ML20128E768

Summary of 921216 Meeting W/Vynp in Rockville,Md Re Licensing Issues Related to Plant.List of Attendees Encl

ML20128E768
Person / Time
Site:	Vermont Yankee
Issue date:	02/04/1993
From:	Dan Dorman Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
GL-84-15, GL-88-01, GL-88-1, NUDOCS 9302110065
Download: ML20128E768 (19)

Text

_ - _ _ _ _ - _ . _ _ _

6 L . M o

'~,,

UNITED STATES 8' c NUCLEAR REGULATORY COMMISSION

{ ,I WASHINGTON, D. C. 20555 February 4, 1993

/

Docket No. 50-271 LICENSEE: Vermont Yankee Nuclear Power Corporation FACILITY: Vermont Yankee Nuclear Power Station

SUMMARY

OF DECEMBER 16, 392, MEETING WITH REPRESENTATIVES OF VERMONT YANKEE NUCLEAR WER CORPORATION On December 16, 1992, pursuant to notice, the NRC staff met with representatives of Vermont Yankee Nuclear Power Corpo' ration at Rockville, Maryland, to discuss licensing issues related to the Vermont Yankee Nuclear Power Station (VY). A list of attendees and a copy of the licensee's handouts dispensed at the meeting are provided as Enclosures 1 and 2, respectively.

The licensee provided a copy of a letter dated December 15,1E92 (Enclosure 3), forwarding proposed Technical Specification (TS) change No.166, "One-Time Extended Emergency Diesel Generator (EDG) LC0 Period to Support Maintenance Activities". The licensee discussed the recent history of cylinder liner failures in the VY 'A' EDG, the corrective maintenance performed on 'A' EDG, the recommendations of the licensee's EDG task force, and the licensee's plans to conduct preventative maintenance on the 'B' EDG during its periodic overhaul early in 1993.

The licensee also provided a copy of a letter dated December 15, 1992 (Enclosure 4), forwarding proposed TS change No. 167, " Calibration Requirements _for Control Rod Block Instrumentation". The licensee considers the propo wd change to be an administrative change to correct an error in the TS regarding calibration of the Startup Range Monitor and the Intermediate Range Monitor in the condition " Detector Not Fully Inserted".

The licensee addressed reduction in frequency of EDG. fast starts. In Generic letter (GL) 84-15, the NRC staff recommended several actions to reduce potential adverse impact of surveillance on EDG relWlity. The licensee stressed that it had implemented the staff's recomme.Jations at that time including reduction in the frequency of fast starts to once-a-month. In response.to a recommendation of the licensee's EDG task force, the licensee now intends to request further reduction in EDG fast start frequency to once every six months.

The licensee's In-Service Testing (IST) submittal of November 30, 1992, was discussed. It included a request for a nine-month extension of the second ten-year interval due to an extended outage during that interval. The licensee had requested review of the submittal by May 1,1993. The staff indicated that the schedule was acceptable.

Regarding the licensee's proposed TS change No. 147 on SLC/ARI changes due to the ATWS rule, the licensee indicated that it will forward corrected TS pages to the staff. The diversity issue was addressed. The licensee is preparing a 9302110065 930204 -

.e l PDR ADOCK 05000271 - < l P

PDR ,,, a w s- +

i

- - i 7

February 4, 1993 l

new proposal regarding implementation of diversity at VY in acccrdance with the ATWS rule.

The licensee indicated that it was confused by the staff's response to the licensee's commitments regarding seismic qualification of equipment (Unresolved Safety Issue A-46). The licensee is preparing a letter to the staff requesting clarification. The licensee emphasized that this request for clarification is not intended to slip or delay the schedule to which they had previously committed for implementation of the Generic Implementation Procedure generated by the Seismic Qualification Utility Group.

Regarding the leak rate detection position of GL 88-01, the licensee's letter of October 27, 1992, withdrew the backfit claim from the licensee's letter of September 21, 1992. The staff will provide the licensee with a letter stating the basis of the staff's position that the leakage rate detection requirement should reside in the plant TS, and the staff's assessment of the licensee's position as stated in previous submittals of March 8, 1990, and September 21, 1992.

