ML20198H424

Application for Amend to License DPR-28,consisting of Proposed Change 131,revising Radiological Effluent Tech Specs.Fee Paid

ML20198H424
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	01/24/1986
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20198H428	List: ML20198H424 ML20198H439
References
FVY-86-9, NUDOCS 8601310024
Download: ML20198H424 (7)

Text

r c VERMONT YANKEE NUCLEAR POWER CORPORATION

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

y ENGINEERING OFFICE 1671 WORCESTER ROAD

• FRAMINGHAM, MASS ACHUSETTS 01701 January 24, 1986 T EL E PHON E 617-872-8100 FVY #86-9 Proposed Change No. 131 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Office of Nuclear Reactor Regulation Mr. H. R. Denton, Director

References:

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

(b) Letter, VYNPC to USNRC, Revised Vermont Yankee Radiological Effluent Technical Specifications (RETS),

Proposed Change No. 78, Supplement 1, FVY 84-6, January 23, 1984 (c) Letter, USNRC to VYNPC, October 9, 1984 (d) Letter, USNRC to VYNPC, May 28, 1985, Inspection Report 50-271/85-17

Subject:

Proposed change to the Vermont Yankee Radiological Effluent Technical Specification (RETS)

Dear Sir:

Pursuant to Section 50.59 of the Commission's Rules and Regulations, Vermont Yankee Nuclear Power Corporation hereby proposes the following modification to Appendix A of the Operating License:

Proposed Change In accordance with our commitment to modify our operating license with a formal RETS amendment, Proposed Change No. 78, Supplement 1 [ Reference (b)],

was submitted to the NRC on January 23, 1984. USNRC subsequently accepted our proposed change and issued Amendment No. 83 to our Appendix A Technical

+ Specifications (Reference (c)] with an implementation date of April 1, 1985.

$c: By this proposed change, we request that you replace Pages Aa, 66, 152,

$f 160a, 160c, 166, 168, and 169 with the attached amended Pages Aa, 66, 152, gg 160a, 160c, 166, 168 and 169 (see Attachment A) . Page 167 is provided for on infstic.ation purposes only.

Lo gd The change on Page 152, 160a, and 160c permits the incineration of oc contaminated oil in equipment, such as the auxiliary boilers, which previously O,@ had not been considered as radioactive effluent release points. The dose Q contribution from the incineration of oil will be held to less than 0.1% of

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United States Nuclear Regulatory Commission January 24, 1986 Attention: Mr. H. R. Denton Page 2 i

the limits in Technical Specification 3.8.G.1.a and b, with the determination of the radioactivity to be released based on grab samples of the liquid oil prior to its incineration.

The change on Page 166 and 168 involves a modification to Table 3.9.2 with the deletion and replacement of table notes as indicated. Note 2 on Page 166 originally referred to both the noble gas activity monitors on the augmented off-gas system (Table 3.9.2, Instrument 2.a) and plant stack (Instrument 3.a). The proposed change deletes Note 2 for the plant stack noble gas activity monitor and replaces it with a new Note 10.

'3 The change on Page 169 modifies Table 3.9.3, Section 1.a. " Airborne Radiolodine and Particulates," with respect to the written description of the locations of the five required air monitoring stations. Reference to site boundary locations in three different sectors of the highest calculated annual average ground level D/Q, and the highest calculated annual average ground level D/Q of a nearby community, as presently stated in Table 3.9.3, have been replaced with more appropriate phrases on which to interpret intent and compliance, and reflects more accurately the long established air monitoring program at Vermont Yankee.

Additionally, modifications to Section 1.0 " Definitions" on Page 4a, and

]

Section 3.2, " Bases" on Page 66 (pertaining to Specification 3.8.C.1.a) are proposed to reflect our current understanding of the intent of the RETS as accepted by NRC..

