FVY-87-107, Application for Amend to License DPR-28,consisting of Proposed Change 142 Re Rev to Surveillance Requirements & Bases for Trip Sys Logic Testing

Application for Amend to License DPR-28,consisting of Proposed Change 142 Re Rev to Surveillance Requirements & Bases for Trip Sys Logic Testing

ML20236V199
Person / Time
Site:	Vermont Yankee
Issue date:	11/30/1987
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	Murley T NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
Shared Package
ML20236V201	List: FVY-87-107, Application for Amend to License DPR-28,consisting of Proposed Change 142 Re Rev to Surveillance Requirements & Bases for Trip Sys Logic Testing ML20236V203 ML20236V211
References
FVY-87-107, FVY-87-111, NUDOCS 8712040150
Download: ML20236V199 (6)

Text

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Proposed Change No. 142 a VERMONT YANKEE NUCLEAR POWER' CORPORATION

. FVY 87-111

. RD 5. Box 169. Ferry Road, Brattleboro. VT 05301 ,

'p- November 30, 1987 ENGINEERING OFFICE 1671 WORCESTER ROAD FVY 87-107 FR AMINGHA M. MASS ACHUSETTS 01701 TELEPHONE 6t? 6?2 6100, United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Attention: Office of Nuclear Reactor Regulation j Mr. T. E. Murley, Director

References:

(a) License No. DPR-28'(Docket No. 50-271) l (b) Letter,.VYNPC to USNRC, WVY 79-63 ." Proposed Change No. 80, ECCS Surveillance," dated May 18, 1979 (c) Letter, VYNPC to USNRC, WVY 79-116, dated October 3, 1979 (d) Letter, USNRC to Iowa Electric Light and Power Company,

" Safety Evaluation by the Office of Nuclear Reactor Regulation Supporting Amendment No. 143 to Facility Operating License No. DPR49", dated May 21, 1987

Subject:

Proposed Change to the Vermont Yankee Technical Specifications - Logic System Functional Test Intervals

Dear Sir:

J l

Pursuant to Section 50.59 of the Commission's Rules and Regulations, Vermont Yankee Nuclear Power Corporation hereby proposes the following change I to Appendix A of the operating license. This proposed change is submitted in place of the proposed changes described in References (b) and (c).

Accordingly, the changes proposed in References (b) and (c) are hereby formally withdrawn in their entirety.

Proposed Change 4 Replace the following pages of the Vermont Yankee Technical Specifications with the attached revised pages with the same page number:

Page Nos.

50 through 53 53a 54 through 59 64 and 67 8712040150 871130 PDR P ADOCK 05000271, pop ({0gg l

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United States Nuclear Regulatory Commission November 30, 1987 Attention: Mr. T. E. Murley, Director Page 2 The proposed changes address revised surveillance requirements and bases

'for trip system logic testing. The specific changes are' described belows 1.

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Pages 50 through 53, 53a', and-54 through 59 revise Tables 4.2.1, 2, 3, 4, and 5 to specify trip system logic. test and calibration frequencies as once per operating cycle ~in place'of 1 every six months. The following systems are affected by this' change:

Core Spray System Low Pressure' Coolant Injection System High Pressure Coolant Injection System Automatic Depressurization System Recirculation Pump Trip Actuation System Primary Containment Isolation l

High Pressure Coolant Injection System Isolation Reactor Core Isolation Cooling System-Isolation Reactor' Building Ventilation System Isolation and Standby Gas q Treatment System Isolation Off-Gas System Isolation j Control Rod Block System Relays (Pages 50 and 54) which were exempted from six-month: trip l system logic tests will now be tested once per operating cycle.

2. Pages 64 and 67 revise the bases in support of the reviced trip _

system logic test and calibration frequencies for the systems described above.

Reason for Change As a result of the recent NRC interpretation of the definition of logic system functional testing at the Duane Arnold Energy Center (DAEC), Vermont-Yankee initiated a review of its own Technical Specifications and testing methodology and performed an informal survey of industry practices concerning-functional logic test methodology. Based upon this review, Vermont Yankee concluded that existing testing methods and procedures adequately complied with the NRC's interpretation of testing requirements as intended within the original Veamont Yankee Technical Specifications. However, based upon NRC's recent interpretation regarding acceptable logic testing as defined by the Duane Arnold Technical Specifications and the close similarity between the Duane Arnold and Vermont Yankee f acilities, it was determined that enhancements could be made.