The NRR Project Manager indicated that the staff is still reviewing the Quality Assurance Program for VY and Yankee Rowe that was submitted by Yankee Atomic Electric Company (YAEC) on October 21, 1992. The staff's review will exceed the 60 days specified in 10 CFR 50.54 due to the large number of changes included in this revision. The staff expects to complete its review in January 1993.

The licensee confirmed a commitment previously made during a telecon on December 7,1992, to clarify the TS Bases on Low Pressure Coolant Injection operability when the associated room cooler has been rendered inoperable.

This correction to the TS Bases may be accomplished pursuant to 10 CFR 50.59.

The licensee indicated that it could not locate one reference cited in the staff's corrected SER on the LOCA analysis computer code, RELAP SYA,' forwarded by letter dated October 21, 1992. Specifically, the reference cited a letter dated July 9,1991, from L. A. Tremblay of YAEC to Patrick M. Sears of the NRC staff regarding response to a fourth request for additional information on use of RELAP SYA. The staff committed to determine the nature of the reference.

/S/

Daniel H. Dorman, Project Manager Project Directorate I-3 Division of Reactor Projects - I/II

Enclosures:

DISTRIBUTION:

1. List of Attendees -Docket File H. Butler JLinville,RI-

2. Licensee's Handout NRC & Local"PDRs D. Dorman

3. Proposed Change No. 16e PDI-3 Reading T. Clark

4. Proposed Change No. 167 'i. Murley/F.Miraglia OGC J. Partlow E. Jordan cc w/ enclosures: S. Varga ACRS (10)

See next page J. Calvo V. McCree, EDO OFFICE LA:PD,I-3/) PM:PDI-3 h lq D:PDI-3 5 fl NAME TC1 h b DDorman:mw WButler W DATE

) /Y/93 1/ Y/93 1/0/93 / / / / {

OFFICIAL RECORD COPY FILENAME: VYHTSUM.

February 4,-1993 new proposal regarding implementation of diversity at VY in accordance with the ATWS rule.

The licensee indicated that it was confused by the staff's response to the licensee's commitments regarding seismic qualification of equipment (Unresolved Safety Issue A-46). The licensee is preparing a letter to the staff requesting clarification. The licensee emphasized that this request for clarification is not intended to slip or delay the schedule to which they had previously committed for implementation of the Generic Implementation Procedure generated by the Seismic Qualification Utility Group.

Regarding the leak rate detection position of GL 88-01, the licensee's letter of October 27, 1992, withdrew the backfit claim from the licensee's letter of September 21, 1992. The staff will- provide the licensee with a letter stating the basis of the staff's position that the leskage rate detection requirement should reside in the plant TS, and the staff's assessment of the licensee's -

position as stated in previous submittals of br'h 8,1990, and September 21, 1992.

The NRR Project Manager indicated that the staff is still reviewing the Quality Assurance Program for VY and Yankee Rowe that was submitted by Yankee Atomic Electric Company (YAEC) on October 21, 1992. The staff's review will exceed the 60 days specified in 10 CFR 50.54 due_to the large number of changes included in this revision. The staff expects to complete its review in January 1993.

The licensee confirmed a commitment previously made during a telecon on December 7,1992, to clarify the TS Bases on Low Pressure Coolant Injection operability when the associated room cooler has been rendered inoperable.

This correction to_the TS Bases may be accomplished pursuant to 10 CFR 50.59.

The licensee indicated that it could not locate one reference cited in the staff's corrected SER on the LOCA analysis computer code, RELAP SYA, forwarded by letter dated October 21, 1992. Specifically, the reference cited a letter dated July 9,1991, from L. A. Tremblay of YAEC to Patrick M.- Sears of the NRC.

staff regarding response to a fourth request for additional information on use of RELAP 5YA. The staff committed to determine the nature of the reference.

a. . . . _

Daniel H. Dorman, Project Manager Project Directorate I-3 Division of Reactor Projects - I/II

Enclosures:

1. List of Attendees

2. Licensee's Handout

3. Proposed Change No. 166

4. Proposed Change No. 167 cc w/ enclosures:

See next page

Mr. J. P. Pelletier, Vice President Vermont Yankee Nuclear Power Station cc:

Mr. Jay Thayer, Vice President G. Dana Bisbee, Esq.

