ML20195C871

TS Proposed Change 203 to License DPR-28,clarifying Suppression Chamber Water Temp SR 4.7.A, Primary Containment & Modifying Associated TS Bases

ML20195C871
Person / Time
Site:	Vermont Yankee
Issue date:	05/26/1999
From:	Wanczyk R VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20195C876	List: ML20195C871 ML20195C884
References
BVY-99-75, NUDOCS 9906090014
Download: ML20195C871 (9)

Text

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VERMONT YANKEE M

NUCLEAR POWER CORPORATION 185 Old Ferry Road, Brattleboro, VT 05301-7002 (802) 257-5271 May 26,1999 BW 99-75 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk .

. Washington, DC 20555

Subject:

Vermont Yankee Nuclear Power Station .

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

' Technical Specification Proposed Change No. 203 Suppression Pool Water Temperature Surveillance Pursuant to 10CFR50.90, Vermont Yankee (W) hereby proposes to amend its Facility Operating License, DPR-28, by incorporating the attached proposed change into the Technical Specifications (TS) of Vermont Yankee Nuclear Power Station. This proposed change clarifies suppression chamber water temperature Surveillance Requirement 4.7.A, Primary Containment, and modifies the associated TS Bases.

Vermont Yankee TS 4.7.A.1 currently states that "The suppression chamber water level and temperature shall be checked once per shift." The proposed change will revise this surveillance wording to specify an ' average' temperature and a ' daily' frequency. TS 4.7.A.1 also states that "Whenever thers is indication of relief valve operation which adds heat to the suppression pool, the pool temperature shall be continually monitored and also observed and logged every five minutes until the heat addition is terminated." The proposed change will revise the .

surveillance such that average suppression pool water temperature will be monitored every 5 l minutes when performing testing that adds heat to the suppression pool. Additionally, the TS l Bases will be modified to reflect these changes. These changes reflect the guidance provided i in NUREG-1433 Rev.1, BWR Standard Technical Specifications. '

Attachment 1 to this letter contains supporting information and the safety assessment of the l proposed change. Attachment 2 contains the . determination of no significant- hazards- l consideration. Attachment 3 provides the marked-up version of the current Technical Specification pages. . Attachment 4 contains the retyped Technical Specification pages.

W has reviewed the proposed Technical Specification change in accordance with 10CFR50.92 and concludes that the proposed change does not involve a significant hazards consideration.

W has evaluated the. proposed amendment against the criteria of 10CFR51.22 for 4 environmental considerations and concludes that the proposed change will not increase the types and amounts of effluents that may be released offsite. Thus, W believes that the proposed change is eligible for categorical exclusion from the requirements for an environmental impact statement in accordance with 10CFR51.22(c)(9).

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. BVY 99-75/Page 2 If you have any questions concerning this transmittal, please contact Mr. Jeffrey T. Meyer at (802) 258-4105. ,

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Sincerely, VERMONT YANKEE NUCLEAR POWER CORPORATION Robert J. a czyk [/d7 Director fety and Regulatory Affairs 4 b,SAhog STATE OF VERMONT ) h,f

)ss NOTAm WINDHAM COUNTY ) l Then personally appeared before me, Robert J. Wanczyk, who, being duly swom, ta at he .- l Director of Safety and Regulatory Affairs of Vermont Yankee Nuclear Power Corpora at h uly 1 authorized to execute and file the foregoing document in the name and on the behalf o Nuclear Power Corporation, and that the statements therein are true to the best of his belief.

S'lly Ah I a A. Sindstrum, Notary Public My Commission Expires February 10,2003 Attachments cc: USNRC Region 1 Administrator USNRC Resident inspector-VYNPS USNRC Project Manager -VYNPS Vermont Department of Public Service

venuos r vmn: Nrcuan enm:n coni oiuuns Docket No. 50-271 BW 99-75 Attachment i Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 203 Suppression Pool Water Temperature Surveillance Suooortina information and Safety Assessment of Proposed Chance 1

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. BVY 99-75 Description of the Proposed Change Pursuant to 10CFR50.90, Vermont Yankee proposes to amend Appendix A, Technical Specification (TS) Surveillance Requirement 4.7 STATION CONTAINMENT SYSTEMS. Item A, Primary Containment and Bases of Facility Operating License DPR-28. The proposed changes are as follows:

Paae 146. Specification 4.7.A.1 Replace the first sentence "The suppression chamber water level and temperature shall be checked once per shift" with the new sentence " Verify daily that the suppression chamber water level and average temperature are within applicable limits." This is to make the surveillance consistent with the Bases and the BWR Standard Technical Specifications.