Reason for Change The change requested on Pages 152, 160s, and 160c will permit the plant to dispose of lightly contaminated waste oil by incineration without the cost

associated with otherwise solidifying the oil and shipping it as solid waste to an approved disposal site. The ability to handle waste oil by on-site incineration will also provide a viable alternative to the plant in treating and dispcsing of this particular waste stream in light of the uncertain future availability of burial ground access.

During review of the accepted RETS Amendment No. 83, a discrepancy was identified in the actions to be taken when the plant stack noble gas activity monitor is unavailable per the minimum channels operable requirement (Page 166). Note 2 to Table 3.9.2 in actuality only reflects the action to be taken for the noble gas activity monitor on the augmented off-gas system. The proper action to be taken for the noble gas monitor on the plant stack was inadvertently omitted and is hereby requested to be reinserted in Table 3.9.2 as Note 10 on Page 168. Note 10 states that, "with the number of channels operable less than required by the Minimum Channels operable requirement, effluent releases via this pathway may continue provided grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

The change requested for Page 169 concerns a recent NRC inspection of our Radiologital Environmental Monitoring Program [ Reference (d)] which concluded that Technical Specification 3.9.C (Table 3.9.3) requires that annual reviews

United States Nuclear Regulatory Commission January 24, 1986 Attention: Mr. H. R. Denton Page 3 be performed to determine the sampling points for airborne iodine and particulate samples to ensure that those sampling points continue to meet the description of monitoring locations given in Technical Specification Table 3.9.3. This infers that, based on random annual fluctuations in site meteorological patterns, fixed air monitoring stations should be required to be moved to new locations. Clearly, this was never the intent in the rationale on how air monitoring stations should be located or used. Currently, the general description of monitoring locations as given in Table 3.9.3, Section 1.a. reflects the generic wording found in NRC's Model Radiological Effluent Technical Specification, but does not fully take into account site specific characteristics, such as river valley conditions, elevated stack releases for a BWR, or long-term accumulation of monitoring data at fixed points on which to perform trending and historical comparison with pre-operational data. The change in wording as proposed eliminates the ambiguity of the current Technical Specification by removing referette to maximum annual average D/Q. The new wording reflects the actual rationale on how air monitoring stations were located (see attached amended Table 3.9.3).

As part of this proposed change in wording, the number of "close to the site boundary" air monitoring stations is requested to be changed from three locations to two; one up-valley and one down-valley. This corrects a discrepancy between the existing air monitoring program and Technical Specification Table 3.9.3 that occurred as a result of the generic NRC guidance used on Table 3.9.3 in Amendment 83. The stations located up-valley /down-valley reflect the two major wind directions at Vermont Yankee. The third location close to the site boundary is in fact not a major wind direction, but is situated cross valley in the nearest community to the plant.

Additionally, by this proposed change we are deleting definitions G.G.

" Radioactive Material" and H.H. " Contamination" (Page Aa) which were incorporated into our Technical Specifications by Amendment No. 83. These definitions have subsequently been determined to be outside the scope of the RETS and not required for Vermont Yankee, and therefore, are being proposed for deletion. Further, an administrative chan5e is proposed for the Section 3.2 " Bases" discussion to revise the reference to Specification 3.8.C.1.a which was deleted from out Technical Specifications by Amendment No. 83.

Basis for Change The proposed addition to the Technical Specifications which would permit the burning of contaminated oil is restricted to quantities such that the potential contribution to the dose or dose commitment 'to a member of the public resulting from this oil incineration represents a very small fraction (0.1%) of the dose limits already permitted by the exicting Technical Specifications for gaseous cffluents. The current effluent Technical ,

Coecifications are,ccasistent with the ALARA dose objective of 10CFR, Part 50, Appendix _I,and'ss such any additional dose resulting from the proposed waste oil incineration will have an insignificant impact.

The proposed correction to Technical Specification Table 3.9.2 reflects direct NRC guidance in their draft Radiological Effluent Technical Specifications (NUREG-0473, Revision 3) for conditions when the minimum

United States Nuclear Regulatory Commission January 24, 1986 Attention: Mr. H. R. Denton page 4 channels operable requirement for a noble gas monitor at a final release point to the environment is not able to be met.

