FVY-85-104, Revised Application to Amend License DPR-28,revising Tech Specs to Delete Sections Associated W/Requirement That Valves in Equalizer Piping Between Recirculation Loops Be Closed During Reactor Operation
| ML20137C166 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/15/1985 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20137C169 | List: |
| References | |
| FVY-85-104, NUDOCS 8511260454 | |
| Download: ML20137C166 (4) | |
Text
PROPOSED CHANGE NO. 130 - Rxubmittsl f
NUCLEAR POWER CORPORATION I
RD 5, Box 169, Ferry Road, Brattleboro, VT 05301
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ENGINEERING OFFICE 1671 WORCESTER ROAD g
FR AMINGHAM, MASSACHUSETTS 01701 TELEPHONE 617-872-8100 November 15, 1985 FVY 85-104 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:
Office of Nuclear Reactor Regulation Mr. H. R. Denton, Director l
References:
(a) License No. DPR-28 (Docket No. 50-271) l (b) Letter, USNRC to VYNPC, NVY 84-200, dated August 28, 1984,
" Order Confirming Licensee Commitments on Pipe Crack i
Related Issues" (c) Letter, VYNPC to USNRC, FVY 85-95, dated October 9, 1985 l
l
Subject:
Recirculation System Equalizer Piping Valves - Resubmittal i
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.
By letter dated October 9, 1985 [ Reference (c)], Vermont Yankee submitted Proposed Change No. 130 to our facility Technical Specifications.
i Subsequently, your staff requested that the license amendment request be revised to specifically address the requirements of 10CFR50.91(a)(1) and be f
resubmitted. In accordance with that request, we herein resubmit Vermont Yankee Proposed Change No. 130 in its entirety. In addition, we are hereby withdrawing Page 51, which was previously submitted with Reference (c), from consideration for amendment.
Proposed Change Replace Pages 109, 110 and 124 of the Vermont Yankee Technical Specifications with the enclosed revised Pages 109, 110 and 124. This proposed change will revise the Vermont Yankee Technical Specifications to delete sections associated with the requirement that valves in the equalizer piping between the recirculation loops be closed during reactor operation.
8511260454 B51115 PDR ADOCK 05000271 1
8 i PDR
1 United States Nuclear Regulatory Commission trovember 15, 1985 Attention:
Mr. H. R. Denton, Director Page 2 Reason for Change Vermont Yankee will be replacing the Recirculation System piping 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 between the two loops by physically ensuring two independent loops without any connection. Therefore, the existing license condition, stated in Section 3.6.H.1 that the equalizer valves remain closed during reactor operation, is no longer required.
Further, the Section 4.6.F.2 surveillance language referencing equalizer valve closure is 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 and 4.6.F.2 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 becoma 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 not 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 (jet pump surveillance) language incorporates the requirement to keep the equalizer valves closed when operating with one recirculation loop. 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 was previously reviewed and approved by the Vermont Yankee Nuclear Safety Audit and Review Committee.
Significant Hazards Consideration 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
e-United States Nuclear Regulatory Commission November 15, 1985 Attention:
Mr. H. R. Denton, Director Page 3 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 proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated because the removal of the equalizer valves does not impact existing safety analyses.
Further, this amendment simply deletes requirements which only apply to'the valves being removed.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated because the change is proposed solely to delete requirements associated with equalizer l
valve closure that become obsolete upon removal of those valves. The removal of the equalizer valves by the Replacement Piping Design achieves the Technical Specification requirement for isolation between the two loops by physically ensuring two independent loops without any connection.
The proposed change does not involve a significant reduction in a margin of safety because the Technical Specification requirements to be deleted are ensured by removal of the valves to which they apply and are thus rendered unnecessary.
-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 i
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 We request that the application fee of $150.00, enclosed in accordance with the provisions of 10CFR170.12 with our October 9, 1985 [ Reference (c)]
submittal, be applied to this resubmittal.
Schedule of Change We request that your review and approval of this proposed change resubmittal be completed no later than March 1986 in order to ensure that the change is incorporated in the Vermont Yankee Technical Specifications prior to
I l-l f
United States Nuclear Regulatory Commission November 15, 1985 Attention:
Mr. H. R. Denton, Director Page 4 restart from the 1985/1986 outage. This change will be incorporated into the l
Vermont Yankee Technical Specifications as soon as practicable following l
receipt of your approval.
We trust that the information above adequately supports our request; however, should you have any questions in this matter, please contact us, i
l Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION gn_- -
fu.e Warren P. Murphy Vice President and M ger of Operations WPM /hj a Enclosure cc:
U.S. Nuclear Regulatory Commission Document Control Desk (40 copies)
Vermont Department of Public Services 120 State Street 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 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.
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Diane McCue l'
Notary Public My commission Expires
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