ML20150E233
| ML20150E233 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/25/1988 |
| From: | Drawbridge B YANKEE ATOMIC ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20150E237 | List: |
| References | |
| FYR-88-39, NUDOCS 8803300168 | |
| Download: ML20150E233 (8) | |
Text
e Telephone (617) 872 8100 TWX 710-3Eo-7619 YANKEE ATOMIC ELECTRIC COMPANY l
k 1671 Worcester Road, Framingham, Massachusetts 01701-g March 25, 1988 FYR 88-39 United States Nuclear Regulatory ComLission Document Control Desk Washington, DC 20555 Attention:
Office of Nuclear Reactor Regulations
References:
(a)
License No. DPR-3 (Docket No. 50-29)
(b)
USNRC NUREG-0452 Revision 4, November 1381, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors" (c)
USNRC letter to YAEC dated November 8,
- 1985, Amendment 86
Subject:
Technical Specifications Governing Containment Isolation Burriers (Proposed Change 214)
Dear Sir:
Pursuant to Section 50.59 of the Commission's Rules and Regulations, the Yankee Atomic Electric Company (YAEC) hereby requests authorization to make the following changes.
Proposed Change Reference is made to the Technical Specifications of License No.
DPR-3 of the Yankee Nuclear Power Station and to Amendment 86 to the License.
Amendment 86, reference (c), was a major revisicn to the Technical Specifications governing containment isolation l
systems and significantly improved the accuracy and clarity of these specifications.
After two years of operation with this amendment, we have noted additional opportunities for improvement i
and propose to furthur modify these Technical Specifications.
Description of Change As described in Attachment A.
Reasons and Basis for Change ss As described in Attachment A.
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United States Nuclear Regulatory Commission Attention: Office of Nuclear Reactor Regulation Page 2 Safety Evaluation This change is requested in order to. enhance implementation of the ALARA concept and to provide operational flexibility to the Technical Specifications governing containment isolation systems.
As such, this proposed change would not:
1.
Involve a significant increase in the probability'or conse-quences of an accident previously evaluated.
Two parts of this change involve brief openings under administrative control of drain taps in piping connected to certain closed systems inside containment.
The remaining parts of this change have no effect on potential leakage paths.
- Brief, administratively controlled openings on closed systems inside containment have negligible effects on the risk of any accident previously evaluated.
Therefore, there is no 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 previously analyzed.
All parts of this change are consistent with Standard Technical Specifications.
None of them introduces a new operating configuration or analytical assumption.
Therefore, there is no possibility of a new or different kind of accident from any previously unulyzed.
3.
Involve a significant reduction in a margin of safety.
This change does not affect the ability of the containment systems to perform their intended functions.
Therefore, there is no significant reduction in the margins of safety associated with containment integrity.
Based on the considerations contained herein, it is concluded that there is reasonable assurance that operation of the Yankee plant, consistent with the proposed Technical Specifications, will not endanger the health and safety of the public.
This froposed change has been reviewed by the Nuclear Safety Audit and Review 1
Committee.
Fee An application fee of $150.00 is enclosed in accordance with 10CFR170.21.
l i
United States Nuclear Regulatory Commission Attention: Office of Nuclear Reactor Regulation Page 3 FYR 88-39 Schedule of Change These changes to the Yankee Technical Specifications will be implemented upon Commission approval.
A timely review and approval of the submittal would be appreciated.
We trust that you will find this submittal satisfactory.
However, should you desire additional information, please contact us.
Sincerely,)
YA KEE ATOMIC ELECTRIC COMPANY
.-?c/n h &
B.
L.
Drawbridge Vice President and Manager of Operations Attachments COMMONWEALTH OF MASSACHUSETTS)
)ss MIDDLESEX COUNTY
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Then did personally appear before me.
B.
L.
Drawbridge, who, being duly sworn, did state that he is Vice President and Manager of Operations of Yankee Atomic Electric Company, that he is duly authorized to execute und file the foregoing document in the name and on the behalf of Yankee Atomic Electric Company and that the statements therein are true to the best of his knowledge and belief.