Yankee Atomic Electric Company Office of the Attorney General 580 Main Street Environmental Protection Bureau Bolton, Massachusetts 01740-1398 State House Annex 25 Capitol Street Regional Administrator, Region I Concord, New Hampshire 03301-6937 U. S. Nuclear Regulatory Commission 475 Allendale Road Resident Inspector King of Prussia, Pennsylvania 19406 Vermont Yankee Nuclear Power Station U.S. Muclear Regulatory Commission R. K. Gad, III P. O. Box 176 Ropes & Gray Vernon, Vermont 05354 One International Place Boston, Massachusetts 02110-2624 Chief, Safety Unit Office of the Attorney General Mr. Richard P.'Sedano, Commissioner One Ashburton Place,19th Floor Vermont Department of Public Service Boston, Massachusetts 02108 120 State Street, 3rd Floor Montpelier, Vermont 05602 Mr. David Rodham, Director Massachusetts Civil Defense Agency Public Service Board 400 Worcester Rd.

State of Vermont P.O. Box 1496 120 State Street Framingham, Massachusetts 01701-0317 Montpelier, Vermont 05602 ATTN: James Muckerheide Chairman, Board of Selectmen Mr. Raymond N. McCandless Town of Vernon Vermont Division of Occupational Post Office Box 116 and Radiological Health Vernon, Vermont 05354-0116 Administration Building.

Montpelier, Vermont 05602:

Enclosure 1-LIST OF ATTENDEES LICENSING ISSUES MEETING REGARDING VERMONT YANKEE NUCLEAR POWER STATION ROCKVillE. MARYLAND DECEMdER 16. 1992 NAME AFFillATION IIILE Dan Dorman NRC/DRPE/ Project Directorate I-3 Project Manager Len Tremblay Yankee Atomic Electric Company Sr. Licensing Engineer VY Project Dean Porter Vermont Yankee Nuclear Power Corp. Engineering Project Sup.

Wm. Snerman Vt. Department of Public Service State Nuclear Engineer l

1

, Enclosure 2l

'4-

- DECEMBER ~ 16.1992' MEETING AT NRC / NHR ,;

VERMONT YANKEE LICENSING ISSUES .

Pmposed Change No.166, Extended EDO LCO Period -

--- Proposed Change No.167, Calibration Requirements for-Control Rod Block (SRAMRM)

Instrumentation (Administrative change)  ;

Proposed Change to reduce the number of EDG fast starts

- IST Program Submittal of'Ihlrd 10 Year Interval and 6 month Response to TER Proposed Change No.147, SLC/ARI/RIrr Changes due to ATWS Rule t

10CFR20.302 Application for Chem. Line Sink Drain -

,,o GL 87-02, Suppl.1 A-46 SQUG Commitments

- GL 88-01 Leakage in Containment Issue e

T t

9

.y -

)

8> -

VERMONT YANKEE NUCLEAR POWER CORPORATION r

.k Ferry nond. Brattleboro. VT 050017002 b yh Ef -

ENGINEE IN OFFICE ssou m sneer

j- s ecaos nomo ace, "wn s

December 15,1992 BVY 92139 United States Nuclear Regulatory Commisalon ATTN: Document Control Desk Washington, DC 20555

References:

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

(b) Letter, VYNPC to USNRC, BVY 92-060, dated June 3,1992 (c) Letter, USNRC to VYNPC, NVY 92-095, dated June 4,1992 (a) Letter, VYNPC to USNRC, BVY 92-074, dated June 29,1992 (e) Letter, USNRC to VYNPC, NVY 92127, dated July 1,1992

Subject:

Proposed Change No.166, One Time Extended Emergency Diesel Generatpr (EDG) LCO Period to Support Maintenance Activities

Dear Sir:

Pursuant to Section 50.59 of the Commission's Rules and Regulations, Vermont Yant(ee hereby proposes the following changes to Appendix A of the Operating License (Reference (a)].

