System Low Condensate Storage Tank Water Level account for the additional water level needed to preclude the potential for vortex formation. These proposed changes represent an additional restriction on plant operation necessary to ensure that HPCI System and RCIC System operability are maintained when aligned to the condensate storage tank and the HPCI and RCIC pump suction transfer to the suppression pool occurs prior to vortex formation.

Primary Containment Isolation Steam Line Related Temperature Setpoints In the LAR, the licensee proposed changes to the temperature setpoints for the Primary Containment Isolation Instrumentation in TS Table 3.2.2. Specifically, the proposed changes would decrease the setpoints for (3) TS Table 3.2.2, Function 1.b, "Main Steam Line Isolation High Main Steam Line Area Temperature," from ":::; 212°F" to ":::; 196°F" for channels monitoring outside the steam tunnel and to ":::; 200°F" for channels monitoring inside the steam tunnel, (4)

TS Table 3.2.2, Function 3.a, HPCI System Isolation High Steam Line Space Temperature,"

from ":::; 212°F" to ":::; 196°F," (5) TS Table 3.2.2, Function 3.d, "HPCI System Isolation High Main Steam Line Tunnel Temperature," from ":::; 212°F" to ":::; 200°F," (6) TS Table 3.2.2, Function 4.a, "RCIC System Isolation High Main Steam Line Tunnel Temperature," from ":::; 212°F" to ":::;

200°F," and (7) TS Table 3.2.2, Function 4.c, "RCIC System Isolation High Steam Line Space Temperature." from u:::; 212°F" to ":::; 196°F."

These are setpoints to provide isolation in the event of breaks in the associated steam lines.

The current setpoints have been determined to be insufficient to ensure isolation occurs in the high energy line break and equipment qualification analyses. The licensee has proposed to decrease the setpoint to ":::; 196°F" for temperature measurements of steam line space and the area outside the steam tunnel and to ":::; 200°F" for temperature measurements of the steam line tunnel and the area inside the steam tunnel. These proposed changes represent an additional restriction on plant operation necessary to ensure that isolation of the associated steam lines occurs as assumed in the analyses.

G.2 Setpoint Calculation The licensee's setpoint calculations for all setpoints in the LAR use the VY Instrument Uncertainty and Setpoints Design Guide, Appendix D to Setpoint Program Manual, Revision 3, dated December 1,2003, which is based on ISA-S67.04. RG 1.105 endorses ISA-S67.04, Part I.

The licensee calculates the setpoints, for all setpoints in the LAR, from the Analytical Limit (AL) and calculates the margin between the AL and the Custom Technical Specification (CTS) Limit and the Limiting Setpoint. The Total Loop Uncertainty is calculated by combining the random errors using the square-root-of-the-sum-of-the-squares method and algebraically adding the non-conservative bias errors. The calibration uncertainty contains the as-left tolerance (ALT).

The licensee's setpoint calculation VYC-0723 proVides sufficient margin between the AL and the CTS Limit to ensure at least 95-percent probability that the ALT will not be exceeded if the setpoint has drifted to the CTS Limit.

For HPCI System Condensate Storage Tank Water Level Setpoint In accordance with Technical Specification Task Force (TSTF) letter to the NRC, "Industry Plan to Resolve TSTF-493, Clarify Application of Setpoint Methodology for LSSS [limiting safety system setting] Functions," dated February 23,2009 (ADAMS Accession No. ML090540849),

the licensee has proposed the addition of TS notes to address the controls to ensure operability

- 14 for TS Table 3.2.1, Trip Setpoint 3.b, "HPCI System, Low Condensate Storage Tank Water Level," as follows:

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the Limiting Trip Setpoint are acceptable provided that as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures to confirm channel performance. The methodologies used to determine the as-found and the as-left tolerances are specified in the Vermont Yankee Setpoint Program Manual.

For RCIC System Condensate Storage Tank Water Level and Containment Isolation Steam Line Related Temperature Setpoints The footnotes recommended by the February 23,2009, TSTF letter is not proposed by the licensee for RCIC system condensate storage tank water level. The licensee's calibration procedures require that if an instrument's as-found value is within the ALT, the technician would document that no action was required and the channel would be returned to service. If an as found value is outside the ALT, the technician would document the discrepancy, inspect the equipment, and calibrate the setpoint to a value within the ALT. If the technician does not identify any degradation during calibration and the as-found value is within the as-found tolerance (AFT), the channel would be considered operable. If the as-found value is outside the AFT, the discrepancy would be entered into the Corrective Action Program. If the setpoint cannot be reset to a value within the ALT, the channel would be declared inoperable.

G.3 Summary The NRC staff finds that the proposed change to the HPCI System Low Condensate Storage Tank Water Level setpoint for the automatic transfer to the suppression pool is acceptable. This is because the change in the setpoint will ensure that the suppression pool, which is the credited safety-related makeup water source, will be available to mitigate AOOs and postulated accidents. The setpoints, footnotes, and surveillance procedures are consistent with the guidance of RG 1.105.

The NRC staff finds that the proposed changes to TS 3.2.9, Trip Setpoint 2, "RCIC System Low Condensate Storage Tank Water Level" for the automatic transfer to the suppression pool and to TS 3.2.2, Primary Containment Isolation, Steam Line related temperature Trip Setpoints 1.b, 3.c, 3.d, 4.a are acceptable. This is because the setpoint calculation and surveillance testing procedures used by the licensee are consistent with the guidance of RG 1.105.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Vermont State official was notified of the proposed issuance of the amendment. The State official had no comments.

- 15

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (73 FR 21659). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: A. Lewin B. Marcus Date: June 12, 2009 Administrative Changes

Administrative Changes TS 1.0 - DEFINITIONS, TS 2.1 LIMITING SAFETY SYSTEM SETTINGS, TS 3.1/4.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION A.1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.1/4.1 and associated Technical Specifications, these changes are depicted in the marked-up CTS pages shown, and include:

Table of Contents, page i-Various editorial changes, including relocation of headers, renumbering starting pages for sections, removing references to deleted sections, and clarifying section names.

TS 2.1, page 8 - LSSS 2.1.A.1.b slightly rewritten for clarity.

TS 2.1, page 10- LSSS 2.1.D through 2.1.H rewritten for clarity and to replace "at least," "greater than," and "less than or equal to" text with appropriate mathematical symbols.

TS 3.1/4.1, page 20 - Rewritten for clarity after incorporation of other changes, and to remove the word "Deleted" where previously eliminated 3.1.B and 4.1.B text was located.

TS Table 3.1.1, page 21 - Title modified for accuracy, column headings changed to match ISTS style, trip function sub-items given specific sequential numbering, "NA" inserted for previously blank entries, columns repositioned for clarity and consistency and certain table contents moved to footnotes.

Table 3.1.1, page - 22, - Title modified for accuracy, column headings changed to match ISTS style, "Deleted" wording removed where previously eliminated line items were located and remaining trip function line items renumbered accordingly, columns repositioned for clarity and consistency and certain table contents moved to footnotes.

Table 3.1.1 Notes, page 23 - Header modified to read "ACTION Notes" and "water" changed to "coolant" in Note 1.

Table 3.1.1 Notes, page 24 - Header changed to read "ACTION Notes," flag added for Footnote (d) and "Deleted" wording removed where previously eliminated line items were located.

Table 4.1.1, page 25 - Title and column headings modified for accuracy, minor text edits made, trip function line items given specific Page 1 of 38

Administrative Changes sequential numbering, Calibration column inserted into table and Footnotes (a), (b) (c) and (e) relocated from Notes pages to reflect combination of CTS Calibration requirements with CTS Functional Test requirements in proposed Table 4.1.1. [Footnote (d) was added by Discussion of Chal1ges (DOC) L.1 0.]

Table 4.1.1 Notes, page 26 - "Not Used" wording deleted from previous Note 1 entry and flag added for Footnote (b).

Table 4.1.2, page 27 - Table renumbered as 4.1.1 to reflect combination of CTS Calibration requirements with CTS Functional Test requiremellts in proposed Table 4.1.1, title and column headings modified for accuracy, Trip Function line items and sub-items given specific sequential numbering to align with Table 4.1.1 Trip Functions, flags added for Footnotes (a), (b), (c) and (e) [Footnote (d) Flag was added to the table by DOC L.1 0], and calibration "Frequency" column retitled "Calibration" and relocated to Table 4.1.2.

Table 4.1.2 Notes, page 28 - Title changed to "Table 4.1.1" to reflect combination with page 26 content and elimination of Table 4.1.2, "Deleted" wording removed where previously eliminated Note 3 entry was located and flags added for Footnote (a), (b), (c) and (e) that are replacing Notes 7, 11, 10 and 9, respectively in new Table 4.1.1.

A2 CTS 3.1.A provides Reactor Protection System (RPS) response time requirements (Le., the system response time from the opening of the sensor contact to and including the opening of the scram solenoid relay... ). This information is moved to proposed WNPS TS definition 1.0.00, "Reactor Protection System (RPS) Response Time." This change does not involve a technical change, but is only a difference in presentation. Therefore, this change is considered administrative.

A3 CTS 3.1.A provides Reactor Protection System (RPS) response time acceptance criteria (Le., system response time shall not exceed 50 milliseconds). CTS Table 4.1.2 Note 4 provides RPS response time test frequency requirements (Le.,

response time will be checked every operating cycle). These requirements are located in proposed Surveillance Requirement (SR) 4.1.A3 and presented as "Verify RPS Response Time is < 50 milliseconds for each automatic RPS Trip Function once every Operating Cycle." This change does not involve a technical chal1ge, but is only a difference in presentation. Therefore, this change is considered administrative.

A4 Deleted.

A5 CTS 4.1.A includes reference to CTS Tables 4.1.1 and 4.1.2 for functional test and calibration requirements for RPS. CTS 4.1.A is revised, in proposed SR 4.1.A1 and Table 4.1.1, to also include reference to check requirements consistent with CTS Table 4.1.1, Note 2. This change is a difference in presentation only and does not alter the current requirements to periodically perform checks of certain RPS instrument trip functions. Therefore, this change is considered administrative in nature.

Page 2 of 38

Administrative Changes A.6 The Surveillance Requirements for RPS instrument trip functions in CTS Table 4.1.1, Table 4.1.2, and associated Notes are combined in proposed Table 4.1.1 as a human factors enhancement. This change is a difference in presentation only and does not alter the current requirements to periodically perform RPS instrument trip function Surveillances. Therefore, this change is considered administrative in nature.

A.7 CTS Table 4.1.1 includes a requirement to functionally test the RPS Scram Test Switches and CTS Table 4.1.1, Note 9, modifies this requirement by stating that the automatic scram contactors shall be exercised once every week by either using the RPS channel test switches or by performing a functional test of any automatic scram function and that a functional test of an automatic scram function satisfies the test using the RPS channel test switch. These requirements have been moved to proposed SR 4.1.A.2 and presented as, "Exercise each automatic scram contactor once every week using the RPS channel test switches or by performing a Functional Test of any automatic RPS Trip Function." This change is a difference in presentation only and does not alter the current requirements to periodically perform functional testing/exercising of the RPS automatic scram contactors. Therefore, this change is considered administrative in nature.

A.8 CTS Table 3.1.1, Note 2, last paragraph, provides an allowance to delay entry into actions for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the situation of a channel inoperable solely for performance of surveillances. This allowance is moved to proposed SR 4.1.A.1.

This change does not involve a technical change, but is only a difference in presentation. Therefore, this change is considered administrative.

A.9 CTS Table 3.1.1 identifies the RPS Trip Functions that are required to be operable when the reactor mode switch is in Refuel and Note 1 to CTS Table 3.1.1 identifies a subset of these RPS Trip Functions that are required to be operable when the reactor mode switch is in Refuel and the reactor is subcritical and the reactor water temperature is less than 212°F. These requirements have been reflected with 1) an Applicability in proposed Table 3.1.1 of Refuel with reactor coolant temperature> 212°F for each of the RPS Trip Functions required to be operable with the reactor mode switch in Refuel in CTS Table 3.1.1 and 2) a separate explicit Applicability of Refuel with reactor coolant temperature < 212°F for those RPS Trip Functions included in Note 1 to CTS Table 3.1.1. (The change to temperature requirement in CTS Table 3.1.1, from less than 212°F to less than or equal to 212°F, is addressed in DOC L.11). In addition, with the reactor mode switch in Refuel, no more than one control rod can be withdrawn and all the other the control rods are inserted in the reactor core. In this condition, the reactor will be subcritical. Therefore, it is not necessary to state the reactor is subcritical when the reactor mode switch is in Refuel and this wording "when the reactor is subcritical" is deleted. Commensurate changes are also made to CTS 2.1.A.1.b. Since the changes involve only a difference in presentation, the changes are considered administrative.

A.10 Note 2 to CTS Table 3.1.1 provides actions when the minimum number of channels per trip system requirement is not met. These requirements are identified in a separate column in proposed Table 3.1.1 titled, "ACTIONS WHEN Page 3 of 38

Administrative Changes REQUIRED CHANNELS ARE INOPERABLE." This change is a difference in presentation only and does not alter the current action requirements when required RPS channels are inoperable. Therefore, this change is considered administrative in nature.

A.11 All Main Steam Line Isolation Valve Closure channels are required to be operable to assure a scram with the worst single failure. The Main Steam Line Isolation Valve Closure Trip Function (CTS Table 3.1.1, Trip Function 10 and proposed Table 3.1.1, Trip Function 9) requires a minimum of 4 channels per trip system.

There is one position switch per valve (one switc.h with two contacts). In reality, each of the eight main steam line isolation valves inputs its closure signal to each RPS trip system (trip system A and B). To ensure the interpretation that all main steam line isolation valve position switches are required for each trip system, each main steam line isolation valve contact is viewed as a separate channel (a total of 16 channels). Therefore, the minimum number of channels per trip system required to be operable in proposed Table 3.1.1 is more appropriately specified as "8." Since this change involves no design change but is only a difference in nomenclature and presentation, this change is considered administrative.

A.12 The Turbine Control Valve Fast Closure RPS Trip Function and the Turbine Stop Valve Closure RPS Trip Function (CTS Table 3.1.1, Trip Functions 11 and 12) are required by CTS Table 3.1.1 to be operable in the Run Mode. CTS Table 3.1.1 Note 10 states that the signals for these Trip Functions may be bypassed when power is < 25% of Rated Thermal Power. The intent of this note is to waive the operability requirements of the Turbine Control Valve Fast Closure RPS Trip Function and Turbine Stop Valve RPS Trip Function when reactor power is <

25%. The "APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS" column in proposed Table 3.1.1 requires the Turbine Control Valve Fast Closure RPS Trip Function and the Turbine Stop Valve RPS Trip Function (proposed Table 3.1.1, Trip Functions 10 and 11) to be operable when reactor power is >

25% RATED THERMAL POWER which is equivalent to CTS requirements. As such, this change is considered administrative in nature.

A.13 All Turbine Stop Valve Closure channels are required to be operable to assure a scram with the worst single failure. The Turbine Stop Valve Closure Trip Function (CTS Table 3.1.1, Trip Function 12 and proposed Table 3.1.1, Trip Function 11) requires a minimum of 2 channels per trip system. There is one limit switch per valve (one switch with two contacts). In reality, each of the four turbine stop valves inputs its closure signal to each RPS trip system (trip system A and B). To ensure the interpretation that all turbine stop valve position switches are required for each trip system, each turbine stop valve limit switch contact is viewed as a separate channel (a total of 8 channels). Therefore, the minimum number of channels per trip system required to be operable in proposed Table 3.1.1 is more appropriately specified as "4." Since this change involves no design change but is only a difference in nomenclature and presentation, this change is considered administrative.

A.14 For CTS Table 3.1.1, Trip Functions 4, 11, and 12 (APRM High Flux [Flow Bias],

Turbine Control Valve Fast Closure, and Turbine Stop Valve Closure). two optional shutdown alternatives are provided when minimum conditions for Page 4 of 38

Administrative Changes operation are not satisfied. One of these optional shutdown alternatives (CTS Table 3.1.1 Note 3.A) requires immediate insertion of operable rods and complete insertion of operable rods within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This action essentially places the plant in a condition beyond that required to exit the applicable Mode or condition of the associated Trip Functions in less time than is necessary for the other optional requirements (CTS Table 3.1.1 Note 3.B for the APRM High Flux (Flow Bias) Trip Function and CTS Table 3.1.1 Note 3.0 for the Turbine Control Valve Fast Closure and Turbine Stop Valve Trip Functions). As such, CTS Table 3.1.1 Note 3.A represents a more restrictive optional requirement for these Trip Functions.

Given the choice of the shutdown actions to take, the optional action to exit the applicable Mode or condition with the longer time period would be selected to potentially avoid the shutdown transient and allow the plant to be shutdown in a more controlled manner. Therefore, the deletion of the optional shutdown action (CTS Table 3.1.1 Note 3.A) for CTS Table 3.1.1 Trip Functions 4, 11, and 12 (proposed Table 3.1.1 Trip Functions 4.a, 10 and 11) does not alter the current plant actions that would be taken when minimum conditions for operation are not satisfied. Since the deleted action is optional and would not be used, the change is considered administrative.

A.15 CTS Table 3.1.1 Note 3 states, in the first paragraph, "When the requirements in the column "Minimum Number of Operating Instrument Channels Per Trip System" can not be met for one system, that system shall be tripped. If the requirements cannot be met for both trip systems, the appropriate ACTIONS listed below shall be taken..." However, due to the presentation of the Notes in CTS Table 3.1.1, Note 3 actions are only taken after CTS Table 3.1.1 Note 2 actions are taken. Since the CTS Table 3.1.1 Note 2 Actions (proposed Table 3.1.1 ACTION Note 1) already provide the appropriate NRC approved actions for each of the conditions addressed in the first paragraph of CTS Table 3.1.1 Note 3, the first paragraph of CTS Table 3.1.1 Note 3 is unnecessary and is deleted.

Since actions when required RPS channels are inoperable will continue to be taken in the same manner and in the same time period, the deletion is considered administrative in nature.

A.16 CTS 4.1.1 Table Notes 2 and 10 require an instrument check to be performed on the reactor water level, reactor pressure and IRM-High Flux RPS Trip Functions once per day. Proposed Table 4.1.1 includes explicit Check requirements for Trip Function 3.a (IRM-High Flux), Trip Function 5 (High Reactor Pressure) and Trip Function 7 (Low Reactor Water Level) with a specified Frequency of "OncelDay."

Since this change only explicitly specifies the Trip Functions requiring Instrument Checks to be performed and does not change the intent of CTS, this change is considered administrative.

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 requirements of these Notes are duplicated in CTS SR 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. In addition, the Bases for Specification 4.0.1 state that surveillances have to be met and performed in accordance with SR4.0.2, prior to returning equipment to OPERABLE status. Since tests cannot be performed on a channel when it is tripped, those portions of the Notes are meaningless. CTS Page 5 of 38

Administrative Changes Specification 4.0.1, like the Notes, requires tests to be performed prior to the channel being required to be operable. Therefore, the requirements of Specification 4.0.1 are equivalent to those of CTS Table 4.1.1 Note 4 and CTS Table 4.1.2 Note 2, and these two Notes can be deleted. This change is considered administrative.

A.18 CTS Table 4.1.1 Note 6 specifies a Frequency not to exceed weekly. CTS Table 4.1.1 Note 6 currently applies to the Functional Test for the APRM High Flux (Reduced) Trip Function. The Frequency of CTS Table 4.1.1 Note 6 is explicitly stated as "Every 7 Days" for the Functional Test Frequency for Trip Function 4.b (APRM High Flux (Reduced) in proposed Table 4.1.1. Therefore, CTS Table 4.1.1 Note 6 is not required and its deletion is considered administrative.

A.19 CTS Table 4.1.1 Note 5 states that this instrumentation is exempt from the Instrument Functional Test Definition and that this Instrument Functional Test will consist of injecting a simulated electrical signal instrument into the measurement channels. The CTS definition 1.0.G, "Instrument Functional Test," allows the injection of a signal into the channel as close to the sensor as practicable. As such, the Functional Test described in CTS Table 4.1.1 Note 5 is adequately addressed by and complies with the CTS definition of Instrument Functional Test.

Therefore, no exemption to the definition of Instrument Functional Test is required and the deletion of CTS Table 4.1.1 Note 5 is considered administrative.

A.20 CTS Table 4.1.2 Note 8 states that the specified Frequency is met if the calibration is performed within 1.25 times the interval specified, as measured from the previous performance. The allowance of this Note is duplicative of CTS SR 4.0.2, which states that periodic surveillance tests, checks, calibrations, and examinations shall be performed within the specified surveillance intervals and that these intervals may be adjusted plus 25%. As such, the allowance of CTS Table 4.1.2 Note 8 is adequately addressed by CTS SR 4.0.2. Therefore, the deletion of CTS Table 4.1.2 Note 8 is considered administrative.

A.21 With the exception of changes described in DOC A.8, LA.4 and M.6, the conversion of CTS Table 3.1.1 Note 2 to proposed Table 3.1.1 Note 1 results in no changes to actions taken by the user in response to a given plant condition. A comparison of the different sections of the two notes is provided below.

The first sentence of CTS Note 2 states that "there shall be two operable or tripped trip systems for each Trip Function." The requirement for two operable trip systems has the same meaning as the condition in proposed Note 1 of "one or more required Reactor Protection System channels inoperable." The option in CTS Note 2 for the trip systems to be tripped matches the actions specified in proposed Notes 1.a and 1.b. The requirement in proposed Note 1 to "take all of the applicable Actions in Notes 1.a, 1.b, and 1.c" ensures that a loss of trip capability is addressed for all situations. This results in the proposed note being more restrictive for the case of the manual RPS trips as described in DOC M.6.

The last sentences of CTS Notes 2.a and 2.b require the appropriate action in Note 3 to be performed as specified in Table 3.1.1. The last Page 6 of 38

Administrative Changes sentence of proposed Note 1 directs the identical action. CTS Note 3 is being converted to proposed Note 2.

The first sentences of CTS Notes 2.a and 2.b are being reworded to become proposed Notes 1.a and 1.b with no change in meaning. The phrase "one less than the required minimum number of operable instrument channels" in CTS Note 2.a and "two or more channels less than the required minimum number of operable instrument channels" in Note 2.b have the same meaning, respectively, as the phrases "one or more required channels inoperable" in proposed Note 1.a and "one or more required channels inoperable in both trip systems" in Note 1.b.

CTS Note 2.b.1 addresses a loss of trip capability by requiring that trip capability is verified within one hour. This note is being replaced by proposed Note 1.c which states that if trip capability is not maintained then it must be restored within one hour. These two requirements are equivalent since they both result in the same actions being taken.

This change, along with the requirement in the first sentence of proposed Note 1 to "take all of the applicable Actions in Notes 1.a, 1.b, and 1.c" ensures that a loss of trip capability is addressed for all situations, as described in DOC M.6.

CTS Note 2.b.2 is being reworded to become proposed Note 1.b with no change in meaning.

CTS Note 2.b.3 is being deleted. This action is addressed by proposed Note 1.a for cases involving any number of inoperable channels due to the requirement in the first sentence of Note 1 to "take all of the applicable Actions in Notes 1.a, 1.b, and 1.c".

Therefore, the conversion of CTS Table 3.1.1 Note 2 to proposed Table 3.1.1

!'Jote 1 is considered administrative.

A.22 CTS Bases Section 1.1 C on CTS Page 13 incorrectly refers to "Specifications 1.1.1A or 1.1.1 B." This has been corrected to read "Specifications 1.1A or 1.1 B."

This change is a reference correction and does not any alter the current action requirements. Therefore, this change is considered administrative in nature.

TS 3.2.N4.2.A - EMERGENCY CORE COOLING SYSTEM INSTRUMENTATION A.1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.2.N4.2.A, these changes are depicted in the marked-up CTS pages shown, and include:

Page 7 of 38

Administrative Changes

TS 3.2/4.2, page 34 - Rewritten for clarity after incorporation of other changes, and to reflect the relocation of TS 3.2.8/4.2.8 and 3.2.C/4.2.C to their own separate set of pages.

Table 3.2.1, pages 38 through 42 - Title and column headings modified for accuracy, trip function line items given specific sequential numbering, columns repositioned for clarity and consistency and ACTION Notes renumbered to agree with new Notes page.

Table 3.2.1 Notes, pages 44, 44a and 44b - Header changed to read "ACTION Notes," Notes renumbered to adjust for deletions, and new Notes 1 through 8 rewritten to include specific Trip Function designations in lieu of general system names.

Table 4.2.1, pages 59 through 62 - Title and column headings modified for accuracy, trip function line items given specific sequential numbering, blank entries currently shown as "--" or "None" changed to "NA" and columns repositioned to place most frequent activity (Check) first.

Table 4.2 Notes, page 74 - "Not Used" and "Deleted" removed wording where previously eliminated Notes were located. (This Notes page is being entirely removed from the proposed TS because the remaining Notes have either been relocated or deleted in accordance with DOC A,10, A,11, A,13, A,15, A,16, A, 17 and LA,5.)