United States Nuclear Regulatory Commission November 30, 1987

' Attention: Mr. T. E. Murley, Director page 3 provided in Enclosure A is the revised methodology by which Vermont Yankee now performs logic system functional testing. This revised methodology was developed following a detailed review of Technical Specifications, testing procedures, and plant drawings. Compliance with this revised methodology has resulted in the need for expanded testing to be performed during refueling outages. In addition, it was determined, particularly in light of the expanded testing to be performed, that surveillance testing intervals need to be revised to extend the requirement for six-month interval testing to once-per-operating cycle.

The attached revised Technical Specification pages detail the changes in l trip system logic functional testing intervals which are necessary as a result of the expanded testing methodology.

Basis for change All Technical Specification page changes identified above are proposed to ,

extend the performance of logic system functional testing from every I six months to once per operating cycle. These changes either directly change wording to read "once per operating cycle" inctead of "every six months" or j change wording to be consistent with performing logic testing once per j operating cycle. The bases for these proposed changes are as follows: j

1. plant safety and operational requirements dictate that many surveillance tests required by the Technical Specifications should be or must be performed during periods of planned plant shutdowns, such as refueling outages. The revised trip system logic testing methodology and procedures have resulted in an increased number of l relays and contacts directly tested. A change in the requirements '

from performing these tests every six months to once per operating cycle allows for safer testing flexibility since many of the relays are not testable during power operation without creating an unnecessary risk to the plant, due to unnecessary challenges to systems and bypasses of portions of systems for testing.

2. Although the effective surveillance interval will change, the proposed logic surveillance test intervals are consistent with those  !

previously approved by the NRC for similar BWRs (Reference (d)). i

3. The proposed logic surveillance test intervals meet the intent and purpose of the surveillance requirements for the systetn(s) and are l l consistent with those specified within the BWR Standard Technical i Specifications (STS).

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4. The proposed surveillance frequency allows greater flexibility in I scheduling the surveillance of the systems and, as such, provides  !

for performance at more opportune times when testing corditions are l less challenging to operational safety.

5. A review of past operational history of logic system equipment at Vermont Yankee has determined that this equipment is very reliable.

Accordingly, a change in the surveillance interval from every six months to once-per-operating cycle will not have a significant affect on plant safety or operation.

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United States Nuclear Regulatory Commission November 30, 1987 Attention: Mr. T. E. Murley, Director page 4 Safety Evaluation The changes proposed meet the intent of Technical Specification requirements for performing trip system logic functional testing in that component operability is assured. A review of past test results and documented failures / discrepancies of logic system equipment at Vermont Yankee' '

has determined that this equipment has an excellent operating history.

Although the proposed amendment extends testing intervals; reliability of these systems will not be decreased because more detailed testing will be performed and operability of these systems is assured because logic system functional tests will be performed in accordance with Technical Specification requirements. In addition, the proposed changes are consistent with those previously approved by the NRC for similar BWRs and with requirements as specified in the BWR STS. Plant safety is actually enhanced by not routinely challenging or bypassing portions of safety systems during testing while the l Plant is operating. Further, the requested change to the logic system functional testing intervals does not impact any FSAR safety analysis l involving these systems nor does it involve any change in Technical Specification setpoints, plant operation, protective function, or design basis l of the plant. Therefore, the changes proposed by this amendment request do l

not present any unreviewed safety questions as defined in 10CFR50.59.

This proposed change was reviewed by the Vermont Yankee Nuclear Safety Audit and Review Committee.

Significant Hazards Consideration The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in the -

Commission's regulations, 10CFR50.92, which state that the operation of the  !

facility in accordance with the proposed amendment would not: 1) involve a significant increase in the probability or consequences of an accident j previously evaluated, 2) create the possibility of a new or different kind of ]

accident from any accident previously evaluated, or 3) involve a significant j reduction in a margin of safety.