Proposed Chanog This request proposes to replace Page 94 of the Vermont Yankee Technical-Specifications with the attached revised Page 94 Section 3.5.H.1 on Page 94 presently stipulates a Limiting Condition for Operation of seven (7) days with one Emergency Diesel Generator out of service. This request proposes to change Section 3.5.H.1 by allowing a one-time extension of the seven (7) day LCO to fourteen (14)-

days during the current operating cycle (Cycle 16) to permit extensive maintenance to be performed on the "B" EDG while the reactor is at power.

l VERMONT YANKEE NUCLE AR POWER CORPO~) AT60N U.S. Nuclear Regulatory Commission December 15,1992 Page 2 NRC approval of !his proposed chango would allow continued reactor operation for an additional seven days t eyond the present seven day LCO period (14 days total) for a one timo cylinder liner replacement and routino preventive maintenance activities on the "B' EDG during the present power cycle (Cycle 16). The extension period will allow tufficient time to periorm the planned maintenanco activity and to thoroughly test the "B" EDG beforo returning it to service.

Reaton for Chanaq On May 28,1992, and again on June 23,1992, the "A" EDG was declared inoperable, in each of theso cases, during a routino monthly EDG surveillance, abnormalities were encountered with the Jacket cooling system. Upon engina disassembly, cracks were discovered in two (2) cylinder liners. For each of these occurrences, Vermont Yanken requested a temporary walvor of compilanco

[ References (b) and (d)) to extend the LCO period such that repairs and proper testing could be mado at power prior to restoring the "A" EDG to se vice. Both of these requests were approved by NRC [ References (c) and (e)]. In the r,econd Instance, the maintenance performed included replacement of all cylinder liners, on the " A" EDG, with new improved liners. The " A" EDG was returned to service within the extended LCO period and has sinco encountered no performance problem re'ated to the cylinder liner replacement.

Following each of those occurrences, Vermont Yankoo periormed a detailed Root Cause Analysis (RCA) to investigate the cause of the speelfic failures. In addition, an EDG Task Force was assembled to review the overall EDG ma'ntenance and surveillanco programs Both of those efforts have been completed and a number of recommendations have been made to management. Vermont Yankee han already implemented some of the recommendations and is in the process of implementing the remainder. One of the recommendations was to replace cylinder liners on '.he "B" EDG coincident with the next scheduled overhaul.

Surveillance testing of the "B" EDG has not revealed any indication of the cylinder liner problems that occurred on the "A" EDG, However, it is prudent to make the same improvements to the "B" EDG that have already been made to the " A" EDG at the earliest opportunity. As a result, Vermont Yankee plans to periorm replacement of all cylinder liners during the next scheduled 18 month overhaul of the "B" EDG.

During this maintenanco period, we also plan to replace the " inverted 'Y' housing" as a result of Vermont Yankee experienco with broken bolts on this componont In'1992 and a Fairbanks Morse Service Information Letter (SIL). In addition, wo will be performing the preventative maintenance tasks normally associated with the schedu'ed 18 month overhaul of the "B" EDG.

I .

VERMONT YAteKEE NUCt. EAR DOWER CORPORATION U.S. Nuclear Regulatory Commission l December 15,1992 Page 3

. Basis for Channe Fourteen (14) days are required to completo the maintenance associated with cylinder liner replacement, replacement of the " inverted 'Y' housing" and porformance of the proventative maintenanco tasks normally associated with the scheduled 18 month overhaul of the "B" EDG. The echeduled 18 month overhaul, including post.

maintenance testing, typically requires most of the allowed 7-day EDG LCO period.

The cylindor liner replacement on the a A" EDG conducted in June, including the required augmented testing, required more than the allowed 7-day LCO, The augmented testing that is planned prior to declaring the "B" EDG operable includes:

operating the englno continuously for approximately twenty-one (21) hours at loads varying from "no load" to 100% load, allowing the EDG to cool down for a minimum of eight (8) hours, thon performing an eight (8) hour operability run. The return of the "B" EDG to operable status v>ould occur after successful complotion of the first one (1) hour of the eight (8) hour operability run. This testing would be conducted with careful monitoring of key diosol engine parameters to further substantiato satisfactory operation, in order to perform this extensive preventative maintenance effort and the additional task of replacing the cylinder liners, including special testing, edditional time is needed beyond the existing seven (7) day LCO period provided in Technical Specifications. Therefore, Vermont Yankee is requesting a one time extension of the present seven (7) day LCO to fourteen (14) days to allow for implementation of those improvements during the current power cycle (Cycle 16).

