ML020700324
| ML020700324 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 05/10/2002 |
| From: | Pulsifer R NRC/NRR/DLPM/LPD1 |
| To: | Balduzzi M Vermont Yankee |
| Pulsifer R M, NRR/DLPM, 415-3016 | |
| References | |
| TAC MB3430 | |
| Download: ML020700324 (13) | |
Text
May 10, 2002 Mr. Michael A. Balduzzi Senior Vice President and Chief Nuclear Officer Vermont Yankee Nuclear Power Corporation 185 Old Ferry Road P.O. Box 7002 Brattleboro, VT 05302-7002
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: ALLOWED OUTAGE TIMES FOR POST-ACCIDENT MONITORING INSTRUMENTATION (TAC NO. MB3430)
Dear Mr. Balduzzi:
The Commission has issued the enclosed Amendment No. 207 to Facility Operating License DPR-28 for the Vermont Yankee Nuclear Power Station, in response to your application dated November 20, 2001.
The amendment would change Technical Specifications Table 3.2.6 by revising the Allowed Outage Times (AOTs) and associated action requirements for certain post-accident monitoring instrumentation.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.
Sincerely,
/RA/
Robert M. Pulsifer, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosures:
- 1. Amendment No. 207 to License No. DPR-28
- 2. Safety Evaluation cc w/encls: See next page
Vermont Yankee Nuclear Power Station cc:
Regional Administrator, Region I Mr. Raymond N. McCandless U. S. Nuclear Regulatory Commission Vermont Department of Health 475 Allendale Road Division of Occupational King of Prussia, PA 19406 and Radiological Health 108 Cherry Street Mr. David R. Lewis Burlington, VT 05402 Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W. Mr. Gautam Sen Washington, DC 20037-1128 Licensing Manager Vermont Yankee Nuclear Power Ms. Christine S. Salembier, Commissioner Corporation Vermont Department of Public Service 185 Old Ferry Road 112 State Street P.O. Box 7002 Montpelier, VT 05620-2601 Brattleboro, VT 05302-7002 Mr. Michael H. Dworkin, Chairman Resident Inspector Public Service Board Vermont Yankee Nuclear Power Station State of Vermont U. S. Nuclear Regulatory Commission 112 State Street P.O. Box 176 Montpelier, VT 05620-2701 Vernon, VT 05354 Chairman, Board of Selectmen Director, Massachusetts Emergency Town of Vernon Management Agency P.O. Box 116 ATTN: James Muckerheide Vernon, VT 05354-0116 400 Worcester Rd.
Framingham, MA 01702-5399 Mr. Michael Hamer Operating Experience Coordinator Jonathan M. Block, Esq.
Vermont Yankee Nuclear Power Station Main Street P.O. Box 157 P.O. Box 566 320 Governor Hunt Road Putney, VT 05346-0566 Vernon, VT 05354 G. Dana Bisbee, Esq.
Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 Ms. Deborah B. Katz Box 83 Shelburne Falls, MA 01370
May 10, 2002 Mr. Michael A. Balduzzi Senior Vice President and Chief Nuclear Officer Vermont Yankee Nuclear Power Corporation 185 Old Ferry Road P.O. Box 7002 Brattleboro, VT 05302-7002
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE: ALLOWED OUTAGE TIMES FOR POST-ACCIDENT MONITORING INSTRUMENTATION (TAC NO. MB3430)
Dear Mr. Balduzzi:
The Commission has issued the enclosed Amendment No. 207 to Facility Operating License DPR-28 for the Vermont Yankee Nuclear Power Station, in response to your application dated November 20, 2001.
The amendment would change the Technical Specifications Table 3.2.6 by revising the Allowed Outage Times (AOTs) and associated action requirements for certain post-accident monitoring instrumentation.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.