WP Robert H.
G r o'c e~
Notary Public My Commission Expires August 29, 1991 cc: USNRC Region I USNRC Resident Inspector. YNPS
1 Attachment A l
1.
DESCRIPTION OF CHANGE In Table 3.6-1, section E.1, page 3/4 6-13, add notation (9) to the ninth line to read:
"LPST Safety Valve Discharge Header 5 Blank Flanges (9)".
REASON FOR CHANGE This change will exempt the five Low Pressure Surge Tank (LPST) blank flanges from monthly position verification surveillances which require personnel to enter a High Radiation Exclusion Area.
This exception is for ALARA considerations.
BASIS FOR CHANGE Both Standard Technical Specification (STS reference (b))
and Yankee Technical Specification (YTS reference (a))
4.6.1.1.a.1 contain provisions for exceptions "as provided in Table 3.6-1".
Rxceptions have been previously applied, via reference (c), to three containment isolation barriers at Yankee.
One such exception applies to the LPST Safety Valve which occupies the sixth position on the header in question and constitutes a precedent for this change.
In addition, per YTS 3.6.1.7, Yankee is equipped with a continuous leak monitoring system designed to continuously monitor containment isolation barriers.
This specification is conservative with respect to STS and functions as a surveillance redundant to those required by Specification 4.6.1.1.a.1 for these blank flanges.
Therefore, these exceptions do not leave the plant unable to detect an inadvertent breach of containment.
2.
DESCRIPTION OF CHANGE a.
On page 3/4 6-1, into Surveillance Requirement 4.6.1.1.c, repeat the exception provided in 4.6.1.1.a.l.
4.6.1.1.c will end with:
.......or appropriate seul, except as provided in Table 3.6-1 of Specification 3.6.2.
b.
On page 3/4 6-15, TABLE NOTATIONS for Table 3.6-1, add surveillance 4.6.1.1.c to note (9).
The note will read:
(9)
T.S.
4.6.1.1.a.1 and 4.6.1.1.c not applicable while in Modes 1, 2,
3, 4,
due to ALARA considerations.
Attachment A REASON FOR CHANGE This change will exempt the Fuel Chute Blank Flange and Expansion Joints, the Low Pressure Surge Tank (LPST) Safety Valve and the five LPST Safety Valve Discharge H.:ader Blank Flanges from quarterly position verifications which require personnel to enter a High Radiation Exclusion Area.
This exception is for ALAF.A considerations.
BASIS FOR CHANGE STS and YTS 4.6.1.1.a.1 provide for monthly position verification for containment barriers.
YTS contains an additional surveillance 4.6.1.1.c to verify test, vent and drain connections and instrumentation port positions on a quarterly basis.
YTS 4.6.1.1.c is not in STS, but was designed to coordinate with and be an extension of Specification 4.6.1.1.a.l.
The Fuel Chute Blank Flange, the Fuel Chute Expansion Joints and the Low Pressure Surge Tank Safety Valve are currently excepted from monthly position verifications (4.6.1.1.a.1) for ALARA purposes.
Item 1 above would extend this excep-tion to include the five LPST Safety Valve Discharge Header Blank Flanges.
Both STS and YTS 4.6.1.1.a.1 also contain provisions for exceptions to be specified in Table 3.6-1 and, since 4.6.1.1.c was designed to be an extension of 4.6.1.1.a.1, the same provisions for exceptions should be applicable to both.
Since 4.6.1.1.c entails the same ALARA concerns as 4.6.1.1.a.1, the table notation should be modified to include both specifications.
Finally. Yankee is equipped per YTS 3.6.1.7 with a contin-uous leak monitoring system designed to continuously monitor containment integrity.
This specification is conservative with respect to STS and functions as a surveillance method redundant to those required by specifications 4.6.1.1.a.1 and 4.6.1.1.c for penetrations which are open to containment atmosphere.
All penetrations to which this exception would be applied are open to containment atmosphere.
Thus, these exceptions do not leave the plant unable to detect an inadvertent breach of containment.