A,2 CTS 3.2.A specifies an Applicability for Emergency Core Cooling System (ECCS) instrumentation of "When the system(s) it initiates or controls is required in accordance with Specification 3.5." Specification 3.5 includes the requirements for the ECCS. This change provides an explicit Applicability, in proposed Table 3.2.1 for each ECCS instrumentation trip function. The specified Applicabilities, in proposed Table 3.2.1, are consistent with the Modes and conditions when the associated ECCS are required to be operable by Specification 3.5, except as provided and justified in DOC L.1 and LA. This is detailed for each ECCS below:

Per CTS 3.5.A, Core Spray is required to be operable whenever irradiated fuel is in the reactor vessel. Therefore, most Core Spray Trip Functions are required by proposed Table 3.2.1 to be operable in Run, Startup/Hot Standby, Hot Shutdown and Refuel with reactor coolant temperature> 212 OF. In addition, CTS 3.5.H specifies limited operability requirements for shutdown conditions. Therefore, in order to address the requirements of CTS 3.5.H, proposed Table 3.2.1 includes a requirement of "when associated ECCS subsystem is required to be operable" for most Core Spray Trip Functions. There are two exceptions to these proposed requirements. Trip Function 1.a, High Drywell Pressure, is only required to be operable in Run, Startup/Hot Standby, Hot Shutdowr. and Refuel with reactor coolant temperature> 212 of, as discussed in DOC L.1. Trip Function 1.f, Pump Discharge Pressure, is only required to be operable in Run and in Startup/Hot Standby, Hot Shutdown and Refuel with reactor steam Page 8 of 38

Administrative Changes pressure> 150 psig. Trip Function 1.f feeds the Automatic Depressurization System (ADS) logic rather than the Core Spray logic.

Therefore, the applicability of this trip matches the ADS applicability of "any time the reactor pressure is above 150 psig and irradiated fuel is in the reactor vessel" as specified in CTS 3.5.F.

Per CTS 3.5.A, Low Pressure Coolant Injection (LPCI) is required to be operable whenever irradiated fuel is in the reactor vessel.

Therefore, most LPCI Trip Functions are required by proposed Table 3.2.1 to be operable in Run, Startup/Hot Standby, Hot Shutdown and Refuel with reactor coolant temperature> 212 of. In addition, CTS 3.5.H specifies limited operability requirements for shutdown conditions. Therefore, in order to address the requirements of CTS 3.5.H, proposed Table 3.2.1 includes a requirement of "when associated ECCS subsystem is required to be operable" for most LPCI Trip Functions. There are four exceptions to these proposed requirements. Trip Function 2.b, High Drywell Pressure (Initiation),

Trip Function 2.d, Reactor Vessel Shroud Level, and Trip Function 2.g, High Drywell Pressure (Containment Spray Permissive), are only required to be operable in Run, Startup/Hot Standby, Hot Shutdown and Refuel with reactor coolant temperature> 212 of, as discussed in DOCs L.1 and LA. Trip Function 2.f, Pump Discharge Pressure, is only required to be operable in Run and in Startup/Hot Standby, Hot Shutdown and Refuel with reactor steam pressure> 150 psig. Trip Function 2.f feeds the Automatic Depressurization System (ADS) logic rather than the LPCllogic. Therefore, the applicability of this trip matches the ADS applicability of "any time the reactor pressure is above 150 psig and irradiated fuel is in the reactor vessel" as specified in CTS 3.5.F.

Per CTS 3.5.E, High Pressure Coolant Injection (HPCI) is required to be operable whenever irradiated fuel is in the reactor vessel and reactor steam pressure is greater than 150 psig. Therefore, all HPCI Trip Functions are required by proposed Table 3.2.1 to be operable in Run and in Startup/Hot Standby, Hot Shutdown and Refuel with reactor steam pressure> 150 psig.

Per CTS 3.5.F, Automatic Depressurization System (ADS) is required to be operable whenever irradiated fuel is in the reactor vessel and reactor steam pressure is greater than 150 psig. Therefore, all ADS Trip Functions are required by proposed Table 3.2.1 to be operable in Run and in Startup/Hot Standby, Hot Shutdown and Refuel with reactor steam pressure> 150 psig.

Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative. The change, providing explicit Mode or conditions of Applicability for each trip function, is consistent with the ISTS.

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Administrative Changes A.3 CTS 4.2.A specifies that instrumentation and logic systems shall be functionally tested and calibrated as indicated in Table 4.2.1. In proposed Surveillance Requirement (SR) 4.2.A.1, the reference to "and logic system," is deleted since associated logic systems are considered part of the ECCS instrumentation Trip Functions as stated in Change L.5. It is not necessary to explicitly identify logic systems in proposed SR 4.2.A.1 since proposed SR 4.2.A.2 (relocated CTS Table 4.2.1 requirements to perform Functional Tests of Trip System Logic) continues to require performance of surveillance testing of Trip System Logic (Le., performance of Logic System Functional Tests for each ECCS instrumentation Trip Function). Therefore, this change is considered administrative.

A.4 CTS 4.2.A includes reference to CTS Table 4.2.1 for functional test and calibration requirements for ECCS instrumentation. CTS 4.2.A'is revised, in proposed SR 4.2.A.1, to also include reference to check requirements consistent with CTS Table 4.2.1. This change is a difference in presentation only and does not alter the current requirements to periodically perform checks of certain ECCS instrument trip functions. Therefore, this change is considered administrative in nature.

A.5 CTS Table 3.2.1, Notes 8 and 9, provide allowances to delay entry into actions for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the situation of a channel inoperable solely for performance of surveillances. These allowances are moved to proposed SR 4.2.A.1 and the allowances of these two notes are combined. This change does not involve a technical change, but is only a difference in presentation. Therefore, this change is considered administrative.

A.6 The CTS Table 3.2.1 Note 5 requirement to apply the action requirements of Specification 3.5, when the support system (Le., ECCS instrumentation trip functions) are inoperable and the actions of Note 5 are applied, is an unnecessary reminder to follow Technical Specification requirements. The actions of Note 5 require the supported systems to be declared inoperable. The reference to "and the requirements of Specification 3.5 apply" is essentially a "cross reference" between Technical Specifications that has been determined to be adequately provided through training. Therefore, the deletion is considered to be administrative. This change is consistent with the ISTS. The deletion of the remainder of CTS Table 3.2.1 Note 5 is discussed in Change L.5.

A.7 CTS Table 3.2.1 Note 8 includes requirements for both ECCS instrumentation and Recirculation Pump Trip instrumentation. The CTS Table 3.2.1 Note 8 requirements applicable to the Recirculation Pump Trip instrumentation are physically moved to proposed SR 4.2.1.1. The movement of the existing requirements is considered administrative.

A.8 CTS 3.2.1 and 4.2.1 provide requirements related to the Low Reactor Pressure (PS-2-128A and B) Trip Function. This trip function acts to isolate the Residual Heat Removal Shutdown Cooling System when reactor pressure is > 150 psig.

Therefore, the associated requirements are physically moved to proposed Specification 3.2.B and 4.2.B, Primary Containment Isolation. The movement of the existing requirements is considered administrative and is consistent with the ISTS.

Page 10 of 38

Administratiye Changes A.9 CTS 3.2.1 and 4.2.1 provide requirements related to Recirculation Pump Trip instrumentation. The requirements applicable to the Recirculation Pump Trip instrumentation, including CTS Table 3.2.1 Note 2, are physically moved to proposed TS 3.2.1/4.2.1, Tables 3.2.7 and 4.2.7. The movement of the existing requirements is considered administrative and is consistent with the ISTS. (See TS 3.2.1/4.2.1 DOC L.1 for final disposition of CTS Table 3.2.1 Note 2.)

A.10 CTS Table 4.2 Note 8 states that functional tests and calibrations are not required when systems are not required to be operable. The requirements of this Note are duplicated in CTS SR 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. Therefore, CTS Table 4.2 Note 8 is unnecessary and its deletion is considered to be administrative. The change is consistent with the ISTS.

A.11 CTS Table 4.2.1 includes a requirement to perform a calibration of Trip System Logic once per Operating Cycle. This requirement is modified by Table 4.2 Note

3. Note 3 states, "Trip system logic calibration shall include only time delay relays and timers necessary for proper functioning of the trip system." In proposed Table 4.2.1, this requirement is reflected with explicit requirements to perform calibrations of the required ECCS instrumentation time delay relays and timers (Le., proposed Table 4.2.1 Trip Function 1.e., Core Spray Pump Start Time Delay, Trip Function 2.e, LPCI Band C Pump Start Time Delay, Trip Function 4.c, Automatic Depressurization System (ADS) Time Delay, and Trip Function 4.d, ADS Sustained Low-Low Reactor Vessel Water Level Time Delay) once per Operating Cycle. Therefore, this change provides greater clarity and detail but does not alter the current requirements for periodic calibration of Trip System Logic time delay relays and timers, and is considered administrative.

A.12 For the High Pressure Coolant Injection (HPCI) System instrumentation, CTS Table 4.2.1 includes a requirement to perform a calibration of Trip System Logic once per Operating Cycle. This requirement is modified by Table 4.2 Note 3.

Note 3 states, "Trip system logic calibration shall include only time delay relays and timers necessary for proper functioning of the trip system." The HPCI System instrumentation does not include any time delay relays or timers necessary for proper functioning of the trip system. Therefore, this Note is unnecessary and is deleted in proposed Table 4.2.1, since the HPCI System instrumentation does not include calibration requirements for time delay relays or timers. As a result, this change removes non-applicable detail, and is considered administrative.

A.13 CTS Table 4.2 Note 4 provides requirements that apply to control rod block and recirculation pump trip instrumentation. The control rod block instrumentation is located in proposed Specifications 3.2.E and 4.2.E. The recirculation pump trip instrumentation requirements are being moved to proposed Specifications 3.2.1 and 4.2.1. The requirements of CTS Table 4.2 Note 4 are physically moved and changes are addressed in proposed Specifications 3.2.E/4.2.E and 3.2.1/4.2.1.

Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative. (See TS 3.2.E/4.2.E DOC A.8 and TS 3.2.1/4.2.1 DOC A.9 for final disposition of CTS Table 4.2 Note 4.)

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Administrative Changes A.14 (not used)

A.15 CTS Table 4.2 Note 9 provides requirements that apply to post-accident monitoring instrumentation. The post-accident monitoring instrumentation is located in proposed Specifications 3.2.G and 4.2.G. The requirements of CTS Table 4.2 Note 9 are physically moved and changes are addressed in proposed Specifications 3.2.G and 4.2.G. Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative.

A.16 CTS Table 4.2 Note 10 provides requirements that apply to degraded grid protective system instrumentation. The degraded grid protective system instrumentation is located in proposed Specifications 3.2.K and 4.2.K. The requirements of CTS Table 4.2 Note 10 are physically moved and changes are addressed in proposed Specifications 3.2.K and 4.2.K. Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative.

A.17 CTS Table 4.2 Notes 12 and 13 provides requirements that apply to control rod block instrumentation. The control rod block instrumentation is located in proposed Specifications 3.2.E and 4.2.E. The requirements of CTS Table 4.2 Notes 12 and 13 are physically moved and changes are addressed in proposed Specifications 3.2.E and 4.2.E. Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative.

A.18 CTS Table 4.2.1 includes a separate Trip System Logic listing for each ECCS sub-system with a requirement for performance of Functional Tests once per Operating Cycle. Trip System Logics are considered part of the ECCS Instrumentation Trip Functions as stated in DOC L.5, and the VYNPS TS definition of Logic System Functional Test (LSFT), Definition 1.0.H, provides the required details for performance of an LSFT to verify operability of the logic circuits for these functions. Proposed Surveillance Requirement 4.2.A.2 requires a Logic System Functional Test (LSFT) of the ECCS Instrumentation Trip Functions once every Operating Cycle. The details in CTS Table 4.2.1 are redundant to proposed Surveillance Requirement 4.2.A.2 and are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Therefore, the CTS Table 4.2.1 listings of Trip System Logics as separate Trip Functions are unnecessary and are deleted. Not including these details in TS is consistent with the ISTS, and is considered administrative.

TS: 3.2.B/4.2.B - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION A.1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Page 12 of 38

Administrative Changes Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.2.B/4.2.B, these changes are depicted in the marked-up CTS pages shown, and include:

TS 3.2/4.2, page 34 - Rewritten for clarity after incorporation of other changes, and to reflect the relocation of TS 3.2.Al4.2.A and 3.2.C/4.2.C to their own separate set of pages.

Table 3.2.1, pages 39 and 40 - Title changed tb "Table 3.2.2" to reflect separation from original Table 3.2.1 as part of relocation under TS 3.2.B/4.2.B, column headings changed to match ISTS style, trip function line items given specific sequential numbering and columns repositioned for clarity and consistency.

Table 3.2.1 Notes, page 44 - Header changed to read "ACTION Notes," Notes renumbered to adjust for deletions, and new Action Notes 1.a, 1.b, 2.a, 2.b, 2.c and 2.d rewritten for clarity.

Table 3.2.2, page 45 - Column headings changed to match ISTS style, trip function line items given specific sequential numbering, and columns repositioned for clarity and consistency.

Table 3.2.2, page 46 - Column headings changed to match ISTS style, trip function line items given specific sequential numbering, Trip Functions 3.d and 3.e modified for accuracy, ACTION Notes renumbered to agree with new Notes page and columns repositioned for clarity and consistency.

Table 3.2.2, page 47 - Column headings changed to match ISTS style, trip function line items given specific sequential numbering, wording of Trip Functions 4.a, 4.b and 4.e modified for accuracy and columns repositioned for clarity and consistency.

Table 3.2.2 Notes, pages 48 and 48a - Header changed to read "ACTION Notes," "Deleted" wording removed where previously eliminated Notes were located, Notes renumbered to adjust for deletions and new Action Notesrewritten for clarity.

Table 4.2.2, pages 60 and 64 through 66 - Titles modified for accuracy, Trip Function line items given specific sequential numbering, columns repositioned to place most frequent activity (Check) first and blank entries currently shown as "--" changed to "NA".

Table 4.2 Notes, page 74 - "Deleted" wording removed where previously eliminated Notes were located. (This Notes page is being entirely removed from the proposed TS because the remaining Notes have either been relocated or deleted in accordance with DOC A.9, A.21, A.22 and LA.8.)

Page 13 of 38

Administrative Changes A.2 CTS 3.2.8 specifies an Applicability for primary containment isolation instrumentation of "When primary containment is required, in accordance with Specification 3.7." CTS Table 3.2.2 Note 12 specifies an Applicability of "Whenever Primary Containment integrity is required by Specification 3.7.A2."

CTS Table 3.2.2 Note 13 specifies an Applicability of "Whenever the High Pressure Cooling Injection System and Reactor Core Isolation Cooling System are required to be operable in accordance with Specification 3.5" for the High Pressure Coolant Injection (HPCI) System and Reactor Core Isolation Cooling (RCIC) System Low Steam Supply Pressure Trip Functions. Specification 3.5 provides requirements for the HPCI and RCIC Systems. Specification 3.7 includes the requirements for the primary containment. This change provides an explicit Applicability, in proposed Table 3.2.2, for each primary containment isolation instrumentation trip function, and associated ACTION statements via reference to proposed Table 3.2.2 ACTION Note 1 (which was relocated from CTS Table 3.2.2 Notes 12 and 13 and CTS Table 3.2.1 Note 10, and aggregated/rewritten for clarity), Notes 2.a through 2.d (addressed in DOC M.1, M.3, MA, LA4, L.3 and L.5) and Footnotes (a), (b) and (c). The specified Applicabilities in proposed Table 3.2.2 are consistent with the Modes and conditions when primary containment integrity is required to be operable by Specification 3.7, and, for the HPCI System and RCIC System Low Steam Supply Pressure Trip Functions, when HPCI and RCIC are required to be operable by Specification 3.5; except as provided and justified in DOC L.1. Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative. The change, providing explicit Mode or conditions of Applicability for each trip function, is consistent with the ISTS.

A3 CTS 4.2.8 specifies that instrumentation and logic systems shall be functionally tested and calibrated as indicated in Table 4.2.2. In proposed Surveillance Requirement (SR) 4.2.8.1, the reference to "and logic systems," is deleted since associated logic systems are considered part of the Primary Containment Isolation instrumentation Trip Functions as stated in DOC LA. It is not necessary to explicitly identify logic systems in proposed SR 4.2.8.1 since proposed SR 4.2.8.2 (relocated CTS Table 4.2.2 requirements to perform Functional Tests of Trip System Logic) continues to require performance of surveillance testing of Trip System Logic (I.e., performance of Logic System Functional Tests for each Primary Containment Isolation instrumentation Trip Function). Therefore, this change is considered administrative.

A4 CTS 4.2.8 includes reference to CTS Table 4.2.2 for functional test and calibration requirements for primary containment isolation instrumentation. CTS 4.2.8 is revised, in proposed SR 4.2.8.1, to also include reference to check requirements consistent with CTS Table 4.2.2. This change is a difference in presentation only and does not alter the current requirements to periodically perform checks of certain primary containment isolation instrument trip functions.

Therefore, this change is considered administrative in nature.

A5 CTS Table 3.2.1, Note 9 and CTS Table 3.2.2 Note 11, provide allowances to delay entry into actions for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the situation of a channel inoperable solely for performance of surveillances. These allowances are moved to proposed SR 4.2.8.1 and the allowances of these two notes are combined. This change does Page 14 of 38

Administrative Changes not involve a technical change, but is only a difference in presentation.

Therefore, this change is considered administrative.

A6 CTS Tables 3.2.1 and 4.2.1 include a Low Pressure Coolant Injection System Low Reactor Pressure Trip Function (PS-2-128A & B). The purpose of this trip function is to provide isolation of the shutdown cooling portion of the Residual Heat Removal (RHR) System to protect that system from overpressurization due to high reactor pressure. This isolation provides for equipment protection to prevent an intersystem LOCA scenario. As a result, the name of this trip function is revised to "Residual Heat Removal Shutdown Cooling Isolation - High Reactor Pressure" in proposed Tables 3.2.2 and 4.2.2 to more accurately reflect its function. The design and operation of the actual instrumentation is unchanged.

Therefore, this change is considered administrative.

A7 CTS Tables 3.2.1 and 4.2.1 include requirements for the Low Pressure Coolant Injection System - Low Reactor Pressure Trip Function (PS-2-128A &B) and associated Trip System Logic. The purpose of this Trip Function and associated Trip System Logic is to provide isolation of the shutdown cooling portion of the Residual Heat Removal (RHR) System to protect that system from overpressurization due to high reactor pressure. This isolation provides for equipment protection to prevent an intersystem LOCA scenario. These requirements are to be moved to the primary containment isolation instrumentation TS. Given the isolation function of this Trip Function and associated Trip System Logic, they are more appropriately located in proposed Tables 3.2.2 and 4.2.2. As a corresponding change, the reference to initiation capability in CTS Table 3.2.1 Note 10 (proposed Table 3.2.2 Action Note 1, as aggregated and rewritten for Clarity per DOC A1 ) is editorially changed to isolation capability. This change does not involve a technical change, but is only a difference in presentation and is considered administrative. The change, including the requirements this Trip Function and associated Trip System Logic in the primary containment isolation instrumentation TS, is consistent with the ISTS.

A8 Notes 10 and 5 to CTS Table 3.2.1 provide actions when the minimum number of channels per trip system requirement is not met. These requirements are divided and identified in two separate columns in proposed Table 3.2.2 titled, "ACTIONS WHEN REQUIRED CHANNELS ARE INOPERABLE" and "ACTIONS REFERENCED FROM ACTION NOTE 1." This change is a difference in presentation only and does not alter the current action requirements when the required channels are inoperable. Therefore, this change is considered administrative in nature.

A.9 CTS Tables 3.2.1 and 4.2.1 and associated Notes provide requirements related to Recirculation Pump Trip instrumentation. The requirements applicable to the Recirculation Pump Trip instrumentation are physically moved and changes are addressed in proposed Specifications 3.2.1 and 4.2.1. CTS Tables 3.2.1 and 4.2.1 and associated Notes also provide requirements for ECCS Instrumentation. The ECCS instrumentation requirements are included in proposed Tables 3.2.1 and 4.2.1. Changes to the ECCS instrumentation requirements are addressed in the safety assessment of changes for TS 3.2.A14.2.A, ECCS Instrumentation.

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Administrative Changes CTS Table 4.2 Notes 4, 12, and 13 provide requirements that apply to control rod block instrumentation. The control rod block instrumentation is located in proposed Specifications 3.2.E and 4.2.E. The requirements of CTS Table 4.2 Notes 4,12, and 13 are physically moved and changes are addressed in proposed Specifications 3.2.E and 4.2.E. CTS Table 4.2 Note 9 provides requirements that apply to post-accident monitoring instrumentation. The post accident monitoring instrumentation is located in proposed Specifications 3.2.G and 4.2.G. The requirements of CTS Table 4.2 Note 9 are physically moved and changes are addressed in proposed Specifications 3.2.G and 4.2.G. CTS Table 4.2 Note 10 provides requirements that apply to degraded grid protective system instrumentation. The degraded grid protective system instrumentation is located in proposed Specifications 3.2.K and 4.2.K. The requirements of CTS Table 4.2 Note 10 are physically moved and changes are addressed in proposed Specification 3.2.K and 4.2.K. CTS Table 4.2 Note 11 provides requirements that apply to ECCS instrumentation. The ECCS instrumentation is located in proposed Specifications 3.2.A and 4.2.A. The requirements of CTS Table 4.2 Note 11 are physically moved and changes are addressed in proposed Specification 3.2.A and 4.2.A. These changes do not involve technical changes, but are only differences in presentation and are considered administrative.

A.10 The Primary Containment Isolation Instrumentation portion of CTS Tables 3.2.2 and 4.2.2 is divided into two sections, Main Steam Line Isolation (Trip Function 1), and Primary Containment Isolation (Trip Function 2) in proposed Tables 3.2.2 and 4.2.2. The appropriate individual trip functions are placed with the proper isolation. Since the current requirements are maintained (except as addressed in DOC M.1 through M.7 and L.1 through L.5), the change is considered to be administrative in nature. This change is consistent with the ISTS.

A.11 Note 12 to CTS Table 3.2.2 provides actions when the minimum number of channels per trip system requirement is not met. These requirements are identified in a separate column in proposed Table 3.2.2 titled, "ACTIONS WHEN REQUIRED CHANNELS ARE INOPERABLE." This change is a difference in presentation only and does not alter the current action requirements when required primary containment isolation instrumentation channels are inoperable.

Therefore, this change is considered administrative in nature.

A.12 The name of the CTS Table 3.2.2 High Main Steam Line Flow Trip Function (OPT-2-116A, 117B, 118C, 1190 (S 1)) is revised to reflect the condition when this trip function is available. This trip function is available only in the Refuel, Shutdown, and Startup Modes (i.e., not available in Run). Therefore, the name of proposed Tables 3.2.2 and 4.2.2 Trip Function 1.e is "High Main Steam Line Flow

- Not in RUN." The design and operation of the actual instrumentation is unchanged. Therefore, this change is considered administrative.

A.13 CTS 3.2.B requires that the instrumentation in CTS Table 3.2.2 be operable when primary containment integrity is required in accordance with Specification 3.7.

CTS 3.7 requires primary containment integrity when reactor water temperature is above 212°F and fuel is in the reactor vessel. The Primary Containment Isolation Instrumentation Low Main Steam Line Pressure Trip Function requirements of CTS Table 3.2.2 are modified by CTS Table 3.2.2 Note 1.

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Administrative Changes CTS Table 3.2.2 Note 1 states that the main steam line low pressure need be available only in the Run Mode. The intent of this note is to waive the operability requirements of the Primary Containment Isolation Instrumentation Low Main Steam Line Pressure Trip Function when the reactor is not in the Run Mode. The "APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS" column in proposed Table 3.2.2 requires the Low Main Steam Line Pressure Trip Function (proposed Table 3.2.2, Trip Function 1.d) to be operable in the Run Mode which is equivalent to CTS requirements. As such, this change is considered administrative in nature. This change is consistent with the ISTS.

A.14 CTS 3.2.B requires that the instrumentation in CTS Table 3.2.2 be operable when primary containment integrity is required in accordance with Specification 3.7.

CTS 3.7 requires primary containment integrity when reactor water temperature is above 212°F and fuel is in the reactor vessel. The Primary Containment Isolation Instrumentation High Main Steam Line Flow Trip Function (DPT-2-116A, 117B, 118C, 119D (S 1)) requirements of CTS Table 3.2.2 are modified by CTS Table 3.2.2 Note 6. CTS Table 3.2.2 Note 6 states that the main steam line high flow is available only in the Refuel, Shutdown, and Startup Modes. The intent of this note is to waive the operability requirements of the Primary Containment Isolation Instrumentation High Main Steam Line Flow Trip Function (DPT-2-116A, 117B, 118C, 119D (S1)) when the reactor is in the Run Mode. The "APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS" column in proposed Table 3.2.2 requires the High Main Steam Line Flow Trip Function (proposed Table 3.2.2, Trip Function 1.e) to be operable in the Startup/Hot Standby, Hot Shutdown, and Refuel (with reactor coolant water temperature> 212°F) Modes which is equivalent to CTS requirements. As such, this change is considered administrative in nature.

