BVY-90-029, Application for Amend to License DPR-28,consisting of Proposed Change 154,revising Tech Spec Table 4.7.2.a Re Primary Containment Isolation Valves Subj to Type C Leakage Tests

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Application for Amend to License DPR-28,consisting of Proposed Change 154,revising Tech Spec Table 4.7.2.a Re Primary Containment Isolation Valves Subj to Type C Leakage Tests
ML20012C610
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 03/09/1990
From: Murphy W
VERMONT YANKEE NUCLEAR POWER CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20012C611 List:
References
BVY-90-029, BVY-90-29, NUDOCS 9003220280
Download: ML20012C610 (4)


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PROPOSED CHANGE NO. 154 !

VERMONT YANKEE f

NUCL.EAg POWER CORPORATION BVY 90-029 L

Ferry Road, Brattleboro, VT 05301-7002 m,3 g[

ENGINEERING OFFICE l

V f,80 MA!N STREET DOLTON. MA 01740 (508) 779-0711 March 9, 1990 U.S. Nuclear Regulatory Commission i

Washington, D.C.

20555 Attention:

Document Control Desk

References:

a)

License No. DPR-28 (Docket No. 50-271) b)

Letter, VYNPC to USNRC, " Vermont Yankee Primary Containment Leak Rate Testing Program," FVY 84-76, dated 6/26/84 c)

Letter, USNRC to VYNPC, " Request for Additional Information, Appendix J Technical Specifications," NVY 86-29, dated 2/14/86 d)

Letter, VYNPC to USNRC, " Response to NRC Request for Additional Information, Appendix J Technical Specifications,"

FVY 86-51, dated 5/30/86 e)

Letter, VYNPC to USNRC, " Supplemental Response to NRC Request for Additional Information, Appendix J Technical Specifications," FVY 86-97, dated 10/10/86 f)

Letter, VYNPC to USNRC, " Vermont Yankee Appendix J Technical Specifications - Clarification and Request Concerning Reactor Cleanup System Valve 12-68," FVY 86-116, dated 12/15/86 g)

Letter, VYNPC to USNRC, " Vermont Yankee Proposed Change No. 121 - Withdrawal of Request for Sepcrate Review of Reactor Water Cleanup System Valve 12-68, BVY 89-35, dated 4/11/89

Dear Sir:

Subject:

Proposed Change No. 154 to Vermont Yankee Technical Specifications Regarding Primary Containment Isolation j

Valves Subject to Type C Leakage Testing i

Pursuant to Section 50.90 of the Commission's Rules and Regulations, Vermont Yankee Nuclear Power Corporation hereby proposes the following modifica-tions to Appendix A of the operating license.

Proposed Chance Replace pages 135 and 136 of the Vermont Yankee Technical Specifications with the attached revised pages 135 and 136. The proposed change revises Table 4.7.2.a (page 135) pertaining to primary containment isolation valves subject to Type C. leakage tests, and Table 4.7.2.b (page 136) pertaining to primary con-tainment isolation valves not subject to Type C leakage tests.

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x VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission March 9, 1990 Page 2 Specifically, the following changes are proposed:

1.

Add Feedwater Check Valves V2-27A, -96A, -28A, and -28B to Table 4.7.2.a 1

(page 135);

4 2.

Delete Reactor Cleanup System Valve V12-68 from Table 4.7.2.a (page 135):

3.

Delete Control Rod Hydraulic Return Check Valve V3-181 from Table 4.7.2.a (page 135):

j 4.

Delete Feedwater Check Valves V2-28A and -288 from Table 4.7.2.b (page 136).

Reason and Basis for Chance In 1981, Vermont Yankee replaced the outboard feedwater check valves, V2-27A and -96A with new check valves which possess resilient seats capable of undergoing Type C, Appendix J 1eak testing. These valves are currently included in the Vermont Yankee leak testing program, but are not included in Technical Specifications.

During the upcoming 1990 scheduled refueling outage, Vermont Yankee plans to implement a design change which will replace the existing inboard feedwater check valves V2-28A and V2-28B with new check valves similar to the outboard check valves.

Included in this design change will be new test connections which will permit Type C leak testing of the new inboard valves as well. Upon comple-tion of this planned design change, Vermont Yankee will have an improved leak testing capability such that both check valves on each of the two feedwater lines can be leak tested.

As a result of inclusion of the feedwater check valves as leak-tested valves in the Vermont Yankee Technical Specifications; Appendix J Type C leak testing of Reactor Water Cleanup System valve V12-68 and Control Rod Drive System valve V3-181 is made unnecessary.

Leak testing of the primary contain-ment boundary will be performed on each of the two feedwater check valves, which lie downstream (inboard) of V12-68 and V3-181.

