ML030130037

Technical Specification Proposed Change No. 255 Definition of Logic System Functional Test

ML030130037
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	01/09/2003
From:	Balduzzi M Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 03-04
Download: ML030130037 (26)

Text

Entergy Nuclear Vermont Yankee, LLC Entergy Nuclear Operations, Inc.

185 Old Ferry Road SEntergy Brattleboro, VT 05302-0500 January 9, 2003 BVY 03-04 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

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

Technical Specification Proposed Change No. 255 Definition of Logic System Functional Test Pursuant to 10CFR50.90, Vermont Yankee' (VY) hereby proposes to amend its Facility Operating License, DPR-28, by incorporating the attached proposed change into the VY Technical Specifications. This proposed change revises the definition of a Logic System Functional Test and makes other related changes to the Technical Specifications and Bases.

Attachment 1 to this letter contains supporting information and the safety assessment of the proposed change. Attachment 2 contains the determination of no significant hazards consideration. Attachment 3 provides the marked-up version of the current Technical Specification pages. Attachment 4 is the retyped Technical Specification pages.

VY has reviewed the proposed Technical Specification change in accordance with IOCFR50.92 and concludes that the proposed change does not involve a significant hazards consideration.

VY has also determined that the proposed change satisfies the criteria for a categorical exclusion in accordance with 10CFR51.22(c)(9) and does not require an environmental review. Therefore, pursuant to I OCFR51.22(b), no environmental impact statement or environmental assessment needs to be prepared for this change.

Upon acceptance of this proposed change by the NRC, VY requests that a license amendment be issued no later than 180 days from the date of this letter for implementation within 60 days of its effective date.

Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. are the licensees of the

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(D Vermont Yankee Nuclear Power Station 'ý/ý

BVY 03-04 / Page 2 If you have any questions on this transmittal, please contact Mr. Gautam Sen at (802) 258-4111.

Sincerely, Michael A. Balduzzi Vice President, Operations STATE OF VERMONT

)ss WINDHAM COUNTY Then personally appeared before me, Michael A. Balduzzi, who, being duly sworn, President, Operations of the Vermont Yankee Nuclear Power Station, that he is duly E file the foregoing document, and that the statements therein are true to the best of his kn Salfy A. Satdstrum, Notary Public My Commission Expires February 10, 2003 Attachments cc: USNRC Region 1 Administrator USNRC Resident Inspector - VYNPS USNRC Project Manager - VYNPS Vermont Department of Public Service

Docket No. 50-271 BVY 03-04 Attachment 1 Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 255 Definition of Logic System Functional Test Supporting Information and Safety Assessment of Proposed Change

BVY 03-04 / Attachment 1 / Page 1 INTRODUCTION Description of Change The Proposed Change to the Vermont Yankee Nuclear Power Station (VYNPS) Technical Specifications (TS) revises the definition of a Logic System Functional Test (LSFT) to bring it into agreement with the industry standard contained within NUREG-1433 1 , deletes the definition of a Simulated Automatic Actuation, clarifies a TS Surveillance Requirement (SR) regarding simulated actuation testing, and clarifies TS Bases. The specific changes are as follows:

1. TS Definition 1.0.H (current TS page 1)

Current TS Definition 1.0.11 is as follows:

Log [sic] System Functional Test -. A logic system functional test means a test of all relays and contacts of a logic circuitfrom sensor to activated device to insure all components are operable per design intent. Where possible, action will go to completion, i.e., pumps will be started and valves opened.

Revise TS Definition 1.0.11 to the following:

Logic System Functional Test - A logic system functional test shall be a test of all logic components requiredfor operability of a logic circuit,from as close to the sensor as practicable up to, but not including, the actuated device, to verify operability. The logic system functional test may be performed by means of any series of sequential, overlapping,or total system steps so that the entire logic system is tested.

2. TS Definition 1.0.W (current TS page 4)

The proposed change to TS Definition 1.0.W, "simulated automatic actuation," is to delete this definition from TS.

Current TS 1.0.W is as follows:

Simulated Automatic Actuation - Simulated automatic actuation means applying a simulated signalto the sensorto actuate circuit in question.

3. TS SR 4.5.G.1.a (current TS page 107)

Current TS SR 4.5.G.l.a is as follows:

A simulated automatic actuation test (testing valve operability) of the RCIC system shall be performedduring each refueling outage.