We believe that approval of a seven day LCO extension will provide sufficient margin to repair and thoroughly test the EDG without compromising the continued safe operation of the plant. As we indicated above, a significant portion of the additional LCO time would be for "run in" of the new components and operability testing. The EDG would be avallable during this period, but not considered operable until testing has been satisfactorily completed.

Upon NRC approval of this proposed change, Vermont Yankee would then utilize the one time LCO extension for the express purpose of performing the "B" EDG maintenance activity, described herein, during Cycle 16 operation at power. Vermont Yankoo is in the process of preparing the necessary procodures, schedules and procuring the parts and equipment necessary to perform this maintenance activity.

It is anticipated that we will be in a position to perform this activity sometime within the first four months of 1993.

m ____.m.m _

VERMONT YANKEE' NUCL.E AR POWER CORPOR ATION U.S. Nuclear Regulatory Com mission December 15,1992 Page 4 As required by Technical Specifications, the alternate EDG will be tested and all of the Low Pressure Core Cooling and Containment Cooling Subsystems connected to the operable EDG will be verifled operable prior to declaring the "B" EDG inoperable and entering the LCO period, in addition, Vermont Yankee procedures require the Station Manager of the Vernon Hydro Station to be contacted to ensure that continued availability of power is expected on the dedicated tie Ilne to Vermont Yankee prior to and for the duration of the LCO period.

A thorough review of all other planned surveillance activities will be performed prior to entering the LCO period and only those determined to be of low risk to eaulpment or system availability will be allowed.

Safety _Qonsidg.r_ajlons In order to provide added assurance that the " A" EDG will perform its function if required, the "A" EDG will be tested for operability prior to entering into the "B" EDG LCO period. The Technical Specifications also require that during the LCO period, all remaining Low Pressure Core Cooling and Containment Cooling Systems connected to the operable EDG remain operable. Vermont Yankee has developed a detalled LCO maintenance plan for EDG LCO maintenance. This plan has been successfully used during prior EDG LCO maintenance and will be invoked for this evolution as well, in addition, the Vernon Hydro Station dedicated tie-line, which historically has demonstrated a very high reliability,is required by Vermont Yankee procedure to be available to supply power to Emergency Bus 3 during the "B" EDG

' 20. Any previously analyzed event postulated daring the seven day extension period can be mitigated by the other available systems. The proposed LCO extension has no significant impact on the consequences of any previously analyzed event.

The proposed extension would allow the "B" EDG to remain inoperable for an additional seven days heyond the present seven day LCO allowed by Technical Specifications. The unavailability of one EDG is not a part of the initiation of cny of the analyzed accidents. Therefore, the proposed change does not increase the probability of an accident previously evaluated.

This proposed change has been reviewed by the Vermont Yankee Plant Operations Review Committee and the Vermont Yankee Nuclear Safety Audit and Review Committee.

, VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission December 15,1992 Page 5 Slanificant Hazards Consideratiga The standarts 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 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 reduction in a margin of safety.

The discussion below addresses the proposed change with recpect to these three criteria and demonstrates that the proposed amendment involves no significant hazards consideration:

1 Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change would not involve a significant increase in the probability '

or consequences of an accident previously evaluated. As discussed above, a seven day extension to an altaady existing seven day LCO period would invc!vi no significant increase in the probability of occurrence or consequences of a design basis accident during the extension period.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?  ;

The proposed change would not create the possibility of a new or different kind of accident from those previously evaluated. The proposed change would have-no impact on the possibility of a new or different initiating event. The proposed change requests a one time extension of 7 days beyond the already authorized 7 day "B" EDG LCO. Any previously analyzed event postulated during the '

seven day extension period 'can be mitigated by the other available systems.

3. Does the change involve a significant reduction in a margin of safety?-

The proposed change would not involve a significant reduction in the margin of safety. As discussed above, approval of this request involves an insignificant reduction in the margin of. safety because ~of the availability.of other plant electrical systems, including the'Vernon tie line, and the short duration of the j extension period.

en **wg- >w& e--tefa m' e- wer- emtev %--e

~

VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission December 15,1992 Page 6 Based upon the above, Vermont Yankee concludes that the proposed change does not constitute a significant hazards consideration as defined in 10CFR50.92(c).