For the change on Page 169, the generic description for placement of air monitoring stations as given on Table 3.9.3 is stated as, "close to three site boundary locations, in different sectors, of the highest calculated annual average ground level D/Q." The intent is obvious in that the monitoring stations should be placed, based on average meteorology, at locations where continuous plant effluents would most likely be first detected at an activity level corresponding to the lower limit of detection (LLD) of the counting system. However, the generic wording does not clearly account for site specific features which could affect the placement of air monitors to meet the intent, nor does it reflect the desirability of maintaining a long established data base of an air monitoring program set up in the early 1970's, before the current guidance was available. Attachment B are amended pages to Vermont Yankee's ODCM, which provides the basis for the existing air monitoring locations. These changes will be reviewed and approved in accordance with Technical Specification 6.13, and in addition, are submitted along with the proposed Technical Specification change to Table 3.9.3 for informational purposes .

In overview, the existing air monitoring locations provide many years of operational data on which trend analysis can be performed. The interpretation which would potentially require these stations to be moved on an annual basis would negate the ability to perform long-term trend analysis and comparison of operational data with pre-operational information with no real gain in the ability to detect plant effluents in the environment at any significant level. In addition, it is not practical to expect to move on a frequent basis air monitoring equipment from one location to another due to the nature of the equipment, its protective enclosure, and electrical power requirements. As a j result, the interpretation which would require station locations being re-evaluated and potentially moved on a periodic frequency is rejected.

Upon review of the existing air monitor locations against a long-term (5 year) meteorological data base for the Vermont Yankee site, the stations are found to be in places which reflect our understanding of the intent of the general guidance. Vermont Yankee is situated in a river valley which, based on a 5-year meteorological record, shows a pronounced two directional wind flow; up-valley and down-valley. Regional meteorological changes over the expected life of the plant which could effect the placement of the air monitoring stations would not be expected to change substantially from the conditions seen over a 5-year time period. Air monitoring stations have been located in up-valley and down-valley directions and, therefore, cover these principal wind directions. In addition, the up-valley air monitor is situated to also cover a nearby population group. Two additional air monitoring stations are located to cover the other nearby populational groups; Hinsdale across valley to east, and Northfield down-valley which also exhibits the maximum long-term average D/Q value of any nearby community. Therefore, the existing air monitoring stations are found to reflect the intent of the guidance in that they are situated in areas where you would most likely be able to detect plant effluents over the course of time as well as at nearby communities to the plant site.

United States Nuclear Regulatory Commission January 24, 1986 )

Attention: Mr. H. R. Denton Page 5 The proposed modification to Page Aa, " Definitions" is essentially an administrative correction to the Technical Specifications. The proposed modification to Page 66 " Bases," is also an administrative correction to the Technical Specification to remove references to an obsolete condition which is no longer applied at the plant.

Safety Considerations The changes proposed are believed to be consistent with the intent of the model NRC RETS and as such are not considered to constitute an unreviewed safety question as defined in 10CFR50.59(a)(2). These changes have been reviewed by the Plant Operations Review Committee and the 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 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 discussion below addecsses each of the proposed changes with respect to these three criteria and demonstrates that the proposed amendment involves a no significant hazards consideration.

The proposed changes to Pages 152, 160a and 160c address the incineration 'x s Ns of radioactively contaminated oil in nonsafety-related equipment, such as the auxiliary boilers. The levels of radioactive effluents permitted by the incineration of waste oil represent a small fraction of allowable dose limits under Appendix I to 10CFR50. As such, there is no impact in the probability or consequences of accident previously evaluated by this change since it does not involve safety system or primary system boundaries. Similarly, no new kinds of accidents involving safety-related systems are created by this change, nor are any changes required in plant operating or design safety margins.