Revise TS SR 4.5.G.1 .a to the following:

1 NUREG-1433, "Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/4)," Revision 2, June 2001

BVY 03-04 / Attachment I I Page 2 A simulated automatic actuation test of the RCIC system shall be performed during each refuelingoutage.

4. Bases to TS 4.2 (current TS page 80a)

Current Bases to TS 4.2 contains the following statements:

Since logic circuit tests result in the actuationofplant equipment, testing of this nature was done while the plant was shut down for refueling. In this way, the testing of equipment would not jeopardizeplant operation.

This Specification is a periodic testing program which is based upon the overall testing of protective instrumentationsystems, including logic circuits as well as sensor circuits. Table 4.2 outlines the test, calibration, and logic system functional test schedule for the protective instrumentationsystems.

Revise the subject Bases to TS 4.2 to the following:

Since logic circuit tests may result in the actuation of plant equipment, testing of this nature is generally performedduring a refueling outage. In this way, the testing of equipment should not jeopardizeplant operation.

These surveillance requirements provide a periodic testing program for protective instrumentationto demonstrate that systems and components function satisfactorily and include schedulesfor performingfunctionaltests, calibrations,andlogic system functional tests.

Purpose of the Change

1. TS Definition 1.0.H The definition of a LSFT is being revised to be consistent with NUREG-1433 and clarify that a LSFT:

a. Involves testing of all logic components required for operability of a logic circuit;

b. Is performed by injecting a signal as close to the sensor as practicable;

c. Excludes testing the actuated device as part of the LSFT; and

d. May be performed as any series of sequential, overlapping, or total system steps such that the entire logic system is tested.

To eliminate ambiguity and unnecessary testing of actuated devices (e.g., pumps and valves) as part of a LSFT, testing of these devices is specifically excluded from the requirements of a LSFT.

In addition, the change in definition of LSFT clarifies that a LSFT need not be performed as a single, integrated test of a logic circuit, but may be performed as a number of discrete tests of logic components, provided the entire logic system is tested.

An administrative error (misspelling of "logic") is also being corrected in the heading of TS definition 1.0.H.

BVY 03-04 / Attachment 1 / Page 3

2. TS Definition 1.0.W The proposed change to TS Definition 1.0.W, "simulated automatic actuation," is to delete this definition from TS because the level of detail provided by the definition does not need to be included in TS.

3. TS SR 4.5.G.1.a The change to TS SR 4.5.G.1.a eliminates the parenthetical expression, "testing valve operability," and any direct or inferred requirement from this TS to perform actual valve performance testing as part of the simulated automatic actuation test of RCIC that is regularly performed during refueling outages. The current provision for "testing valve operability" is unclear as to what valve testing is intended as part of the simulated automatic actuation test. To avoid confusion this Specification is being revised.

4. Bases to TS 4.2 Bases changes are being made to clarify the meaning and intent of SRs for protective instrumentation.

BACKGROUND Logic systems are comprised of detection devices activated by certain physical conditions (e.g., pressure switches, temperature switches, etc.) and decision-making relay networks that will cause a safety system component or device (e.g., pump, valve, etc.) to operate when needed. Each relay in a decision-making logic network has one or more contact pairs associated with it. A LSFT includes all logic components (including relays and contacts) in these decision-making networks to assure that the system will operate as designed upon demand.

LSFTs are complex surveillance tasks which may require numerous temporary alterations and complicated administrative controls. The complexity of the surveillance tests has a significant potential for undesired actuations and operator error which can induce undesirable plant transients. In addition, system redundancy is reduced during the performance of the test. Therefore, LSFTs are best performed during conditions that apply during a plant outage, which reduces the potential for unplanned transients at power.

LSFTs should test for operability of all relays, contacts, trip units and solid-state logic elements from as close to the sensor as practicable up to, but need not include, the actuated device. A LSFT may consist of a single, integrated test, but may also be performed as a series of tests, provided that when combined, the entire logic system is tested. To ensure that no part of the logic is overlooked, the procedures for these partial functional tests ensure that an overlap occurs between where one section of testing ends and the next section begins. Logic testing is typically performed on an once-per-operating cycle, or every refueling outage, basis at VYNPS (except for the reactor protection system).