A.15 CTS 3.2.B requires that the instrumentation in CTS Table 3.2.2 be operable when primary containment integrity is required in accordance with Specification 3.7.

CTS 3.7 requires primary containment integrity when reactor water temperature is above 212°F and fuel is in the reactor vessel. The Primary Containment Isolation Instrumentation Condenser Low Vacuum Trip Function requirements of CTS Table 3.2.2 are modified by CTS Table 3.2.2 Note 10. CTS Table 3.2.2 Note 10 states "A key lock switch is provided to permit the bypass of this trip function to enable plant startup and shutdown when condenser vacuum is greater than 12 inches Hg absolute provided that both turbine stop and bypass valves are closed." The intent of this note is to waive the operability requirements of the Primary Containment Isolation Instrumentation Condenser Low Vacuum Trip Function when the reactor is not in the Run Mode and all turbine stop and bypass valves are closed. The "APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS" column in proposed Ta.ble 3.2.2 requires the Condenser Low Vacuum Trip Function (proposed Table 3.2.2, Trip Function 1.f) to be operable in the Run, Startup/Hot Standby (with any turbine stop valve or turbine bypass valve not closed), Hot Shutdown (with any turbine stop valve or turbine bypass valve not closed), and Refuel (with reactor coolant water temperature> 212°F and with any turbine stop valve or turbine bypass valve not closed) Modes which is equivalent to CTS requirements. As such, this change is considered administrative in nature.

Page 17 of 38

Administrative Changes A.16 All HPCI System Isolation High Steam Line Space Temperature channels are required to be operable to assure isolation with the worst single failure. CTS Table 3.2.2 requires a minimum of 2 per set of 4 channels per trip system of the HPCI System Isolation High Steam Line Space Temperature Trip Function (proposed Table 3.2.2, Trip Function 3.a) to be operable. There are three locations (i.e., 3 sets), each monitored by one set of 4 channels. As a result, there are a total of 12 channels for this trip function, with 6 channels per trip system. Therefore, the minimum number of channels per trip system required to be operable for this trip function is specified as "6" in proposed Table 3.2.2.

Since this change involves no design change but is only a difference in nomenclature and presentation, this change is considered administrative.

A.17 Withdrawn per RAI response number 9 in Supplement 2 (ML082660371) dated 9/15/08.

A.18 CTS Table 3.2.2 Notes 12 and 13 refer to automatic isolation trip functions.

However, CTS Table 3.2.2 (proposed Table 3.2.2) includes only automatic isolation trip functions. Manual isolation instrumentation trip functions are not included in the VYNPS CTS. Therefore, it is unnecessary to use the word "automatic" when referring to CTS Table 3.2.2 isolation trip functions in proposed Table 3.2.2 Action Note 1. This change is a difference in presentation only and does not alter the current action requirements when required primary containment isolation instrumentation channels are inoperable. Therefore, this change is considered administrative in nature.

A.19 CTS Table 3.2.2 Note 2 states, in the first paragraph, "If the minimum number of operable instrument channels are not available for one trip system, that trip system shall be tripped. If the minimum number of operable instrument channels are not available for both trip systems, the appropriate actions listed below shall be taken..." However, due to the presentation of the Notes in CTS Table 3.2.2, Note 2 actions are only taken after actions associated with CTS Table 3.2.2 Note 12 or 13, as applicable, are taken. Since the CTS Table 3.2.2 Note 12 and 13 actions (proposed Table 3.2.2 ACTION Note 1) already provide the appropriate NRC approved actions for each of the conditions addressed in the first paragraph of CTS Table 3.2.2 Note 2, the first paragraph of CTS Table 3.2.2 Note 2 is unnecessary and is deleted. Since actions when required primary containment isolation instrumentation channels are inoperable will continue to be taken in the same manner and in the same time period, the deletion is considered administrative in nature.

A.20 For the Trip System Logic associated with the Low Pressure Coolant Injection System - Low Reactor Pressure Trip Function (PS-2-128A & B), CTS Table 4.2.1 includes a requirement to perform a calibration of Trip System Logic once per Operating Cycle. For the Trip System Logic associated with the Primary Containment Isolation Instrumentation, CTS Table 4.2.2 includes a requirement to perform a calibration of Trip System Logic once per Operating Cycle. These requirements are modified by Table 4.2 Note 3. Note 3 states, "Trip system logic calibration shall include only time delay relays and timers necessary for proper functioning of the trip system." The Low Pressure Coolant Injection System Low Reactor Pressure Trip Function instrumentation of CTS 4.2.1 and the Primary Containment Isolation Instrumentation Trip Functions of CTS 4.2.2 do Page 18 of 38

Administrative Changes not include any time delay relays or timers necessary for proper functioning of the trip systems. Therefore, this Note is deleted and, in proposed Table 4.2.2, the Residual Heat Removal Shutdown Cooling Isolation instrumentation (proposed Trip Function 5.a), Main Steam Line Isolation instrumentation (proposed Trip Functions 1.a through 1.f) and Primary Containment Isolation instrumentation (proposed Trip Functions 2.a and 2.b) do not include calibration requirements for time delay relays or timers. As a result, this change removes non-applicable detail, and is considered administrative.

A.21 CTS Table 4.2 Note 8 states that functional tests and calibrations are not required when systems are not required to operable. The requirements of this Note are duplicated in CTS SR 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. Therefore, CTS Table 4.2 Note 8 is unnecessary and its deletion is considered to be administrative. The change is consistent with the ISTS.

A.22 CTS Table 4.2.2 includes a requirement to perform a calibration of Trip System Logic once per Operating Cycle. This requirement is modified by Table 4.2 Note

3. Note 3 states, "Trip system logic calibration shall include only time delay relays and timers necessary for proper functioning of the trip system." This requirement is reflected in proposed Table 4.2.2 with explicit requirements to perform calibrations of the required HPCI System Isolation and RCIC System Isolation instrumentation time delay relays and timers (Le., proposed Table 4.2.2 Trip Function 3.e., HPCI System Isolation - High Main Steam Tunnel Temperature Time Delay, and Trip Function 4.b, RCIC System Isolation - High Main Steam Tunnel Temperature Time Delay) once per Operating Cycle. Therefore, this Note can be deleted. The change does not involve a technical change, but is only a difference in presentation and is considered administrative.

A.23 CTS Table 4.2.2 includes a separate Trip System Logic listing for each Primary Containment Isolation sub-system with a requirement for performance of Functional Tests once per Operating Cycle. Trip System Logics are considered part of the Primary Containment Isolation Instrumentation Trip Functions as stated in DOC LA, and the VYNPS TS definition of Logic System Functional Test (LSFT), Definition 1.0.H, provides the required details for performance of an LSFT to verify operability of the logic circuits for these functions. Proposed Surveillance Requirement (SR) 4.2.B.2 requires a Logic System Functional Test (LSFT) of the Primary Containment Isolation Instrumentation Trip Functions once every Operating Cycle. The details in CTS Table 4.2.2 are redundant to proposed SR 4.2.B.2 and are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Therefore, the CTS Table 4.2.2 listings of Trip System Logics as separate Trip Functions are unnecessary and are deleted. Not including these details in TS is consistent with the ISTS, and is considered administrative.

TS: 3.2.C/4.2.C - REACTOR BUILDING VENTILATION ISOLATION AND STANDBY GAS TREATMENT SYSTEM 1f\\lITIATIOf\\lINSTRUMENTATION A.1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are Page 19 of 38

Administrative Changes adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.2.C/4.2.C, these changes are depicted in the marked-up CTS pages shown, and include:

TS 3.2/4.2, page 34 - Rewritten for clarity after incorporation of other changes, and to reflect the relocation of TS 3.2.N4.2.A and 3.2.B/4.2.B to their own separate set of pages.

Table 3.2.3, page 49 - Title modified for accuracy, column headers modified for accuracy or to adopt ISTS style, Trip Function line items given specific sequential numbering and columns repositioned for clarity and consistency.

Table 3.2.3 Notes, page 49a - Header changed to read "ACTION Notes" and ACTION Notes renumbered and rewritten for clarity.

Table 4.2.3, page 67 - Title modified for accuracy, Trip Function line items given specific sequential numbering, columns repositioned to place the most frequent activity (Check) first and blank entries currently shown as "--" changed to "NA".

Table 4.2 Notes, page 74 - "Deleted" wording removed where previously eliminated Notes were located. (This Notes page is being entirely removed from the proposed TS because the remaining Notes have either been relocated or deleted in accordance with DOC A.9, A.10andA.11.)

A.2 CTS 4.2.C specifies that instrumentation and logic systems shall be functionally tested and calibrated as indicated in Table 4.2.3. In proposed Surveillance Requirement (SR) 4.2.C.1, the reference to "and logic systems," is deleted since associated logic systems are considered part of the Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation Instrumentation Trip Functions as stated in DOC L.3. It is not necessary to explicitly identify logic systems in proposed SR 4.2.C.1 since proposed SR 4.2.C.2 (relocated CTS Table 4.2.3 requirements to perform Functional Tests of Trip System Logic) continues to require performance of surveillance testing of Trip System Logic (Le., performance of Logic System Functional Tests for each Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation Instrumentation Trip Function). Therefore, this change is considered administrative.

A.3 CTS 4.2.C includes reference to CTS Table 4.2.3 for functional test and calibration requirements for reactor building ventilation isolation and Standby Gas Treatment System initiation instrumentation. CTS 4.2.C is revised, in proposed SR 4.2.C.1, to also include reference to check requirements consistent with CTS Table 4.2.3. This change is a difference in presentation only and does not alter Page 20 of 38

Administrative Changes the current requirements to periodically perform checks of certain reactor building ventilation isolation and Standby Gas Treatment System initiation instrumentation trip functions. Therefore, this change is considered administrative in nature.

AA CTS Table 3.2.3 Note 2 provides allowances to delay entry into actions for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the situation of a channel inoperable solely for performance of surveillances. These allowances are moved to proposed SR 4.2.C.1. This change does not involve a technical change, but is only a difference in presentation. Therefore, this change is considered administrative.

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. These requirements are identified in a separate column in proposed Table 3.2.3 titled, "ACTIONS WHEN REQUIRED CHANNELS ARE INOPERABLE." This change is a difference in presentation only and does not alter the current action requirements when required reactor building ventilation isolation and Standby Gas Treatment System initiation instrumentation channels are inoperable. Therefore, this change is considered administrative in nature.

A.6 CTS Table 3.2.3 includes a Reactor Building Vent Trip Function and a Refueling Floor Zone Radiation Trip Function, and Table 4.2.3 provides the associated instrumentation tests and frequencies. The purpose of these trip functions is to provide isolation of the reactor building and initiation of the Standby Gas Treatment System on receipt of a valid high radiation signal. As a result, the name of these trip functions are revised to "High Reactor Building Ventilation Radiation" and "High Refueling Floor Zone Radiation," respectively, in proposed Tables 3.2.3 and 4.2.3 to more accurately reflect their functions. The design and operation of the actual instrumentation is unchanged. Therefore, this change is considered administrative.

A.7 CTS Table 3.2.3 Note 3 provides actions to be taken when one or more reactor building ventilation isolation and Standby Gas Treatment System initiation instrumentation channels are inoperable. In the event these actions are not completed within the specified time period, CTS Table 3.2.3, Notes 3.A and 3.B (as applicable) require the action required by Table 3.2.3 to be taken. For each of the reactor building ventilation isolation and Standby Gas Treatment System initiation instrumentation trip functions, CTS Table 3.2.3 specifies that CTS Table 3.2.3 Note 1 is required. As a human factors improvement, the actions of CTS Table 3.2.3 Notes 1 and 3 have been combined into one action (proposed Table 3.2.3 Action Note 1). Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative.

A.8 CTS Table 3.2.3 Note 3 specifies an Applicability for reactor building ventilation isolation and Standby Gas Treatment System initiation instrumentation of "When Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation are required by Specification 3.7.B and 3.7.C." Specifications 3.7.B and 3.7.C include the requirements for the Standby Gas Treatment System and the Secondary Containment System (which requires reactor building isolation). This change provides an explicit Applicability, in proposed Table 3.2.3 for each reactor building ventilation isolation and Standby Gas Treatment System initiation instrumentation trip function. The specified Applicabilities, in proposed Table Page 21 of 38

Administrative Changes 3.2.3, are consistent with the Modes and conditions when the Standby Gas Treatment System and the Secondary Containment System are required to be operable by Specifications 3.7.B and 3.7.C, respectively, except as provided and justified in DOC L.2 and L.3. This change provides greater clarity and detail but does not alter the current requirements for reactor building ventilation isolation and Standby Gas Treatment System initiation instrumentation, and is considered administrative. The change, providing explicit Mode or conditions of Applicability for each trip function, is consistent with the ISTS.

A.9 CTS Table 4.2 Note 8 states that functional tests and calibrations are not required when systems are not required to be operable. The requirements of this Note are duplicated in CTS SR 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. Therefore, CTS Table 4.2 Note 8 is unnecessary and its deletion is considered to be administrative. The change is consistent with the ISTS.

A.10 For the Trip System Logic associated with the reactor building ventilation and the Standby Gas Treatment System instrumentation, CTS Table 4.2.3 includes requirements to perform a calibration of Trip System Logics once per Operating Cycle. These requirements are modified by Table 4.2 Note 3. Note 3 states, "Trip system logic calibration shall include only time delay relays and timers necessary for proper functioning of the trip system." The reactor building ventilation isolation and the Standby Gas Treatment System initiation Trip Functions of CTS Table 4.2.3 do not include any time delay relays or timers necessary for proper functioning of the trip systems. Therefore, this Note is deleted and, in proposed Table 4.2.3, the reactor building ventilation isolation and the Standby Gas Treatment System initiation instrumentation (proposed Trip Functions 1 through 4) do not include calibration requirements for time delay relays or timers. As a result, this change removes non-applicable detail, and is considered administrative.

A.11 CTS Table 4.2 Notes 2, 10, and 11 provide requirements that apply to ECCS instrumentation. The ECCS instrumentation is located in proposed Specifications 3.2.A and 4.2.A. The requirements of CTS Table 4.2 Notes 2, 10, and 11 are physically moved and addressed in the changes for proposed Specifications 3.2.A and 4.2.A. CTS Table 4.2 Notes 4, 12, and 13 provides requirements that apply to control rod block instrumentation. The control rod block instrumentation is located in proposed Specifications 3.2.E and 4.2.E. The requirements of CTS Table 4.2 Notes 4, 12, and 13 are physically moved and addressed in the changes to proposed Specifications 3.2.E and 4.2.E. CTS Table 4.2 Note 9 provides requirements that apply to post-accident monitoring instrumentation.

The post-accident monitoring instrumentation is located in proposed Specifications 3.2.G and 4.2.G. The requirements of CTS Table 4.2 Note 9 are physically moved and changes are addressed in proposed Specifications 3.2.G and 4.2.G. Therefore, these changes do not involve technical changes, but are only differences in presentation and are considered administrative.

A.12 CTS Table 4.2.3 includes separate Trip System Logic listings for the Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation functions with a requirement for performance of Functional Tests once per Operating Cycle. Trip System Logics are considered part of the Reactor Building Page 22 of 38

Administrative Changes Ventilation Isolation and Standby Gas Treatment System Initiation Instrumentation Trip Functions as stated in DOC L.3, and the VYNPS TS definition of Logic System Functional Test (LSFT), Definition 1.0.H, provides the required details for performance of an LSFT to verify operability of the logic circuits for these functions. Proposed Surveillance Requirement 4.2.C.2 requires a Logic System Functional Test (LSFT) of the Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation Instrumentation Trip Functions once every Operating Cycle. The details in CTS Table 4.2.3 are redundant to proposed Surveillance Requirement 4.2.C.2 and are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Therefore, the CTS Table 4.2.3 listings of Trip System Logics as separate Trip Functions are unnecessary and are deleted. Not including these details in TS is consistent with the ISTS, and is considered administrative.

TS: 3.2.0/4.2.0 - OFF-GAS SYSTEM ISOLATION INSTRUMENTATION A.1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.2.0/4.2.0, these changes are depicted in the marked-up CTS pages shown, and include:

TS 3.2/4.2, page 35 - Changed to reflect relocation of TS 3.2.E/4.2.E and 3.2.F/4.2.F to their own separate set of pages.

Table 4.2 Notes, page 74 - "Not Used" and "Deleted" wording removed where previously eliminated Notes were located. (This Notes page is being entirely removed from the proposed TS because the remaining Notes have either been relocated or deleted in accordance with DOC A.2 and R.1.)

A.2 Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS) 3.2.E, 4.2.E, and Table 4.2 Notes 4,12, and 13 provide requirements that apply to control rod block instrumentation. The control rod block instrumentation is located in proposed Specifications 3.2.E and 4.2.E. The requirements of CTS 3.2.E, 4.2.E, and Table 4.2 Notes 4, 12, and 13 are physically moved and addressed in the changes to proposed Specifications 3.2.E and 4.2.E. CTS Table 4.2 Note 9 provides requirements that apply to post accident monitoring instrumentation. The post-accident monitoring instrumentation is located in proposed Specifications 3.2.G and 4.2.G. The requirements of CTS Table 4.2 Note 9 are physically moved and changes are addressed in proposed Specifications 3.2.G and 4.2.G. CTS Table 4.2 Notes 10 and 11 provide requirements that apply to ECCS instrumentation. The ECCS instrumentation is located in proposed Specifications 3.2.A and 4.2.A. The requirements of CTS Table 4.2 Notes 10 and 11 are physically moved and Page 23 of 38

Administrative Changes addressed in the changes for proposed Specifications 3.2.A and 4.2.A Therefore, these changes do not involve technical changes, but are only differences in presentation and are considered administrative.

TS 3.2.E/4.2.E - CONTROL ROD BLOCK INSTRUMENTATION A1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.2.E/4.2.E, these changes are depicted in the marked-up CTS pages shown, and include:

TS 3.2/4.2, page 35 - Rewritten for clarity after incorporation of other changes, and to reflect the relocation of TS 3.2.F/4.2.F to its own separate set of pages. (TS 3.2.0/4.2.0 is being relocated as described in DOC A2.)

Table 3.2.5, page 51 - Column headers modified for accuracy or to agree with ISTS style, Trip Function line items given specific sequential numbering and columns repositioned for clarity and consistency.

Table 3.2.5 Notes, page 52 - Header changed to read "ACTION Notes," "Not Used" and "Deleted" wording removed where previously eliminated Notes were located, Notes renumbered to adjust for deletions and new Action Notes rewritten for clarity.

Table 4.2.5, page 69 - Title and Rod Block Monitor Trip Function header modified for accuracy and clarity.

Table 4.2 Notes, page 74 - "Not Used" and "Deleted" wording removed where previously eliminated Notes were located. (This Notes page is being entirely removed from the proposed TS because the remaining TS 4.2.5-applicable Notes have either been relocated or deleted in accordance with DOC A4, A7, A8, A9 and M.1.)

A2 CTS 3.2.0 and 4.2.0 provide requirements that apply to off-gas isolation instrumentation. These CTS off-gas isolation instrumentation requirements are being deleted and relocated to the Technical Requirements Manual (TRM) as described in the Safety Assessment of Changes for CTS 3.2.0/4.2.0, Off-Gas Isolation Instrumentation. Therefore, this change does not involve a technical change, and is considered administrative.

Page 24 of 38

Administrative Changes A.3 CTS 3.2.E indicates that, during power operation, the control rod block instrumentation shall be operable in accordance with Table 3.2.5. The Rod Block Monitor (RBM) Trip Functions (proposed Table 3.2.5, Trip Functions 1.a, 1.b and 1.c) are required by CTS Table 3.2.5 to be operable in the Run Mode. CTS Table 3.2.5 Note 7 (first sentence) applies to these Trip Functions and indicates that these Trip Functions may be bypassed when reactor power is < 30% of Rated Thermal Power. The intent of this note is to waive the operability requirements of the RBM Trip Functions when reactor power is < 30%. The "APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS" column in proposed Table 3.2.5 requires the RBM Trip Functions to be operable when reactor power is > 30%

RATED THERMAL POWER which is equivalent to CTS requirements. For the Reactor Mode Switch - Shutdown Position Trip Function, CTS Table 3.2.5 Note 12 modifies the requirements and indicates that this Trip Function is required to be operable when the reactor mode switch is in the shutdown position. The "APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS" column in proposed Table 3.2.5 requires the Reactor Mode Switch - Shutdown Position to be operable as identified in proposed Table 3.2.5 Footnote (a). This footnote states, "When the reactor mode switch is in the shutdown position." As such, these changes are considered administrative in nature.

A.4 CTS 4.2.E specifies that instrumentation and logic systems shall be functionally tested and calibrated as indicated in Table 4.2.5. In proposed Surveillance Requirement (SR) 4.2.E.1, the reference to "and logic system," is deleted since associated logic systems are considered part of the Control Rod Block Instrumentation Trip Functions included in proposed Tables 3.2.5 and 4.2.5. In addition, proposed Tables 3.2.5 and 4.2.5 will delete explicit reference to "Trip System Logic" as a separate Trip Function. The requirement that the "Trip System Logic" be operable is specified by both the definition of Operable and the TS operability requirements for the Control Rod Block Instrumentation Trip Functions, without explicit reference to "Trip System Logic." The Control Rod Block Instrumentation design at VYNPS only includes one "Trip System Logic."

Therefore, when the "Trip System Logic" is inoperable, both RBM channels would be inoperable and proposed Table 3.2.5 Action Note 1.b, would require one channel to be tripped in one hour, which is equivalent to the actions in CTS Table 3.2.5 Note 8 (which is also proposed to be deleted as part of this change). For the purpose of testing, it is not necessary to explicitly identify "Trip System Logic" in CTS Table 4.2.5 for this design, since proposed Table 4.2.5 continues to require performance of surveillance testing of the "Trip System Logic" through the requirements for performance of Instrument Functional Tests and Calibrations.

Therefore, this change does not involve a technical changes, but is only a difference in presentation and is considered administrative.

A.5 CTS Table 3.2.5 Note 10 provides an allowance to delay entry into actions for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the situation of a RBM channel inoperable solely for performance of surveillances. This allowance is moved to proposed SR 4.2.E.1. This change does not involve a technical change, but is only a difference in presentation.

Therefore, this change is considered administrative.

A.6 Notes 9 and 13 to CTS Table 3.2.5 provide actions when the required channels requirement is not met for the associated Trip Functions. These requirements are identified in a separate column in proposed Table 3.2.5 titled, "ACTIONS Page 25 of 38

Administrative Changes WHEN REQUIRED CHANNELS ARE INOPERABLE," for each of the associated Trip Functions. This change is a difference in presentation only and does not alter the current action requirements when required control rod block instrumentation channels are inoperable. Therefore, this change is considered administrative in nature.

A.7 For the Trip System Logic associated with the RBM control rod block instrumentation, CTS Table 4.2.5 includes requirements to perform a calibration of Trip System Logics once per Operating Cycle. These requirements are modified by Table 4.2 Note 3. Note 3 states, "Trip system logic calibration shall include only time delay relays and timers necessary for proper functioning of the trip system." The control rod block instrumentation Trip Functions of CTS Table 4.2.5 do not include any time delay relays or timers necessary for proper functioning of the trip systems. Therefore, this Note is deleted and, in proposed Table 4.2.5, the control rod block instrumentation trip functions (proposed Trip Functions 1.a, 1.b, 1.c, and 2) do not include calibration requirements for time delay relays or timers. As a result, this change removes non-applicable detail, and is considered administrative.

A.8 CTS Table 4.2.5 includes Functional Test requirements for the RBM Upscale and Downscale Trip Functions. These requirements are modified by CTS Table 4.2 Note 4. Note 4 states, "This instrumentation is excepted from functional test definition. The functional test will consist of injecting a simulated electrical signal into the measurement channeL" The definition of Instrument Functional Test for this type of instrumentation (CTS 1.0.G.1) is, "the injection of a signal into the channel as close to the sensor as practicable to verify operability including alarm and/or trip functions." The requirements of CTS Table 4.2 Note 4 are consistent with the requirements of the Instrument Functional Test definition. The CTS definition of Instrument Functional Test allows the method of testing described in CTS Table 4.2 Note 4 to be used. Therefore, CTS Table 4.2 Note 4 is unnecessary and is deleted. This change does not involve a technical change, but is only a difference in presentation and is considered administrative.

A.9 CTS Table 4.2 Notes 2, 8, 10, and 11 provide requirements that apply to ECCS instrumentation. The ECCS instrumentation is located in proposed Specifications 3.2.A and 4.2.A. The requirements of CTS Table 4.2 Notes 2, 8, 10, and 11 are physically moved and addressed in the changes for proposed Specifications 3.2.A and 4.2.A. CTS Table 4.2 Note 9 provides requirements that apply to post accident monitoring instrumentation. The post-accident monitoring instrumentation is located in proposed Specifications 3.2.G and 4.2.G. The requirements of CTS Table 4.2 Note 9 are physically moved and changes are addressed in proposed Specifications 3.2.G and 4.2.G. Therefore, these changes do not involve technical changes, but are only differences in presentation and are considered administrative.