Replace the third sentence "Whenever there is indication of relief valve operation which adds heat to thn suppression pool, the pool temperature shall be continually monitored and also observed and logged every 5 minutes until the heat addition is terminated" with the new sentence " Verify suppression pool average temperature is within the applicable limits every 5 minutes when performing testing that adds heat to the suppression pool." This is to make the surveillance consistent with BWR Standard Technical Specifications.

Also add paragraph breaks to separate individual requirements within the larger paragraph.

Pace 166. Bases Section 4.7.A Delete the first sentence in its entirety. This sentence is repetitious with information contained later in this Bases section. Move the section heading to page 166a.

Pace 166a. Bases Section 4.7.A Relocate the section title from previous page to this page.

In the first paragraph, delete the words "approximately once per year" in the second sentence.

The inspection discussed is performed during refueling outages as specified in the 4.7.A.1 surveillance requirement.

In the second paragraph, first sentence, replace the word " volume" with " level" to make the 1 Bases consistent with the TS 4.7.A.1 surveillance requirement. j i

in the second paragraph, delete the entire second sentence and replace with the following: l "The average temperature is determined by taking an arithmetic average of OPERABLE suppression pool water temperature channels. The daily frequency has been shown, based I on operating experience, to be acceptable. The frequencies are fuither justified in view of other indications available in the Control Room, including alarms, to alert operators to an  !

abnormal condition.  :

When heat is being added to the suppression pool by testing, however, it is necessary to monitor suppression pool temperature more frequently. The 5 minute frequency during

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. BW 99-75 testing is justified by the rate at which tests will heat up the suppression pool, has been shown to be acceptable based on operating experience, and provides assurance that allowable pool temperatures are not exceeded."

Purpose of the Proposed Change {j The current suppression pool - surveillance requirement, Specification 4.7.A.1, states:

"Whenever there is indication of relief valve operation which adds heat to the suppression pool, the pool temperature shall be continually monitored and also observed and logged every five minutes until the heat addition is terminated." The TS surveillance as currently written is a reg:lrement for an operator to provide continuous observation and monitoring of suppression pool water temperature instrumentation and physically log the temperature every 5 minutes

' during a potential transient condition. Dedicating an operator to monitor and log a single-parameter during a transient is not an appropriate and effective utilizaticn of Control Room personnel. There are sufficient Control Room indications such that dedicating an operator to i monitor a single parameter is not appropriate as it would dilute attention to other equivalent i parameters. BWR Standard Technical Specifications prescribes verifying suppression pool  ;

temperature at 5 minute intervals only during testing evolutions that add heat to the suppression  !

pool and is a more appropriate surveillance requirement. This change will revise the surveillance requirement to be consistent with the BWR Standard Technical Specifications.

4 Additionally, the surveillance requirement for suppression pool water level and temperature to be " checked once per shift" is not consistent with the associated TS Bases. Our Bases lists a weekly and daily monitoring frequency for these parameters. BWR Standard Technical Specifications prescribes an ' average' suppression pool water temperature and a once per day verification of these parameters. This surveillance and bases will be revised to be consistent ,

and reflect the BWR Standard Technical Specification guidance. '

Also proposed are changes to the Bases for clarification and to make them consistent with the revised TS surveillance requirements.

Safety Assessment of Proposed Change The. proposed change to the frequency for monitoring suppression pool water level and temperature is made to resolve inconsistenA with the associated Technical Specification Bases. The frequency is revised from "once ;<r shift" to " daily" because the large volume and thermal capacity of the suppression pool resc .n very slow changes and " daily" monitoring is sufficient. Also, suppression pool water tsmperature is clarified to be an ' average' temperature to more accurately depict the condition of the entire volume of water. These changes were chosen for consistency with BWR Standard Technical Specificatlons.

