FVY-85-117, Suppl 1 to 841214 Application for Amend to License DPR-28, Consisting of Proposed Change 124,responding to NRC Concerns Re Containment Hydrogen/Oxygen Monitor & Control Room Toxic Gas Monitor
| ML20138F200 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/26/1985 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20138F207 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 FVY-85-117, GL-83-36, NUDOCS 8512160037 | |
| Download: ML20138F200 (4) | |
Text
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VER610NT YANKEE NUCLEAR POWER CORPORATION RD 5 Box 169. Ferry Road, Brattleboro. VT 05301 y
ENGINEERING OFFICE 1671 WORCESTER ROAD FRAMINGHAM, MASSACHUSETTS 01701 TELEPHOedE 617-472-8100 Proposed Change No. 124 - Supplement 1 November 26, 1985 FVY 85-117 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 83-257, Generic Letter 83-36, dated Ncvember 1, 1983 (c) Letter, VYNPC to USNRC, FVY 84-12, dated February 22, 1984 (d) Letter, VYMPC to USNRC, FVY 84-146, dated December 14, 1984
Subject:
NUREC-0737 Technical Specifications - Supplement 1 Dear Sir Pursuant to Section 50.59 of Commission's Rules and Regulations, Vermont Yankee Power Corporation hereby proposes the following modifications to Appendix A of the Operating License.
By Generic Letter 83-36 (Reference (b)), NRC provided guidance on Technical Specifications for NUREG-0737 items scheduled after December 31, 1981.
Reference (b) also requested that all boiling water reactor licensees review their facility's Technical Specifications to determine if they were consistent with that guidance.
For those items where deviations or absence of a specification were identified, NRC requested that an application for a license amendment be submitted.
By letter, dated December 14, 1984 (Reference (d)], Vermont Yankee (VY) submitted Proposed Change No. 124 to our facility's Technical Specifications.
That submittal addressed Generic Letter 83-36 [ Reference (b)] guidance and-amended or added Pages 34a, 49, 49a, 49b, 49c, 60, 60s, 61b, 66 and 67 of our Technical Specifications to incorporate the following installed instrumentation:
containment high-range radiation monitor, containment hydrogen / oxygen monitor, containment. pressure monitor, containment water level monitor and control Room toxic gas monitor.
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United States Nuclear Regulatory Commission November 26, 1985 Attention:
Mr. H. R. Denton, Director Page 2 Subsequent to that submittal, your staff requested additional information concerning the containment hydrogen / oxygen monitor and Control Room toxic gas monitor. The purpose of this supplement is to respond to the staff's requests and provide the enclosed revised Pages 49, 49a and 49b, which supersede those same pages previously submitted.
In addition, we provide the basis upon which j
' W deviated from Generic Letter 83-36 guidance concerning the Control Room l
toxic gas monitor operability time limit conditions.
PROPOSED CHANGE j
Replace Pages 49, 49a and 49b of the W Technical Specifications submitted with Reference (d) with the attached revised Pages 49, 49a and 49b.
These changes incorporate reference to Amendment No. 90 (Pages 49 and 49a) and revisions to Table 3.2.6, Note 1 (Page 49b) in response to the staff's
. request concerning the containment hydrogen / oxygen monitor.
Pages 34a, 49c, 60, 60s, 61b, 66 and 67, submitted with Reference (d), are not
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affected by this supplement.
i.
EgASON AND BASIS FOR CHANGs The reason and basis for Proposed Change No. 124 are discussed in Reference (d).
The supplemental changes to Pages 49 and 49a are made solely to include reference to Amendment No. 90 to the W Technical Specification. The supplemental change to Page 49b (Table 3.2.6, Note 1) is based upon the NRC
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staff's request for W to provide a specified time to achieve hot shutdown after expiration of the limiting condition for operation for the containment hydrogen / oxygen monitor. The revised Note 1 is consistent with the guidance provided for this post-accident-instrumentation parameter contained in Generic Letter 83-36.