A.10 CTS Table 4.2.5 includes Functional Test requirements for the RBM Upscale and Downscale Trip Functions. These requirements are modified by CTS Table 4.2 Note 13. Note 13 states, as applicable to the RBM Upscale (Flow Bias) Trip Function calibration requirement: "Includes calibration of the RBM Reference Downscale function (Le., RBM upscale function is not bypassed when> 30%

Page 26 of 38

Administrative Changes Rated Thermal Power." CTS Table 4.2 Note 13 is relocated to Footnote (c) in proposed Table 4.2.5.

TS3.2.F/4.2.F - MECHANICAL VACUUM PUMP ISOLATION INSTRUMENTATION A.1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.2.F/4.2.F, these changes are depicted in the marked-up CTS pages shown, and include:

TS 3.2/4.2, page 35 - Rewritten for clarity after incorporation of other changes, and to reflect the relocation of TS 3.2.E/4.2.E to its own separate set of pages. (TS 3.2.0/4.2.0 is being relocated to the TRM as described in DOC A.2.)

TS 3.2/4.2, page 36 - Rewritten for clarity after incorporation of other changes, and to reflect the relocation of TS 3.2.G/4.2.G to its own separate set of pages. (TS 3.2.H/4.2.H is being relocated to the TRM as described in DOC A.2.)

A.2 CTS 3.2.0 and 4.2.0 provide requirements that apply to off-gas isolation instrumentation. These CTS off-gas isolation instrumentation requirements are deleted and relocated to the Technical Requirements Manual (TRM) as described in the Safety Assessment of Changes for CTS 3.2.0/4.2.0, Off-Gas Isolation Instrumentation. CTS 3.2.E and 4.2.E provide requirements that apply to control rod block actuation instrumentation. These CTS control rod block actuation instrumentation requirements are relocated to a separate set of pages within the TS. CTS 3.2.G and 4.2.G provide requirements that apply to post-accident instrumentation. These CTS post-accident instrumentation requirements are relocated to a separate set of pages within the TS. CTS 3.2.H and 4.2.H provide requirements that apply to drywell to torus liP instrumentation. These CTS drywell to torus liP instrumentation requirements are deleted and relocated to the Technical Requirements Manual (TRM) as described in the Safety Assessment of Changes for CTS 3.2.H/4.2.H, Orywell to Torus liP Instrumentation. Therefore, these changes do not involve technical changes, but are only differences in presentation and are considered administrative.

TS: 3.2.G/4.2.G - POST ACCIOENT MONITORING INSTRUMENTATION A.1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are Page 27 of 38

Administrative Changes adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 32.G/4.2.G, these changes are depicted in the marked-up CTS pages shown, and include:

TS 3.2/4.2, page 36 - Rewritten for clarity after incorporation of other changes, and to reflect the relocation of TS 3.2.F/4.2.F to its own separate set of pages. (TS 3.2.H/4.2.H is being relocated to the TRM as described in DOC A.3.)

Table 3.2.6, page 53 - Title modified for accuracy, column headers modified for accuracy and to agree with ISTS style, columns repositioned for clarity, Parameters (Functions) given specific sequential numbering, reference to Note 3 under each Parameter (Function) eliminated due to combination in proposed Note 1, reference to Note 1 relocated to a new column and Containment High Range Radiation Monitor Parameter (Function 9) relocated from page

54.

Table 3.2.6, page 54 - Remaining Parameter (Function) on second page of table moved to first page of table, conformed to new column format and given a specific sequential number, and Note 6 renumbered as Note 2 due to combination in proposed Note 2.

Table 3.2.6 Notes, page 55 - Header changed to read "ACTION Notes," "Deleted" wording removed where previously eliminated Notes were located, Notes renumbered to adjust for deletions and new Action Notes rewritten for clarity.

Table 4.2.6, pages 70 and 71 - Titles and column headers modified for accuracy, columns repositioned to place the more frequent activity (Check) first and Parameters (Functions) given specific sequential numbering.

Table 4.2 Notes, page 74 - "Not Used" and "Deleted" wording removed where previously eliminated Notes were located. (This Notes page is being entirely removed from the proposed TS because the remaining Notes have either been relocated or deleted in accordance with DOC A.6 and R.1.)

A.2 CTS 4.2.G includes reference to CTS Table 4.2.6 for functional test and calibration requirements for post-accident monitoring instrumentation. CTS 4.2.G is revised, in proposed Surveillance Requirement (SR) 4.2.G.1, to delete the reference to functional testing and include reference to check requirements consistent with CTS Table 4.2.6. (CTS Table 4.2.6 includes calibration and check requirements, but does not include Functional Test requirements). This change properly aligns the text with the table and does not alter the current requirements for periodic checks and calibrations of post-accident monitoring instrument functions. Therefore, this change is considered administrative in nature.

Page 28 of 38

Administrative Changes A3 CTS 3.2.H and 4.2.H provide requirements that apply to drywell to torus i1P instrumentation. These CTS drywell to torus i1P instrumentation requirements are being deleted and relocated to the Technical Requirements Manual (TRM) as described in the Safety Assessment of Changes for CTS 3.2.H/4.2.H, Drywell to Torus i1P Instrumentation. Therefore, this change does not involve a technical change, and is considered administrative.

AA CTS Table 3.2.6 Note 8 provides an allowance to delay entry into actions for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the situation of a post-accident monitoring instrumentation channel inoperable solely for performance of surveillances. This allowance is moved to proposed SR 4.2.G.1. This change does not involve a technical change, but is only a difference in presentation. Therefore, this change is considered administrative.

A5 CTS 3.2.G specifies an Applicability for post-accident monitoring instrumentation of "During reactor power operation." The CTS definition of reactor power operation states "Reactor power operation is any operation with the mode switch in the Startup/Hot Standby or Run..." This change provides an explicit Applicability, in proposed Table 3.2.6, for each post-accident monitoring instrumentation Function. The specified Applicabilities in proposed Table 3.2.6 are consistent with the CTS definition of reactor power operation (Le., RUN and STARTUP/HOT STANDBY). Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative.

The change, providing explicit Modes or Conditions of Applicability for each trip function, is consistent with the ISTS.

A6 CTS Table 4.2 Notes 2, 8, 10, and 11 provide requirements that apply to ECCS instrumentation. The ECCS instrumentation is located in proposed Specifications 3.2.A and 4.2.A The requirements of CTS Table 4.2 Notes 2, 8, 10, and 11 are physically moved and addressed in the changes for proposed Specifications 3.2.A and 4.2.A CTS Table 4.2 Notes 12 and 13 provide requirements that apply to control rod block instrumentation. The control rod block instrumentation is located in proposed Specifications 3.2.E and 4.2.E. The requirements of CTS Table 4.2 Notes 12, and 13 are physically moved and changes addressed in proposed Specifications 3.2.E and 4.2.E. CTS Table 4.2 Note 3 provides requirements that apply to ECCS, PCIS, Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation, Off-Gas System Isolation, Control Rod Block Actuation and RCIC Instrumentation. The requirements of CTS Table 4.2 Note 3 are physically moved and addressed in the changes for proposed Specifications 3.2.A/4.2.A (DOC A11), 3.2.B/4.2.B (DOC A22), 3.2.C/4.2.C (DOC A1 0), 3.2.0/4.2.0 (DOC R.1), 3.2.E/4.2.E (DOC A 7) and 3.2.L/4.2.L (DOC A8). CTS Table 4.2 !\\Jote 4 provides requirements that apply to Recirculation Pump Trip and Control Rod Block Actuation Instrumentation. The requirements of CTS Table 4.2 Note 4 are physically moved and addressed in the changes for proposed Specifications 3.2.E/4.2.E and 3.2.1/4.2.1. Therefore, these changes do not involve technical changes, but are only differences in presentation and are considered administrative.

A7 CTS 3.2.G includes descriptive information regarding the design, location and analysis assumptions of post accident monitoring parameters. As described in Page 2£1 of 38

Administrative Changes DOC A.5 of this Safety Assessment of Changes, this general*information is being replaced with reference to Table 3.2.6 for each post accident monitoring function.

Similar information is included in the Bases for CTS 3.2 (CTS Page 79) and is being retained in the Background section of the proposed Bases for TS Section 3.2.G/4.2.G (proposed Page 79). Such information is not necessary for determination of the requirements of the specification. Therefore, this change does not involve a technical change and is considered administrative.

A.8 The parameter labeled "Containment Pressure" in CTS Table 3.2.6 is designated as Function 2 and is being renamed "Drywell Pressure" in proposed Table 3.2.6.

The VY Primary Containment is comprised of two sections, the Drywell and the Suppression Chamber (also referred to as the Torus). These two sections have separate airspaces that normally do not communicate. The Post-Accident Monitoring Instrumentation required by proposed Table 3.2.6 as Function 2 is only capable of monitoring the pressure in the Drywell portion of the Primary Containment. This change in designation provides a more accurate description of the monitoring function of the subject instrumentation. Therefore, this change does not involve a technical change, and is considered administrative.

A.9 The parameter in CTS Table 3.2.6 Function 3, "Torus Pressure" (Meters #PI-16 19-36A(B)) lists the Instrument Range as (-15) - (+ 65) psig. The actual range of the installed instruments is (-15) - (+85) psig. This information is being corrected in the TS Table before being relocated per DOC LA.1. This information is also being corrected in the Proposed Bases for the Applicable Safety Analyses for Function 3.

TS: 3.2.H/4.2.H - DRYWELL TO TORUS bP INSTRUMENTATION A.1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.2.H/4.2.H, these changes are depicted in the marked-up CTS pages shown, and include:

TS 3.2/4.2, Page 36 and 37 - Changed to reflect relocation of TS 3.2.G/4.2.G and TS 3.2.1/4.2.1 to their own separate set of pages. (TS 3.2.H/4.2.H has been relocated to the TRM by DOC R.1.

TS 3.2.1/4.2.1-RECIRCULATION PUMP TRIP INSTRUMENTATION A.1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, re!<ormatting. and revised numbering are Page 30 ot 38

Administrative Changes adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.2.1/4.2.1, these changes are depicted in the marked-up CTS pages shown, and include:

TS 3.2.1/4.2.1, page 37 - Rewritten for clarity after incorporation of other changes, and to refleCt the relocation of TS 3.2.KJ4.2.K and 3.2.Ll4.2.L to their own separate set of pages.

Table 3.2.1, page 43 - Table number changed to "Table 3.2.7" to reflect separation from original Table 3.2.1 as part of relocation under TS 3.2.1/4.2.1, title modified for accuracy, column headers modified for accuracy and to agree with ISTS style, Trip Function line items given specific sequential numbers, columns repositioned for clarity and consistency and Note numbering changed to agree with renumbering of Notes on next page.

Table 3.2.1 Notes, page 44 - Header changed to 'Table 3.2.7 ACTION Notes" to reflect separation from original Table 3.2.1 as part of relocation under TS 3.2.1/4.2.1 and to agree with ISTS style, and page modified to indicate relocation of Notes 9, 10 and 11 to other sections, as described in TS 3.2.Al4.2.A DOC A.5 (Note 9) and DOC A.1 (Notes 10 and 11).

Table 3.2.1 Notes, page 44b - Header changed to "Table 3.2.7 ACTION Notes" to reflect separation from original Table 3.2.1 as part of relocation under TS 3.2.1/4.2.1 and to agree with ISTS style, page modified to indicate relocation of Note 18 to another section, as described in TS 3.2.Al4.2.A DOC A.1, and Note 19 rewritten for clarity and to assign specific sub-numbering to each action statement.

Table 3.2.7, page 55a - Wording regarding previous intentional deletion of Table 3.2.7 being removed, and to be replaced with proposed Table 3.2.7.

Table 4.2.1, page 63 - Table number changed to "Table 4.2.7" to reflect separation from original Table 4.2.1 as part of relocation under TS 3.2.1/4.2.1, title and column headers modified for accuracy, Trip Function line items given specific sequential numbers, columns repositioned to place the most frequent activity (Check) first, and blank entries previously shown as "_" changed to "NA."

Table 4.2.7, page 71a - Wording regarding previous intentional deletion of Table 4.2.7 being removed, and to be replaced with proposed Table 4.2.7.

Table 4.2 Notes, page 74 - "Not Used" and "Deleted" wording removed where previously eliminated Notes were located. (This Notes page is being entirely removed from the proposed TS because Page 31 of 38

Administrative Changes the remaining Notes have either been relocated or deleted in accordance with DOC A7, A8, A9 and A1 0.)

A2 CTS 3.2.H and 4.2.H provide requirements that apply to drywell to torus tlP instrumentation. These CTS drywell to torus tlP instrumentation requirements are being deleted and relocated to the Technical Requirements Manual (TRM) as described in the Safety Assessment of Changes for CTS 3.2.H/4.2.H, Drywell to Torus tlP Instrumentation. Therefore, this change does not involve a technical change, and is considered administrative.

A3 CTS 3.2.1 specifies an Applicability for recirculation pump trip instrumentation of "During reactor power operation." The CTS definition of reactor power operation states "Reactor power operation is any operation with the mode switch in the Startup/Hot Standby or Run..." This change provides an explicit Applicability, in proposed Table 3.2.7 for each recirculation pump instrumentation Trip Function.

The specified Applicabilities in proposed Table 3.2.7 are consistent with the CTS definition of reactor power operation as modified by the CTS Table 3.2.1 Note 19 actions to exit the applicability by placing the plant in Startup/Hot Standby (i.e.,

Run). Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative. The change, providing explicit Mode or conditions of Applicability for each trip function, is consistent with the ISTS.

A4 CTS 4.2.1 includes reference to CTS Table 4.2.1 for functional test and calibration requirements for recirculation pump trip instrumentation. CTS 4.2.1 is revised, in proposed Surveillance Requirement (SR) 4.2.1.1, to also include reference to check requirements consistent with CTS Table 4.2.1. This change is a difference in presentation only and does not alter the current requirements to periodically perform checks of certain recirculation pump trip instrument trip functions.

Therefore, this change is considered administrative in nature.

A5 CTS Table 3.2.1 Note 8 provides an allowance to delay entry into actions for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the situation of a recirculation pump trip instrumentation channel inoperable solely for performance of surveillances. This allowance is moved to proposed SR 4.2.1.1. This change does not involve a technical change, but is only a difference in presentation. Therefore, this change is considered administrative.

A6 CTS Table 3.2.1 Notes 3, 4, 5, 6, 7, and a portion of Note 8 provide requirements related to Emergency Core Cooling System (ECCS) instrumentation. The ECCS instrumentation is located in proposed Specifications 3.2.A and 4.2.A Therefore, the requirements of CTS Table 3.2.1 Notes 3, 4, 5, 6, 7, and the applicable portion of Note 8 are physically moved and changes addressed in proposed Specifications 3.2.A and 4.2.A Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative.

A7 CTS Table 4.2.1 includes a requirement to perform a calibration of Recirculation Pump Trip Instrumentation Trip System Logic once per Operating Cycle. Similar to other calibration requirements for Trip System Logic in the VYNPS CTS, the intent of this requirement is to perform a calibration of time delay relays Page 32 of 38

Administrative Changes necessary for proper functioning of the trip system. In proposed Table 4.2.7, this requirement is reflected with explicit requirements to perform periodic calibrations of the required Recirculation Pump Trip Instrumentation time delay relays (Le.,

proposed Table 4.2.7 Trip Function 2, Time Delay). Therefore, this change provides greater detail and clarity but does not alter the current requirement for performance of periodic time delay relay calibrations in this trip system (see DOC M.5), and is considered administrative.

A.8 CTS Table 4.2 Note 8 states that functional tests and calibrations are not required when systems are not required to operable. The requirements of this Note are duplicated in CTS SR 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. Therefore, CTS Table 4.2 !'Jote 8 is unnecessary and its deletion is considered to be administrative. The change is consistent with the ISTS.

A.9 CTS Table 4.2.1 includes Functional Test requirements for the recirculation pump trip Low - Low Reactor Vessel Water Level and High Reactor Pressure Trip Functions. These requirements are modified by CTS Table 4.2 Note 4. Note 4 states, "This instrumentation is excepted from functional test definition. The functional test will consist of injecting a simulated electrical signal into the measurement channel." The definition of Instrument Functional Test for this type of instrumentation (CTS 1.0.G.1) is, "the injection of a signal into the channel as close to the sensor as practicable to verify operability including alarm and/or trip functions." The requirements of CTS Table 4.2 Note 4 are consistent with the requirements of the Instrument Functional Test definition. The CTS definition of Instrument Functional Test allows the method of testing described in CTS Table 4.2 Note 4 to be used. Therefore, CTS Table 4.2 Note 4 is unnecessary and is deleted. This change does not involve a technical change, but is only a difference in presentation and is considered administrative.

A.10 CTS Table 4.2 Notes 2, 10, and 11 provide requirements that apply to ECCS instrumentation. The ECCS instrumentation is located in proposed Specifications 3.2.A and 4.2.A. The requirements of CTS Table 4.2 Notes 2, 10, and 11 are physically moved and addressed in the changes for proposed Specifications 3.2.A and 4.2.A. CTS Table 4.2 Note 9 provides requirements that apply to post accident monitoring instrumentation. The post-accident monitoring instrumentation is located in proposed Specifications 3.2.G and 4.2.G. The requirements of CTS Table 4.2 Note 9 are physically moved and changes addressed in proposed Specifications 3.2.G and 4.2.G. CTS Table 4.2 Notes 12 and 13 provide requirements that apply to control rod block instrumentation. The control rod block instrumentation is located in proposed Specifications 3.2.E and 4.2.E. The requirements of CTS Table 4.2 Notes 12 and 13 are physically moved and changes addressed in proposed Specifications 3.2.E and 4.2.E. Therefore, these changes do not involve technical changes, but are only differences in presentation and is considered administrative.

A.11 CTS Table 4.2.1 (being relocated to proposed TS 3.2.114.2.1 as Table 4.2.7) includes a separate Trip System Logic listing for the Recirculation Pump Trip Actuation Instrumentation with a requirement for performance of Functional Tests once per Operating Cycle. Trip System Logic is considered part of the Recirculation Pump Trip Actuation System Instrumentation Trip Functions as Page 33 of 38

Administrative Changes stated in DOC L.1, and the VYNPS TS definition of Logic System Functional Test (LSFT), Definition 1.0.H, provides the required details for performance of an LSFT to verify operability of the logic circuits for these functions. Proposed Surveillance Requirement 4.2.1.2 requires a Logic System Functional Test (LSFT) of the Recirculation Pump Trip Actuation System Instrumentation Trip Functions once every Operating Cycle. The details in CTS Table 4.2.1 are redundant to proposed Surveillance Requirement 4.2.1.2 and are not required to be in the VYNPS TS to provide adequate protection of the public health and safety.

Therefore, the CTS Table 4.2.1 listing of Trip System Logic as a separate Trip Function is unnecessary and is not carried over to proposed Table 4.2.7. Not including these details in TS is consistent with the ISTS, and is considered administrative.

TS 3.2.K14.2.K - DEGRADED GRID PROTECTIVE SYSTEIVIINSTRUIVIENTATION A.1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (lSTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.2.K14.2.K, these changes are depicted in the marked-up CTS pages shown, and include:

TS 3.2.K14.2.K, page 37 - Rewritten for clarity after incorporation of other changes, and to reflect the relocation of TS 3.2.1/4.2.1 and 3.2.L/4.2.L to their own separate set of pages.

Table 3.2.8, page 56 - Title modified for accuracy, column headers modified for accuracy and to agree with ISTS style, Parameter (Trip Function) line items given specific sequential numbering, columns repositioned for clarity and Trip Setting numerical values and ranges reformatted to adopt a ";:::" and "~" notation instead of the previous "+/-"

notation.

Table 3.2.8 Notes, page 56 - Notes relocated to a separate page, retitled "ACTION Notes" and rewritten for clarity.

Table 4.2.8, page 72 - Title and column headers modified for accuracy, Trip Function line items given specific sequential numbering, table restructured for clarity and Footnote (a) - formerly Note 10 - relocated from Table 4.2 Notes, page 74 and rewritten for clarity.

Table 4.2 Notes, page 74 - "Not Used" and "Deleted" wording removed where previously eliminated Notes were located, and relocated Note 10 to Table 4.2.8 as Footnote (a). (This Notes page is being entirely removed from the proposed TS because the remaining Notes have Page 34 of 38

Administrative Changes either been relocated or deleted in accordance with DOC A.4 and A.5.)

A.2 CTS 3.2.H and 4.2.H provide requirements that apply to drywell to torus ~P instrumentation. These CTS drywell to torus ~P instrumentation requirements are deleted and relocated to the Technical Requirements Manual (TRM) as described in the Safety Assessment of Changes for CTS 3.2.H/4.2.H, Drywell to Torus ~P Instrumentation. Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative.

A.3 CTS 3.2.K specifies an Applicability for Degraded Grid Protective System instrumentation of "During reactor power operation." This change provides an explicit Applicability, in proposed Table 3.2.8 for each Degraded Grid Protective Instrumentation Trip Function. The specified Applicability, in proposed Table 3.2.8, is consistent with the Modes and conditions specified in CTS 3.2.K, except as provided and justified in DOC M.1. This change provides greater clarity and detail but does not alter the current requirements for Degraded Grid Protective System instrumentation, and is considered administrative. The change, providing explicit Mode or conditions of Applicability for each trip function, is consistent with the ISTS.

A.4 CTS Table 4.2 Note 8 states that functional tests and calibrations are not required when systems are not required to operable. The requirements of this Note are duplicated in CTS SR 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. Therefore, CTS Table 4.2 Note 8 is unnecessary and its deletion is considered to be administrative. The change is consistent with the ISTS.

A.5 CTS Table 4.2 Notes 2, 3 and 11 provide requirements that apply to ECCS instrumentation. The ECCS instrumentation is located in proposed Specifications 3.2.A and 4.2.A. The requirements of CTS Table 4.2 Notes 2, 3 and 11 are physically moved and addressed in the changes for proposed Specifications 3.2.A and 4.2.A. CTS Table 4.2 Note 9 provides requirements that apply to post accident monitoring instrumentation. The post-accident monitoring instrumentation is located in proposed Specifications 3.2.G and 4.2.G. The requirements of CTS Table 4.2 Note 9 are physically moved and changes are addressed in proposed Specifications 3.2.G and 4.2.G. CTS Table 4.2 Notes 4, 12 and 13 provide requirements that apply to control rod block instrumentation.

The control rod block instrumentation is located in proposed Specifications 3.2.E and 4.2.E. The requirements of CTS Table 4.2 Notes 4, 12 and 13 are physically moved and changes are addressed in proposed Specifications 3.2.E and 4.2.E.

Therefore, these changes do not involve technical changes, but are only differences in presentation and are considered administrative.

A.6 Supplement 3 (ML082970191) dated 10/17/08, adds clarifications for TS Table 3.2.8. Note (b) states that items a and b are Trip Functions related to only LOCA condition. Note (c) states that items c and d are Alarm Functions related to only Non-LOCA condition. The CTS do not contain these notes. This information is found in the UFSAR, under Section 6.5, Section 8.5.3, and Section 14.

Therefore, these changes do not involve technical changes, but are only differences in presentation and are considered administrative. DOC A.6 is not Page 35 of 38

Administrative Changes found in the original submittal, but is created to discuss changes submitted under supplemental 3.

TS 3.2.Ll4.2.L - REACTOR CORE ISOLATION COOLING SYSTEM INSTRUMENTATION A1 In the revision of the Vermont Yankee Nuclear Power Station (VYNPS) current Technical Specifications (CTS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the VYNPS Technical Specifications (TS) more consistent with human factor principles used in the Boiling Water Reactor Improved Standard Technical Specifications (ISTS), NUREG-1433, Rev. 2. These format and presentation changes are being made to improve usability and clarity. The changes are considered administrative. For TS 3.2.Ll4.2.L, these changes are depicted in the marked-up CTS pages shown, and include:

TS 3.2.K/4.2.K, page 37 - Rewritten for clarity after incorporation of other changes, and to reflect the relocation of TS 3.2.1/4.2.1 and 3.2.K/4.2.K to their own separate set of pages.

Table 3.2.9, page 57 - Title modified for accuracy, column headers modified for accuracy and to agree with ISTS style, Trip Function line items given specific sequential numbers, columns repositioned for clarity and consistency and Note numbering changed to agree with renumbering of Notes on next page.

Table 3.2.9 Notes, page 58 - Notes 7, 8 and 9 renumbered as Notes 1, 2 and 3 following incorporation of other changes, and rewritten for clarity.

Table 4.2.9, page 73 - Title and column headers modified for accuracy, Trip Function line items given specific sequential numbers, columns repositioned to place the most frequent activity (Check) first, and blank entries previously shown as "--" changed to "NA"

Table 4.2 Notes, page 74 - "Not Used" and "Deleted" wording removed where previously eliminated Notes were located. (This Notes page is being entirely removed from the proposed TS because the remaining Notes have either been relocated or deleted in accordance with DOC A7, A8 and A9.)

A2 CTS 3.2.H and 4.2.H provide requirements that apply to drywell to torus ilP instrumentation. These CTS drywell to torus ilP instrumentation requirements are being deleted and relocated to the Technical Requirements Manual (TRM) as described in the Safety Assessment of Changes for CTS 3.2.H/4.2.H, Drywell to Torus ilP Instrumentation. Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative.