Simulated automatic actuation tests verify the ability of a system to perform its design automatic initiation function by confirming the proper operation of electrical, electronic, and mechanical components of a system, but not all system components are necessarily tested during the simulated actuation. As part of a LSFT, the simulated automatic actuation tests for certain VYNPS systems (i.e., HPCI, RCIC, LPCI, CS, and ADS) are performed once per operating cycle or during refueling outages.

System functional tests that verify pump and valve operability are performed on a nominal quarterly basis in accordance with the inservice testing program requirements, and the operability of those mechanical

BVY 03-04 / Attachment 1 / Page 4 components is thus demonstrated more frequently. Industry reliability studies for boiling water reactors2 show that overall safety system reliabilities are not dominated by the reliabilities of the logic system, but by the reliabilities of the mechanical components (e.g., pumps and valves). Consequently, pumps and valves are usually tested on a more frequent basis, but need not be tested as part of the LSFT.

VY's surveillance program testing methodology that addresses logic system functional testing of safety related instrumentation was reviewed by NRC staff in support of License Amendment No. 106 (TAC No.

66702), issued on August 9, 1988. Later, to address industry problems in testing of safety-related logic circuits, the NRC staff issued Generic Letter (GL) 96-01, "Testing of Safety-Related Logic Circuits," on January 10, 1996. GL 96-01 requested that power reactor licensees compare certain safety-related system instrument logic against plant surveillance test procedures to ensure that all portions of the logic circuitry are adequately covered in the surveillance procedures to fulfill the TS requirements. As a result, VY changed its surveillance testing methods and reported to the NRC staff regarding GL 96-01 by letters dated April 18, 1996; September 30, 1997; and February 23, 1998. The NRC staff subsequently found VY's response to GL 96-01 to be acceptable (TAC No. M94746, dated March 4, 1998).

LSFTs (including trip system logic or simulated automatic actuation tests) are conducted on the following systems at VYNPS:

"* Reactor Protection System

"* Primary Containment Isolation

"* High Pressure Coolant Injection

"* Reactor Core Isolation Cooling

"* Low Pressure Coolant Injection

"* Core Spray

"* Automatic Depressurization System

"* Recirculation Pump Trip

"* Reactor Building Vent Isolation and Standby Gas Treatment

"* Control Rod Block Instrumentation

"* Off-Gas System

"* Mechanical Vacuum Pump Depending upon safety function, not all logic circuitry requires logic system functional testing. For example, the circuitry used to automatically open a pathway need not be tested if this action is not required for system operability. However, the circuitry that isolates the same pathway to preclude a potential radioactive release would normally be included. In addition, test switches and associated contacts that are not required for system operability need not be tested as part of the logic circuit.

Comparison to Standard Technical Specifications (STS) and Other Boiling Water Reactors The proposed TS definition of LSFT is the definition in NUREG-1433, Revision 2. The separation of details regarding valve testing as part of RCIC simulated automatic actuation testing is also consistent with STS and requirements for testing of the HPCI system.

STS does not contain a definition of "simulated automatic actuation."

2 For example, NEDC-30936P-A, Parts 1 and 2, "BWR Owners Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation),"

December 1988

BVY 03-04 / Attachment I / Page 5 The NRC issued Amendment No. 248 to the operating license for the James A. FitzPatrick Nuclear Power Plant on December 11, 1998 (TAC No. MA1372). Among other changes, the amendment consisted of a revised definition of LSFT similar to the change requested herein.

Updated Final Safety Analysis Report (UFSAR)

VY UFSAR section 7.1.5, "Definitions," addresses logic system functional testing and includes, through references, much of the licensing basis for VY's current practices for conducting LSFTs. Upon issuance of a license amendment in this matter, the UFSAR will be updated, as necessary.

BVY 03-04 / Attachment 1 / Page 6 SAFETY ASSESSMENT

1. TS Definition 1.0.H (Logic System Functional Test)

The proposed change to the definition of a LSFT is consistent with current industry standards, clarifies the definition so that the testing requirement is more clearly understood, and expands the definition to state that the test may be performed as a series of sequential, overlapping or total system steps such that the entire logic system is tested. The revised definition does not necessarily require testing of the sensor or actuated device as part of the LSFT. However, existing requirements for the testing of sensors and actuated devices as part of channel calibrations and inservice tests (ISTs) are unchanged and are adequate to verify operability of those components or devices.