. Schedule of Chan_gg This proposed change will be incorporated into the Vermont Yankee Technical Specifications as soon as practicable following recolpt of your approval.

Vermont Yankee plans to utilize the one time extended LCO provision for the "B" EDG during the current power cycle (Cycle 16).

Vermont Yankee will keep the NRC Senior Resident inspector informed of our progress In preparing for this maintenance activity and will notify the NRC Senior Resident inspector in advance of entering this extended maintenance LCO.

We view the proposed activity as a positive contributor toward our mutual goal of maintaining a high degree of plant safety through improved equipment reliability, We trust that the Information provided herein adequately cupports our request, however, should you have any questions or should you need to discuss this matter further, please contact this office.

Very truly yours, Vermont Yankee Nuclear Power Corporation k

Warren P.yurph f 4+n f '

Senior Vice Preside p rations cc: USNRC Reglon i Administrator USNRC Resident inspector - VYNPS f

4 '

\ N USNRC Project Manager VYNPS STATE OF VERMONT )

) SS WINDHAM COUNTY )

Then pctsonally appeared before me, Warron P. Murphy, who, being duly swo,rn, did state that he is Senior Vice President. Operations of Vermont Yankee Nuclear Power Corporation, that he is authorized to execute and file the foregoing document in the name and on the behalf of Vermont Yankee Nuclear Power Corporation and that the statements therein are true to the best of his knowledge and belief.

Sally A. Safidstrum Notary Public j i

My Commission Expires February 10,1995

VYNPS -

3.5 LIMITING CONDITIONS.FOR OPERATION 4.5 SURVEILLANCE REQUIREMENTS -

3. If the requirements of Specification 3.5.G cannot.be met.'an orderly shutdown shall be initiated and the reactor pressure shall be reduced to 120 psig within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

. H .' Minimum Core and Containment Coolinq System- H. Minimum Core and Containment Cooling System Availability Availability

1. During any period when one of the standby- 1. When one of the standby diesel generators is diesel generators is inoperable, continued made or found to be inoperable. the remaining reactor operation is permissible only during diesel generator shall have been or shall be the succeeding seven days, or the succeeding demonstrated to be operable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

fourteen days for a one-time extended maintenance activity for the *B* standby diesel generator during Cycle 16, provided that all of.the Low Pressure Core Cooling and Containment Ccoling Subsystems connecting to the operable- diesel' generator shall be operable. If this requirement cannot be met.

an orderly shutdewn shall be initiated and the reactor shall be in the cold. shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2. Any combination of inoperable components in the Core and Containment Cooling Systems shall not defeat'the capability.of the remaining operable components to fulfill the core and containment cooling functions.

3. When irradiated fuel is in the reactor vessel and the react' 'is in the. cold shutdown ,

condition. .' '*re and Containment Cooling Subsystems may us inoperable provided no work is permitted which has.the potential for

. draining the reactor vessel.

Amendment No. N. H4 94

, e . . . . -. _ _ -. - _ _ - - _ . _ - _ _ _ _ - _ _ _ _ _ _ . __

EnCIO$ UFO 4 VERMONT YANKEE NUCLEAR POWER CORPORATION

• g Ferry Road, erattleboro, VT 053017002 e, *. a

[

ENGINEERING OFFICE G' ,

S.f;}

$B3 M Al'd $i A&&T

../ BottON VA 01?40 (Mt 779 6711 December 15,1992 BVY 92140 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

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

Subject:

Proposed Change No.167, Calibration Requirements For Control Rod Block Instrumentation

Dear Sir:

Pursuant to Section 50.90 of the Commission's Rules and Regulations, Vermont Yankee Nuclear Puwer Corporation hereby proposes the following change to Appendix A of the operating license Reference (a).

Proposed ChaH92 Replace Page 59 of the Vermont Yankee Technical Specifications with the attached re<! sed Page 59. A change to Page 59 is being proposed to correct the -

surveillance requirements applicable to the calibration of equipment responsible for the "Detoctor Not Fully Inserted" Trip Function for the Startup Range Monitor (SRM) and Intermediate Range Monitor (IRM).