Page 36 of 3:,

Administrative Changes A.3 CTS 3.2.L specifies an Applicability for Reactor Core Isolation Cooling (RCIC)

System instrumentation of "When the Reactor Core Isolation Cooling System is required in accordance with Specification 3.5.G." Specification 3.5.G includes the requirements for the RCIC System. This change provides an explicit Applicability, in proposed Table 3.2.9 for each RCIC System instrumentation Trip Function.

The specified Applicabilities, in proposed Table 3.2.9, are consistent with the Modes and conditions when the RCIC System are required to be operable by Specification 3.5.G. Therefore, this change does not involve a technical change, but is only a difference in presentation and is considered administrative. The change, providing explicit Mode or conditions of Applicability for each trip function, is consistent with the ISTS.

A.4 CTS 4.2.L specifies that instrumentation and logic systems shall be functionally tested and calibrated as indicated in Table 4.2.9. In proposed Surveillance Requirement (SR) 4.2.L.1, the reference to "and logic systems," is deleted since associated logic systems are considered part of the Reactor Core Isolation Cooling (RCIC) System instrumentation Trip Functions as stated in DOC L.1. It is not necessary to explicitly identify logic systems in proposed SR 4.2.L.1 since proposed SR 4.2.L.2 (relocated CTS Table 4.2.9 requirements to perform Functional Tests of Trip System Logic) continues to require performance of surveillance testing of Trip System Logic (i.e., performance of Logic System Functional Tests for RCIC System Instrumentation Trip Functions). Therefore, this change is considered administrative.

A.5 CTS 4.2.L includes reference to CTS Table 4.2.9 for functional test and calibration requirements for RCIC System instrumentation. CTS 4.2.L is revised, in proposed SR 4.2.L.1, to also include reference to check requirements consistent with CTS Table 4.2.9. This change is a difference in presentation only and does not alter the current requirements to periodically perform checks of certain RCIC System instrument Trip Functions. Therefore, this change is considered administrative in nature.

A.6 CTS Table 3.2.9, Notes 5 and 6, provide allowances to delay entry into actions for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the situation of a channel inoperable solely for performance of surveillances. These allowances are moved to proposed SR 4.2.L.1 and the allowances of these two notes are combined. This change does not involve a technical change, but is only a difference in presentation. Therefore, this change is considered administrative.

A.7 CTS Table 4.2 Note 8 states that functional tests and calibrations are not required when systems are not required to operable. The requirements of this Note are duplicated in CTS SR 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. Therefore, CTS Table 4.2 Note 8 is unnecessary and its deletion is considered to be administrative. The change is consistent with the ISTS.

A.8 For the Trip System Logic associated with the RCIC System instrumentation, CTS Table 4.2.9 includes requirements to perform a calibration of Trip System Logics once per Operating Cycle. These requirements are modified by Table 4.2 Note 3. Note 3 states, "Trip system logic calibration shall include only time delay relays and timers necessary for proper functioning of the trip system." The RCIC Page 37 of 38

Administrative Changes System instrumentation Trip Functions of CTS Table 4.2.9 do not include any time delay relays or timers necessary for proper functioning of the trip systems.

Therefore, this Note is deleted and, in proposed Table 4.2.9, the RCIC System instrumentation (proposed Trip Functions 1, 2, and 3) do not include calibration requirements for time delay relays or timers. As a result, this change removes non-applicable detail and is considered administrative.

A.9 CTS Table 4.2 Notes 2, 10, and 11 provide requirements that apply to ECCS instrumentation. The ECCS instrumentation is located in proposed Specifications 3.2.A and 4.2.A. The requirements of CTS Table 4.2 Notes 2, 10, and 11 are physically moved and addressed in the changes for proposed Specifications 3.2.A and 4.2.A. CTS Table 4.2 Note 9 provides requirements that apply to post accident monitoring instrumentation. The post-accident monitoring instrumentation is located in proposed Specifications 3.2.G and 4.2.G. The requirements of CTS Table 4.2 Note 9 are physically moved and changes are addressed in proposed Specifications 3.2.G and 4.2.G. CTS Table 4.2 Notes 4, 12, and 13 provide requirements that apply to control rod block instrumentation.

The control rod block instrumentation is located in proposed Specifications 3.2.E and 4.2.E. The requirements of CTS Table 4.2 Notes 4,12, and 13 are physically moved and changes are addressed in proposed Specifications 3.2.E and 4.2.E.

Therefore, these changes do not involve technical changes, but are only differences in presentation and are considered administrative.

A.10 CTS Table 4.2.9 includes a separate Trip System Logic listing for the Reactor Core Isolation Cooling (RCIC) System Instrumentation with a requirement for performance of Functional Tests once per Operating Cycle. Trip System Logic is considered part of the RCIC System Instrumentation Trip Functions as stated in DOC L.1, and the VYNPS TS definition of Logic System Functional Test (LSFT),

Definition 1.0.H, provides the required details for performance of an LSFT to verify operability of the logic circuits for these functions. Proposed Surveillance Requirement (SR) 4.2.L.2 requires a Logic System Functional Test (LSFT) of the RCIC System Instrumentation Trip Functions once every Operating Cycle. The details in CTS Table 4.2.9 are redundant to proposed SR 4.2.L.2 and are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Therefore, the CTS Table 4.2.9 listing of Trip System Logic as a separate Trip Function is unnecessary and is deleted from proposed Table 4.2.9. Not including these details in TS is consistent with the ISTS, and is considered administrative.

TS 3.5/4.5 - CORE At\\ID CONTAINMENT COOLING SYSTEMS A.1 Withdrawn per RAI response number 8 in supplement 5 (ML083640317) dated 12/18/08.

Page 38 of 38 Less Restrictive Changes

Less Restrictive Changes TS 1.0 - DEFINITIONS, TS 2.1 LIMITING SAFETY SYSTEM SETTINGS, TS 3.1/4.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION L.1 Category 2 - Change 1: In Refuel, if reactor water temperature is less than 212°F, CTS Table 3.1.1 Note 1 requires the Reactor Mode Switch in Shutdown Position Trip Function, Manual Scram Trip Function, IRM High Flux Trip Function, and the Scram Discharge Volume High Water Level Trip Function to be operable.

Proposed Table 3.1.1 only requires these Trip Functions to be operable in Refuel when reactor water temperature is less than or equal to 212°F (the change to less than or equal to 212°F is addressed in DOC L.11) and when a control rod is withdrawn from a core cell containing one or more fuel assemblies (proposed Table 3.1.1 Footnote (b)). This is consistent with the ISTS.

Category 4 - Change 2: The applicability of Refuel with reactor water temperature less than or equal to 212°F is modified, as discussed above, to only require RPS Trip Functions to be operable in Refuel with reactor water temperature less than or equal to 212°F and any control rod withdrawn from a core cell containing one or more fuel assemblies. In addition, proposed Table 3.1.1 ACTION Note 2.d only requires action to be initiated to fully insert control rods in core cells containing one or more fuel assemblies. The Actions for inoperable equipment in Refuel with reactor water temperature less than or equal to 212°F are also revised to be consistent with the proposed applicability. This is consistent with the ISTS.

Category 3 - Change 3: CTS Table 3.1.1 Note 3.a, "...complete insertion of...

control rods within four hours" is revised in proposed Table 3.1.1 ACTION Note 2.d, to "immediately initiate action to insert...." This is consistent with the ISTS.

L.2 Category 4 - The Actions associated with RPS instrumentation in CTS Table 3.1.1 Note 3.a requires immediate initiation of insertion of operable rods and complete insertion of all operable control rods (Le., placing the reactor in Hot Shutdown) within four hours. In proposed Table 3.1.1 ACTION Note 2.a, the requirement is to be in Hot Shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This is consistent with the ISTS.

L.3 Category 4 - CTS Table 3.1.1, for the APRM High Flux (Flow Bias) Trip Function, requires the reactor to be placed in Hot Shutdown within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (CTS Table 3.1.1 Note 3.a) or to reduce power level to the IRM range and place the mode switch in the "Startup/Hot Standby' position within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (CTS Table 3.1.1 Note 3.b). CTS Table 3.1.1, for the Main Steam Line Isolation Valve (MSIV) Closure Trip Function, requires the reactor to be placed in Hot Shutdown within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (CTS Table 3.1.1 Note 3.a) or to close the main steam isolation valves within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , which will cause a reactor trip placing the reactor in Hot Shutdown (CTS Table 3.1.1 Note 3.c). However, the APRM High Flux (Flow Bias) and the Main Steam Line Isolation Valve Closure Trip Functions are only required to be operable in "Run." Therefore, the appropriate action to take when minimum conditions for operation are not satisfied for these Trip Functions is to place the reactor in "Startup/Hot Standby" (proposed Table 3.1.1 Action Note 2.b). This is consistent with the ISTS.

Page 1 of 8

Less Restrictive Changes LA Category 4 - CTS Table 3.1.1 Note 3.d applies to the Turbine Control Valve Fast Closure and Turbine Stop Valve Trip Functions and requires, when minimum conditions for operation are not satisfied, that reactor power be reduced to less than 25% of Rated Thermal Power within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Proposed Table 3.1.1 ACTION Note 2.c revises this requirement to state that reactor power must be reduced to less than or equal to 25% of rated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This action places the reactor in a Mode in which the Turbine Control Valve Fast Closure and Turbine Stop Valve Trip Functions are no longer required to be operable. This is consistent with the ISTS.

L.5 Category 1 - CTS Tables 4.1.1 and 4.1.2 and associated Notes (Table 4.1.1 Note 3 and Table 4.1.2 Note 1) contain design information related to the groups for each of the RPS Trip Function scram sensors. Information on groups for RPS Trip Functions is deleted and is not included in proposed Table 4.1.1. This is consistent with the ISTS.

L.6 Category 7 - Footnote (b) to Table 4.1.1 is added for the APRM High Flux (Reduced) Trip Function 4.b to exempt the Functional Test and Calibration requirements until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering Startup/Hot Standby from Run.

Footnote (b) to Table 4.1.1 is already present and applicable to the IRM High Flux and Inop Trip Functions 3.a and 3.b. The wording of Footnote (b) is being changed to clarify that the surveillance must be completed within the specified time limit. This footnote provides an exception to SR 4.0.1 by allowing operability in the specified mode for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months without the required Surveillances being completed. This is consistent with the ISTS.

L.7 Category 5 - CTS Table 4.1.1 requires performing a Functional Test on alarms of certain RPS Trip Functions. The proposed Table 4.1.1 Functional Test requirement does not include RPS Trip Function alarms. This change is consistent with the ISTS.

L.8 Category 6 - CTS Table 4.1.2 lists calibration standards to be used when performing Calibrations of RPS Trip Functions. Listed calibration standards are not required and are deleted. This change is consistent with the ISTS.

L.g (not used)

L.10 Category 7 - A footnote is added to the APRM High Flux (output signal) heat balance calibration (CTS Table 4.1.2 and proposed Table 4.1.1 Trip Function 4.a and Footnote (d)) that states the Surveillance is not required to be completed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor power n 23% Rated Thermal Power. This footnote provides an exception to SR 4.0.1 by allowing operability in the specified mode for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months without the required Surveillance being completed. The change is consistent with the ISTS.

L.11 Category 2 - In Refuel, if reactor water temperature is less than 212°F, CTS Table 3.1.1 Note 1 requires the Reactor Mode Switch in Shutdown Position Trip Function, Manual Scram Trip Function, IRM High Flux Trip Function, and the Scram Discharge Volume High Water Level Trip Function to be operable.

Proposed Table 3.1.1 and TS 2.1.A.1.b only require these Trip Functions to be operable in Refuel when reactor water temperature is less than or equal to 212°F Page 2 of 8

Less Restrictive Changes and when a control rod is withdrawn from a core cell containing one or more fuel assemblies (the change associated with the status of control rods in core cells is addressed in change L.1 above).

L.12 Categories 6 & 7 - CTS Table 4.1.2 requires the performance of a heat balance calibration of the APRM High Flux Output Signal (Reduced) once every 7 days.

This requirement is deleted and replaced with the requirement to perform a trip unit calibration on a frequency consistent with that for the Logic System Functional Test for this trip function. Proposed Table 4.1.1 Trip Function 4.b requires a Calibration to be performed within 7 days before entering STARTUP/HOT STANDBY, every 7 days during STARTUP/HOT STANDBY and every 7 days during refueling. The Calibration requirement is modified by Footnote (b) that provides a 12-hour time period for completion of the calibration upon entering STARTUP/HOT STANDBY from RUN, Footnote (c) that excludes neutron detectors from the calibration, and Footnote (e) that defines the calibration as a trip unit calibration. The change, including the modification of the Calibration requirement by the added footnotes, is consistent with the ISTS.

TS 3.2.A14.2.A - EMERGENCY CORE COOLING SYSTEM INSTRUMENTATION L.1 Category 2 - CTS 3.2.A requires the Core Spray and LPCI High Drywell Pressure Trip Functions (proposed Table 3.2.1 Trip Functions 1.a, 2.b, and 2.g) to be operable whenever the Core Spray and LPCI subsystems are required to be operable. Per CTS 3.5.A, Core Spray and LPCI are required to be operable whenever irradiated fuel is in the reactor vessel. In addition, CTS 3.5.H specifies limited operability requirements for shutdown conditions. The result is that Core Spray and LPCI are currently required to be operable whenever irradiated fuel is in the reactor vessel in Run, Startup/Hot Standby, and Hot Shutdown, and in Cold Shutdown and Refuel when operations with a potential for draining the reactor vessel (OPDRVs) are in progress. Proposed Table 3.2.1 only requires these Trip Functions to be operable in Run, Startup/Hot Standby, Hot Shutdown and Refuel with reactor coolant temperature> 212°F, regardless of whether or not OPDRVs are in progress. This change is consistent with the ISTS.

L.2 Category 4 - CTS Table 3.2.1, Notes 1a.A, 11.A, 12.A, 17.A, and 18.A require that associated systems be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of discovery of loss of initiation capability for feature(s) in one division or one trip system (as applicable) when ECCS instrumentation channels are inoperable. Proposed Table 3.2.1 Action Notes 1.a, 2.a, 7.a, and 8.a are revised to require that associated systems be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of discovery of loss of initiation capability for feature(s) in both divisions or two trip systems (as applicable) when ECCS instrumentation channels are inoperable. This change is consistent with the ISTS.

L.3 Category 4 - CTS Table 3.2.1 Note 13.A requires that associated systems be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of discovery of loss of LPCI System initiation capability when LPCI Reactor Vessel Shroud Level Trip Function instrumentation channels are inoperable. Proposed Table 3.2.1 Action !\\Jote 3.a does not apply this "loss of LPCI initiation capability" requirement to the LPCI Reactor Vessel Shroud Level Trip Function (proposed Table 3.2.1 Trip Function 2.d). As such, a Page 3 of 8

Less Restrictive Changes total loss of LPCI Reactor Vessel Shroud Level Trip Function capability for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (proposed Table 3.2.1 Action Note 3.b) is allowed. This change is consistent with the ISTS.

LA Category 2 - CTS 3.2.A requires the LPCI Reactor Vessel Shroud Level Trip Function to be operable whenever the LPCI subsystems are required to be operable. Per CTS 3.5.A, LPCI is required to be operable whenever irradiated fuel is in the reactor vessel, with exceptions for shutdown conditions specified in CTS 3.5.H. The result is that LPCI is currently required to be operable whenever irradiated fuel is in the reactor vessel in Run, Startup/Hot Standby, and Hot Shutdown, and in Cold Shutdown and Refuel when operations with a potential for draining the reactor vessel (OPDRVs) are in progress. Proposed Table 3.2.1 only requires this Trip Function (Trip Function 2.d) to be operable in Run, Startup/Hot Standby, Hot Shutdown and Refuel with reactor coolant temperature> 212°F, regardless of whether or not OPDRVs are in progress. This change is consistent with the ISTS.

L.5 Category 4 - CTS Table 3.2.1 includes requirements for Trip System Logics associated with the ECCS instrumentation Trip Functions. The CTS Table 3.2.1 listing of Trip System Logics as separate Trip Functions is deleted. This change is consistent with the ISTS.

TS: 3.2.B/4.2.B - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION L.1 Category 2 - CTS Tables 3.2.1 and 4.2.1 include requirements for the Low Pressure Coolant Injection System - Low Reactor Pressure Trip Function (PS-2 128A & B) and associated Trip System Logic. (This description was changed to "High Reactor Pressure" in proposed Tables 3.2.2 and 4.2.2 by DOC A.6.) CTS 3.2.A specifies an Applicability for this Trip Function and associated Trip System Logic of "When the system(s) it initiates or controls is required in accordance with Specification 3.5." Per CTS 3.5.A, LPCI is required to be operable whenever irradiated fuel is in the reactor vessel, with exceptions for shutdown conditions specified in CTS 3.5.H. The result is that LPCI is currently required to be operable whenever irradiated fuel is in the reactor vessel in Run, Startup/Hot Standby, and Hot Shutdown, and in Cold Shutdown and Refuel when operations with a potential for draining the reactor vessel (OPDRVs) are in progress. The "APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS" column in proposed Table 3.2.2 requires the Residual Heat Removal Shutdown Cooling Isolation Trip Function (i.e., Trip Function 5.a) to be operable in Run, Startup/Hot Standby, Hot Shutdown, and Refuel (with reactor coolant water temperature>

212°F). The requirements of CTS 3.5.A for LPCI operability in Cold Shutdown or Refuel during OPDRVs (i.e., with reactor coolant water temperature < 212°F) are deleted. This change is consistent with the ISTS.

L.2 Category 4 - CTS Table 3.2.1 Note 1a.A requires that associated systems be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of discovery of loss of initiation capability for feature(s) in one division when Low Pressure Coolant Injection System - Low Reactor Pressure Trip Function channels are inoperable. Proposed Table 3.2.2 Action Note 1.b is revised to require, with isolation capability not maintained, that Page 4 of 8

Less Restrictive Changes isolation capability be restored within one hour. This change is consistent with the ISTS.

L.3 Category 4 - CTS 3.2.B provides requirements for the Primary Containment Isolation Instrumentation Low-Low Reactor Vessel Water Level Trip Function (proposed Table 3.2.2 Trip Function 1.a) and the Primary Containment Isolation Instrumentation Condenser Low Vacuum Trip Function (proposed Table 3.2.2 Trip Function 1.f). In the event minimum conditions for operation are not satisfied for these trip functions, CTS Table 3.2.2 requires compliance with CTS Table 3.2.2 Note 2.A. CTS Table 3.2.2 Note 2.A requires an orderly load reduction to be initiated and to have the reactor in Cold Shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The function of this instrumentation is to provide main steam line isolation. Therefore, proposed Table 3.2.2 Action Note 2.a will require, in the same condition, the associated main steam line to be isolated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (which satisfies the isolation function of the inoperable instrumentation) or that the reactor be placed in Hot Shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in Cold Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (which places the reactor in a Mode in which the instrumentation is not required to be operable). Some conditions may affect the isolation logic for only one main steam line. In these cases, it is not necessary to require a shutdown of the unit; rather, isolation of the affected line returns the system to a status where it can perform the remainder of its isolation function, and continued operation is allowed (although it may be at a reduced power level) consistent with the plant specific reload analyses which support operation with one main steam line out of service.

The change is consistent with the ISTS.

LA Category 4 - CTS Table 3.2.2 includes requirements for Trip System Logics associated with the isolation instrumentation Trip Functions for Primary Containment, HPCI and RCIC. CTS Table 3.2.1 includes requirements for Trip System Logic associated with LPCI actuation instrumentation. The CTS Table 3.2.2 listing of Trip System Logics as separate Trip Functions is deleted. This change is consistent with the ISTS. The CTS Table 3.2.1 listing of Trip System Logic as a separate Trip Function was already deleted by DOC L.5 in the TS 3.2.AJ4.2.A Safety Assessment of Changes.

L.5 Category 1 - CTS 3.2.B does not allow primary containment penetration flow paths that are isolated as a result of complying with actions in CTS Table 3.2.2 to be unisolated under administrative controls. Proposed Table 3.2.2 Action Notes 1, 2.a and 2.d contain an allowance for intermittently unisolating, under administrative control, primary containment penetrations that were isolated as a result of complying with proposed Table 3.2.2 Action Notes.

TS: 3.2.C/4.2.C - REACTOR BUILDING VENTILATION ISOLATION AND STANDBY GAS TREATMENT SYSTEM INITIATION INSTRUMENTATION L.1 Category 2 - The Applicability of the Low Reactor Vessel Water Level Trip Function of CTS Table 3.2.3 is "When Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation are required by Specification 3.7.B and 3.7.C." The requirements of Specifications 3.7.B and 3.7.C, and as a result the requirements for this Trip Function, are applicable in Run, Startup/Hot Standby, Hot Shutdown, and Refuel (with reactor coolant water temperature> 212°F) and Page 5 of 8

Less Restrictive Changes during operations with a potential for draining the reactor vessel, during movement of irradiated fuel assemblies or fuel cask in secondary containment, and during alteration of the reactor core. Proposed Table 3.2.3 Trip Function 1 is revised to only be required in Run, Startup/Hot Standby, Hot Shutdown and Refuel (with reactor coolant temperature> 212°F) and during OPDRVs. This change is consistent with the ISTS in that ISTS Table 3.3.6.2-1 does not require the Low Reactor Vessel Water Level Trip Function to be operable during movement of irradiated fuel assemblies or fuel cask in secondary containment, or during alteration of the reactor core.

L.2 Category 2 - The Applicability of the High Drywell Pressure Trip Function of CTS Table 3.2.3 is "When Reactor Building Ventilation Isolation and Standby Gas Treatment System Initiation are required by Specification 3.7.B and 3.7.C." The requirements of Specifications 3.7.B and 3.7.C, and as a result the requirements for this Trip Function, are applicable in Run, Startup/Hot Standby, Hot Shutdown, and Refuel (with reactor coolant water temperature> 212°F) and during operations with a potential for draining the reactor vessel, during movement of irradiated fuel assemblies or fuel cask in secondary containment, and during alteration of the reactor core. Proposed Table 3.2.3 Trip Function 2 is revised to only be required in Run, Startup/Hot Standby, Hot Shutdown and Refuel (with reactor coolant temperature> 212°F). This change is consistent with the ISTS in that ISTS Table 3.3.6.2-1 does not require the High Drywell Pressure Trip Function to be operable during operations with a potential for draining the reactor vessel, during movement of irradiated fuel assemblies or fuel cask in secondary containment, or during alteration of the reactor core.

L.3 Category 4 - CTS Table 3.2.3 includes requirements for Trip System Logics associated with the reactor building ventilation isolation and the Standby Gas Treatment System initiation instrumentation Trip Functions. The CTS Table 3.2.3 listing of Trip System Logics as separate Trip Functions is deleted. This change is consistent with the ISTS.

TS: 3.2.D/4.2.D - OFF-GAS SYSTEM ISOLATION INSTRUMENTATION None TS 3.2.E/4.2.E - CONTROL ROD BLOCK INSTRUMENTATION L.1 Deleted.

L.2 Category 6 - This change adds a note to the RBM Instrument Calibrations in CTS Table 4.2.5 excluding the neutron detectors from this Surveillance (proposed Table 4.2.5 Footnote (b)). This change is consistent with the ISTS.

TS 3.2.F/4.2.F - MECHANICAL VACUUM PUMP ISOLATION INSTRUMENTATION None Page 6 of 8

Less Restrictive Changes TS: 3.2.G/4.2.G - POST ACCIDENT MONITORING INSTRUMENTATION None TS: 3.2.H/4.2.H - DRYWELL TO TORUS ~P INSTRUMENTATION None TS 3.2.1/4.2.1-RECIRCULATION PUMP TRIP INSTRUMENTATION L.1 Category 4 - CTS Table 3.2.1 includes requirements for Trip System Logic associated with the recirculation pump trip instrumentation Trip Functions. The CTS Table 3.2.1 listing of Trip System Logic as a separate Trip Function is deleted. This change is consistent with the ISTS.

TS 3.2.K14.2.K - DEGRADED GRID PROTECTIVE SYSTEM INSTRUMENTATION L.1 Category 4 - When one or more Degraded Bus Voltage - Time Delay channels are inoperable, CTS Table 3.2.8, Note 2 limits operation to 7 days, but does not include explicit actions to restore the inoperable channels. In proposed Table 3.2.8 Action Note 2, an explicit requirement is provided to restore the inoperable channels within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to requiring the associated diesel generators to be declared inoperable. Since the applicable VYNPS diesel generator TS allows operation for up to 7 days with an inoperable diesel generator, the total time allowed for the plant to remain in reactor power operation with an inoperable Degraded Bus Voltage - Time Delay channel is extended from 7 days to 7 days +

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period for this condition is provided to attempt to evaluate and repair any discovered inoperabilities prior to declaring the associated diesel generator inoperable. The change is consistent with the ISTS.

L.2 Category 4 - CTS Table 3.2.8 Note 1, in the event of one or more inoperable Degraded Bus Voltage - Voltage channels, requires the channel to be tripped within one hour, but does not provide direction regarding actions to take if the associated channels are not tripped. As such, a shutdown of the reactor would be required in accordance with 10 CFR 50.36(c)(2). Under these conditions, proposed Table 3.2.8 Action Note 1 provides actions to declare the associated diesel generator inoperable, which results in entering and taking the appropriate actions in the associated diesel generator TS if a channel is not tripped or restored within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The change is consistent with the ISTS.