Attachment A 3.
DESCRIPTION OF CHANGE In the TABLE NOTATIONS, page 3/4 6-15 for Table 3.6-1, add Limiting Condition for Operation 3.0.4 to note (11).
The note should read:
"(11) The ACTION statements of T.S.
3.6.2, 3.0.3 and 3.0.4 do not apply."
REASON FOR CHANGE This change will except the Operability requirements for Secondary Barriers listed in Table 3.6-1 from restricting mode changes unless specified elswhere in the Technical Specifications.
BASIS FOR CHANGE Standard Technical Specifications allow the exception of Containment Barriers from the provisions of Specification 3.0.4 when justified.
The containment boundaries affected by this exception are secondary and are not subject to the severity of the ACTION statements associated with primary-to-secondary
.-'in coolant leakage rates or the primary containment boundaries.
In similar cases where other Technical Specifications govern Secondary Barriers, Spocification 3.0.4 is excepted.
Examples are the twelve Secondary Safety Valves covered by YTS 3.7.1.1 and the four steam isolation non-return valves covered by YTS 3.7.1.5.
4.
DESCRIPTION OF CHANGE Add a rica notation (13) to Table 3.6-1, "Containment Barriers".
Specifically:
a.
In Table 3.6-1, section C, page 3/4 6-12, add notation (13) to two check valves:
"SI-V-14 Safety Injection (UP) (13)"
"CS-V-621 Safety Injection-(LP) (13)"
b.
In the Table Notations for Table 3.6-1, page 3 '4 6-15, add notation (13), which reads:
"(13) Test taps SI-V-94 and SI-V-98 may be open under administrative control to relieve safety injection discharge header pressure following surveillance testing."
Attachment A REASON FOR CHANGE Yankee Nuclear Power Station is equipped with instrumenta-tion to monitor safety injection discharge header pressure between the containment isolation check valves outside and inside containment.
The objective of the instrumentation is to monitor for main coolant leakage past the inside check valves.
The instrumentation has control room alarm capability.
Surveillance testing of the safety injection system raises the safety injection discharge header pressure above the setpoint for the main coolant leakage alarm.
The prescure is then normally trapped between the check valves unless relieved.
This proposed change will allow quick reduction of the pressure between the check valves in order to reset the alarm in a timely manner.
BASIS FOR CHANGE Standard Technical Specifications allow containment barriers to be opened according to notations to Table 3.6-1, on an intermittent basis and under administrative controls where necessary for normal operations.
This change facilitates the operability of a continuous leakage monitoring system for check valves in the safety injection system.
In addition, the check valves being monitored are also the containment barriers in the associated penetrations.
The benefits gained by enabling an additional monitoring capability more than offset the incremental risk due to the brief opening of a small (1/4 inch as tubing) containment barrier in a system which is closed inside containment.
5.
DESCRIPTION OF CHANGE Add a new notation (14) to Table 3.6-1, "Containment Barriers".
Specifically:
a.
In Table 3.6-1, section A.1, page 3/4 6-11, add notation (14) to two automatic isolation valves:
"HC-TV-409 Containment Heating Condensate Return (14)"
"HC-TV-413 Containment Heating Steam Supply (14)"
b.
In the Table Notations for Table 3.6-1, page 3/4 6-15, add notation (14), which reads:
"(14) Strainer Blowdown Valves may be open under administrative control during system startup or for strainer cleanout."
Attachment A i
1 REASON FOR CHANGE The containment heating system at Yankee is equipped with strainers and strainer blowdown (cleanout) valves between the containment isolation valves and the containment.
For system startup and routine maintenance, one of these valves should be opened for up to eight hours during system startup and the remaining valves for approximately one hour each for strainer cleanout.
These openings generally occur once per year per valve.
BASIS FOR CHANGE Standard Technical Specifications allow containment barriers to be opened according to notations to Table 3.G-1, on an intermittent basis and under administrative controls where necessary for normal operations.
This change facilitates the operability of a system (containment heating) which is needed for atmospheric control inside containment.
This system is also closed inside containment.
I
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