Safety Considerations The change proposed by this amendment request does not present any unre-viewed safety questions as defined in 10CFR50.59. Replacement of feedwater check valves V2-28A&B with valves that are leak-testable and inclusion of leak testing of the feedwater check valves in Vermont Yankee's Type C testing program and Technical Specifications will result in an improvement to primary contain-ment boundary integrity.

This change renders Type C leakage testing of Reactor Water Cleanup System valve V12-60A and Control Rod Drive System valve V3-181 unnecessary, since leak tightness will be verified at the feedwater check valves.

f VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuc} ear Regulatory Commission March 9, 1990 Page 3 This change has been reviewed by the Vermont Yankee Plant Operations Review Committee and the Vermont Yankee Nuclear Safety Audit and Review Committee.

Sionificant Hazards Considerations The standards used to arrive at a determination that a request for amend-ment involves no significant hazards considerations are included in the Commission's regulation 10CFR60.92.

10CFR50.92 states that a proposed amendment does not:

1) involve a significant increase in the probability or consequences of an accident previously evaluated; 2) create the possibility of a new or dif-ferent 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 three criteria and demonstrates that the proposed amendment involves no significant hazards considerations.

This proposed change constitutes an improvement in leak testing capability for the feedwater lines at Vermont Yankee. After the replacement of feedwater check valves V2-28A and -288 during the planned 1990 refueling outage, both the inboard and outboard feedwater check valves (four valves total on two feedwater lines) will have the capability to be Type C, Appendix J 1eak tested.

The valves are designed to meet 10CFR50, Appendix J criteria for leak tightness.

The newly installed valves will not alter the manner in which the feedwater j

system operates. The feedwater check valves function to allow flow in one direction only, toward the reactor vessel. When flow either reverses or stops, the valve will seat itself and prevent reverse flow. The primary difference between the new swing check valves and the older "Y" lift check valves is the inclusion of a resilient seat.

The new valves will be able to seat under feed-water system design pressures as well as under the containment design basis accident pressures.

Because of the dual seat design of the new feedwater check valves, the integrity of the feedwater line primary containment penetrations is improved.

Inclusion of a leak testing capability for the feedwater check valves also precludes the need to test Reactor Water Cleanup System valve V12-68 and Control Rod Drive System valvo V3-181.

This will have no effect on the cperation of either system.

This proposed change to include feedwater check valves V2-27A, -96A, -28A, and -288 and remove the Reactor Water Cleanup System valve V12-68 and Control Rod Drive System valve V3-181 from Technical Specifications as primary contain-ment isolation valves that are subject to Type C leakage testing does not in-volve an increase in the probability or consequences of an accident previously evaluated. Operation of the Feedwater System, the Reactor Water Cleanup system, and the Control Rod Drive System is not altered or reduced from existing requirements and is still bounded by the assumptions used in the safety analysis l

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VERMONT YANKEE NUCLEAR POWER CORPORAT3ON

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U.S. Nuclear Regulatory Commission MarcN 9, 1b90 Page 4 thus the proposed change does not create the possibility of a new or different

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kind of accident from any event previously evaluated. Leak testing capability is being added to the primary containment boundary penetrations that the feed-water check valves form, thereby eliminating the need to test Reactor Water Cleanup System valve V12-68 and Control Rod Drive System valve V3-181 thus, the proposed changes in such testing involves no decrease in any plant margin of safety.

Therefore, we conclude that the proposed change does not constitute a significant hazards consideration as defined in 10CFR50.92.

Schedule of Chance This change to the Vermont Yankee Technical Specifications will be imple-mented as soon as practicable following receipt of your approval.

We trust that the information provided above adequately supports our requests however, should you have any questions in this matter, please do not hesitate to contact us.

Very truly yours, VERM0 T YANKEE NUCLEAR POWER CORPORATION

.E s r

Warren P.

rphy Vice Presi ent and Manager of Operations

/dm cc USNRC Regional Administrator, Region I USNRC Resident Inspector, VYNPS USNRC Project Manager, VYNPS VT Department of Public Service STATE OF VERMONT)

)ss WINDHAM COUNTY )

Then

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appeared before me, Warren P. Murphy, who, being duly

sworn,

$ ate t is Vice President and Manager of Operations of Vermont i.

Yanke N lear Power Cor ration, that he is duly authorized to execute and file l

the oregoin ent in the name and on the behalf of Vermont Yankee Nuclear Powa Corp ggva d that the statemen therein are true to the best of his kno< iledge nd M fef O

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Diane M. McCue i

Notary Public My Commission Expires February 10, 1991 l

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