Sincerely,
/RA/
Robert M. Pulsifer, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosures:
- 1. Amendment No. 207 to License No. DPR-28
- 2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC J. Clifford T. Clark W. Beckner PDI-2 R/F R. Pulsifer OGC ACRS B. Thomas E. Marinos G. Hill (2) C. Anderson, RI Accession Number: ML020700324 *See previous concurrence OFFICE PDI-2/PM PDI-2/LA EEIB* RORP* SPLB* OGC* PDI-2/SC NAME RPulsifer TClark EMarinos RDenning for BThomas AHodgdon JClifford WBeckner DATE 5/6/02 5/5/02 3/25/02 4/10/02 3/27/02 4/16/02 5/7/02 OFFICIAL RECORD COPY
VERMONT YANKEE NUCLEAR POWER CORPORATION DOCKET NO. 50-271 VERMONT YANKEE NUCLEAR POWER STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 207 License No. DPR-28
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment filed by the Vermont Yankee Nuclear Power Corporation (the licensee) dated November 20, 2001, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.
- 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. 207, are hereby incorporated in the license. The licensee 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 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
James W. Clifford, Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: May 10, 2002
ATTACHMENT TO LICENSE AMENDMENT NO. 207 FACILITY OPERATING LICENSE NO. DPR-28 DOCKET NO. 50-271 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 53 53 54 54 55 55 79 79
79a
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 207 TO FACILITY OPERATING LICENSE NO. DPR-28 VERMONT YANKEE NUCLEAR POWER CORPORATION VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271
1.0 INTRODUCTION
By letter dated November 20, 2001, the Vermont Yankee Nuclear Power Corporation (the licensee) submitted a request to amend the Vermont Yankee Nuclear Power Station Technical Specifications (TSs). The proposed amendment would revise the TSs by modifying Allowed Outage Times (AOTs) and associated action requirements for certain post-accident monitoring (PAM) instrumentation in TS Table 3.2.6. The Nuclear Regulatory Commission (NRC) staffs review involves the following changes to TS Table 3.2.6 and the associated TS Bases:
Drywell Atmospheric Temperature - Replace current Note 1 by revised Notes 1 and 3 Containment Pressure - Replace current Note 1 by revised Notes 1 and 3 Torus Pressure - Replace current Note 1 by revised Notes 1 and 3 Torus Water Level - Replace current Note 3 by revised Notes 1 and 3 Torus Water Temperature - Replace current Note 1 by revised Notes 1 and 3 Reactor Pressure - Replace current Note 1 by revised Notes 1 and 3 Reactor Vessel Water Level - Replace current Note 1 by revised Notes 1 and 3 Torus Air Temperature - Replace current Note 1 by revised Notes 1 and 3 Safety/Relief Valve Position - Replace current Note 4 by revised Notes 1 and 3 Safety Valve Position - Replace current Note 5 by revised Note 5 Containment Hydrogen/ - Replace current Note 1 by revised Notes 1 and 3 Oxygen Monitor The current Note 1 states:
From and after the date that a parameter is reduced to one indication, operation is permissible for 30 days. If a parameter is not indicated in the Control Room, continued operation is permissible during the next seven days. If indication cannot be restored within the next six hours, an orderly shutdown shall be initiated and the reactor shall be in a hot shutdown condition in six hours and a cold shutdown condition in the following 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
The revised Note 1 states:
Within 30 days following the loss of one indication, restore the inoperable channel to an operable status or a special report to the Commission must be prepared and submitted within the subsequent 14 days, outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to operable status.