The proposed change to Technical Specification 4.7.A.1 for monitoring suppression pool water temperature revises the surveillance requirement to apply during testing evolutions. The

_ revised wording was chosen to be consistent with BWR Standard Technical Specifications and there is no adverse effect on plant safety. Suppression pool water temperature is continually monitored, displayed and recorded by installed control room instrumentation. Additionally.

there are alarms to indicate if a relief valve is open or leaking and when the suppression pool approaches a limiting temperature, providing assurance that the operators are alerted and

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. BW 99-75 warned about abnormal conditions. Similarly, there are digital displays, recorders and computer monitoring available for observation and to trend this parameter. By not requiring an operator to physically observe and log this already available information, an unnecessary burden will be removed from the Control Room staff. In this instance an additional operator would be available to carry out other ~ duties instead of just observing and logging this parameter, Plant procedures also require close monitoring of suppression pool temperature if relief valve leakage or actuation occurs and/or if suppression pool temperature exceeds TS specified values.

The changes to the Bases are to eliminate repetition, achieve consistency in wording with the revised surveillance requirements and delete the Bases wording u>ecifying refueling cutages as "approximately once per year".

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Docket No. 50-271 BVY 99-75 l

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Attachment 2 l Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 203 Suppression Pool Water Temperature Surveillance Determination of No Sionificant Hazards Consideration i

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. - BW 99-75 No Significant Hazard Determination Pursuan, to 10CFR50.92, Vermont Yankee Nuclear Power Corporation has reviewed the proposed change and concludes that the change does not involve a significant hazards consideration since the proposed change satisfies the criteria in 10CFR50.92(c).

1. The operation of Vermont Yankee Nuclear Power Station in accordance with the proposed amendment. will not involve a sianificant increase in the probability or conseauences of an accident previousiv evaluated.

Vermont Yankee has determined that the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed charge revises the surveillance frequency for "once per shift" suppression pool water level and temperature monitoring. Additionally, the surveillance requirement for suppression pool water temperature monitoring when there are indications of relief valve operation that add heat to the suppression pool is also revised. The proposed change will revise the surveillance wording such that routine suppression pool monitoring will be " daily" and an operator will verify pool temperature every 5 minutes only during testing that adds heat to the suppression pool. Also clarified, is that the  !

parameter being monitored is ' average' suppression pool water temperature. The wording of these changes have been generically endorsed in BWR Standard Technical Specifications (NUREG-1433 Rev.1).

Existing Control Room instrumentation provides multiple sources of information to operations personnel indicating relief valve status and suppression pool water temperature. Additionally, procedures prompt operators to respond to abnormal conditions such as relief valve opening and elevated suppression pool temperatures.

These procedures provide appropriate guidance for both responding and monitoring the abnormal condition (s) until resolved.

The Bases changes are administrative in nature to provide clarification and consistency with the revised TS surveillance requirements.

l The proposed change affects only surveillance requirements and does not require any hardware or equipment modification. Equipment operation, plant limiting conditions for operation and accident analyses will be unchanged. Thus, there will be no change in ,

the probability or consequences of accidents.  !

1 2.' The operation of Vermont Yankee Nuclear Power Station in accordance with the orooosed amendment. will not create the possibility of a new or different kind of accident l from any accident oreviousiv evaluated.  !

VY has determined that the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed change I involves revision of Technical Specification surveillance requirements and the associated Bases. There are no hardware modifications or equipment changes involved and operation of plant equipment will be unchanged. Thus, no new or different accident precursors will be created by this change.

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3. The . operation of Vermont Yankee Nuclear Power Station in accordance with the proposed amendmont. will not involve a sionificant reduction in a marain of safety.

VY has determined that the proposed change does not involve a significant reduction in a margin of safety. The proposed change involves revision of Technical Specification surveillance requirements and revision of the Bases for consistency and clarification.

There are no hardware modifications or equipment changes involved and plant operation and accident analyses are unchanged. The change to the surveillance for suppression pool water temperature monitoring during relief valve operation revises the wording of the surveillance to apply during any testing that adds heat to the suppression pool. This will remove a burden from the operating crew and will allow control room personnel to be available for other duties during potential transient conditions that result from relief valve operation. Revision of the routine surveillance frequency for suppression pool level and temperature to daily is justified based upon the large volume and thermal capacity of the water and the very slow changes that occur. Thus, no reduction in the margin of safety is created by any of these changes.

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