The specific change is to correct the calibration interval for a SRM and IRM

" Detector Not Fully inserted" Trip Function, it is proposed to change the interval from "a required frequency not to exceed once por week" to "NA" (Not Applicable). A calibration requirement is not applicable to equipment performing this function, it is believed that the Note 6 entry dictating calibration frequency was an error. Actual maintenance and functional testing performed on the equipment of concern will not chango. Therefore, this change is considered to be Administrative.

a---,-- ___

VERMONT YANKEE NUCLEAR POWER CORPORADON U.S. Nuclear Regulatory Commission December 15,1992 Page 2 I

I Rearon for Chanao I l

We are proposing a change to the Technical Specification calibration requiremer.ts in Table 4.2.5 to reflect that no meaningful callbration of the SRM and  !

IRM " Detector Not Fully Inserted" Control Rod Block function is possible. Verification of proper operation of the " Detector Not Fully inserted" Trip Function is provided by l functional testing. As such, it is proposed to change the " Note 6" entry under  ;

calibration to "NA" In Table 4.2.5. Actual surveillances and testing presently performed on the subject equipment will not change. A "NA" entry for this requirement is consistent with the requirements in the BWR Standard Technical Specifications and with requirements existing in Technical Specifications of other BWRs.

Basis for Chance Table 4.2.5 has been rovised to include a "NA" entry under calibration frequency for the SRM and IRM " Detector Not Fully inserted" Trip Function. Vermont  :

Yankee docs not consider any of the actions performed to assure proper operation of this trip function to fall under the category of calibration nor do we believe that any additional actions other than functional testing are necessary. Additional assurance of proper equipment operation is provided by periodic maintenance on this equipment.

Only the listed calibration frequencyin the Technical Specifications has changed. The correction in calibration frequency will not change any of the surveillances or testing which are currently being performed. All the required maintenance will remain the same. The callbration requirements have been revised to agree with those which currently exist .in the BWR Standard Technical Specifications and in Technical Specifications of other BWRs. This change will not pose any change to the design basis, protective function, redundancy, trip point, or logic of the criginal system, flafety Conside.tptions The change in the surveillance requirements for SRM and IRM " Detector Not Fully inserted" calibration will not change the function of any equipment. Current maintenance and functional testing will assure component operability of this equipment.

The SRM and IRM equipment installed at Vermont Yankee has proven to function properly with the tests and calibrations presently being performed in accordance with applicable Technical Specification requirements.

VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission December 15,1992 Pago 3 The requested change to the calibration frequency of the " Detector Not Fully inserted" Rod Block function does not impact any FSAR safety analysis nor does it involve any change in Technical Specification setpoints, plant operation, protective function or design basis of the plant. Assurance of equipment operation is still provided by the functional tests, calibrat!cns and maintenance, which are still to be performed, such that intended Control Rod Block Functions are provided.

The proposed change has been reviewed by the Plant Operations Review Committee and the Vermont Yankee Nuclear Safety Audit and Review Committee.

Sicnificant Hazards Considerptions 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 previously evaluated, 2) create the possibility of a new or different kind of accident from any accident previously evaluated, or 3) involve a significant reduction in a margin of safety.

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

1. The proposed change to correct the " Detector Not Fully inserted" calibration interval from "not to exceed once per week" to "NA" reflects what is considered to be a correction to the Technical Specifications. The proposed calibration interval is consistent with that which appears in the BWR Standard Technical Specifications and the Technical Specifications of some other BWRs.

The procedures currently performed to assure the " Detector Not Fully inserted" Function is operable are actually covered by functional testing and equipment maintenance. This existing testing and maintenance, which will not change, has dernonstrated that it is appropriate to assure reliable operation of the -

subject trip functions. The proposed change does not result in any system hardware modification or new plant configuration. The requested change to the existing calibration interval does not impact any FSAR safety analysis involving the Control Rod Block System. Operability is still assured and Control Rod Block Functions are still provided as required. Therefore,it is concluded that

• l w -

i VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission December 15,1992 Page 4

)

there is not a signifier..nt increase in the probability or consequence of an i accident previously evaluated.  !

