ML20083Q463

Proposed Change 111 to License DPR-28,allowing Reactor Mode Switch to Be Placed in Startup W/Low Pressure Range Monitors Disconnected During Refueling Outage Testing

ML20083Q463
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	02/22/1983
From:	Heider L VERMONT YANKEE NUCLEAR POWER CORP.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20083Q466	List: ML20083Q463 ML20083Q482
References
FVY-83-11, NUDOCS 8302250403
Download: ML20083Q463 (3)

Text

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VERMONT YANKEE NUCLEAR POWER CORPORATION PROPOSED CHANGE NO. 111 2.C.15.1

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RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 M OU

. ,,,Ly ,g y ENGINEERING OFFICE 1671 WORCESTER ROAD

= FRAMINGHAM, MASSACHUSETTS 01701

. TELEPHONE 617-872-8100 February 22, 1983 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Office of Nuclear Reactor Regulation

Reference:

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

Subject:

Proposed Change to Reactor Protection System Instrument Requirements

Dear Sir:

Pursuant to Section 50.59 of the Commissions Rules and Regulations, Vermont Yankee Nuclear Power Corporation hereby proposes the following modifications to Appendix A of the Operating License.

PROPOSED CHANGE Replace pages 5b, 14a, 19, 21, 21a, 29, and 30 with the attached revised pages 5b,14a,19, 21, 21a, 29, and 30. These pages replace Table 3.1.1, Table 3.1.1 notes, and test with new sections which allow placing the reactor mode switch in Startup with the LPRMs disconnected during refueling outage testing.

REASON FOR CHANGE During refueling outages, the LPRM electrical connections have frequently suffered damage as a result of other under vessel work. This has contributed to LPRM failure, has necessitated extensive maintenance, and has resulted in increased personnel radiation exposure. Allowing disconnection of the LPRMs during refueling outage work and testing would preclude such damage and Table 3.1.1 of the exposure without being detrimental to any safety margin.

existing Technical Specifications allows for LPRM disconnection when the reactor mode switch is in Shutdown or Refuel (subject to the restrictions in Note 1), but requires APRM operability when the mode switch is in Startup.

This requirement is unnecessarily cumbersome during outages when the mode switch is placed in Startup solely for refueling interlock checks.

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.J United States Nuclear Regulatory Commission' . February.22,;1983 Attention: Office of Nuclear Reactor' Regulation- -Page 2

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LSAFETY CONSIDERATIONS The' greatest' reactivity additions available:when-the reactor-vessel head'

~.is;off and the' temperature is less than 2120F are from fuel installation 1 Linto'the-reactor and control rod withdrawal. . Administrative limits _ provide-

protection against_ power levelfincreases during fuel addit' ion and control rod ~

i , withdrawal _is limited to two rods when in the Refuel mode. This Proposed-j Change governs ' outage . testing in the Startup mode with uthe reduced APRM scram

? inoperable under similar conditions to those stated above- lUnder such-circumstances, a 15% power APRM scram capability is overly conservative'since:

l operability of both the high flux IRM scram and;the high flux SRM scram would meet the criteria set. forth in the basis to Section 2.1 of. the Technical' Specifications for : adequate thermal margin between their scram setpoints and

, the-safety limit (25% of rated thermal power). They would also meet the-criterion set forth'in the basis to Section 3.1 for preserving the

-  ; effectiveness of the Reactor Protection System to tolerate a single failure and.still perform its intended function of: scramming the reactor. With full range on the SRMs at approximately 0001% power and .the . IRM scram in range 1 at"approximately 001% power, the APRM reduced flux scram point would never be reached.

Limiting the exemption from APRM-operability to evolutions involving movement 1of not more than two' control rods: insures that the intent of the

. criterion for rate of power rise stated in the basis to Section 2.1 is met and

. adds . assurance that a significant power level increase will not occur.

. Vermont Yankee will implement administrative controls to assure that,- for

. ~the purpose of refueling -interlock checks, no more than two control. rods can t _be withdrawn (provided they are not face adjacent'or diagonally. adjacent) and-4

< that th'e SRM, IRM, and mode switch scrams are-functional, when'the mode switch' I' is in Startup with the LPRMs disconnected.

t Based on the above, we have concluded that the probability of previously evaluated-accident would not be increased by this. change. The possibility of

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a'different type of accident is not created nor are the margins of safety as defined in the bases of the Technical Specifications reduced by th~1s Proposed Change. Therefore, this change does not constitute an unreviewed safety '

question as defined in 10CFR50.59(a)(2).

This submittal has.been reviewed.by the Vermont Yankee Nuclear. Safety-p Audit.and Review Committee.

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FEE DETERMINATION

-This Proposed Change requires an approval that involves a single safety issue and is deemed not.to involve a significant hazard consideration. For

!= these reasons, Vermont Yankee Nuclear Power Corporation proposes this as a Class III_ Amendment. A payment of $4,000.00'is enclosed.

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-United States Nuclear Regulatory Commission.

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February 22, 1983

. Attention: Office of Nuclear Reactor Regulation Page 3

! SCHEDULE OF CHANGE This change is requested to support our scheduled refueling outage. We-therefore request that the NRC approve this change by March 1, 1983.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION' L. H. Heider Vice President JBS/dd COMMONWEALTH OF MASSACHUSETTS)

)ss MIDDLESEX COUNTY ).

~Ihen personally appeared before me, L..H. Heider, who, being duly sworn, did state that he is a Vice President of Vermont Yankee Nuclear Power Corporation, that he is duly authorized to execute and file the foregoing request in the name and on the behalf of Vermont Yankee Nuclear Pcwer Corporation and that the statements therein are true to the best'of his knowledge and~ belief.

(f. B. Sinclair. Notary Public

My Commission Expires June 1, 1984 w

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