ML031200144
| ML031200144 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/25/2003 |
| From: | Balduzzi M Entergy Nuclear Vermont Yankee, Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY 03-40 | |
| Download: ML031200144 (4) | |
Text
Entergy Nuclear Vernont Yankee, LLC Entergy Nuclear Operations, Inc.
E nter y 185 Old Ferry Road Brattleboro, VT 05302-0500 April 25, 2003 BVY 03-40 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 Specifications Proposed Change No. 259 Instrumentation Technical Specifications 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 (TS). The proposed change revises TS Sections 2.1, "Limiting Safety System Setting," 3.1, "Reactor Protection System," 3.2, "Protective Instrument System," associated Surveillance Requirements, and other TS with similar requirements as these instrumentation TS sections. The Improved Standard Technical Specifications (ISTS)2 were used as guidance in developing the proposed change.
The proposed changes include the following:
- 1. Revisions are made to wording, and human factors principles are applied to the format and presentation of Actions, Notes and Tables.
These enhancements are made to improve usability and clarity for the operators and other users.
- 2. Technical changes are made to resolve non-conservative TS issues (currently addressed by administrative controls), provide relaxation of overly restrictive requirements, and ensure consistency between TS requirements and the design and licensing basis through implementation of both more and less restrictive requirements.
- 3. Certain requirements are relocated to plant controlled documents to allow the change process for these requirements to be enhanced.
- 4. Enhancements are made to the associated Bases.
As a result, the proposed change will correct deficiencies in the TS, reduce operator work-arounds, improve and correct confusing and ambiguous TS requirements, and allow for process enhancements. to this letter contains (by TS section) the revised TS and Bases, the markup of the current Technical Specifications (CTS), the safety assessment discussion of changes to the CTS, and the No Significant Hazards Consideration (NSHC) for each of the changes to the CTS. Attachment 2 provides a listing of the affected TS and Bases pages.
Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. are the licensees of the Vermont Yankee Nuclear Power Station 2
NUREG 1433, Revision 2, Standard Technical Specifications, General Electric Plants, BWRI4, dated April 30,2001 A Dl
BVY 03-40 / Page 2 is organized in a manner similar to a request for conversion to ISTS on a TS section/specification by TS section/specification basis, generally as follows:
TAB 1:
Proposed TS This tab contains the re-typed, proposed TS.
TAB 2:
Proposed Bases This tab contains the re-typed, proposed Bases.
TAB 3:
CTS Markups This tab contains a copy of the CTS pages, annotated to provide a cross-reference to the equivalent proposed TS requirements, showing the disposition of the existing requirements into the proposed TS.
The annotated copy of the CTS pages is marked with sequentially numbered "boxes" which provide a cross-reference to a Safety Assessment Discussion of Change (DOC) between the CTS and the proposed TS. When the proposed TS requirement differs from the CTS requirement, the CTS being revised is annotated with an alpha-numeric designator. This provides a justification for the proposed change.
The alpha-numeric designator is based on the category of the change and a sequential number within that category. The changes to the CTS are categorized as follows:
A ADMINISTRATIVE - associated with restructuring, interpretation, and complex rearranging of requirements, and other changes not substantially revising an existing requirement. There is a single NSHC for this category.
M TECHNICAL CHANGES - MORE RESTRICTIVE - changes to the CTS being proposed, resulting in added restrictions or eliminating flexibility. There is a single NSHC for this category.
L TECHNICAL CHANGES - LESS RESTRICTIVE - changes where requirements are relaxed, relocated, eliminated, or new flexibility is provided. There are two groups of changes in this category-"Generic" and "Specific." Each "Specific LESS RESTRICTIVE change has a corresponding unique NSHC. The "Generic" LESS RESTRICTIVE changes are subdivided into two subcategories, each uniquely identified as either an LA or LC change. Each subcategory of "Generic" LESS RESTRICTIVE change has a single NSHC.
These subcategories and their designation are as follows:
The "LA" changes consist of relocation of details out of the CTS and into the Bases, Technical Requirements Manual, or plant procedures. Typically, this involves details of system design and function or procedural details on methods of conducting a surveillance.
The "LC" changes reflect elimination of various instrumentation requirements, where the instrument is an alarm or an indication-only
BVY 03-40 / Page 3 instrument function that does not otherwise meet the NRC TS selection criteria.
R RELOCATED - specific requirements that do not meet the NRC TS selection criteria. These items are being relocated to other plant documents as part of the TS revision. There is a single NSHC for this category.
TAB 4:
Safety Assessment DOCs The Safety Assessment DOC for each proposed TS section immediately follows the marked-up CTS pages. The alpha-numeric designator also relates the proposed change to the applicable NSHC.
TAB 5:
NSHCs This tab contains the evaluation performed using the criteria in 10CFR50.91(a)(1) and provides information supporting a finding of no significant hazards consideration using the standards in 10CFR50.92(c) for the proposed changes associated with the corresponding proposed TS section. The NSHCs are categorized as Administrative, Relocated, More Restrictive, Less Restrictive - Generic, and Less Restrictive - Specific, and are identified by an alpha-numeric designator relating the marked-up CTS and Safety Assessment DOC to the applicable NSHC.
TAB 6:
References This tab contains a list of references used in the development of the proposed change.
VY has reviewed the proposed TS changes in accordance with 10CFR50.92 and concludes that the proposed change does not involve a significant hazards consideration.
VY has also determined that the proposed changes satisfy the criteria for a categorical exclusion in accordance with 10CFR51.22(cX9) and do not require an environmental review. Therefore, pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment needs to be prepared for these changes.
Upon acceptance of this proposed change by the NRC, VY requests that a license amendment be issued for implementation within 90 days of its effective date.
If you have any questions on this transmittal, please contact Mr. Len Gucwa at (802) 258-4225.
Sincerely, Michael A. Balduzzi Vice President, Operations
BVY 0340 / Page 4 STATE OF VERMONT
)ss WINDHAM COUNTY Then personally appeared before me, Michael A. Balduzzi, who, being duly sworn, did state that he is Vice President, Operations of the Vermont Yankee Nuclear Power Station, that he is duly authorized to execute and file the foregoing document, and that the statements therein are true to the best of his knowledge and belief.
Sahly A. Sa'ndstrum, Notary Public,<
My Commission Expires Febru arY 0
g g 4O.TA~t Attachments PU¶.IC cc:
USNRC Region I Administrator USNRC Resident Inspector - VYNPS USNRC Project Manager - VYNPS Vermont Department of Public Service