ML20133K623

Application for Amend to License DPR-28,consisting of Proposed Change 130,revising Tech Spec Pages 51,109,110 & 124 to Delete Sections Requiring Valves in Equalizer Piping Be Closed During Operation.Fee Paid

ML20133K623
Person / Time
Site:	Vermont Yankee
Issue date:	10/09/1985
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20133K626	List: ML20133K623 ML20133K634
References
FVY-85-95, NUDOCS 8510220212
Download: ML20133K623 (4)

Text

,.

VERMONT YANKEE PROPOSED CHANGE NO. 130 NUCLEAR POWER CORPORATION

. RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 ,,.

ENGINEERING OFFICE 1671 WORCESTER ROAD

• FR AMINGHAM, MASSACHUSETTS 01701

. turpsoNE sir-en a:00 October 9, 1985 FVY 85-95 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Office of Nuclear Reactor Regulation Mr. H. R. Denton, Director

References:

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

(b) Letter, USNRC to VYNPC, NVY 84-200, dated August 28, 1984,

" Order Confirming Licensee Commitments on Pipe Crack Related Issues"

Subject:

Recirculation System Equalizer Piping Valves

Dear Sir:

Pursuant to Section 50.59 of the Commission's Rules and Regulations, Vermont Yankee Nuclear Power Corporation hereby proposes the following changes to Appendix A of the operating license.

Proposed Change Replace Pages $1, 109, 110 and 124 of the Vermont Yankee Technical Specifications with the enclosed revised Pages 51, 109, 110 and 124. This proposed change will revise the Vermont Yankee Technical Specifications to l

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United States Nuclear Regulatory Commission October 9, 1985 Attention: Mr. H. R. Denton, Director Page 2 delete sections associated with the requirement that valves in the equalizer piping between the recirculation loops be closed during reactor operation.

Reason for Change Vermont Yankee will be replacing the Recirculation System Pipir.c during the present refueling outage which began on September 21, 1985. The replacement piping design includes the removal of the equalizer valves located between the recirculation loops. This design will thus achieve the Section 3.6.H.1 required isolation betwoon the two loops by physically ensuring two ,

l independent loops without any connection. Therefore, the existing license l

condition, stated in Section 3.6.H.1 that the equalizer valves remain closed l

during reactor operation, is no longer required. Further, the Table 4.2.1 LPCI crosstic monitor functional test, calibration and instrument check l requirements, and Section 4.6.F.2 surveillance language referencing equalizer valve closure, are no longer applicable.

Basis for Change Because the required isolation between the recirculation loops will be ensured through the removal of the equalizer valves as a result of the Recirculation System Piping Replacement Program design, Technical Specification Sections 3.6.H.1, 4.6.F.2 and Table 4.2.1 requirements associated with equalizer valve closure are no longer required. Therefore, this change is proposed solely to delete requirements from the Technical Specifications which will become obsolete upon completion of the Recirculation System piping replacement during the next outage.

Safety considerations This proposed change does not present an unreviewed safety question as defined in 10CFR50.59, and removal of the equalizer valves does t.ot impact existing safety analyses. The purpose of the equalizer valves was to interconnect the pump discharge lines so that one recirculation pump could  !

provide flow to the discharge lines in the event that the other recirculation pump was inoperable. The requirement to keep the valves in the equalizer piping between the recirculation loops closed during reactor operation is based on the largest recirculation break area assumed in the ECCS evaluation.

This break size is based on operation with a closed valve in the equalizer line between the two recirculation loops. Technical Specification 3.6.H.1 prohibits reactor operation unless the main equalizer valves in the equalizer lines are closed. Section 4.6.F.2 (jot pump surveillance) language incorporates the requirement to keep the equalizer valves closed when '

operating with one recirculation loop. The Table 4.2.1 LPCI crosstle monitor minimum test and calibration frequencies requires an instrument check once 7 1

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_______________________..__________________E

United States Nu'elear Regulatory Conimission October 9, 1985 Attention: Mr. H. R. Denton, Director Page 3 each day. Thus, deletion of the above Technical Specification requirements associated with the equalizer valves, which will be removed as a result of the Recirculation System Piping Replacement Design, does not constitute an unreviewed safety question.

This proposed change has been reviewed and approved by the Vermont Yankee Nuclear Enfety Audit and Review Committee.

Sinnificant Hazards consideration i The NRC has provided guidance concerning the application of standards for conclusions regarding "Significant Hazards Consideration" (48FR14870). The examples of actions involving no significant hazards consideration include. "A change to make a license confirm to changes in the regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations."

This change is similar to the example cited above because Vermont Yankee is removing the equalizer valves and thus the need for Technical Specification restrictions as a result of our Recirculation System Piping Replacement Program, which is being performed in accordance with NRC Confirmatory Order, dated August 28, 1984 [ Reference (b)). This proposed change will result in a change to facility operations clearly in keeping with the regulations.

Based on the above, we have determined that this change does not constitute a significant hazards consideration as defined in 10CFR50.92(c).

Fee Determination In accordance with the provisions of 10CFR170.12, an application fee of

$150.00 is enclosed.

Schedule of Change We request that your review and approval of this proposed change be completed no later than March 1986, in order to insure that the change is incorporated in the Vermont Yankee Technical Specifications prior to restart from the 1985/1986 outage. This change will be incorporated into the Vermont Yankee Tecnnical Specifications as soon as practicable following receipt of '

your approval.

United States Nuclear Regulatory Comission October 9, 1985 Attention: Mr. H. R. Denton, Director Page 4 l

We trust that the information above adequately supports our request;

. however, should you have any questions in this matter, please contact us.

Very truly yours, ,

VERMONT YANKEE NUCLEAR POWER CORPORATION N

Warren P. Murphy ,

Vice President and Manager of Operations WPM /mt Enclosure

<l cc: U.S. Nuclear Regulatory Comission Document Control Desk (40 copies)

Vermont Department of Public Services 120 State Street 2

Montpelier, Vermont 05602 Attention: Mr. Gerald Tarrant, Chairman

STATE OF VERMONT)

)ss ,

WINDHAM COUNTY )

Then personally appeared before me, Warren P. Murphy, who, being duly sworn, did state that he is a Vice President and Manager of Operations of I

Vermont Yankee Nuclear Power Corporation, that he is duly 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, i

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, Diane McCue ,

Notary Public My Comission Expires

+1- CCyp NOTARY  !

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