The current TS definition of LSFT is expanded to include all logic components, not just relays and contacts. This change is necessary with the introduction of solid-state logic elements into protective circuitry. The revised definition requires injecting a test signal as close to the sensor as practical in recognition of the impracticality of injecting a simulated automatic injection signal at the sensor in all cases. In a number of current VYNPS TS SRs this exception is already noted. Sensor testing is týpically included in channel calibrations (with certain exceptions; e.g., neutron detectors) independent of L*SFT.

The proposed change also clarifies the existing LSFT definition by stating that the test may be performed as a series of sequential, overlapping, or total system steps such that the entire logic system is tested. This aspect of the changed definition is acceptable because it clarifies the LSFT requirement without changing its intent. In many cases, it is not practicable to test all logic functions in a single test.

The change to TS Definition 1.0.1 also corrects the misspelling of "logic" in TS 1.0.H. This misspelling was inadvertently introduced as a typographical error during the processing of a previous license amendment. This change is acceptable because it merely corrects an administrative error that does not change the technical meaning or implementation of any TS requirement.

The current definition of LSFT further states that the action will go to completion, (i.e., pumps will be started and valves operated). The revised definition does not require testing of the actuated device as part of the LSFT. The explicit exclusion of any requirement to test the actuated device as part of the LSFT is consistent with industry standards 3, as the operability of these devices is verified on a more frequent basis by other TS surveillance requirements. Testing instrument channels and logic circuits separate from their actuated devices is acceptable industry practice. Actuated devices (i.e., pumps and valves) are subject to IST requirements, and the combined testing of the various components and logic systems verify the operability of the entire system.

This change is consistent with the improved TS definition in NUREG-1433, Revision 2, and is therefore acceptable.

2. TS Definition 1.0.W (Simulated Automatic Actuation)

The proposed change to TS Definition 1.0.W, "simulated automatic actuation," is to delete this definition from TS because the level of detail provided by the definition is unnecessary to ensure compliance with applicable surveillance requirements. A simulated automatic actuation may be considered a subset of a 3 ANSMIEEE Standard 338-1987, "IEEE Standard Criteria for the Periodic Surveillance Testing of Nuclear Power Generating Station Safety Systems," Section 6.3.5, defines a LSFT as a test of logic components consisting of relays, contacts, and solid-state logic elements of a logic circuit.

BVY 03-04 / Attachment I / Page 7 system functional test (or a LSFT) because the test sequence is embodied within the meaning of a LSFT.

Therefore, an explicit definition of a "simulated automatic actuation" does not need to be included in TS.

Because "simulated automatic actuation" may be considered as falling within the scope of a LSFT, it is unnecessary to define this term in TS. Unlike the definition of LSFT, the current TS definition of "simulated automatic actuation" is not an industry standard term and does not provide the same understanding as the revised definition for a LSFT. Standard TS does not contain a definition of "simulated automatic actuation," or similar terms, as these definitions are unwarranted.

This change is consistent with the improved standard TS and is therefore acceptable.

3. TS SR 4.5.G.l.a (RCIC System Testing)

The current provision for "testing valve operability" in TS SR 4.5.G.l.a is unclear as to what valve testing is intended as part of the simulated automatic actuation test, because automatic initiation of the RCIC system does not actuate all system valves, nor does it re-position those valves that are already in the correct position. Therefore, to avoid confusion and to make this Specification consistent with the HPCI Specification (i.e., TS SR 4.5.E.l.a), the parenthetical expression, "testing valve operability," is being deleted.

A reasonable interpretation of what is meant by "testing valve operability" in conjunction with a simulated automatic actuation is a verification that automatic valves in the flow path actuate to their correct position (or remain in the correct position). However, testing a valve's movement need not be part of the LSFT because certain valves (e.g., check valves) may not be capable of moving during the LSFT without actual coolant flow, and the valves themselves are adequately tested within the scope of the quarterly RCIC IST flow tests.

Inservice tests are required to ensure that the RCIC pump and valves are operable in order to perform their intended safety functions. The IST program, required by 10CFR50.55a and TS 4.6.E, provides requirements for the testing of all ASME Code Class 1, 2, and 3 valves in accordance with Section XI of the ASME code. Compliance with these requirements is adequate to ensure the required valve testing is performed to verify system operability. Periodic testing of RCIC valves in accordance with the IST program (as required by TS SR 4.5.G.l.b, SR 4.5.G.l.c, and SR 4.6.E) is sufficient to demonstrate operability, and additional valve testing as part of the simulated automatic actuation test of RCIC is overly burdensome. RCIC valve operability testing is performed quarterly and during startups in conjunction with RCIC pump tests. Therefore, additional details or requirements for valve operability testing do not need to be included in TS 4.5.G.l.a.