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In response to the NRC staff's request that W document the basis for l
deviating from the guidance of Generic Letter 83-36 concerning operability j
time limit conditions for the Control Room Toxic Gas Monitoring System, we provide the following. W believes our 30-day limit to have one toxic gas 4
detector channel out of service is an acceptable deviation from the seven days recosmonded in the Generic Letter's sample Technical Specifications because:
(1) this, time period is fully consistent with the time periods applied to other detectors contained in our Technical Specifications (e.g., fire detectors), and (2) we believe it is appropriate to apply time requirements upon this detector consistent with those applied to Post-Accident Monitoring System equipment in our Technical Specifications (Reference Table 3.2.6).
Further, because the installation of the Control Room Toxic Gas Monitoring System is based upon a low probability event (i.e., a release of toxic chemicals from a rail line shipment incident under certain conditions with a i
sufficient plume size to present a hazard to Control Room personnel), W i
believes that the combination of this low probability event coincidentally i
occurring with the low probability of toxic gas monitor unavailability is sufficiently remote to preclude the necessity for stricter operability time limit conditions for our facility's Toxic Gas Monitoring System.
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United States Nuclear Regulatory Commission November 26,- 1985 Attention:
Mr. H. R. Denton,. Director Page 3 SAFETY CONSIDERATIONS The safety considerations of Proposed Change No. 124 are discussed in Reference (d).
The probability of accidents previously evaluated is not increased; the possibility.of a different type of accident-is not created, nor are the margins of safety, as defined in the basis of.the Technical Specifications, reduced by the supplemental proposed change. Thus, this supplemental proposed change does not constitute an unreviewed safety question as defined by 10CFR50.59(a)(2).
Proposed Change No. 124 was previously reviewed by the Vermont Yankee Nuclear Safety Audit Review Committee.
SIGNIFICANT HAZARDS CONSIDERATIONS The standards used to arrive at a determination that a request for amendment to a facility license. 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; or (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.
This supplemental proposed change to Table 3.2.6, Note 1 (Page 49b) does not involve a significant increase in the probability or consequences of an accident previously evaluated, nor does it :reate the possibility of a new or different kind of accident from any accident previously evaluated because it constitutes an additional restriction not presently included in the VY Technical Specifications and does not impact existing safety analyses.
The supplemental proposed change to Table 3.2.6, Note 1 (Page 49b) does not involve a significant reduction in a margin of safety because it provides a specified time to achieve hot shutdown after the expiration of the limiting condition for operation of a parameter.
The Commission has also provided guidance for the application of the standards in 10CFR50.92 by providing certain examples (48FR14870) of actions likely to involve no significant hazards consideration. One of the examples (ii) is a change that constitutes an additional limitation, restriction or control not presently included in the Technical Specifications.
The supplemental modifications to Page 49b of the Technical Specifications in response to NRC staff's request constitutes an additional limitation, restriction or control not presently included in the VY Technical specifications. Therefore, the supplemental proposed change is similar to the Commission's example (ii) above, and is not considered'to constitute a significant hazards consideration as defined in 10CFR50.92(c).
The corrective updates to the supplemental proposed changes to Pages 49 I
and 49a, which simply provide a reference to Amendment No. 90, are purely administrative changes and, therefore, are not considered a significant j
hazards consideration as defined in 10CFR50.92(c).
l United States Nuclear Regulatory Commission November 26, 1985 Attention:
Mr.-H. R. Denton, Director Page 4 FEE DETERMINATION We request that the application fee of $150.00, enclosed in accordance with the provisions of 10CFR170.12 with Reference (d), be applied to this supplemental submittal.
SCHEDULE OF CHANGE This change'to the VY Technical Specifications will be implemented as soon as practicable following receipt of your approval.
We trust that the information provided above is adequately responsive to your staff's request; however, should you have any further questions in this matter, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION W
Warren P.
rphy l
Vice Pres dent and a er of Operations WPW/RWC/dps Enclosures cc:
US. Nuclear Regulatory Conmission 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 clear Power Corporation and that the statements therein are teu his knowledge and belief.
0 AA NOT W Diane McCue
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Notary eublic
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