L.3 Category 4 - CTS Table 3.2.8 includes two Degraded Bus Voltage - Voltage channels per bus and two Degraded Bus Voltage - Time Delay channels per bus.

One of the time delay relays for each bus feeds the actuation circuitry and the other one feeds the alarm circuitry. Both of the low voltage relays for each bus feed both the actuation and alarm circuitry. CTS Table 3.2.8 does not distinguish between the actuation and alarm circuits, and the required LCO actions are the same for each. Proposed Table 3.2.8 includes two new Trip Functions to account for the alarm circuitry: Degraded Bus Voltage - Voltage Alarm and Page 7 of 8

Less Restrictive Changes Degraded Bus Voltage - Alarm Time Delay. Since the alarm circuitry is arranged in a one-out-of-two logic configuration, alarm capability for a bus can be maintained with one Degraded Bus Voltage - Voltage Alarm channel inoperable, and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to restore the inoperable channel to operable status (proposed Table 3.2.8 ACTION Note 3.b). If alarm capability is not maintained for a bus, either due to both Degraded Bus Voltage - Voltage Alarm channels or the one Degraded Bus Voltage - Alarm Time Delay channel being inoperable, only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore alarm capability (proposed Table 3.2.8 ACTION Note 3.a). If the Action and associated completion time of proposed ACTION Note 3.a or 3.b are not met, rather than declare the associated diesel generator inoperable, proposed ACTION Note 3 will require increased voltage monitoring of the associated 4.16 kV emergency bus(es) to twice per shift.

TS 3.2.L/4.2.L - REACTOR CORE ISOLATION COOLING SYSTEM INSTRUMENTATION L.1 Category 4 - CTS Table 3.2.9 includes requirements for Trip System Logics associated with the RCIC System instrumentation Trip Functions. The CTS Table 3.2.9 listing of Trip System Logics as separate Trip Functions is deleted.

This change is consistent with the ISTS.

TS 3.5/4.5 - CORE AND CONTAINMENT COOLING SYSTEMS None Page 8 of 8 Removed Details

Removed Details TS 1.0 - DEFINITIONS, TS 2.1 LIMITING SAFETY SYSTEM SETTINGS, TS 3.1/4.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION LA. 1 Type 1 - The CTS Tables 3.1.1, 4.1.1, and 4.1.2 details relating to system design and operation (i.e., the specific instrument tag numbers) are unnecessary in the TS and are proposed to be relocated to the Technical Requirements Manual (TRM). Proposed Specification 3.1.A and Table 3.1.1 require the RPS Trip Functions to be operable. In addition, the proposed Surveillance Requirements in Table 4.1.1 ensure the required instruments are properly tested. These requirements are adequate for ensuring each of the required RPS Trip Functions is maintained operable. As such, the relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety.

Changes to the TRM are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.2 Type 2 - Details of the methods for performing CTS Table 3.1.1 Note 3.b (proposed Table 3.1.1 ACTION Note 2.b), associated with placing the reactor mode switch in Startup/Hot Standby (i.e., reduce power level to the IRM range),

are to be relocated to plant procedures. These details are not necessary to ensure the shutdown action of placing the reactor mode switch in Startup/Hot Standby and exiting the applicable Mode of the associated RPS instrumentation is accomplished. The requirements of proposed Table 3.1.1 and Table 3.1.1 ACTION Note 2.b are adequate to ensure this action is accomplished. As such, these relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the plant procedures are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA. 3 Deleted LAA Type 2 - The details in the CTS Table 3.1.1 Note 2 "*,, and "**,, Notes, relating to placing channels in trip, are to be relocated to Specification 3.1.A Bases. The requirements of proposed Table 3.1.1 ACTIONS Notes ensure inoperable channels are placed in trip or the unit is placed in a non-applicable Mode or condition, as appropriate. As a result, the relocated details in "*,, and "**,, Notes are not necessary for ensuring the appropriate actions are taken in the event of inoperable RPS channels. As such, these relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety.

Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.5 Type 1 - CTS Table 3.1.1 Note 4 contains design and operational details of the APRM High Flux (Flow Bias) Trip Function Trip Setting for two recirculation loop and single recirculation loop operation. These details are not necessary to ensure the operability of APRM High Flux (Flow Bias) Trip Function. Therefore, the information in this note is to be relocated to Specification 3.1.A Bases and reference to this information is deleted from VYI'JPS TS. The requirements of Specification 3.1.A and associated Table 3.1.1 which includes APRM High Flux (Flow Bias) Trip Function Trip Settings for both two recirculation loop and single recirculation loop operation are adequate to ensure the APRM High Flux (Flow Bias) Trip Function is maintained operable. As such, these relocated Page 1 of 12

Removed Details requirements are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA6 Type 1 - The LPRM inputs for operability of the APRM in CTS Table 3.1.1 Note 5 are relocated to Specification 3.1.A Bases. The Specification 3.1.A Bases indicates that if sufficient LPRMs are not available (the same requirements as specified in CTS Table 3.1.1, Note 5), then the associated APRM is inoperable.

As such, CTS Table 3.1.1 Note 5 is not necessary in VYNPS TS RPS Instrumentation Table 3.1.1. The definition of operability suffices. Therefore, the relocated details of the note are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA? Type 1 - For Trip Settings associated with reactor vessel water level, CTS Table 3.1.1 Note 6 states that the top of enriched fuel has been designated as 0 inches and provides common reference level for all vessel water level instrumentation.

This detail is to be relocated to the Bases. This reference is not necessary to be included in the VYNPS TS to ensure the operability of the RPS instrumentation.

Operability requirements are adequately addressed in proposed Specification 3.1.A, Table 3.1.1 and the specified Trip Setting. As such, this relocated reference is not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA8 Type 1 - CTS Table 3.1.1 Note 10 states that the Turbine Stop Valve Closure and Turbine Control Valve Fast Closure scram signals may be bypassed at < 25% of reactor Rated Thermal Power. The design of these Trip Functions is that they are automatically bypassed when reactor power is < 25% of reactor Rated Thermal Power as measured by turbine first stage pressure. The system design details in CTS Table 3.1.1 Note 10 are to be relocated to the Bases and the reference to this information is deleted from the VYNPS TS. These design details are not necessary to be included in the TS to ensure the operability of the RPS instrumentation since operability requirements are adequately addressed in proposed Specification 3.1.A Therefore, these relocated details are not required to be in the TS to provide adequate protection of the public health and safety.

Changes to the Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA9 Type 4 - CTS Table 4.1.1 Note 8 requires the performance of a reactor vessel water level perturbation test once every month. This requirement is proposed to be relocated from the VYNPS TS to plant procedures. This test is not directly related to verifying the operability of the Low Reactor Water Level Trip Function.

The Instrument Functional Test and Calibration Surveillance Requirements in proposed Table 4,1.1 are adequate to ensure that the Low Reactor Water Level Trip Function is verified and maintained operable. Therefore, this relocated requirement is not required to be in the TS to provide adequate protection of the public health and safety Changes to the plant procedures are controlled by the Page 2 of 12

Removed Details provisions of 10 CFR 50.59. Not including this requirement in TS is consistent with the ISTS.

LA. 10 Type 3 - Proposed Surveillance Requirement 4.1.A.4 requires a Logic System Functional Test (LSFT) of the Reactor Protection System once every Operating Cycle. CTS Table 4.1.1 and associated Note 7 describe details of the performance of Logic System Functional Tests of the RPS. These details are being deleted since they are not necessary to ensure the operability of the RPS.

The VYNPS TS definition of LSFT, Definition 1.0.H, provides the required details for performance of an LSFT and is adequate to ensure RPS is maintained operable. As such, these details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Not including these details in TS is consistent with the ISTS.

LA.11 Type 3 - CTS Table 4.1.2 Note 6 provides details on how to perform the calibration of position switches (for the Turbine Stop Valve Closure Trip Function and the Main Steam Line Isolation Valve Closure Trip Function). The details of the methods of performing Surveillances in CTS Table 4.1.2 Note 6 are to be relocated to the Bases. The requirements of Specification 3.1.A and the associated Surveillance Requirements (including the requirement for periodic calibrations) for the RPS instruments are adequate to ensure the instruments are maintained operable. As such, the details of the methods of performing Surveillances are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.12 Type 1 - CTS Table 4.1.2 Note 5 indicates that LPRMs do not provide a scram function. These system design details are to be relocated to the Bases and the reference to this information is deleted from the VYt\\lPS TS. These design details are not necessary to be included in the TS to ensure the operability of the RPS instrumentation since operability requirements are adequately addressed in proposed Specification 3.1.A. Therefore, these relocated details are not required to be in the TS to provide adequate protection of the public health and safety.

Changes to the Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.13 Type 4 - The last sentence of CTS Table 4.1.1 Note 9 states that the automatic scram contactors shall also be exercised after maintenance of the contactors.

This post maintenance testing requirement is to be relocated to plant procedures.

Post maintenance testing requirements are not necessary to ensure the operability of the RPS instrumentation. Any time the operability of a system or component has been affected by repair, maintenance, or replacement of a component, post maintenance testing is required to demonstrate operability of the system or component. Therefore, explicit post maintenance testing Surveillance Requirements are not required to be in the TS to provide adequate protection of the public health and safety. Changes to plant procedures are controlled by the provisions of 10 CFR 50.59. Not including this post maintenance test requirement in TS is consistent with the ISTS.

Page 3 of 12

Removed Details TS 3.2.N4.2.A - EMERGENCY CORE COOLING SYSTEM INSTRUMENTATION LA. 1 Type 1 - The CTS Tables 3.2.1 and 4.2.1 details relating to system design and operation (i.e., the specific instrument tag numbers) are unnecessary in the TS and are proposed to be relocated to the Technical Requirements Manual (TRM).

Proposed Specification 3.2.A and Table 3.2.1 require the ECCS Instrumentation Trip Functions to be operable. In addition, the proposed Surveillance Requirements in Table 4.2.1 ensure the required instruments are properly tested.

These requirements are adequate for ensuring each of the required ECCS Instrumentation Trip Functions are maintained operable. As such, the relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TRM are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.2 Type 1 - CTS Table 3.2.1 and associated Note 1 contain design and operational details of the ECCS and RPT instrumentation (i.e., nomenclature for each of the subsystems, that each of the two Core Spray, LPCI and RPT, subsystems are initiated and controlled by a trip system, and that subsystem "B is identical to subsystem "A"). These details are not necessary to ensure the operability of ECCS and RPT instrumentation. Therefore, the information in this note is to be relocated to Specifications 3.2.A and 3.2.1 Bases, as applicable, and reference to this information is deleted from VYNPS TS. The requirements of Specifications 3.2.A and 3.2.1 and the associated Surveillance Requirements for the ECCS and RPT instruments are adequate to ensure the instruments are maintained operable. As such, these relocated requirements are not required to be in the VYNPS TS to provide adequate protection of the public health and safety.

Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA. 3 Type 1 - The Trip Settings associated with reactor vessel water level trip functions (proposed Table 3.2.1 Trip Functions 1.b, 2.c, and 3.d) are currently referenced to "above the top of enriched fuel." This detail is to be relocated to the Bases.

This reference is not necessary to be included in the VYNPS TS to ensure the operability of the associated ECCS instrumentation. Operability requirements are adequately addressed in proposed Specification 3.2.A, Table 3.2.1 and the specified Trip Settings. As such, this relocated reference is not required to be in the VYNPS TS to provide adequate protection of the public health and safety.

Changes to the TS Bases are controlled by 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA. 4 Type 1 - CTS Table 3.2.1 Notes 3, 4, 7, and the first sentence of Note 6, contain design details of the ECCS instrumentation (i.e., one trip system with initiating instrumentation arranged in a one-out-of-two taken twice logic, one trip system with initiating instrumentation arranged in a one-out-of-two logic, one trip system arranged in a two-out-of-two logic, and anyone of the two trip systems will initiate ADS). These details are not necessary to ensure the operability of ECCS instrumentation. Therefore, the information in these notes is to be relocated to Specification 3.2.A Bases and reference to this information is deleted from VYNPS TS. The requirements of Specification 3.2.A and the associated Surveillance Requirements for the ECCS instruments are adequate to ensure the Page 4 of 12

Removed Details instruments are maintained operable. As such, these relocated requirements are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA5 Type 3 - CTS Table 4.2.1 and associated Notes 2 and 11 describe details of the performance of the Functional Test of the ADS Trip System Logic. These details are to be relocated to Bases. These details are not necessary to ensure the operability of the ADS Trip System Logic instrumentation. The VYNPS TS definition of Logic System Functional Tests, the requirements of proposed Specification 3.2.A, and the associated Surveillance Requirements (including the requirements to periodically perform Logic System Functional Tests) are adequate to ensure the ADS Trip System Logic is maintained operable. As such, these relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

TS: 3.2.B/4.2.B - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION LA1 Type 1 - The CTS Tables 3.2.1, 3.2.2 and 4.2.1 details relating to system design and operation (Le., the specific instrument tag numbers) are unnecessary in the TS and are proposed to be relocated to the Technical Requirements Manual (TRM). Proposed Specification 3.2.B and Table 3.2.2 require the Primary Containment Isolation Instrumentation Trip Functions to be operable. In addition, the proposed Surveillance Requirements in Table 4.2.2 ensure the required instruments are properly tested. These requirements are adequate for ensuring each of the required Primary Containment Isolation Instrumentation Trip Functions are maintained operable. As such, the relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TRM are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA2 Type 4 - CTS Table 3.2.1 includes requirements for the Low Pressure Coolant Injection System - Low Reactor Pressure Trip Function (PS-2-128A & B). The purpose of this trip function is to provide isolation of the shutdown cooling portion of the Residual Heat Removal (RHR) System to protect that system from overpressurization due to high reactor pressure. This isolation provides for equipment protection to prevent an intersystem LOCA scenario. CTS Table 3.2.1 includes Trip Settings of 100 < P < 150 psig. The upper Trip Setting ensures the RHR System is isolated from the Reactor Coolant System prior to being overpressurized due to high reactor pressure. The lower Trip Setting is an operational detail that is not directly related to the operability of the associated instrumentation. This detail is to be relocated to plant procedures. The upper Trip Setting is the required limitation for the parameter and this value is retained in the VYNPS TS. As such, the lower Trip Setting for this trip function is not required to be in TS to provide adequate protection of the public health and safety. Changes to the relocated lower Trip Setting in the plant procedures will be controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

Page 5 of 12

Removed Details LA.3 Type 1 - The Trip Setting associated with the Low-Low Reactor Vessel Water Level trip function (proposed Table 3.2.2 Trip Function 1.a) is currently referenced to "above the top of enriched fuel" in CTS Table 3.2.2. This detail is to be relocated to the Bases. This reference is not necessary to be included in the WNPS TS to ensure the operability of the associated primary containment isolation instrumentation. Operability requirements are adequately addressed in proposed Specification 3.2.B, Table 3.2.2 and the specified Trip Setting. As such, this relocated reference is not required to be in the WNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.4 Type 2 - Details of the methods for performing CTS Table 3.2.2 Notes 2.A and 2.B (proposed Table 3.2.2 Action Notes 2.b and 2.c), associated with placing the reactor in Cold Shutdown (Le., initiating an orderly shutdown) or Hot Standby (Le.,

initiating an orderly load reduction), are to be relocated to plant procedures.

These details are not necessary to ensure the actions of placing the reactor in Cold Shutdown mode or Hot Standby and exiting the applicable Mode of the associated primary containment isolation instrumentation are accomplished. The requirements of proposed Table 3.2.2 and Table 3.2.2 Action Notes 2.b and 2.c are adequate to ensure this action is accomplished. As such, these relocated details are not required to be in the WNPS TS to provide adequate protection of the public health and safety. Changes to the plant procedures are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.5 Type 1 - For the Primary Containment Isolation Instrumentation - Condenser Low Vacuum Trip Function, CTS Table 3.2.2 Note 10 states that "A key lock switch is provided to permit the bypass of this trip function to enable plant startup and shutdown when condenser vacuum is greater than 12 inches Hg absolute provided that both turbine stop and bypass valves are closed." The system design details in CTS Table 3.2.2 Note 10 are to be relocated to the Bases and the reference to this information is deleted from the WNPS TS. These design details are not necessary to be included in the TS to ensure the operability of the Condenser Low Vacuum Trip Function instrumentation since operability requirements are adequately addressed in proposed Specification 3.2.B and Table 3.2.2. Therefore, these relocated details are not required to be in the TS to provide adequate protection of the public health and safety. Changes to the Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.6 Type 1 - CTS Table 3.2.2 Note 12 contains design and operational details of the primary containment isolation instrumentation (i.e., there shall be two operable or tripped trip systems for each Trip Function). These details are not necessary to ensure the operability of associated primary containment isolation instrumentation. Therefore, the information in this note regarding trip system design and operational status is to be relocated to Specification 3.2.B Bases and reference to this information is deleted from WNPS TS. The requirements of Specification 3.2.B and the associated Surveillance Requirements for the associated primary containment isolation instruments are adequate to ensure the Page 6 of 12

Removed Details instruments are maintained operable. As such, these relocated requirements are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA7 Type 1 - CTS Table 3.2.2 Note 5 contains design details of the HPCI System Isolation - Low Steam Supply Pressure Trip Function and RCIC System - Low Steam Supply Pressure Trip Function instrumentation (Le., one trip system arranged in a one-out-of-two taken twice logic). These details are not necessary to ensure the operability of associated isolation instrumentation. Therefore, the information in these notes is to be relocated to Specification 3.2.B Bases and reference to this information is deleted from VYNPS TS. The requirements of Specification 3.2.B and the associated Surveillance Requirements for these isolation instruments are adequate to ensure the instruments are maintained operable. As such, these relocated requirements are not required to be in the VYNPS TS to provide adequate protection of the public health and safety.

Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LAB Type 3 - CTS Table 4.2 Note 2 describes details of the performance of the Functional Test of the Trip System Logic associated with the Main Steam Line Isolation Trip Functions. The details of Note 2 are to be relocated to Bases.

These details are not necessary to ensure the operability of the associated Trip System Logic instrumentation. The VYNPS TS definition of Logic System Functional Tests, the requirements of proposed Specification 3.2.B, and the associated Surveillance Requirements (including the requirements to periodically perform Logic System Functional Tests in proposed SR 4.2.B.2) are adequate to ensure the associated Trip System Logic is maintained operable. As such, these relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

TS: 3.2.C/4.2.C - REACTOR BUILDING VENTILATION ISOLATION AND STANDBY GAS TREATMENT SYSTEM INITIATION INSTRUMENTATION LA1 Type 1 - The CTS Table 3.2.3 details relating to system design and operation (Le., the specific instrument tag numbers) are unnecessary in the TS and are proposed to be relocated to the Technical Requirements Manual (TRM).

Proposed Specification 3.2.C and Table 3.2.3 require the reactor building ventilation isolation and the Standby Gas Treatment System initiation instrumentation Trip Functions to be operable. In addition, the proposed Surveillance Requirements in Table 4.2.3 ensure the required instruments are properly tested. These requirements are adequate for ensuring each of the required reactor building ventilation isolation and the Standby Gas Treatment System initiation Trip Functions are maintained operable. As such, the relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TRM are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

Page 7 of 12

Removed Details LA.2 Type 1 - CTS Table 3.2.3 Note 3 contains design and operational details of the reactor building ventilation isolation and the Standby Gas Treatment System initiation instrumentation (Le., there shall be two operable or tripped trip systems for each Trip Function). These details are not necessary to ensure the operability of associated reactor bUilding ventilation isolation and the Standby Gas Treatment System initiation instrumentation. Therefore, the information in this note is to be relocated to Specification 3.2.C Bases and reference to this information is deleted from VYNPS TS. The requirements of Specification 3.2.C and the associated Surveillance Requirements for the associated reactor building ventilation isolation and the Standby Gas Treatment System initiation instrumentation are adequate to ensure the instruments are maintained operable.

As such, these relocated requirements are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

TS: 3.2.0/4.2.0 - OFF-GAS SYSTEM ISOLATION INSTRUMENTATION None TS 3.2.E/4.2.E - CONTROL ROD BLOCK INSTRUMENTATION LA. 1 Type 1 - The CTS Table 3.2.5 details relating to system design and operation (Le., the specific instrument tag numbers) are unnecessary in the TS and are proposed to be relocated to the Technical Requirements Manual (TRM).

Proposed Specification 3.2.E and Table 3.2.5 require the control rod block instrumentation Trip Functions to be operable. In addition, the proposed Surveillance Requirements in Table 4.2.5 ensure the required instruments are properly tested. These requirements are adequate for ensuring each of the required control rod block instrumentation Trip Functions are maintained operable. As such, the relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TRM are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.2 Type 1 - The LPRM inputs for operability of the RBM are relocated to Specification 3.2.E Bases, and the applicability is clarified to provide for adequate coverage of the entire core in the axial direction for every non-peripheral control rod selected for movement. The Specification 3.2.E Bases indicates that if sufficient LPRMs are not available (the same requirements as specified in CTS Table 3.2.5, Note 7, second sentence), and then the associated RBM is inoperable. As such, CTS Table 3.2.5 Note 7, second sentence, is not necessary in VYNPS TS control rod block instrumentation Table 3.2.5. The above definition of operability suffices. Therefore, the relocated details of the note are not required to be inthe VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

Page 8 of 12

Removed Details LA.3 Type 1 - CTS Table 3.2.5 Note 5 contains design and operational details of the RBM Upscale (Flow Bias) Trip Function Trip Setting for two recirculation loop and single recirculation loop operation. These details are not necessary to ensure the operability of the RBM Upscale (Flow Bias) Trip Function. Therefore, the information in this note is to be relocated to Specification 3.2.E Bases and reference to this information is deleted from VYf\\lPS TS. The requirements of Specification 3.2.E and associated Table 3.2.5 which includes RBM Upscale (Flow Bias) Trip Function Trip Settings for both two recirculation loop and single recirculation loop operation are adequate to ensure the RBM Upscale (Flow Bias)

Trip Function is maintained operable. As such, these relocated requirements are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.4 Deleted.

TS 3.2.F/4.2.F - MECHANICAL VACUUM PUMP ISOLATION INSTRUMENTATION None TS: 3.2.G/4.2.G - POST ACCIDENT MONITORING INSTRUMENTATION LA. 1 Type 1 - The CTS Table 3.2.6 details relating to system design and operation (Le., type of indication, specific instrument tag numbers, and instrument range) are unnecessary in the TS and are proposed to be relocated to the Technical Requirements Manual (TRIV1). Proposed Specification 3.2.G and Table 3.2.6 require the post-accident monitoring instrument Functions to be operable. In addition, the proposed Surveillance Requirements in Table 4.2.6 ensure the required instruments are properly tested. These requirements are adequate for ensuring each of the required post-accident monitoring instrument Functions are maintained operable. As such, the relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety.

Changes to the TRM are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

TS: 3.2.H/4.2.H - DRYWELL TO TORUS ~P INSTRUMENTATION None TS 3.2.1/4.2.1-RECIRCULATION PUMP TRIP INSTRUMENTATION LA. 1 Type 1-The CTS Table 3.2.1 details relating to system design and operation (Le.,

the specific instrument tag numbers) are unnecessary in the TS and are proposed to be relocated to the Technical Requirements Manual (TRM).

Proposed Specification 3.2.1 and Table 3.2.7 require the recirculation pump trip instrumentation Trip Functions to be operable. In addition, the proposed Surveillance Requirements in Table 4.2.7 ensure the required instruments are Page 9 of 12

Removed Details properly tested. These requirements are adequate for ensuring each of the required recirculation pump trip instrumentation Trip Functions is maintained operable. As such, the relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TRM are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.2 Type 1 - CTS Table 3.2.1 and associated Note 1 contain design and operational details of the ECCS and RPT instrumentation (Le., nomenclature for each of the subsystems, that each of the two Core Spray, LPCI and RPT, subsystems are initiated and controlled by a trip system, and that subsystem "B is identical to subsystem "A"). These details are not necessary to ensure the operability of ECCS and RPT instrumentation. Therefore, the information in this note is to be relocated to Specifications 3.2.A and 3.2.1 Bases, as applicable, and reference to this information is deleted from VYNPS TS. The requirements of Specifications 3.2.A and 3.2.1 and the associated Surveillance Requirements for the ECCS and RPT instruments are adequate to ensure the instruments are maintained operable. As such, these relocated requirements are not required to be in the VYNPS TS to provide adequate protection of the public health and safety.

Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.3 Type 1 - The Trip Setting associated with reactor vessel water level trip function (proposed Table 3.2.7 Trip Function 1) is currently referenced to "above the top of enriched fuel." This detail is to be relocated to the Bases. This reference is not necessary to be included in the VYNPS TS to ensure the operability of the assdci'ated recirculation pump trip instrumentation. Operability requirements are adequately addressed in proposed Specification 3.2.1, Table 3.2.7 and the specified Trip Setting. As such, this relocated reference is not required to be in the VYNPS TS to provide adequate protection of the public health and safety.