The current Note 3 states:
From and after the date that this parameter is reduced to one indication in the Control Room, continued reactor operation is permissible during the next 30 days. If both channels are inoperable and indication cannot be restored in six hours, an orderly shutdown shall be initiated and the reactor shall be in a hot shutdown condition in six hours and a cold shutdown condition in the following 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
The revised Note 3 states:
Within 7 days following the loss of both indicators, restore at least one required channel to an operable status or place the reactor in a hot shutdown condition within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The current Note 4 states:
From and after the date that safety/relief valve position from pressure switches is unavailable, reactor operation may continue provided safety/relief valve position can be determined by monitoring safety/relief valve discharge temperature and torus water temperature. If both parameters are not available, the reactor shall be in a hot shutdown condition in six hours and a cold shutdown condition in the following 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
The current Note 5 states:
From and after the date that safety valve position from the acoustic monitor is unavailable, reactor operation may continue provided safety valve position can be determined by monitoring safety valve discharge temperature and primary containment pressure. If both indications are not available, the reactor shall be in a hot shutdown condition in six hours and in a cold shutdown condition in the following 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
The revised Note 5 states:
From and after the date that safety valve position from the acoustic monitor is unavailable, reactor operation may continue for 30 days provided safety valve position can be determined by monitoring safety
valve discharge temperature and primary containment pressure. If after 30 days the inoperable channel has not been returned to an operable status, a special report to the Commission must be prepared and submitted within the subsequent 14 days, outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to operable status.
If one or both parameters are not available (i.e., safety valve discharge temperature and primary containment pressure indication) with one or more safety valve position indications from the acoustic monitor unavailable, continued reactor operation is permissible during the next seven days. In this condition, if both secondary parameters are not restored to an operable status within seven days, the reactor shall be placed in a hot shutdown condition within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
2.0 BACKROUND The staff finds that attachment 1 of the submittal identified the applicable regulatory requirements. The regulatory requirements on which the staff based its acceptance are Regulatory Guide 1.97, Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 3, May 1983.
3.0 EVALUATION The licensee stated that the current AOTs specified in TS Table 3.2.6 are overly conservative in most cases and do not properly reflect the importance to safety that is commensurate with PAM instruments. For example, while the loss of a safety valve position indication has a very small contribution to plant risk, the existing TSs require that the reactor be placed in a hot shutdown condition in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> upon loss of a safety valve position indication. These overly restrictive AOTs can present undue and significant burden when conducting maintenance and plant betterment activities. Furthermore, the licensee stated that the proposed changes are consistent with the Standard Technical Specifications, NUREG-1433, Revision 1, Standard Technical Specifications, General Electric Plants, BWR/4 dated April 1995. The staff verified that the proposed changes conform to the requirements specified in the PAM Instrumentation of NUREG-1433, Section 3.3.3.1.
The licensee proposes to replace the current Notes 1 and 3 with revised Notes 1 and 3. The revised Note 1 addresses action requirements associated with loss of one indication and the revised Note 3 addresses action requirements associated with loss of two indications.
The licensee stated that it is not clear from current Note 1 what actions are required if one indication cannot be restored after the 30-day period specified in the first sentence.
Conservatively, it may be assumed that the last sentence of current Note 1 applies to this condition and that if the lost single indication cannot be restored within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> an orderly shutdown shall be initiated and the reactor placed in a hot shutdown condition in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and a cold shutdown condition in the following 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. However, the meaning of indication
as used in the last sentence of Note 1 may be interpreted as meaning all indication (i.e., both instrument channels). That is, if any one channel is operable, no further action is required, and the statement and shutdown requirements are only applicable to the condition where no indication is operable.
The proposed Note 1 replaces the required shutdown actions with a requirement for a special written report similar to the requirements of current Notes 6 and 7 of Table 3.2.6. and Specification 5.6.8 of NUREG-1433, Revision 1. This change will eliminate the requirement to shut down the reactor following loss of a single parameter indication (i.e., when only one instrument channel is inoperable). The 30-day completion time is based on operating experience and takes into account each PAM instrumentation remaining operable channel, or other non-Regulatory Guide 1.97 instrument channels to monitor the function, the passive (no critical automatic action is assumed to occur from this instrumentation) nature of the instrument, and the low probability of an event requiring PAM instrumentation during this interval. This special written report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative actions. This action is appropriate in lieu of a shutdown requirement, since alternative actions are identified before loss of function capability, and given the likelihood of plant conditions that would require information provided by this instrumentation.