The LSFT demonstrates the operability of the required initiation logic for a specific channel and includes simulated automatic actuation of the channel. This change is acceptable because the system functional testing performed in SR 4.5.G.1 overlaps with the LSFT requirement of SR 4.2.L (and TS Table 4.2.9, "Minimum Test and Calibration Frequencies - Reactor Core Isolation Cooling System Actuation Instrumentation") to provide complete testing of the safety function. The LSFT demonstrates the operability of the required initiation logic for a specified channel and includes simulated automatic actuation of the channel.

4. Bases to TS 4.2 The TS Bases provide explanation and rationale for associated TS requirements, and in some cases, how they are to be implemented. Associated changes to the TS Bases are being made to conform to the

BVY 03-04 / Attachment I / Page 8 changed TS and to add clarity to existing requirements. Bases do not establish actual requirements, and as such do not change technical requirements of the TS. The Bases changes are therefore acceptable, since they administratively document the reasons and provide additional understanding for the associated TS.

Conclusion/Summary In conclusion, based on the considerations discussed above, (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 requested license amendment will not be inimical to the common defense and security or to the health and safety of the public.

Docket No. 50-271 BVY 03-04 Attachment 2 Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 255 Definition of Logic System Functional Test Determination of No Significant Hazards Consideration

BVY 03-04 / Attachment 2 / Page 1 Description of Amendment Request:

The proposed change revises the Technical Specification definition of a logic system functional test, deletes the definition of a simulated automatic actuation, and deletes unnecessary details regarding valve operability testing from a surveillance requirement for testing of the Reactor Core Isolation Cooling system. In addition, changes that clarify Technical Specification Bases regarding protective instrumentation are also being made. In general, these changes are largely editorial and involve clarifications that do not change the intent of the required surveillance testing.

Basis for No Significant Hazards Determination:

Pursuant to 10CFR50.92, Vermont Yankee has reviewed the proposed change and concludes that the change does not involve a significant hazards consideration since the proposed change satisfies the criteria in 10CFR50.92(c). These criteria require that the operation of the facility in accordance with the proposed amendment will not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

The proposed change does not involve a significant hazards consideration because the changes would not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change involves surveillance requirements and definitions of surveillance tests. As such, the proposed change does not involve any plant physical changes, change any Technical Specification instrumentation setpoints, or introduce any new mode of plant operation. The proposed change to surveillance requirements and definitions does not result in any significant change in the availability of logic systems or safety-related systems themselves. Protective functions will be maintained. The proposed change does not degrade plant design, operation, or the performance of any safety system assumed to function in the accident analysis.

Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Create the possibility for a new or different kind of accident from any previously evaluated.

The proposed change does not: introduce any new accident initiators or failure mechanisms because the changes do not introduce any new modes of plant operation, make any physical changes (no new or different type of equipment will be installed); or change any Technical Specification instrumentation setpoints or methods of plant operation. The proposed change will not substantially impose new requirements or eliminate any existing requirements.

Therefore, the changes to the surveillance requirements and testing definitions that encompass this proposed change do not create the possibility of a new or different kind of accident than those previously evaluated.

BVY 03-04 / Attachment 2 / Page 2

3) Involve a significant reduction in a margin of safety.

The proposed change does not alter the manner in which safety limits, limiting safety system settings, or limiting conditions for operation are determined. There is no change or impact on any safety analysis assumptions. The proposed change does not involve any increase in calculated off-site dose consequences. Operability of protective instrumentation and the associated systems is unaffected, and performance of equipment will not be significantly affected. Since the proposed change is consistent with the BWR/4 Standard Technical Specifications, NUREG-1433, Revision 2, approved by the NRC staff, revising the Technical Specifications in a manner which clarifies and reflects the approved level of detail ensures that safety margins are acceptable.

Therefore, there is no significant reduction in the margin of safety as a result of this Technical Specification change.

Conclusion On the basis of the above, VY has determined that operation of the facility in accordance with the proposed change does not involve a significant hazards consideration as defined in 10CFR50.92(c), in that it: (1) does not involve a significant increase in the probability or consequehces of an accident previously evaluated; (2) does not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) does not involve a significant reduction in a margin of safety.