2. The proposed change to correct the calibration Interval for control rod block _

instrumentation meets the Intent of Technical Specification requirements for  !

assuring operation of equipment as designed. This change does not relieve the operation of the Control Rod Block Instrumentation from existing requirements l

and this instrumentation system is still bounded by the assumptions used in the  :

H safety analysis. Based upon past operational history, current functional testing and maintenance performed at Vermont Yankee adequately assure operntion as designed, The proposed change does not involve any change in Technical Specification setpoints, plant operation, redundancy, protective function or i design basis of the plant. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously j evaluated.

3. Changing the calibration Interval for the SRM and IRM " Detector Not Fully Inserted" Function from "nnt to exceed once per week" to "NA" does not affect any existing safety margins. Operation, testing and maintenance of this control rod block instrumentation will remain the same. The change is considered an Administrative change since it is believed to be correcting an error. None of the surveillances and testing presently performed .on the instrumentntion- will-change. Also, there are no additional surveillances required to be performed on this instrumentation. System function an i design basis is maintained.

Assurance that Control- Rod Block Instrumentation operates-within limits determined to be acceptable continues to be provided._ Based upon the above, it is concluded that the proposed . change does not involve a significant reduction in a margin of safety.

The Commission has provided guidance for the applicatlon of the standards in 10CFR50.92 by providing certain examples (51FR7751, dated March 6,1986) of actions likely to involve no significant hazards consideration. One of these.

examples (i) is a purely administrative change to the Technical Specifications;;

for example, a change:to achieve consistency throughout the Technical -

Specifications, correction of an error, or a change in nomenclature. This . -

proposed change falls within the scope of this Commission example since it involves correcting a Technical Specification entry but not deleting any of the present surveillance or testing performed on the subject equipment. ,

~ _

• VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission December 15,1992 Page 5 Based upon the above, we conclude that the proposed change does not constitute a significant hazards consideration as defined in 10CFR50.92(c).

Schedule of Chanra o The proposed change will be incorporated into the 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 questions on this matter, please contact us.

Very truly yours, Vermont Yankee Nuclear Power Corporation fd.tw N Warren P. Aurphy [

Senior Vice Presiden Q tions cc: USNRC Region 1 Administrator ~%

USNRC Resident inspector, VYNPS ,./ ; R!q.h USNRC Project Manager, VYNPS f,y(.r. , en~. Y.\

STATE OF VERMONT ) . .

)SS .

,E-(.6, ** # f.#j WINDHAM COUNTY )

Then personally appeared before me, Warren P. ' phy,$3 ing duly sworn, did state that he is Senior Vice President, Operations of Vermont Yankee Nuclear Power Corporation, that he is authorized to execute and file the foregoing document in the name and on the behalf of Vermont Yankee Nuclear Power Corporatfor, and that the statements therein are true to the best of his knowledge and bellef.

say. 0 ~d Gally A. Sandstrum Notary Public lb Commission Expires February 10,1995

. o:

s VYNPS TABLE 4.2.5 MINIMUM TEST AND CAllBRATION FREQUENCIES CONTROL R00 BLOCK INSTRUMENTATION Trio Function ' unctional Test I Calibration Startup Range Monitor

a. Upscale' Notes 4 and 6 Note 6

b. Detector Not Fully Inserted Note 6 NA l

Intermediate Range Monitor

a. Upscale Notes 4 and 6 Note 6

b. 'Downscale _

Notes 4 and 6 Note 6

c. Detector.Not Fully Inserted Note 6 NA l Average Power. Range Monitor

a. Upscale-(Flow Bias) Notes 1 and 4 Every Three Month-

b. Downscale Notes I and 4 Every Three Months Rod Blcck Monitor

a. Upscale (Flow Bias) Notes I and 4 Every Three Months

b. Downscale Notes 1 and 4 Every Three Months Trip System Logic Once/ Operating Cycle Once/ Operating Cycle (Note 3)

High Water Level in Scram .Every Three Months Refueling Outage Discharge tolume.

Amendment.No. 106, ils.

-59

. _ . . . , ,, -, - --, , .. .. - . ._. - . . . - -