ML20207Q467
| ML20207Q467 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 01/16/1987 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20207Q468 | List: |
| References | |
| FVY-87-10, NUDOCS 8701270398 | |
| Download: ML20207Q467 (4) | |
Text
- VERMONT YANKEE Proposed Change No. 136 NUCLEAR POWER CORPORATION RD 5, Box 169. Ferry Road, Brattleboro, VT 05301 g,87-10
. g ENGINEERING, OFFICE yp-1671 WORCESTER HOAD FRAMINGHAM, MASS ACHUSETTS 01701 TELEPHONE 617-e72 4100 January 16, 1987 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 86-43, " Inspection Report No. 50-271/86-05 " dated March 11, 1986 (c) Letter, USNRC to VYNPC, NVY 86-70, " Enforcement Conference for Inspection Report No. 50-271/86-05," dated April 15, 1986 (d) Letter, USNRC to VYNPC, NVY 86-74, " Notice of Violation,"
dated April 22, 1986 (e) Letter, VYNPC to USNRC, FVY 86-43, " Response to Inspection Report 85-05 Notice of Violation," dated May 22, 1986 (f)
IE Information Notice No. 86-13, Supplement 1, NVY 86-160,
" Standby Liquid Control Squib Valves Failure to Fire,"
dated August 5, 1986
Subject:
Proposed Change to the Vermont Yankee Reactor Standby Liquid Control System Technical Specification Dear Sire Pursuant to Section 50.59 of the Commission's Rules and Regulations, Vermont Yankee (VY) Nuclear Power Corporation hereby proposes the following change to Appendix A of the operating license.
Proposed Change Replace Pages 79, 80, 83, and 84 of the VY Technical Specifications with the attached Pages 79, 79a, 80, 83, and 84 This proposed change revises Sections 3.4 and 4.4 of the Technical Specification Limiting conditions for Operation, Surveillance Requirements, and Bases pertaining to Reactor Standby Liquid Control System (SLC System) operability testing and surveillance.
Reason For Change _
As a result of problems identified during the 1986 SLC System surveillance test, wherein both redundant components of the SLC System were 8701270398 870116 b
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4 United States Nuclear Regulatory Commission January 16, 1987 Attention:
Mr. H. R. Denton, Director Page 2 inoperable in that their explosive squib valves would not actuate, if required, to provide a flow path from the Standby Liquid Control System storage tank to the reactor vessel [ References (a) to (f)]; VY initiated several corrective actions, including a review of the Technical Specifications pertaining to specific requirements concerning testing / surveillance of the SLC System (Sections 3.4 and 4.4).
Accordingly, VY determined that enhancements to Sections 3.4 and 4.4 were warranted to better reflec6 SLC System operability requirements and the revised and upgraded functional test requirements contained in Revislon 8 of Operating Procedure 4203, " Maintenance and Testing of SLC Squib Valves." Therefore, a change to Sections 3.4 and 4.4 of the VY Technical Specifications is proposed.
Further, VY stated in Reference (e) that if the review determined that Technical Specification changes were warranted, they would be submitted to NRC for review and approval in time to support the next demonstration of SLC System operability, which is scheduled for the 1987 refuellag outage.
Basis for Change Currently, the VY Technical Specification Limiting condition for Operation (LCO) 3.4.A requires the Standby Liquid Control System (SLCS) to be operable whenever fuel is in the reactor and the reactor mode switch is not in the shutdown posltion. Technical Specification LCO 3.4.B permits operation to continue in the existing mode for seven days if a redundant component of the SLCS is inoperable. Unless Technical Specification LCOs 3.4.A or 3.4.B are met, the reactor shall be in the cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
As stated previously, to effectively address the problems identified during the 1986 SLC System surveillance test, certain enhancements to Technical Specifications Sections 3.4. and 4.4 were determined to be warranted. Specifically, VY proposes to reformat Sections 3.4.A 4.4.A, 3.4.C, and 4.4.C to clarify SLC operability and surveillance requirements.
Further, the Section 4.4 surveillance requirement is revised to specify the flow, relief valve, circuitry, and trigger assembly operability functional test surveillance requirements. The flow testing surveillance requirement for the SLC loops and normal maintenance practices during the removal and installation of the primer chamber for surveillance provide a basis for removing the requirement to inspect the exploslon valves for clogging.
In addition to the above, the Section 3.4 and 4.4 Bases Section is revised to specify the SLC System operability functional testing requirements.
Safety Considerations The changes proposed by this amendment request do not present any unreviewed safety questions as defined in 10CFR50.59. The changes proposed reflect human factors enhancements to the SLC System operability requirements sections and further add SLC System operability functional testing requirements. As such, these changes are considered to be improvements to the safety of the plant.
These changes have been reviewed by the Plant Operations Review Committee and the Nuclear Safety Audit and Review Committee.
~
United States Nuclear Regulatory Commission January 16, 1987 Attention:
Mr. H. R. Denton, Director Page 3 Significant Hazards Consideration The standards used to arrive at a determination that a request for amendment requires 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 now or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety. The discussion below addresses each of these three criteria and demonstrates that the proposed amendment involves no significant hazards considerations.
The changes proposed for Sections 3.4 and 4.4 of the Vermont Yankee Technical Specifications reflect human factors enhancements and additional surveillance testing requirements pertaining to SLC System operability. These changes are proposed to reduce the probability of plant operation with an inoperable SLC System. Thus, the propssed changes do not involve a significant increase in the probability or consequences of an event previously evaluated. Operation of the SLC Syste:a is not reduced from existing requirements and is still bounded by the assumptions used in the safety analysis, thus the proposed change doe 1 not create the possibility of a new or different kind of accident from any event previously evaluated. The human factors enhancements, and additional surveillance requirements for SLC System operability testing proposed by this c'1ange do not affect any existing safety margins, thus no significant reduction in any margin of safety is involved.
The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (48FR14870). One of those examples (ii) of actions which involve no significant hazards consideration is a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications, such as a more stringent surveillance requirement. As discussed above, the proposed Technical Specifications changes for Sections 3.4 and 4.4 concerning SLC System operability constitute human factors enhancements and additional surveillance requirements not presently included in the Technical Specifications.
Therefore, we conclude that those proposed changes do not constitute a significant hazards consideration, as defined in 10CFR50.92.
Fee Determination In accordance with the provisions of 10CFR170.12, an application fee of
$150.00 is enclosed.
Schedule of Change In order to permit the use of this Technical Specification change prior to the next operability demonstration of the SLC System squib valves scheduled for the 1987 refueling outage, we request that your review and approval of this proposed change be completed no later than June 30, 1987. This change to the Vermont Yankee Technical Specliications will be implemented as soon as practiceble following receipt of your approval.
United States Nuclear Regulatory Commission January 16, 1987 Attention:
Mr. H. R. Denton, Director Page 4 We trust that the information provided above adequately supports our request; however, should you have any questions in this matter, please contact us.
i Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION
<24 s4---
Ye*r 4
Warren P Murphy Vice President a d a ager of Operations RWC/bil Enclosure i
cc: Vermont Department of Public Services 120 State Street Montpelier, VT 05602 j
Attention:
Mr. G. Tarrant, Chairman STATE OF VERMONT
)
)ss OF WINDHAM COUNTY
)
l 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 request in the name and on the behalf of I
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 Notary Public My Commission Expires l
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