Docket No. 50-271 BVY 03-04 Attachment 3 Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 255 Definition of Logic System Functional Test Marked-up Version of the Current Technical Specifications

VYNPS 1.0 DEFINITIONS 1.0 DEFINITIONS The succeeding frequently used terms are explicitly defined so that a uniform interpretation of the specifications may be achieved.

A. Reportable Occurrence - The equivalent of a reportable event which shall be any of the conditions specified in Section 50.73 to 10CFR Part 50.

B. Alteration of the Reactor Core - The act of moving any component affecting reactivity within the reactor vessel in the region above the core support plate, below the upper grid and within the shroud. Normal movement of control rods or neutron detectors, or the replacement of neutron detectors is not defined as a core alteration.

C. Hot Standby - Hot standby means operation with the reactor critical and the main steam line isolation valves closed.

D. Immediate - Immediate means that the required action will be initiated as soon as practicable considering the safe operation of the unit and the importance of the required action.

E. Instrument Calibration - An instrument calibration means the adjustment of an instrument signal output so that it corresponds, within acceptable range and accuracy, to a known value(s) of the parameter which the instrument monitors. Calibration shall encompass the entire instrument including actuation, alarm, or trip. Response time as specified is not part of the routine instrument calibration but will be checked once per operating cycle.

F. Instrument Check - An instrument check is qualitative determination of acceptable operability by observation of instrument behavior during operation. This determination shall include, where possible, comparison of the instrument with other independent instruments measuring the same variable.

G. Instrument Functional Test - An instrument functional test shall be:

1. Analog channels - the injection of a signal into the channel as close to the sensor as practicable to verify operability including alarm and/or trip functions.

2. Bistable channels - the injection of a signal into the sensor to verify the operability including alarm and/or trip functions.

H. Log System Funct al Test - A logic s tem functional t t means a test of all r ys and contacts of ogic circuit fro sensor to activated pýice to insure all coX onents are oper e per design intent. /*ere possible, actio ill go to comple on, i.e., pumps will be ost --,ed and valves opened Amendment No. 44-v, ;4 9~, ~414, a3-, 1681

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

1. Hot Shutdown means conditions as above with reactor coolant temperature greater that 2120 F.

2. Cold Shutdown means conditions as above with reactor coolant temperature equal to or less than 212 0 F. Deleted

3. Shutdown means conditions as above such that the effective multiplication factor (Km) of the core shall be less than 0.99.

W. Simulate Automatic Actuat n - Simulated autom ic actuation means Coapply rg a simulated sig 1 to the sensor to tuate circuit in7 X. Transition Boiling - Transition boiling means the boiling regime between nucleate and film boiling. Transition boiling is the regime in which both nucleate and film boiling occur intermittently with neither type being completely stable.

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

If it is discovered that a surveillance was not performed within its specified frequency, declaring applicable Limiting Conditions for Operation (LCOs) not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is less. This delay period is permitted to allow performance of the surveillance.

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

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

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

Amendment No. 74O, 12-4, 4-6.&,4-7L9, 197 4

VYNPS BASES :

4.2 PROTECTIVE INSTRUMENTATION (Cont'd) testing of this ature was done while th plant was shut do for refueling. I this way, the testing o equipment would no jeopardize plant operation.

This Spe fication is a periodic esting program whic is based upon the overall/testing of protective i trumentation syste , including logic cru sawelssensor ci uits Table 4.2 ou ines the test, Scali ration, and logic syste functional test sc dule for the protective

• in rmentation systems. ihe testing of a suey-ste Includes a functional test o each reay wherever practicable. The testing of each relay includes all circuitry necessary to make the relay operate, and also the proper functioning of the relay contacts. Testing of the automatic initiation inhibit switches verifies the proper operability of the switches and relay contacts. Functional testing of the inaccessible temperature switches associated with the isolation systems is accomplished remotely by application of a heat source to individual switches.

All subsystems are functionally tested, calibrated, and operated in their entirety.

A channel functional test is performed for the Reactor Mode Switch Shutdown Position function to ensure that the .entire channel will perform the intended function. The surveillance is only required to be performed once per operating cycle during refueling. The Refueling Outage frequeency is based on the need to perform this surveillance under the conditions that apply during a plant outage. operating experience has shown that this surveillance frequency is adequate to ensure functional operability.