Changes to the TS Bases are controlled by 10 CFR 50.59. Not including these details in TS is consistent with the ISTS. As part of this change, the previous reference to ~ 6' 10.5" (above TEF) is changed to ~ 82.5" to agree with conventions used elsewhere in the TS.

LA.4 Type 2 - The details in the CTS Table 3.2.1 Note 2, relating to the method used for placing channels in trip, are to be relocated to Specification 3.2.1 Bases. The requirements of proposed Table 3.2.7 ACTIONS Notes ensure inoperable channels are placed in trip or the unit is placed in a non-applicable Mode or condition, as appropriate. As a result, the relocated details in the CTS Table 3.2.1 Note 2 are not necessary for ensuring the appropriate actions are taken in the event of inoperable recirculation pump trip instrumentation channels. As such, these relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

Page 10 of 12

Removed Details TS 3.2.K/4.2.K - DEGRADED GRID PROTECTIVE SYSTEM INSTRUMENTATION LA. 1 Type 1 - The CTS Table 3.2.8 details relating to system design and operation (Le., the specific instrument tag numbers) are unnecessary in the TS and are proposed to be relocated to the Technical Requirements Manual (TRM).

Proposed Specification 3.2.K and Table 3.2.8 require Degraded Grid Protective instrumentation Trip Functions to be operable. In addition, the proposed Surveillance Requirements in Table 4.2.8 ensure the required instruments are properly tested. These requirements are adequate for ensuring each of the required Degraded Grid Protective instrumentation Trip Functions is maintained operable. As such, the relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TRM are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.2 Type 2 - The details in the CTS Table 3.2.8 Note 1, relating to the method used for placing channels in trip, are to be relocated to Specification 3.2.K Bases. The requirements of proposed Table 3.2.8 Action Notes are adequate to ensure inoperable channels are placed in trip. As a result, the relocated details in the CTS Table 3.2.8 Note 1 are not necessary for ensuring the appropriate actions are taken in the event of inoperable Degraded Grid Protective instrumentation channels. As such, these relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

TS 3.2.L/4.2.L - REACTOR CORE ISOLATION COOLING SYSTEM INSTRUMENTATION LA. 1 Type 1 - The CTS Table 3.2.9 details relating to system design and operation (Le., the specific instrument tag numbers) are unnecessary in the TS and are proposed to be relocated to the Technical Requirements Manual (TRM).

Proposed Specification 3.2.L and Table 3.2.9 require the RCIC System Instrumentation Trip Functions to be operable. In addition, the proposed Surveillance Requirements in Table 4.2.9 ensure the required instruments are properly tested. These requirements are adequate for ensuring each of the required RCIC System Instrumentation Trip Functions are maintained operable.

As such, the relocated details are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TRM are controlled by the provisions of 10 CFR 50.59. Not inclUding these details in TS is consistent with the ISTS.

LA.2 Type 1 - CTS Table 3.2.9 Notes 1, 2, and 3 contain design details of the RCIC System instrumentation (Le., one trip system with initiating instrumentation arranged in a one-out-of-two taken twice logic, one trip system with initiating instrumentation arranged in a one-out-of-two logic, and one trip system arranged in a two-out-of-two logic). These details are not necessary to ensure the operability of RCIC System instrumentation. Therefore, the information in these notes is to be relocated to Specification 3.2.L Bases and reference to this information is deleted from VYNPS TS. The requirements of Specification 3.2.L Page 11 of 12

Removed Details and the associated Surveillance Requirements for the RCIC System instruments are adequate to ensure the instruments are maintained operable. As such, these relocated requirements are not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by the provisions of 10 CFR 50.59. Not including these details in TS is consistent with the ISTS.

LA.3 Type 1 - The Trip Settings associated with reactor vessel water level trip functions (proposed Table 3.2.9 Trip Functions 1 and 3) are currently referenced to "Above Top of Enriched Fuel" in Table 3.2.9. This detail is to be relocated to the Bases.

This reference is not necessary to be included in the VYNPS TS to ensure the operability of the associated RCIC System instrumentation. Operability requirements are adequately addressed in proposed Specification 3.2.L, Table 3.2.9 and the specified Trip Settings. As such, this relocated reference is not required to be in the VYNPS TS to provide adequate protection of the public health and safety. Changes to the TS Bases are controlled by 10 CFR 50.59.

Not including these details in TS is consistent with the ISTS.

TS 3.5/4.5 - CORE AND CONTAINMENT COOLING SYSTEMS None Page 12 of 12 More Restrictive Changes

More Restrictive Changes TS 1.0 - DEFINITIONS, TS 2.1 LIMITING SAFETY SYSTEM SETTINGS, TS 3.1/4.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION M.1 Current TS (CTS) Table 3.1.1 Note 12 provides an allowance to not require the APRM High Flux (Reduced) Trip Function to be operable during refuel interlock checks which require the mode switch to be in startup if certain conditions are met. The allowance of CTS Table 3.1.1 Note 12 is no longer used and is deleted.

Required refuel interlock checks are performed without the use of CTS 3.1.1 Note 12. This change represents an additional restriction on plant operation through the elimination of an allowance. The change is consistent with the ISTS.

M.2 CTS Table 3.1.1 specifies an Applicability of Startup and Run for the APRM Inop Trip Function. The APRM Inop Trip Function is a design feature that supports the other APRM Trip Functions. The other APRM Trip Functions are required to be operable in Run (for the APRM High Flux (Flow Bias) Trip Function) and Startup and Refuel with reactor coolant temperature> 212°F (for the APRM High Flux (Reduced) Trip Function). As such, the Applicability of the APRM Inop Trip Function is increased to also include Refuel with reactor coolant temperature>

212°F. This change represents an additional restriction on plant operation to ensure the APRM Inop Trip Function is operable to support the other APRM Trip Functions. This change is consistent with the ISTS.

M.3 For CTS Table 3.1.1, Trip Function 4, for APRM Inop, two shutdown alternatives are provided when minimum conditions for operation are not satisfied. One of these shutdown alternatives (CTS Table 3.1.1 Note 3.A) requires immediate insertion of operable rods and complete insertion of operable rods within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The other shutdown alternative (CTS Table 3.1.1 Note 3.B) requires power to be reduced to the IRM range and the reactor mode switch to be placed in the "Startup/Hot Standby" position within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The applicability of the APRM Inop Trip Function is currently Run and Startup. As a result, if the optional shutdown action of CTS Table 3.1.1 Note 3.B is selected to be taken (when the minimum conditions for operation are not satisfied for the APRM Inop Trip Function), the plant would still be in an applicable Mode of the associated Trip Function.

Therefore, the deletion of the optional shutdown action (CTS Table 3.1.1 Note 3.B) for the APRM Inop Trip Function ensures that the shutdown action required to be taken for this Trip Function actually results in exiting the Mode of applicability for the Trip Function. This change represents an additional restriction on plant operation and is consistent with the ISTS.

M.4 (not used)

M.5 CTS Table 3.1. 'I Note 1 provides the option to require either the IRM High Flux Trip Function or the SRM High Flux in coincidence Trip Function to be operable when the reactor is in Refuel and reactor water temperature is less than 212°F.

The allowance to substitute the SRM High Flux in coincidence Trip Function for the IRM High Flux Trip Function is deleted since it will no longer be used.

Instead the IRM High Flux Trip Function will be required to be operable in this condition. This change represents an additional restriction on plant operation through elimination of an allowance. In addition, the IRM Inop Trip Function is a design feature that supports the IRM High Flux Trip Function. As such, the Page 1 of 13

More Restrictive Changes applicability of the IRM Inop Trip Function is increased to also include Refuel with reactor coolant temperature less than or equal to 212°F. This change represents an additional restriction on plant operation to ensure the IRM Inop Trip Function is operable to support the IRM High Flux Trip Function. These changes are consistent with the ISTS.

M.6 With one manual RPS channel inoperable in one trip system, a manual RPS trip will not occur due to the VYNPS design of these Trip Functions. Therefore, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (CTS Table 3.1.1 Note 2.a) is reduced to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in proposed Table 3.1.1 ACTION Note 1.c. Proposed Table 3.1.1 ACTION Note 1.c limits the time to restore RPS trip capability to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months when inoperability in one or both manual Trip Functions (Manual Scram and Reactor Mode Switch in Shutdown) results in a loss of RPS trip capability (i.e., one or two channels inoperable in one or both Trip Functions). This change is an additional restriction on plant operation necessary to achieve consistency with the ISTS.

M.7 Deleted.

M.8 For the APRM High Flux (Reduced) Trip Function, an additional Frequency for performance of an Instrument Functional Test is provided in proposed Table 4.1.1. Currently, the Instrument Functional Test of this Trip Function is required to be performed before each startup with a Frequency that need not exceed weekly and weekly during Refueling. The additional Frequency to be provided for this Trip Function is "Every 7 Days During Each STARTUP/HOT STANDBY."

This additional restriction ensures that the instrumentation is maintained operable in the Mode of applicability. In addition, for consistency and accuracy, the "weekly" Frequencies for prior to startup and during refueling are being changed to "within 7 days before entering STARTUP/HOT STANDBY' and "every 7 days during REFUELING," respectively. These changes are consistent with the ISTS.

M.9 In CTS Table 4.1.2, the current Calibration Frequency for the First Stage Turbine Pressure Permissive is "Every 6 Months and After Refueling." In proposed Table 4.1.1, the Calibration Frequency of the First Stage Turbine Pressure Permissive is "Every 6 months and prior to entering STARTUP/HOT STANDBY for plant startup after Refueling." Specifying the time period to complete the Calibration after Refueling represents an additional restriction on plant operation necessary to ensure that the permissive is calibrated in a timely manner prior to startup after Refueling.

M.10 Deleted.

M.11 CTS Table 4.1.2 only includes explicit requirements to calibrate APRM trip units.

Proposed Table 4.1.1 requires calibration of the trip units of the following additional Trip Functions every 3 months: High Reactor Pressure (proposed Table 4.1.1 Trip Function 5); High Drywell Pressure (proposed Table 4.1.1 Trip Function 6); Reactor Low Water Level (proposed Table 4.1.1 Trip Function 7);

and Scram Discharge Volume High Level (proposed Table 4.1.1 Trip Function 8).

The trip units of these Trip Functions are currently required by CTS Table 4.1.2 to be calibrated with the rest of the associated instrument loops once per operating cycle. Therefore, this change is more restrictive. This change is Page 2 of 13

More Restrictive Changes necessary to ensure consistency with assumptions regarding trip unit calibration frequency used in the associated setpoint calculations.

TS 3.2.AJ4.2.A - EMERGENCY CORE COOLING SYSTEM INSTRUMENTATION M.1 CTS Table 3.2.1 Note 9 provides an allowance to delay entry into actions for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the situation of a channel inoperable solely for performance of surveillances regardless of whether ECCS initiation capability is maintained. This note is applied to the Core Spray Pump Start Time Delay, the Low Pressure Coolant Injection (LPCI) Reactor Vessel Shroud Level and the LPCI Pump Start Time Delay Trip Functions of Table 3.2.1. In proposed SR 4.2.A.1, for these Trip Functions, the allowance to delay entry into actions for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is revised to require that the allowance only be used when the redundant Trip Function maintains ECCS initiation capability. This represents an additional restriction on plant operation necessary to maintain consistency with the basis for the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance, i.e., NEDC-30936-P-A, "BWR Owners' Group Technical Specification Improvement Analyses for ECCS Actuation Instrumentation, Part 2," December 1988. This change is consistent with the ISTS.

M.2 CTS Table 3.2.1 Note 10 provides actions for inoperable channels for Cor~ Spray and LPC!. These actions allow the inoperable channel to be tripped, rather than requiring the channel to be restored to operable status. Note 10 is applied to the Core Spray Auxiliary Power Monitor (LNPX C/O), Core Spray Pump Bus Power Monitor (27/3AJB, 27/4AJB), the LPCI Auxiliary Power Monitor (LNPX C/O), and the LPCI Pump Bus Power Monitor (27/3AJB, 27/4AJB). These Power Monitor Trip Functions act as perrnissives for the Core Spray and LPCI Pump Start Delay Functions. As such, placing these Power Monitor Trip Function channels in trip (as allowed by Note 1O.B) does not necessarily result in a safe state for the channel in all events and could result in overloading the diesel generators during load sequencing. Therefore, the actions for inoperable channels of these Power Monitor Trip Functions are revised, in proposed Table 3.2.1 Action Note 2, to require that they be restored to operable status rather than being placed in trip.

This change represents an additional restriction on plant operation and is consistent with the ISTS (i.e., inoperable permissives are required to be restored to operable status rather than placed in trip).

M.3 CTS Table 3.2.1 Note 12 provides actions for inoperable actuation timer channels for Core Spray and LPC!. These actions allow the inoperable channel to be tripped, rather than requiring the channel to be restored to operable status. The subject channels are associated with Time Delay Trip Functions. As such, placing these Time Delay Trip Functions channels in trip (as allowed by Note 12.B) does not perform the intended function (providing a time delay for actuation after certain conditions are satisfied) and could adversely impact the capability of safety systems to perform their intended functions. Therefore, the actions for inoperable channels of these Time Delay Trip Functions are revised, in proposed Table 3.2.1 Action Note 2, to require that they be restored to operable status rather than being placed in trip. This change represents an additional restriction on plant operation and is consistent with the ISTS (i.e., inoperable time delays are required to be restored to operable status rather than placed in trip).

Page 3 of 13

More Restrictive Changes MA Deleted.

M.5 CTS Table 4.2.1 does not include explicit requirements to calibrate trip units.

Proposed Table 4.2.1 requires calibration of the trip units of the following Trip Functions every 3 months: Core Spray High Drywell Pressure (proposed Table 4.2.1 Trip Function 1.a); Core Spray Low-Low Reactor Vessel Water Level (proposed Table 4.2.1 Trip Function 1.b); Core Spray Low Reactor Pressure (proposed Table 4.2.1 Trip Functions 1.c and 1.d); LPCI Low Reactor Pressure (proposed Table 4.2.1 Trip Functions 2.a and 2 h); LPCI High Drywell Pressure (proposed Table 4.2.1 Trip Functions 2.b and2.g); LPCI Low-Low Reactor Vessel Water Level (proposed Table 4.2.1 Trip Function 2.c); LPCI Reactor Vessel Shroud Level (proposed Table 4.2.1 Trip Function 2.d); HPCI Low-Low Reactor Vessel Water Level (proposed Table 4.2.1 Trip Function 3.a); HPCI High Drywell Pressure (proposed Table 4.2.1 Trip Function 3.c); HPCI High Reactor Vessel Water Level (proposed Table 4.2.1 Trip Function 3.d); ADS Low-Low Reactor Vessel Water Level (proposed Table 4.2.1 Trip Function 4.a); and ADS High Drywell Pressure (proposed Table 4.2.1 Trip Function 4.b). The trip units of these Trip Functions are currently required by CTS Table 4.2.1 to be calibrated with the rest of the associated instrument loops once per operating cycle.

Therefore, this change is more restrictive. This change is necessary to ensure consistency with assumptions regarding trip unit calibration frequency used in the associated setpoint calculations. This change is consistent with the ISTS.

M.6 CTS Table 3.2.1 specifies for the Low Condensate Storage Tank Water Level Trip Function that the Trip Setting be> 3%. The function of the Low Condensate Storage Tank Water Level is to provide an automatic transfer of the HPCI suction source from the condensate storage tank to the suppression pool when the level in the condensate storage tank is no longer sufficient to support adequate HPCI pump suction head. The CTS Trip Setting has been determined to be insufficient to ensure that transfer of the HPCI System suction from the condensate storage tank to the suppression pool occurs prior to potential vortex formation at the HPCI suction inlet in the condensate storage tank. Therefore, 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 the potential for vortex formation. This minimum level corresponds to the Process Limit used in the associated setpoint calculation. To account for instrument uncertainties, the instrument setpoint and as-found tolerance (i.e.,

instrument operability limit) were developed using the Vermont Yankee Instrument Uncertainty and Setpoints Design Guide. Footnote (d) in proposed Table 3.2.1 clarifies that the trip setting is specified in terms of percent instrument span. The instrument setpoint and as-found tolerance are located in plant procedures. This change represents an additional restriction on plant operation necessary to ensure that HPCI System operability is maintained when aligned to the condensate storage tank and that HPCI pump suction transfer to the suppression pool occurs prior to the vortex formation.

M.7 CTS Table 3.2.1 requires 2 channels per trip system for Core Spray Pump Discharge Pressure (proposed Trip Function 1 f). As described in the proposed Bases, the two Core Spray Pump A discharge pressure channels feed ADS trip Page 4 of 13

More Restrictive Changes system A, and the two Core Spray Pump B discharge pressure channels feed ADS trip system B. Therefore, in order to provide redundancy, both channels for each pump must be operable. The number of required channels per trip system for Trip Function 1.f is being changed from "2" to "2 per pump." This matches the current requirement for LPCI Pump Discharge Pressure (proposed Trip Function 2.f). This change is consistent with the ISTS.

M.8 RAI response number 7 in supplement 2 (ML082660371) dated 9/15/08 and RAI response numbers 1 and 5 in supplement 4 (ML083540188) dated 12/15/08 add Note (e) to Trip Function 1.a and 1.b of Table 3.2.1. Note (e) states that these functions are required to initiate the emergency diesel generators when core spray is required to be operable per specification 3.5. The CTS do not contain these notes. This information is found in the UFSAR, under Section 6.3. This change is consistent with the ISTS. DOC M.8 is not found in the original submittal, but is created to discuss changes submitted under supplements 2 and

4.

TS: 3.2.B/4.2.B - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION M.1 CTS Table 3.2.1 includes a Low Pressure Coolant Injection System - Low Reactor Pressure Trip Function (PS-2-128A & B). The purpose of this trip function is to provide isolation of the shutdown cooling portion of the Residual Heat Removal (RHR) System to protect that system from overpressurization due to high reactor pressure. This isolation provides for equipment protection to prevent an intersystem LOCA scenario. The associated action for this Trip Function, in the event the instrumentation is inoperable and not restored within the allowed time period, in CTS Table 3.2.1 Note 10, requires that the associated systems be declared inoperable. Continued operation in this condition is then allowed for a limited duration in accordance the associated system TS. However, the TS actions for Low Pressure Coolant Injection System inoperabilities do not require that overpressure protection of the RHR System be provided. Therefore, in the same condition, proposed Table 3.2.2 Action Notes 1.b.1 and 2.d will require, respectively, that the isolation capability be restored and that the associated penetration be isolated within one hour, thus restoring overpressure protection for the RHR System. This change represents an additional restriction on plant operation necessary to provide overpressure protection to prevent an intersystem LOCA scenario. The change is consistent with the ISTS.

M.2 CTS Table 3.2.2 provides requirements for the Primary Containment Isolation Instrumentation - High Main Steam Line Area Temperature Trip Function. CTS Table 3.2.2 specifies that, for this trip function, the minimum number of operable instrumentation channels per trip system is 2 of 4 in each of 2 channels. There are 2 trip systems for this trip function, each with 2 channels. As such, the CTS require that only 2 temperature sensor inputs (out of 4) per channel be operable per trip system. Therefore, the total number of temperature sensors required to be operable by CTS Table 3.2.2 is 8 (Le., 2/channel x 2 channels/trip system x 2 trip systems). The temperature sensor arrangement in the channels is such that each of the 4 sensors in a channel monitors temperature of a different area of the main steam lines. This arrangement, when combined with the CTS allowance for Page 5 of 13

More Restrictive Changes any two sensors in one or more logic channels to be inoperable without affecting compliance with the Limiting Conditions for Operation, results in the possibility for a loss of isolation capability for a leak in a specific main steam line area.

Therefore, the required number of operable channels per trip system for the High Main Steam Line Area Temperature Trip Function (proposed Table 3.2.2 Trip Function 1.b) is revised to 8 per trip system (for a total number of temperature sensors required to be operable of 16). This change represents an additional restriction on plant operation to ensure adequate temperature monitoring of the main steam line areas is provided.

M.3 CTS 3.2.8 requires that the Primary Containment Isolation Instrumentation High Main Steam Line Area Temperature Trip Function (proposed Table 3.2.2 Trip Function 1.b) and the High Main Steam Line Flow (DPT-2-(116-119) (A-D) (M))

Trip Function (proposed Table 3.2.2 Trip Function 1.c) be operable in Run, Startup/Hot Standby, Hot Shutdown, and Refuel (with reactor coolant water temperature> 212°F) Modes and that the Primary Containment Isolation Instrumentation High Main Steam Line Flow(DPT-2-116A, 1178, 118C, 1190 (S1)) Trip Function (proposed Table 3.2.2 Trip Function 1.e) be operable in Startup/Hot Standby, Hot Shutdown, and Refuel (with reactor coolant water temperature> 212°F) Modes. In the event minimum conditions for operation are not satisfied for these trip functions, CTS Table 3.2.2 requires compliance with CTS Table 3.2.2 Note 2.8. CTS Table 3.2.2 Note 2.8 requires an orderly load reduction to be initiated and to the have the reactor in Hot Standby within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

However, this action does not result in satisfying the isolation function of the inoperable instrumentation. Nor does this action result in placing the reactor in a Mode in which the instrumentation is not required to be operable to provide isolation. As a result, CTS would allow continued operation with the isolation function of this instrumentation not maintained. Therefore, proposed Table 3.2.2 Action Note 2.a will require, in the same condition, the associated main steam line to be isolated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (which satisfies the isolation function of the inoperable instrumentation) or that the reactor be placed in Hot Shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in Cold Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (which places the reactor in a Mode in which the instrumentation is not required to be operable). The time period specified for exiting the Modes of Applicability are consistent with times to reach the same Modes provided in other VYNPS TS. This change represents an additional restriction on plant operation necessary to ensure that either the isolation function of the inoperable instrumentation is satisfied or that the reactor is placed in a Mode in which the instrumentation is not required to function to provide isolation. The change is consistent with the ISTS.

M.4 CTS Table 3.2.2 Note 3 effectively specifies actions to isolate the affected penetration flow path (Le., close isolation valves in the system) but does not state the time period in which this action is to be completed. Proposed Table 3.2.2 Action Note 2.d provides a one hour time period in which to complete the action of isolating the affected penetration flow. Placing a limitation on the time allowed to complete the associated actions represents an additional restriction on plant operation since the time period allowed to complete the isolation will be controlled through TS. This change is consistent with the ISTS.

M.5 CTS Table 3.2.2 Note 13.8 provides actions for inoperable time delay channels for HPCI and RCIC Isolation instrumentation. These actions allow the inoperable Page 6 of 13

More Restrictive Changes channel to be tripped, rather than requiring the channel to be restored to operable status. The subject channels are associated with Time Delay Trip Functions. As such, placing these Time Delay Trip Functions channels in trip (as allowed by Note 13.8) does not perform the intended function (providing a time delay for isolation after certain conditions are satisfied) and could adversely impact the capability of the HPCI or RCIC Systems to perform their intended functions.

Therefore, the actions for inoperable channels of these Time Delay Trip Functions (proposed Table 3.2.2 Trip Functions 3.e, HPCI System Isolation High Main Steam Line Tunnel Temperature Time Delay, 4.b, RCIC System Isolation - High Main Steam Line Tunnel Temperature Time Delay, and 4.e, RCIC System Isolation - High Steam Line dip Time Delay) are revised, in proposed Table 3.2.2 Action Note 1.a.2), to require that they be restored to operable status rather than being placed in trip. This change represents an additional restriction on plant operation and is consistent with the ISTS (Le.,

inoperable time delays are required to be restored to operable status rather than placed in trip).

M.6 CTS Table 4.2.2 does not include explicit requirements to calibrate trip units.

Proposed Table 4.2.2 requires calibration of the trip units of the following Trip Functions every 3 months: Main Steam Line Isolation - Low-Low Reactor Vessel Water Level (proposed Table 4.2.2 Trip Function 1.a); Main Steam Line Isolation

- High Steam Line Flow (proposed Table 4.2.2 Trip Function 1.c); Main Steam Line Isolation - High Steam Line Flow-Not in Run (proposed Table 4.2.2 Trip Function 1.e); Primary Containment Isolation - Low Reactor Vessel Water Level (proposed Table 4.2.2 Trip Function 2.a); and Primary Containment Isolation High Drywell Pressure (proposed Table 4.2.2 Trip Function 2.b). The trip units of these Trip Functions are currently required by CTS Table 4.2.2 to be calibrated with the rest of the associated instrument loops once per operating cycle.

Therefore, this change is more restrictive. This change is necessary to ensure consistency with assumptions regarding trip unit calibration frequency used in the associated setpoint calculations. This change is consistent with the ISTS.