The discussion below addresses the proposed changes with respect to these three criteria and demonstrates that the proposed amendment involves a no-significant-hazards consideration:

1. The proposed change to increase surveillance test intervals is posed for logic systems utilizing equipment with an excellent operating history as was determined from a review of past test results and documented failures. The requested change to the existing logic system functional testing intervals does not impact any FSAR safety analysis involving the applicable systems. Although the proposed amendment extends testing intervals, reliability of these systems '

will not be decreased and operability of these systems is still assured. In addition, more detailed testing will be performed during each test than that which is currently performed. Therefore, it is concluded that there is not a significant increase in the probability or consequences of an accident previously evaluated.

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-United States Nuclear Regulatory' Commission . November 30, 1987 Attention: Mr. T. E. Murley, Director page 5 l

2. The proposed changes to increase the surveillance test intervals will meet the intent'of Technical Specification requirements for l performing' trip, system logic tests to verify the operation of

. equipment as' designed. : Based,upon past operability history.of the

' Vermont Yankee: logic systeru equipment, performance of surveillance -

requirements'once per operating cycle will adequately; verify.-_

operation as designed. Neither the expanded testing methodology nor I the increase in surveillance test interval involves any change in Technical. Specification setpoints, plant operation, protective function, or. design basis of.the plant.. Therefore, these proposed L

changes do not create'the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed. changes actually.representLan increase in safety for the following reasons:

(a) The occurrence of trip system inoperability during.the performance of surveillance testing is reduced by requiring-less f requent surveillance.

(b) The po'tential for inadvertent reactor scrams and resultant transients is reduced by not routinely performing the subject surveillance testing during operations.

(c) The capability of performing testing on' complete logic' systems-without excluding specific components is provided by I

eliminating the requirement to test every six months (i.e.,

during operation).

(d) The potential of disabling equipment operation by leaving leads lif ted and jumpers in place as the result of human error is reduced by requiring less frequent surveillance..

(e) Radiation exposures to personnel performing surveillance testing will be reduced by not performing the subject surveillance testing during power operations and by requiring less frequent surveillance.

Based.upon the above, it is concluded that the proposed changes do' not involve a significant reduction in a margin of safety. '

In the March 6, 1986 Federal Register, the NRC published examples of  ;

amendments that are not likely to involve a significant hazards consideration if operation of the facility in accordance with the proposed amendment ]

i involves only one or more of a list of specific examples. . Example Number (iv) I; states:

a (iv) A relief granted upon demonstration of acceptable operation from an  !

operating restriction that was imposed because acceptable operation was not yet demonstrated. This assumes that the operating j restriction and the criteria to be applied to a request for relief l have been established in'a prior review and that it is justified in a satisfactory way that the criteria have been met. j 5

I United States Nuclear Regulatory Commission' ,

November 30, 1987 Attention: Mr. T. E. Murley, Director Page 6 Based upon the above and the fact that proposed changes are consistent-

'with requirements of NRC-approved STS, we. conclude that these proposed changes do not' constitute a significant hazards consideration as defined in '

10CFR50.92(c). '

Fee Determination In_accordance with the provisions of 10CFR170.12, an application fee of '

$150.00 is enclosed.

Schedule of Chante Because Vermont Yankee's next scheduled six-month testing is to be during March of 1988, we request approval by February 15, 1988.

We trust that the information provided above adequately supports our request, however, should you have any questions in this matter, please contact us.

Very truly yours, VERMONT YANKEE NUCLEAR' POWER CORPORATION M $.

W. P. Mu y Vice Presiden and Manager of Operations wpm /16.154 Enclosures cc: Vermont Department of Public Services 120 State Street Montpelier. Vermont 05602 Attention: Mr. G. Tarrant, Chairman STATE OF VERMONT )

)ss OF WINDHAM COUNTY)

Then personally appeared before me W. P. Murphy, who, being' duly; sworn, did state that he is Vice President and Manager: of Operations of Vermont Yankee Nuclear power Corporation, that he is duly authorized to execute'and file the foregoing document in the name and on the behalf of Vermont Yankee Nuclear Pow on and that the statements therein are true to the best of his k ge'an kdi f.

h c & '

G . -

Diane McCue Notary Public d

- My Commission Expires { February 10, 1991

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