Note 12 of Table 4.2.5 specifies that if the surveillance frequency of every Refueling Outage is not met, functional testing of the Reactor Mode Switch - Shutdown Position function shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the reactor mode switch is placed in the Shutdown position for the purpose of commencing a scheduled Refueling Outage. This allows entry into the Shutdown mode when the surveillance requirement is not met.

Amendment No. 94-, &&

-,

• 6-, 211 80a

VYNPS 3.5 LIMITING CONDITION FOR 4.5 SURVEILLANCE REQUIREMENT OPERATION due to malfunction of the electrical portion of the valve when the reactor is pressurized above 150 psig with irradiated fuel in the reactor vessel, continued reactor operation is permissible only during the succeeding seven days unless such a valve is sooner made operable, provided that during such seven days both the remaining Automatic Relief System valves and the RPCI System are operable.

3. If the requirements of Specification 3.5.F cannot be met, an orderly shutdown shall be initiated and the reactor pressure shall be reduced to

• 150 psig within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. G. Reactor Core Isolation Cooling System (RCIC)

G. Reactor Core Isolation Cooling System (RCIC) Surveillance of the RCIC System shall be performed as

1. Except as specified in follows:

Specification 3 .5.G.2 below, the RCIC System 1. Testing shall be operable whenever the reactor a. A simulated automatic steam pressure is greater actuation tes (t- ting val i*oper-a* it* o f/

than 150 psig and irradiated fuel is in the th RCIC System s all reactor vessel. be performed during each refueling outage.

2. From and after the date that the RCIC System is b. Operability testing of made or found to be the pump and valves inoperable for any shall be in accordance reason, reactor operation with Specification is permissible only 4 .6.E.

during the succeeding I 14 days unless such system is sooner made operable, provided that:

c. Upon reactor startup, RCIC operability testing shall be performed as required

a. The HPCI System is by Specification 4.6.E immediately verified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after by administrative exceeding 150 psig means to be operable, reactor steam pressure.

and Amendment No. &, ;4, 14, 4-24, , a-74, 205 107

INSERT#1 (Definition 1.0.H)

Lo.gic System Functional Test - A logic system functional test shall be a test of all logic components required for operability of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify operability. The logic system functional test may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

INSERT #2 (Bases 4.2)

Since logic circuit tests may result in the actuation of plant equipment, testing of this nature is generally performed during a refueling outage. In this way, the testing of equipment should not jeopardize plant operation.

These surveillance requirements provide a periodic testing program for protective instrumentation to demonstrate that systems and components function satisfactorily and include schedules for performing functional tests, calibrations, and logic system functional tests.

Docket No. 50-271 BVY 03-04 Attachment 4 Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 255 Definition of Logic System Functional Test Retyped Technical Specification Pages

BVY 03-04 / Attachment 4 / Page 1 Listing of Affected Technical Specifications Pages Replace the Vermont Yankee Nuclear Power Station Technical Specifications pages listed below with the revised pages included herein. The revised pages contain vertical lines in the margin indicating the areas of change.

1 1 4 4 80a 80a 107 107

VYNPS 1.0 DEFINITIONS 1.0 DEFINITIONS The succeeding frequently used terms are explicitly defined so that a uniform interpretation of the specifications may be achieved.

A. Reportable Occurrence - The equivalent of a reportable event which shall be any of the conditions specified in Section 50.73 to 10CFR Part 50.

B. Alteration of the Reactor Core - The act of moving any component affecting reactivity within the reactor vessel in the region above the core support plate, below the upper grid and within the shroud. Normal movement of control rods or neutron detectors, or the replacement of neutron detectors is not defined as a core alteration.

C. Hot Standby - Hot standby means operation with the reactor critical and

'the main steam line isolation valves closed.

D. Immediate - Immediate means that the required action will be initiated as soon as practicable considering the safe operation of the unit and the importance of the required action.

E. Instrument Calibration - An instrument calibration means the adjustment of an instrument signal output so that it corresponds, within acceptable range and accuracy, to a known value(s) of the parameter which the instrument monitors. Calibration shall encompass the entire instrument including actuation, alarm, or trip. Response time as specified is not part of the routine instrument calibration but will be checked once per operating cycle.

F. Instrument Check - An instrument check is qualitative determination of acceptable operability by observation of instrument behavior during operation. This determination shall include, where possible, comparison of the instrument with other independent instruments measuring the same variable.