The licensee has committed to update the Bases to indicate that the special written report will include in the outline of actions taken an outline of the preplanned alternative method of monitoring. Therefore, this change to Note 1 is acceptable.
The proposed Note 3 specifically addresses the requirement when no indication is available in the control room. The proposed Note 3 will require that the reactor be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of exceeding the allowed 7-day outage time, which is in conformance with NUREG-1433, Revision 1. This shutdown action requirement is different from the current requirement to restore the inoperable channel to an operable status within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, proceeding to a hot shutdown condition in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and then a cold shutdown condition in the following 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. The completion time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information; therefore, this change is acceptable. The change in end-state from cold shutdown to hot shutdown is also acceptable because these instruments are only required to be operable during power operation.
The current Note 4 does not specify an action requirement if one or two indications per safety/relief valve are inoperable, provided that the specified alternate monitoring capability, which consists of both safety/relief valve discharge temperature and torus water temperature, is available. To overcome this limitation the licensee proposed to replace current Note 4 with the revised Notes 1 and 3.
The proposed Note 3 will address requirements associated with the loss of both safety/relief valve position indications. This Note will provide a 7-day AOT with a 12-hour completion time to achieve hot shutdown, if at least one channel has not been restored to an operable status. The proposed Note 1 will provide the appropriate action in lieu of a shutdown requirement or requirement for the availability of two alternate means for monitoring the safety/relief valve position parameter as stated in current Note 4. The licensee stated that, similar to other PAM instrumentation, a 30-day allowed outage time is appropriate, and there is no need to require
reactor shutdown when one safety/relief valve position indication is inoperable and cannot be restored to an operable status within the 30-day allowed outage time. Proposed Note 1 requires action to report to the Commission within 14 days on actions taken, cause of the failure, and plans for restoration. This change will allow continued operation with one channel inoperable. This change is acceptable based on operating experience and because there is a remaining operable channel to provide the monitoring function, and the special report will adequately address actions taken and planned, such as availability of diverse or alternate monitoring capability. Therefore, this change to replace Note 4 with the proposed Notes 1 and 3 is acceptable.
The current Note 5 is only applicable to the safety valve position indication. The current Note 5 does not specify any required action if one or two alternate monitoring parameter indications per valve are inoperable. Alternate monitoring parameters consist of the safety valve discharge temperature and the primary containment pressure. If safety valve position from an acoustic monitor is unavailable and both alternate parameters are not available, the reactor shall be placed in a hot shutdown condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and a cold shutdown condition in the following 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
Similar to the proposed Notes 1 and 3, the proposed Note 5 will provide a 30-day allowed outage time when the safety valve position indication from an acoustic monitor is inoperable but alternate monitoring capability is available. Proposed Note 5 also provides for a special report to the NRC within 14 days after the 30-day AOT. Continued reactor operation is permitted for 7 days if both means of secondary indications are not operable. If both secondary parameters are not restored to an operable status within the 7-day allowed outage time, the reactor shall be placed in a hot shutdown condition within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. As discussed for proposed TS changes for Notes 1 and 3, the proposed Note 5 will eliminate the limitations of the current Note 5 and is in conformance with NUREG-1433. Based on operating experience, the relatively low probability of an event requiring PAM instrument operation, and the availability of alternate means to obtain the required information, this change to Note 5 is acceptable.
The proposed changes in the Bases section of TS are in conformance with the above changes and the staff has no objection to these changes. However, the licensee has committed to clarify the Bases regarding an outline of preplanned alternative methods of monitoring in the 14-day special report.
The proposed changes to TS Table 3.2.6 will clarify action statements, eliminate unnecessary plant shutdowns, and are in conformance with NUREG-1433, Revision 1. The staff finds the proposed changes to Notes 1, 3, and 5 and the deletion of Note 4 acceptable.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Vermont State official was notified of the proposed issuance of the amendment. The State official had no comments.
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. 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 (67 FR 934).
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 Commissions 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: S. Mazumdar D. Cullison R. Pulsifer Date: May 10, 2002