The changes on Pages 166, 168 and 169 involve modifications to the off-site environmental monitoring program. The location of air monitoring stations as described in NRC guidance or as requested in this proposed change are not related to accident analyses or plant safety. As such, this change does not impact the probability or consequences of any accident previously evaluated, nor does it create the possibility of a new or different kind of accident from any accident previously considered. Since the change concerns only off-site environmental monitoring, no change in any plant safety margin is required.

United States Nuclear Regulatory Commission January 24, 1986 Attention: Mr. H. R. Denton Page 6 The proposed change on Page 4a concerns the deletion from the Technical Specifications definitions' of " Radioactive Materials" and " Contamination" which were included in Amendment No. 83, but later determined to be outside the scope of RETS. The removal of these definitions have no bearing on any accident previously evaluated, noc create the possibility of a new or different kind of accident since they have not been applied to any accident analysis. Similarly, no changes in any plant operating or design bases safety margins are required by the removal of these definitions.

The proposed change on Page 66 concerns the deletion from Bases Section 3.2 reference to a plant stack release rate limit Technical Specification (3.8.c.1.a) which became obsolete with the adoption of Amendment 83, but administrative 1y overlooked with respect to its removal. The deletion of the obsolete information on Page 66 and its replacement with limiting conditions of operations as it relates to maximum off-site dose rates which were accepted as part of Amendment 83, creates no significant change in the probability or consequences of an accident previously evaluated, nor creates a new or different kind of accident. No significant changes in any plant operating or design bases safety margins are required by the editorial change proposed for Page 66.

In addition, the Commission has provided guidance concerning the practical application of the 10CFR50.92 standards for determining whether a "significant hazards" consideration exists by providing certain examples (48FR14870).

One of these examples (vi) states that a change which either may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results of 1 the changes are clearly within all acceptable criteria with respect to the l

system or component specified in the Standard Review Plan: for example, a .

change resulting from the application of a small refinement of a previously used calculational model or design method, does not involve a significant hazard consideration. Clearly, the proposal to incinerate contaminated oil in quantities restricted to the above noted limits on off-site dose are well within the release limits for normal effluents and present little probability of accidental release involving plant safety systems.

Another of the Commission's examples (ii) states that a change which

' constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications, for example, a more stringent survel.11ance requirement, does not involve a significant hazard considerption. As described above, the changes being proposed for Table 3.9.2 constituto an additional limitation and control not presently included in the Technical Specifications for Vermont Yankee, which is being added to conform withtheregul{ementsof10CFRPart50,AppendixI.

In addition,\one of the commission's examples (vii) states that a change I to make a license c'onform to changes in the regulations, where the license '

change results in ver'y minor changes to facility operations clearly in keeping with the regulations. Ao described above, the change proposal for Table 3.9.3 l in the placement of air monitoring stations constitutes such a change. l 1

United States Nuclear Regulatory Commission January 24, 1986 Attention: Mr. H. R. Denton Page 7 Another of the Commisalon's examples (i) states that a purely administrative change involves a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature. As described above, the changes proposed for Page 4a

" Definitions" and Page 66 " Bases" constitute administrative changes to correct items in the Technical Specifications resulting from Amendment No. 83.

Therefore, we conclude that these proposed changes do 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 These changes will be incorporated into the Technical Specifications immediately upon approval by NRC.

We trust that this information is acceptable; however, should you have any questions regarding this matter, please contact us.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION e24*--/kA+

Warren P./Murph ~

Vice President and Manager of Operations MSS /gms Enclosure cc: U.S. Nuclear Regulatory Commission g g,ggO Document Control Desk (40 copies) gh Mg Vermont Department of Public Services 120 State Street fl0TARY Montpelier, Vermont 05602 Attention: Mr. G. Tarrant, Chairman

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Then personally appeared before me, Warren P. Murphy, who, being d'uly 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 b f.

(O Diane McCue i Notary Public My Commission Expires