BVY-96-120, Application for Amend to License DPR-28,revising Existing Requirements Re Amount of Foam Concentrate Required to Support Operability of Recirculation Motor Generator Set Foam Sys in TS 3.13.G.1 & 3.13.G.2
| ML20128N594 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/11/1996 |
| From: | Reid D VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20128N598 | List: |
| References | |
| BVY-96-120, NUDOCS 9610160443 | |
| Download: ML20128N594 (3) | |
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VERMONT YANKEE NUCLEAR POWER CORPORATION 1
+- r Ferry Road, Brattleboro, VT 05301-7002 REPLY TO ENGINEERING OFFICE 580 MAIN STREET BOLTON, MA 01740 October 11,TOF*
United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
References:
(a) License No. DPR-28 (Docket No. 50-271)
(b) Letter, VYNPC to USNRC, Licensee Event Report 96-13, BVY 96-68, dated l
May 23,1996 l
Subject:
Proposed Change Number 188, Revised Recirculation Motor Generator Set Fire j.
Protection Foam System Capacity l
Pursuant to Section 50.90 of the Commission's Rules and Regulations, Vermont Yankee Nuclear Power Corporation hereby proposes the following change to Appendix A of the l
operating license [ Reference (a)].
Proposed Chanae:
This proposed change revises the existing requirements.regarding the amount of foam concentrate required to support the operability of the Recirculation Motor Generator (M. G.) Set l
Foam System as stated in Technical Specifications 3.13.G.1 and 3.13.G.2. In both instances, the required amount of foam concentrate is increased from 100 gallons to 150 gallons.
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Specifically, the changes proposed are as follows:
l (1)' Page 248, Specification 3.13.G.1.- The parenthetical description of a " full tank"is revised from 100 gallons to 150 gallons.
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,(2) Page 248, Specification 3.13.G.2. The amount of foam concentrate required to be available on site whenever the Recirculation M. G. set Foam Set is inoperable is revised l
' from 100 gallons to 150 gallons.
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- Reason / Basis For Chance:
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l Reference (b) reported, in part, that the Reactor Recirculation M. G. Set foam suppression system area of coverage per foam nozzle was found to exceed the manufacturer's
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recommended coverage. The system was aaministratively daclared inoperabie and
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compensatory measures were put in place. The stated corrective action for this problem was that the system would be modified as necessary to bring it to its requireo design configuration prior to startup from the 1996 refueling outage. To that end, a design change has been i
prepared to replace the existing equipment with a system capable of satisfying National Fire Protection Association (NFPA) discharge density requirements, thereby restoring the system to 9610160443 961011 ADOCK0500g1 DR
l Unit d Statts Nucl:ar Rzgul: tory Commission VERMONT YANKEE NUCLEAR POWER CORPORATIOr4 Octobtr 'li,1996 Page 2 of 3 its originally approved design configuration. As part of this new system, a 150 gallon foam concentrate tank will be installed to provide the capacity required to meet the NFPA Standards.
The intent of the current Technical Specification regarding foam concentrate inventory is to keep the existing tank full and to keep a 100% refill capacity on site at all times. This proposed change will ensure that intent continues to be met.
Safety Considerations:
This Proposed Change will only modify the Technical Specifications to reflect the actual inventory of foam concentrate required to support the operability of the Recirculation M. G.
Set Foam System. The method of system operation and initiation remain unchanged from the originally approved design. The increase in inventory is required to assure that NFPA Code requirements for this system are met. This system is not considered an accident initiator; the Proposed Change does not change the radiological dose to the public in any way; and there are no plant safety functions impacted by this change such that the probability of a malfunction which could impact analyzed transients is increased. The ew system design has been evaluated to ensure that the enhanced spray pattern and inc.aased volume of spray does not impact any equipment not previously evaluated and does not create any threat of flooding to equipment. Therefore the possibility of a different type of malfunction of equipment than previously evaluated in the FSAR is not created.
This Proposed Change has been reviewed by the Vermont Yankee Plant Operations Review Committee and the Vermont Yankee Nuclear Safety Audit and Review Committee.
Sianificant Hazards Considerations:
The standards used to arrive at a determination that a request for amendment invcives 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 accidant 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. In addition the Commission has provided practical guidance in the practical application of these criteria in 51FR7751, dated March 6,1986.
The discussion below addresses the proposed changes with respect to these three criteria snd demonstrates that the proposed amendment involves a no-significant-hazards consideration:
- 1. The changes proposed herein affect only the amount of foam concentrate inventory required to support the operability of the Recirculation M. G. Set Foam System and therefore do not modify or add any initiating parameters that would significantly increase the probability or consequences of any previously analyzed accident.
- 2. These changes involve the upgrade of an existing system using staridard fire protection components to provide the level of protection originally required. An eva uation has been comp!eted to ensure that the enhanced spray pattern and increased volume of spray does not impact : iy equipment not previously evaluated and does not create any throat of flooding to equipment. Therefore, the proposed change does not create the possibihty of a new or different kino of accident from any accident previously evaluated.
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United States Nuclear Regulatory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION October '<1,1996 Page 3 of 3 l
- 3. These changes do not affect any equipment involved in potentialinitiating events or safety l
limits. Therefore, it is concluded that the proposed change does not involve a significant j
reduction in a margin of safety.
Based on the above, we conclude that the proposed change does not constitute a significant hazards consideration as defined in 10CFR50.92(c).
Schedule of Chanae:
l The proposed change will be incorporated into Vermont Yankee Technical Specifications as l
soon r s practicable following receipt of your approval.
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We trust that the information provided adequately supports our request, however, should you l
have any questions regarding this matter, please do not hesitate to contact this office.
Sincerely, VERMONT YANKEE NUCLEAR POWER CORPC RATION i
Donald A. Reid Vice-President, Operations Enclosure A: Affected Technical Specification page Enclosure B: New Technical Specification page c:
USNRC Region I Administrator USNRC Resident inspector - VYNPS USNRC Project Manager -VYNPS STATE OF VERMONT
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)ss WINDHAM COUNTY
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Then personally appeared before me, Donald A. Reid, who, being duty sworn, did state that he is Vice President-Operations of Yankee Nuclear Power Corporation, that he is duly authorized to execute and file the foregoin me and on the behalf of Vermont Yankee Nuclear Power Corporation, and that the statert N erein are t e best of his knowled g'elief.
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