G. Instrument Functional Test - An instrument functional test shall be:

1. Analog channels - the injection of a signal into the channel as close to the sensor as practicable to verify operability including alarm and/or trip functions.

2. Bistable channels - the injection of a signal into the sensor to verify the operability including alarm and/or trip functions.

H. Logic System Functional Test - A logic system functional test shall be a test of all logic components required for operability of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify operability. The logic system functional test may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

Amendment No. -1, ý-, 9--, 44-6, -_, 4-654 1

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

1. Hot Shutdown means conditions as above with reactor coolant temperature greater that 212 0 F.

2. Cold Shutdown means conditions as above with reactor coolant temperature equal to or less than 212 0 F.

3. Shutdown means conditions as above such that the effective multiplication factor (Kýff) of the core shall be less than 0.99.

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

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

If it is discovered that a surveillance was not performed within its specified frequency, declaring applicable Limiting Conditions for Operation (LCOs) not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is less. This delay period is permitted to allow performance of the surveillance.

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

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

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

Amendment No. 4, 4, a6, 4-74-,94 4

VYNPS BASES:

4.2 PROTECTIVE INSTRUMENTATION (Cont'd)

Since logic circuit tests may result in the actuation of plant equipment, testing of this nature is generally performed during a refueling outage.

In this way, the testing of equipment should not jeopardize plant operation.

These surveillance requirements provide a periodic testing program for protective instrumentation to demonstrate that systems and components function satisfactorily and include schedules for performing functional tests, calibrations, and logic system functional tests. The testing of a subsystem includes a functional test of each relay wherever practicable.

The testing of each relay includes all circuitry necessary to make the relay operate, and also the proper functioning of the relay contacts.

Testing of the automatic initiation inhibit switches verifies the proper operability of the switches and relay contacts. Functional testing of the inaccessible temperature switches associated with the isolation systems is accomplished remotely by application of a heat source to individual switches.

All subsystems are functionally tested, calibrated, and operated in their entirety.

A channel functional test is performed for the Reactor Mode Switch Shutdown Position function to ensure that the entire channel will perform the intended function. The surveillance is only required to be performed once per operating cycle during refueling. The Refueling Outage frequeency is based on the need to perform this surveillance under the conditions that apply during a plant outage. Operating experience has shown that this surveillance frequency is adequate to ensure functional operability.

Note 12 of Table 4.2.5 specifies that if the surveillance frequency of every Refueling Outage is not met, functional testing of the Reactor Mode Switch - Shutdown Position function shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the reactor mode switch is placed in the Shutdown position for the purpose of commencing a scheduled Refueling Outage. This allows entry into the Shutdown mode when the surveillance requirement is not met.

Amendment No. 1, 9- 94-4-,

• 4,-4, 24--S 80a

VYNPS 3.5 LIMITING CONDITION FOR 4.5 SURVEILLANCE REQUIREMENT OPERATION due to malfunction of the electrical portion of the valve when the reactor is pressurized above 150 psig with irradiated fuel in the reactor vessel, continued reactor operation is permissible only during the succeeding seven days unless such a valve is sooner made operable, provided that during such seven days both the remaining Automatic Relief System valves and the HPCI System are operable.

3. If the requirements of Specification 3.5.F cannot be met, an orderly shutdown shall be initiated and the reactor pressure shall be reduced to

• 150 psig within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

G. Reactor Core Isolation G. Reactor Core Isolation Cooling System (RCIC) Cooling System (RCIC)

1. Except as specified in Surveillance of the RCIC Specification 3.5.G.2 System shall be performed as below, the RCIC System follows:

shall be operable whenever the reactor 1. Testing steam pressure is greater than 150 psig and a. A simulated automatic irradiated fuel is in the actuation test of the reactor vessel. RCIC System shall be performed during each

2. From and after the date refueling outage.

that the RCIC System is made or found to be b. Operability testing of inoperable for any the pump and valves reason, reactor operation shall be in accordance is permissible only with Specification during the succeeding 4.6.E.

14 days unless such system is sooner made c. Upon reactor startup, operable, provided that: RCIC operability testing shall be

a. The HPCI System is performed as required immediately verified by Specification 4.6.E by administrative within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after means to be operable, exceeding 150 psig and reactor steam pressure.

Amendment No. 44, - 114, 424, 4r64, 4-7, 2-05 107