ML20117C390
| ML20117C390 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/22/1996 |
| From: | Reid D VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20117C394 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 BVY-96-99, GL-83-36, NUDOCS 9608270378 | |
| Download: ML20117C390 (4) | |
Text
VERMONT YANKEE NUCLEAR POWER CORPORATION Ferry Road, Brattleboro, VT 05301-7002
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ENGINEERING OFFICE 580 MAIN STREET l
BOLTON, MA 01740 (508)779-6711 l
August 22,1996 BVY 96-99 i
United States Nuclear Regulatory Commission l
ATTN: Document Control Desk Washington, D.C. 20555
References:
(a)
License No. DPR-28 (Docket No. 50-271)
(b)
NRC Generic Letter No. 83-36, NUREG-0737 Technical Specifications, November 1,1983
Subject:
Proposed Change No.181, High Range Stack Monitor Action Statement i
I Pursuant to Section 50.90 of the Commisalon's Rules and Regulations, Vermont Yankee Nuclear Power Corporation hereby proposes the following change to Appendix A of the facility Operating License l
[ Reference (a)].
Proposed Chance This proposed change removes the existing action statement for the High Range Stack Noble Gas Monitor and replaces it with an action statement based on the guidance provided in Reference (b).
I The change proposed is as follows:
(1)
Page 55, Section 3.2.G., Table 3.2.6, Note 7. Delete the existing note and replace with the l
following: "From and after the date that this parameter is unavailable by Control Room indication, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> insure that local sampling capability is available. If the Control Room indication is not restored within 7 days, prepare and submit a Special Repon to the NRC within 14 days following the event, outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to operable status."
l Reason / Basis for Changg n
b 1
This Proposed Change will remove the action statement requiring reactor shutdown after 30 days of Inoperability of the High Range Stack Gas Monitor and substitute an action statement consistent with k.
the guidance provided in NRC Generic Letter 83-36. Enclosure 1 to Reference (b) rrovides the following guidance concerning Noble Gas Effluent Monitors (NUREG-0737 item II.F.1.1):
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9608270378 960822 PDR ADOCK 05000271 i
P PDR.
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bis. Nuc' lear R:gulatory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION August 22,1996 Page 2.
I Noble Gas Effluent monitors provide information, during and following an accident, which is considered helpful to the operator in assessing the plant condition. It is l
desired that these monitors ba operable at all times during plant operation, but they are l
not required for safe shutdown of the plant. In case of failure of the monitor, appropriate actions should be taken to restore its operational capability in a reasonable period of time. Considering the importance of the availability of the equipment and possible delays involved in administrative controls.-7 days is considered to be the appropriate time period to restore the operability of the monitor. An alternate method for monitoring the effluent should be initiated as soon as practical, but no later than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the identification of the failure of the monitor. if the monitor is not restored I
to operable condition within 7 days after the failure, a special report should be l
submitted to the NRC within 14 days following the event, outlining the cause of the inoperability, actions taken and the planned schedule for restoring the system to operable status.
The High Range Stack Noble Gas Monitor consists of a single instrument with no redundant counterpart. This change will minimize the potential for an unnecessary shutdown in the event the instrument is damaged by lightning, or otherwise out of service and cannot be immediately repaired.
Safety Consideration The High Range Stack Monitor provides an estimate of gross stack activity that has exceeded the upper limit of the normal range instrumentation. The High Range Monitor reading serves as input to dose projection systems for initial estimation of off-site conditions. The monitor reading would be used prior to the acquisition of stack isotopic sample data which would provide a more accurate indication of stack activity.
Due to the passive function of the instruments and the ability to monitor this parameter utilizing j
alternate methods, it is not appropriate to impose stringent requirements on the operation of the unit.
Further, the proposed required action to restore, provide an alternate method of monitoring, and report any long term inoperability will minimize the potential for plant transients that can occur during required shutdowns. This monitor is identified in the Vermont Yankee Reg. Guide 1.97 submittal as Category 2, Type E. This monitor provides post accident information for use in determining the magnitude of the release of radioactive materials and for monitoring such release. However, the High Range Stack j
Monitor does not have any safety function associated with the prevention or automatic mitigation of
~ design basis accidents, neither does it provide primary information needed to permit the control room operating personnel to take required manually controlled actions.
This Proposed Change has been reviewed by the Vermont Yankee Plant Operations Review Committee and Nuclear Safety Audit and Review Committee.
4 Slanificant Hazards Consideration The Standards used to arrive at a determination that a request for amendment involves no significant hazards are included in the Commission's regulations (10CFR50.92) which states 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 previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant
b,S. Nuc'leIr Regulatory Ccmmission VERMONT YANKEE NUCLEAR POWER CORPORATION August 22,1996 Page 3.
l reduction in a margin of safety. In addition, the Commission has provided guidance in the practical l
application of these criteria in 51FR7751, dated March 6,1986.
The discussion below addresses each of these criteria and demonstrates that the proposed amendment involves no significant hazards consideration.
l 1)
The High Range Stack Monitor is a RG 1.97, Category 2, Type E instrument with no specified i
safety function associated with the prevention or automatic mitigation of design basis accidents, neither does it provide primary information needed to permit the control room l
operating personnel to take required manually controlled actions. The proposed change to the action statement associated with this monitor will not change the function of this monitor, and since the monitor is not assumed to initiate any accidents, nor function to mitigate any accidents, this change will not significantly increase the probability or consequences of any previously analyzed accident.
i 2)
The proposed change does not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant i
operation. The proposed change will still ensure effective methods are available to assess post accident conditions. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
l 3)
The proposed change to the action statement associated with this monitor will not change the l.
function of this monitor, and since the monitor is not assumed to function for the prevention or mitigation of any previously evaluated accidents, this change will not significantly reduce a margin of safety.
Based on the above discussion, we have determined that this change does not constitute a significant j
hazard consideration as defined in 10CFR50.92(c).
j Schedule of Chance The proposed change will be incorporated into Vermont Yankee Technical Specifications as soon as practicable following receipt of your approval.
We trust that the information provided above adequately supports our request. However, should you have any question in this matter, please do not hesitate to contact us.
Sincerely, l
Vermont Yankee Nuclear Power Corporation l
Donald A. Reid Vice President, Operations cc:
USNRC Region 1 Administrator USNRC Resident inspector - WNPS USNRC Project Manager - WNPS
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b,S. Nuc' liar R;gul: tory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION August 22,1996 Page 4, y SANO 4
NOTARY STATE OF VERMONT
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pyggg WINDHAM COUNTY
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7 Then personally appeared before me, Donald A. Reid, who, being duly id state that h i President, Operations, of Vermont Yankee Nuclear Power Corporation, that he is duly autho e foregoing n
document in the name and on the behalf of Vermont Yankee Nuclear Power Corporatio,
ents therein are true to the best of his knowledge and belief.
Salli A. Sands (rum, Nofary Public My Commission expires February 10,1999
.