M.7 CTS Table 3.2.2 specifies for the Primary Containment Isolation High Main Steam Line Area Temperature, the HPCI System Isolation High Steam Line Space Temperature, the HPCI System Isolation Main Steam Line Tunnel Temperature, the RCIC System Isolation Main Steam Line Tunnel Temperature, and the RCIC System High Steam Line Space Temperature Trip Functions that the Trip Settings be < 212°F. The function of these instruments is to provide isolation in the event of breaks in the associated steam lines. The CTS Trip Settings have been determined to be insufficient to ensure isolation occurs as assumed in the high energy line break and Equipment Qualification (EQ)

Program analyses. Therefore, in proposed Table 3.2.2, the Trip Setting for the Primary Containment Isolation High Main Steam Line Temperature Area Temperature Trip Function (Trip Function 1.b) has been decreased to < 196°F for channels monitoring outside the steam tunnel and < 200°F for channels monitoring inside the steam tunnel; the Trip Settings for the HPCI System Isolation and RCIC System Isolation High Steam Line Space Temperature Trip Functions (Trip Functions 3.a and 4.c, respectively) have been decreased to <

196°F; and the Trip Settings for the HPCI System Isolation and RCIC System Isolation Main Steam Line Tunnel Temperature Trip Functions (Trip Functions 3.d and 4.a, respectively) have been decreased to < 200°F. These revised Trip Page 7 of 13

More Restrictive Changes Settings are consistent the assumptions of the high energy line break and EO Program analyses and correspond to the Analytical Limit used in the associated setpoint calculations. To account for instrument uncertainties, the instrument setpoints and as-found tolerances (Le., instrument operability limits) were developed using the Vermont Yankee Instrument Uncertainty and Setpoints Design Guide. The instrument setpoints and as-found tolerances are located in plant procedures. This change represents an additional restriction on plant operation necessary to ensure that isolation of the associated steam lines occurs as assumed in analyses.

TS: 3.2.C/4.2.C - REACTOR BUILDING VENTILATION ISOLATION AND STANDBY GAS TREATMENT SYSTEM INITIATION INSTRUMENTATION M.1 CTS Table 3.2.3 Note 1 provides actions to isolate the Reactor Building Ventilation System and operate the Standby Gas Treatment System but does not state the time period in which these actions are to be completed. Proposed Table 3.2.3 Action Note 1 provides a one hour time period in which to complete the action of isolating the Reactor Building Ventilation System and placing the Standby Gas Treatment System in operation. Placing a limitation on the time allowed to complete the associated actions represents an additional restriction on plant operation since the time period allowed to complete the isolation will be controlled through TS. This change is consistent with the ISTS.

M.2 CTS Table 4.2.3 does not include explicit requirements to calibrate trip units.

Proposed Table 4.2.3 requires calibration of the trip units of the following Trip Functions every 3 months: Low Reactor Vessel Water Level (proposed Table 4.2.3 Trip Function 1) and High Drywell Pressure (proposed Table 4.2.3 Trip Function 2). The trip units of these Trip Functions are currently required by CTS Table 4.2.3 to be calibrated with the rest of the associated instrument loops once per operating cycle. Therefore, this change is more restrictive. This change is necessary to ensure consistency with assumptions regarding trip unit calibration frequency used in the associated setpoint calculations. This change is consistent with the ISTS.

TS: 3.2.0/4.2.0 - OFF-GAS SYSTEM ISOLATION INSTRUMENTATION None TS 3.2.E/4.2.E - CONTROL ROD BLOCK INSTRUMENTATION M.1 CTS Table 4.2 Note 12 applies to the Reactor Mode Switch - Shutdown Position Trip Function. This note allows the Functional Test of the Reactor Mode Switch Shutdown Position Trip Function to be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after the reactor mode switch is placed in shutdown. This note does not include a time limit on completion of the Functional Test. Since testing of this Trip Function with the reactor mode switch in any other position cannot be performed without using jumpers, lifted leads, or movable links, the intent of this allowance is to ensure the required Functional Test is completed in a timely manner as soon as plant Page 8 of 13

More Restrictive Changes conditions exist to perform the test. Therefore, in proposed Table 4.2.5 Footnote (a), the allowance is revised by requiring the Functional Test of this Trip Function to be performed (Le., completed) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after the reactor mode switch is placed in the shutdown position. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowance continues to provide a reasonable time in which to complete the required Functional Test. This change represents an additional restriction on plant operation necessary to ensure that the Functional Test is satisfactorily completed in a timely manner. The change is consistent with the ISTS.

TS 3.2.F/4.2.F - MECHANICAL VACUUM PUMP ISOLATION INSTRUMENTATION M.1 CTS 3.2.F.1 provides actions for one or more mechanical vacuum pump isolation instrumentation channels inoperable. These actions provide 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to restore the inoperable channel(s) or place them or their associated trip system in the trip condition. Proposed TS 3.2.F.2 is revised to address the condition of multiple, inoperable, untripped mechanical vacuum pump isolation instrumentation channels that result in the High Main Steam Line Radiation Trip Function not maintaining mechanical vacuum pump isolation capability. The proposed change will eliminate the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed outage time for this condition. In this condition (Le., loss of mechanical vacuum pump isolation capability), continued operation in accordance with the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed outage time is not appropriate, nor consistent with the applicable analyses of NEDC-30851 P-A, Supplement 2, "Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation." This change is an additional restriction on plant operation necessary to achieve consistency with applicable analyses.

TS: 3.2.G/4.2.G - POST ACCIDENT MONITORING INSTRUMENTATION None TS: 3.2.H/4.2.H - DRYWELL TO TORUS ~P INSTRUMENTATION None TS 3.2.//4.2.1-RECIRCULATION PUMP TRIP INSTRUMENTATION M.1 CTS Table 3.2.1 Note 19.A provides actions for the condition of a loss of recirculation pump trip capability from all recirculation pump trip instrumentation trip functions, except Trip System Logic. In the event all applicable recirculation pump trip instrumentation trip functions lose trip capability, CTS Table 3.2.1 Note 19.A only requires one trip function to be restored within one hour. The intent of this action was to ensure that in the event of a loss of recirculation pump trip capability from both the low reactor vessel water level function and the high reactor pressure function, recirculation pump trip capability for at least one of these two functions would be restored within one hour to support continued operation in that condition for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . However, CTS Table 3.2.1 includes a Page 9 of 13

More Restrictive Changes Low - Low Reactor Vessel Water Level Trip Function (proposed Table 3.2.1 Trip Function 1); a Time Delay Trip Function (proposed Table 3.2.1 Trip Function 2),

which supports the operability of the Low - Low Reactor Vessel Water Level Trip Function; and High Reactor Pressure Trip Function (proposed Trip Function 3) for which CTS Table Note 19 is applicable. As a result, if all three applicable Trip Functions lose trip capability and only one Trip Function is restored, it is still possible that a loss of recirculation pump trip capability would exist for both the low reactor vessel water level function and the high drywell pressure function (e.g., in the case where only trip capability of the Time Delay Trip Function is restored) and operation would be allowed to continue for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in this condition. Therefore, in the event all applicable recirculation pump trip instrumentation trip functions lose trip capability, CTS Table 3.2.1 Note 19.A (proposed Table 3.2.7 Action Note 1.c) is revised to require restoration of trip capability for all but one Trip Function within one hour. A corresponding change is also made to CTS Table 3.2. 'I Note 19.C. CTS Table 3.2.1 Note 19.C states "Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from discovery of one trip function capability not maintained..."

The CTS Table 3.2.1 Note 19.C reference to "one trip function capability not maintained" is changed to "Trip Functions 1 and 2 with recirculation pump trip capability not maintained or Trip Function 3 with recirculation pump trip capability not maintained" in proposed Table 3.2.7 Action Note 1.b. This change represents an additional restriction on plant operation to ensure continued operation with a loss of recirculation pump trip capability from both the low reactor vessel water level and high reactor pressure functions is not allowed for longer than one hour.

The change is consistent with the intent of the ISTS (the ISTS does not include a time delay for this type of recirculation pump trip instrumentation).

M.2 CTS Table 3.2.1 Note 19.6 requires inoperable recirculation pump trip instrumentation channels to be restored or placed in the tripped condition.

Proposed Table 3.2.7 Action Note 1.a provides the same alternative actions as CTS Table 3.2. 'I Note 19.6 but includes a limitation on the use of the action to place the inoperable channels in trip. Proposed Table 3.2.7 Action Note 1.a precludes the use of the action to trip the inoperable channel if the inoperability is associated with Trip Function 2 (Le., Time Delay) channels or if the inoperability is the result of an inoperable recirculation pump trip breaker. These restrictions are added since (1) placing the Time Delay Trip Function channels in trip (as allowed by CTS Table 3.2.1 Note 19.6) does not perform the intended function (providing a time delay for actuation after certain conditions are satisfied) and could make the consequences of a postulated LOCA more severe, and (2) with the channels inoperable due to an inoperable breaker, tripping the affected channels may not adequately compensate for the inoperable breaker (e.g., the breaker may be inoperable such that it will not open). This change represents an additional restriction on plant operation by requiring the channels in these conditions to be restored to operable status rather than tripped. The change is consistent with the ISTS.

M.3 CTS Table 4.2.1 does not include explicit requirements to calibrate trip units.

Proposed Table 4.2.7 requires calibration of the trip units of the following Trip Functions every 3 months: Low - Low Reactor Vessel Water Level (proposed Table 4.2.7 Trip Function 1) and High Reactor Pressure (proposed Table 4.2.7 Trip Function 3). The trip units of these Trip Functions are currently required by Page 10 of 13

More Restrictive Changes CTS Table 4.2.1 to be calibrated with the rest of the associated instrument loops once per operating cycle. Therefore, this change is more restrictive. This change is necessary to ensure consistency with assumptions regarding trip unit calibration frequency used in the associated setpoint calculations. This change is consistent with the ISTS.

MA CTS Table 4.2.1 requires a Functional Test of the recirculation pump trip instrumentation Trip System Logic. The CTS definition of Logic System Functional Test (CTS 1.0.H) requires where possible for the action during the test to go to completion and actuate the end device (i.e., pumps will be started and valves will be opened). For the recirculation pump trip instrumentation, actuation of the end device would require actuation of the recirculation pump trip breakers.

In proposed SR 4.2.1.2 (encompassing the CTS Table 4.2.1 requirement to perform functional tests of the Trip System Logic), the Logic System Functional Test of the recirculation pump trip instrumentation Trip Functions explicitly requires the actuation of the recirculation pump trip breakers to be included in the test. This change represents an additional restriction on plant operation necessary to ensure complete testing of the safety function. This change is consistent with the ISTS.

M.5 CTS Table 4.2.1 includes a requirement to perform a calibration of Recirculation Pump Trip Instrumentation Trip System Logic once per Operating Cycle. Similar to other calibration requirements of Trip System Logic in the VYNPS CTS, the intent of this requirement is to perform a calibration of time delay relays necessary for proper functioning of the trip system once per Operating Cycle. In proposed Table 4.2.7, this requirement is made more restrictive and is reflected with explicit requirements to perform calibrations of the reqUired Recirculation Pump Trip Instrumentation time delay relays (i.e., proposed Table 4.2.7 Trip Function 2, Time Delay) "Every 3 Months." This change is necessary to ensure consistency with assumptions regarding the calibration frequency of these time delays used in the associated setpoint calculations.

TS 3.2.K14.2.K - DEGRADED GRID PROTECTIVE SYSTEM INSTRUMENTATION M.1 CTS 3.2.K requires the Degraded Grid Protective System instrumentation to be operable only during reactor power operation. In proposed Table 3.2.8, the Applicability of the Degraded Grid Protective instrumentation Trip Functions is expanded in Footnote (a) to, "When the associated diesel generator is required to be operable per specifications 3.5,3.7, and 3.10." The VYNPS CTS Applicability for diesel generators, which are supported by the Degraded Grid Protective instrumentation, includes more than just "during power operation." For example, CTS 3.5.HA (which provides low pressure Emergency Core Cooling System (ECCS) requirements) requires a diesel generator to be operable during Refuel or Cold Shutdown when operations with the potential for draining the reactor vessel are being performed and CTS 3.7.B.1.b (which provides Standby Gas Treatment System requirements) requires diesel generators to operable under certain conditions during Refuel or Cold Shutdown when secondary containment integrity is required. This change represents an additional restriction on plant operation necessary to ensure that the ECCS and other assumed systems powered by the diesel generators remain capable of providing Page 11 of 13

More Restrictive Changes plant protection during the conditions when the diesel generators are required to be operable.

TS 3.2.Ll4.2.L - REACTOR CORE ISOLATION COOLING SYSTEM INSTRUMENTATION M.1 CTS Table 4.2.9 does not include explicit requirements to calibrate trip units.

Proposed Table 4.2.9 requires calibration of the trip units of the following Trip Functions every 3 months: Low-Low Reactor Vessel Water Level (proposed Table 4.2.9 Trip Function 1), Low Condensate Storage Tank Water Level (proposed Table 4.2.9 Trip Function 2), and High Reactor Vessel Water Level (proposed Table 4.2.9 Trip Function 3). The trip units of these Trip Functions are currently required by CTS Table 4.2.9 to be calibrated with the rest of the associated instrument loops once per operating cycle. Therefore, this change is more restrictive. This change is necessary to ensure consistency with assumptions regarding trip unit calibration frequency used in the associated setpoint calculations. This change is consistent with the ISTS.

M.2 CTS Table 3.2.9 specifies for the Low Condensate Storage Tank Water Level Trip Function that the Trip Setting be > 3%. The function of the Low Condensate Storage Tank Water Level is to provide an automatic transfer of the RCIC suction source from the condensate storage tank to the suppression pool when the level in the condensate storage tank is no longer sufficient to support adequate RCIC pump suction head. The CTS Trip Setting has been determined to be insufficient to ensure that transfer of the RCIC System suction from the condensate storage tank to the suppression pool occurs prior to potential vortex formation at the RCIC suction inlet in the condensate storage tank. Therefore, in proposed Table 3.2.9.

the Trip Setting for the Low Condensate Storage Tank Water Level Trip Function (Trip Function 2) has been increased to > 3.81 % to account for the additional water level needed to preclude the potential for vortex formation. This minimum level corresponds to the Process Limit used in the associated setpoint calculation. To account for instrument uncertainties, the instrument setpoint and as-found tolerance (i.e., instrument operability limit) were developed using the Vermont Yankee Instrument Uncertainty and Setpoints' Design Guide. Footnote (b) in proposed Table 3.2.9 clarifies that the trip setting is specified in terms of percent instrument span. The instrument setpoint and as-found tolerance are located in plant procedures. This change represents an additional restriction on plant operation necessary to ensure that RCIC System operability is maintained when aligned to the condensate storage tank and that RCIC pump suction transfer to the suppression pool occurs prior to the vortex formation.

M.3 CTS Table 3.2.9 contains a column labeled "Minimum Number of Operable Instrument Channels per Trip System." For the Low-Low Reactor Vessel Water Level Trip Function, this value is listed as 2, with amplifying information provided in Notes 1 and 5. Note 1 states that there is one trip system with initiating instrumentation arranged in a one-out-of-two taken twice logic. This note implies that there are a total of 4 instrument channels, and that all of them must be operable in order for the logic system to be single failure proof. In order to clarify this requirement. the column in proposed Table 3.2.9 is labeled "Required Channels per Function," and the value for the Low-Low Reactor Vessel Water Page 12 of 13

More Restrictive Changes Level Trip Function is listed as 4. This change will ensure that the logic system will be able to withstand a single failure and still perform its intended function and that appropriate actions are taken for instrument channel inoperabilities.

TS 3.5/4.5 - CORE AND CONTAINMENT COOLING SYSTEMS None Page 13 of 13 Relocated Specifications

Relocated Specifications TS 1.0 - DEFINITIONS, TS 2.1 LIMITING SAFETY SYSTEM SETTINGS, TS 3.1/4.1 REACTOR PROTECTION SYSTEM II\\JSTRUIVIEI\\JTATION None TS 3.2.A14.2.A - EMERGENCY CORE COOLING SYSTEM INSTRUMENTATION R.1 The CTS Table 3.2.1 LPCI Time Delay (1 OA-K72A & B) Trip Function and associated requirements are to be relocated. The function of the subject LPCI Time Delay Trip Function is to preclude the Residual Heat Removal Heat Exchanger (RHR) Bypass Valve from being manually closed during a LOCA until a specified amount of time has passed. This ensures that the maximum amount of LPCI flow reaches the reactor vessel during a LOCA. While this instrumentation provides added assurance of LPCI flow under certain conditions, it is not assumed to mitigate any design basis accident (DBA) or transient. In addition, there are many other instances where the operator must reduce or secure LPCI flow, and may do so by other means that are not interlocked (e.g.,

securing the RHR pump). The CTS requirements for the LPCI Time Delay Trip Function associated with the RHR Bypass Valve Time Delay do not meet any of the Technical Specification criteria of 10CFR50.36(c)(2)(ii) and are to be relocated the Technical Requirements Manual (TRM). Changes to the TRM are controlled by the provisions of 10 CFR 50.59.

R.2 The CTS Table 3.2.1 LPCI Time Delay (1 OA-K45A & B) Trip Function and associated requirements are to be relocated. The function of the subject LPCI Time Delay Trip Function is to ensure that the outboard LPCI injection valves are fully opened to ensure full flow to the reactor vessel, prior to allowing the operator to manually divert full flow for other post-accident purposes. While this instrumentation provides added assurance of full LPCI flow to the reactor vessel under certain conditions, these instruments are not credited in any DBA or transient. The CTS requirements for the LPCI Time Delay Trip Function associated with the LPCI Outboard Injection Valve Time Delay do not meet any of the Technical Specification criteria of 10CFR50.36(c)(2)(ii) and are to be relocated the Technical Requirements Manual (TRM). Changes to the TRM are controlled by the provisions of 10 CFR 50.59.

TS: 3.2.B/4.2.B - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION None TS: 3.2.C/4.2.C - REACTOR BUILDING VENTILATION ISOLATION AND STANDBY GAS TREATMENT SYSTEM INITIATION INSTRUMENTATION None Page 1 of 4

Relocated Specifications TS: 3.2.0/4.2.0 - OFF-GAS SYSTEM ISOLATION INSTRUMENTATION R1 The radioactive off-gas processing system is not a safety system and is not connected to the primary coolant piping. The off-gas isolation instrumentation is used to ensure conformance with the discharge limits of 10 CFR 20. There is another Specification (Specification 3.8.K/4.8.K, Steam Jet Air Ejector) that ensures 10 CFR 100 limits are not exceeded in the event of a failure of the radioactive off-gas processing system. Information provided by this instrumentation on radiation levels would be of limited or no use in identifying/assessing core damage in the event of an accident, and it is not installed to detect excessive reactor coolant leakage. The Off-Gas System Isolation Instrumentation LCO, Actions, Surveillances and Notes will be relocated to the Technical Requirements Manual. Changes to the Technical Requirements Manual are controlled using 10 CFR 50.59.

TS 3.2.E/4.2.E - CONTROL ROD BLOCK INSTRUMENTATION None TS 3.2.F/4.2.F - MECHANICAL VACUUM PUMP ISOLATION INSTRUMENTATION None TS: 3.2.G/4.2.G - POST ACCIDENT MONITORING INSTRUMENTATION R1 Each individual post-accident monitoring parameter has a specific purpose; however, the general purpose for accident monitoring instrumentation is to provide sufficient information to confirm an accident is proceeding per prediction, i.e. automatic safety systems are performing properly, and deviations from expected accident course are minimal.

The NRC position on application of the deterministic screening criteria to post accident monitoring instrumentation is documented in letter dated May 7, 1988 from T.E. Murley (NRC) to RF. Janecek (BWROG). The position was that the post-accident monitoring instrumentation table list should contain, on a plant specific basis, all Regulatory Guide 1.97 Type A instruments specified in the plant's Safety Evaluation Report (SER) on Regulatory Guide 1.97, and all Regulatory Guide 1.97 Category 1 instruments. Accordingly, this position has been applied to the VYNPS Regulatory Guide 1.97 instruments. Those instruments meeting these criteria have remained in Technical Specifications.

The instruments not meeting these criteria have been relocated from the Technical Specifications to plant controlled documents.

The following summarizes the VYNPS position for those instruments currently in Technical Specifications.

From NRC SER dated December 4, 1990,

Subject:

Conformance to Regulatory Guide 1.97 for Vermont Yankee Nuclear Power Station:

Page 2 of 4

Relocated Specifications Type A Variables

1. Reactor Pressure

2. Reactor Vessel Level

3. Drywell Pressure

4. Drywell Temperature

5. Torus Pressure

6. Torus Water Temperature

7. Torus Water Level

8. Torus Airspace Temperature From Regulatory Guide 1.97 and VYNPS submittal to the NRC dated October 30, 1984, and NUREG-0737, Supplement 1 - Regulatory Guide 1.97, as modified by VYNPS letters dated October 25, 1985, August 11, 1987, July 28, 1988, September 1, 1989, and March 29, 1996, and NRC letter dated April 29, 1993.

Other Type, Category 1 Variables Primary Containment Isolation Valve Position Containment and Drywell Hydrogen Concentration Containment and Drywell Oxygen Concentration Primary Containment High Radiation For other post-accident monitoring instrumentation currently in Technical Specifications, their loss is not risk significant since the variable they monitored did not qualify as a Type A or Category 1 variable (one that is important to safety and needed by the operator, so that the operator can perform necessary normal actions). Since the screening criteria have not been satisfied for non Regulatory Guide 1.97 Type A or Category 1 variable instruments, their associated LCOs and Actions, Surveillance Requirements, and applicable Table 3.2.6 and 4.2.6 Notes may be relocated to the Technical Requirements Manual. Changes to the Technical Requirements Manual are controlled using 10 CFR 50.59. The instruments to be relocated are as follows:

1. Safety/Relief Valve Position from Pressure Switches

2. Safety Valve Position from Acoustic Monitor

3. Stack Noble Gas Effluent This conclusion also supports relocating the surveillance requirements of CTS Table 4.2 Note 9, for the thermocouples that provide back-up position indication for the Main Steam Safety/Relief Valves and Safety Valves, to the Technical Requirements Manual.

TS: 3.2.H/4.2.H - DRYWELL TO TORUS 6P INSTRUMENTATION R.1 The monitored parameter (drywell to torus 6p) is an initial condition of a design basis accident analysis that assumes the failure of a fission product barrier.

Therefore, the limits on this parameter required by TS 3.7.A.9/4.7.A.9 meet criterion for inclusion in TS. However, the instrumentation used to verify Page 3 of 4

Relocated Specifications compliance with these limits does not meet criterion for inclusion. CTS 3.2.H and 4.2.H specify requirements for the drywell to torus 6p instrumentation. This monitoring instrumentation does not necessarily relate directly to maintaining the monitored parameter (drywell to torus 6p) within limits. The ISTS do not specify indication-only equipment to be operable to support operability of a system or component or maintaining variables within limits. Control of the availability of, and necessary compensatory activities if not available, for indication and monitoring instruments are addressed by plant procedures and policies. Therefore, these requirements are to be relocated to the Technical Requirements Manual.

Changes to the Technical Requirements Manual are controlled using 10 CFR 50.59. Not including these requirements in the TS is consistent with the ISTS.

TS 3.2.1/4.2.1-RECIRCULATION PUMP TRIP INSTRUMENTATION None TS 3.2.K14.2.K-DEGRADED GRID PROTECTIVE SYSTEM INSTRUMENTATION None TS 3.2.Ll4.2.L - REACTOR CORE ISOLATION COOLING SYSTEM INSTRUMENTATION None TS 3.5/4.5 - CORE AND CONTAINMENT COOLING SYSTEMS None Page 4 of 4

June 12, 2009 Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354 SUB..IECT:

VERMONT YANKEE NUCLEAR POWER STATION -ISSUANCE OF AMENDMENT RE: INSTRUMENTATION TECHNICAL SPECIFICATIONS (TAC NO. MD8111)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 236 to Facility Operating License DPR-28 for the Vermont Yankee Nuclear Power Station, in response to your application dated February 12, 2008, as supplemented by letters dated August 28, 2008, September 15, 2008, October 17, 2008, December 15,2008, December 18, 2008 (two letters), April 9, 2009, and May 20,2009.

The amendment would revise Technical Specification (TS) Sections 2.1, "Limiting Safety System Setting," 3.1, "Reactor Protection System," 3.2, "Protective Instrument Systems," associated Surveillance Requirements, and other TS with similar requirements as these instrumentation TS sections.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, IRA!

James Kim, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosures:

1. Amendment No. 236 to License No. DPR-28

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC DJackson, RI JKim ALewin RidsOGCMailCenter Resource SUttle BMarcus GHili (2)

RidsAcrsAcnw_MailCTR Resource RidsRgn1 MailCenter Resource RidsNrrDorlLpl1-1 Resource RidsNrrDirsltsb Resource RidsNrrDeEicb Resource Accession No... ML091410358

'See memos dated OFFICE LPLI-1/PM LPLI-1/LA ITSB/BC EICB/BC OGC/NLO LPLI-1/BC NAME JKim SUttle RElliot' WKemper' LSubin JBoska DATE 06/03/09 06/03/09 112112009 5/12/2009 06/10109 06/12/09 OFFICIAL RECORD COPY

v t e Letter Sequence Approval
TAC:MD8111, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed)
Initiation Request, Request, Request Acceptance... Supplement, Supplement, Supplement, Supplement, Supplement Administration Questions 19 August 2008 Answers Results Approval Other:
MONTHYEAR2008-08-19 [Table View]

ML091410358

Text

Dear Sir or Madam:

Enclosures:

Attachment:

4.2 Applicability

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

Subject:

Dear Sir or Madam:

Enclosures:

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