ML20212K266

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Application to Amend License DPR-28,consisting of Proposed Change 137,revising Tech Spec Tables 3.2.6 & 4.2.6 by Incorporating Redundant post-accident Instrumentation & Associated Limiting Conditions for Operation.Fee Paid
ML20212K266
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 01/12/1987
From: Murphy W
VERMONT YANKEE NUCLEAR POWER CORP.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML20212K270 List:
References
RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 FVY-87-08, FVY-87-8, NUDOCS 8701290033
Download: ML20212K266 (5)


Text

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VERMONT YANKEE NUCLEAR POWER CORPORATION Proposed Change No. 137 FVY 87-08 RD 5, Box 169, Ferry Road, Brattleboro, VT 05301

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ENGINEERING OFFICE N

1671 WORCESTER ROAD FRAMINGHAM, MASS ACHUSETTS 01701 TELEPHONE 617472-6100 January 12, 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, VYNPC to USNRC, FVY 84-127, dated October 30, 1984, "NUREG-0737 Supplement 1 - Regulatory Guide 1.97" (c) Letter, VYNPC to USNRC, FVY 85-99, dated October 25, 1985

Subject:

Post-Accident Instrumentation Technical Specifications

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.

Proposett Change Replace Pages 49, 60, and 66 of the VY Technical Specifications with the attached, revised Pages 49, 60, and 66.

These changes incorporate the addition of redundant post-accident instrumentation and associated limiting conditions for operation and surveillance requirements, a range change, and several minor corrective updates for currently installed instrumentation.

Reason for Change The purpose of the three changes proposed by this amendment request is to revise Tables 3.2.6 and 4.2.6 of the Technical Specifications for the following reasons:

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bnited'StatesNuclearRegulatoryCommission January 12, 1987 Attention:

Mr. H. R. Denton, Director Page 2 Change I is proposed to incorporate the addition of certain redundant post-accident instrumentation installed as a result of NUREG-0737, Supplement 1 and Regulatory Guide 1.97 [ References (b) and (c)]. Change II is proposed to reflect the change to the torus water level instrument range made to support the new emergency operating procedures. Additionally, Change III proposes corrective updates to Table 3.2.6.

Basis for Change I.

Based on the Regulatory Guide 1.97 commitment documented'in Reference (b), the following changes are proposed to Page 49, Table 3.2.6 and Page 60, Table 4.2.6:

(A) The torus pressure parameter was upgraded to provide two (2) redundant, fully qualified instrument channels. The Table 3.2.6 drywell pressure parameter type of indication is accordingly revised to identify the two (2) 0-80 psia pressure indicators, Meters PI-16-19-36A, B.

(B) Based on the torus pressure instrumentation upgrade, the calibration frequency listed in Table 4.2.6, Page 60, was revised to read once/ Operating Cycle to reflect the installation of analog transmitters. This is consistent with the calibration frequency for other analog instrumentation in the plant.

(C) The torus air temperature instrument channel was upgraded to include a redundant fully qualified instrument channel.

Temperature indicator, Meter TI-16-19-41, with a range of 0

50-300 F is accordingly added to Table 3.2.6.

(D) The reactor vessel water level instrumentation range was upgraded to provide an expanded range indication for the redundant, fully qualified instrumentation. The indication range of Meters 2-3-91A, B was expanded from (-150)-0-(+150) inches of water to (-200)-0-(+200) inches of water.

Accordingly, the Table 3.2.6 reactor vessel water level parameter indication instrument range is being changed.

II.

NUREG-0737, Supplement i required symptom-based Emergency Operating Procedures (EOPs). These EOPs require the ability to measure water level to at least 22.4 feet in the torus. Therefore, the torus water level instrumentation was changed to provide a range of 0-25 feet as indicated by Meters LI-16-19-12A, B.

Accordingly, revisions to Table 3.2.6 (Page 49) and to Section 3.2 Bases (Page 66) are proposed to reflect this indication change.

UnitchStatesNuclearRegulatoryCommission January 12, 1987 Attention:- Mr. H. R. Denton, Director-Page 3 III. A corrective' update to Table 3.2.6, Page 49, is proposed for the drywell pressure indicators because containment pressure indication is provided by Noters PI-16-19-12A, B and not by Meters 16-19-29 A, B as presently indicated in Table 3.2.6.

16-19-29A, B are the identification numbers of the transmitters which supply the signal to the indicators. Additionally, the indication recorder number (No..TR-1-149) for the drywell atmospheric temperature parameter on Table 3.2.6 is revised to read as No. TR-1-149-1 to better specify the actual indication recorder number.

Safety Considerations The upgraded redundant, environmentally, and seismically qualified instrumentation (Changes I(A), I(C), and I(D)] enhances the operator's ability to follow the course of an event.

The calibration frequency change

[ Change I(B)] reflects the increased reliability of the upgraded instrumentation, also enhancing plant safety.

The range change to the torus water level instrumentation [ Change II) enhances plant safety by enveloping with margin the EOP requirement. The corrective update (Change III) reflects the proper identification number for the control board mounted indicators and is administrative in nature.

These changes have been determined not to constitute an unreviewed safety question as defined by 10CFR50.59(a)(2).

This proposed change has been reviewed by the Vermont Yankee Nuclear Safety Audit Review Committee.

Sinnificant 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 addresses each of the proposed changes with respect to these three criteria, and demonstrates that the proposed changes do not constitute a significant hazards consideration.

Proposed Changes I(A), I(B)

I(C), and I(D) involve the addition of redundant, environmentally, and seismically qualified instrumentation, an associated calibration frequency change and an expanded indicator range.

These changes enhance the safety of the plant by assuring the upgraded / qualified instrumentation will operate properly following a Loss of Coolant Accident (LOCA) or High Energy Line Break (HgLB). The calibration frequency change to Table 4.2.6 from every six months to once per operating cycle reflects the increased reliability and reduced setpoint drift of the upgraded instrumentation, and is consistent with the existing Technical Specification calibration frequency for other similar equipment in the plant.

United States Nuclear Regulatory Commission January 12, 1987 Attention:

Mr. H. R. Denton, Director Page 4 The equipment added and modified in these changes complies with NRC accepted design and installation standards.

In' addition it has been selected to enhance operator interface and support emergency operating procedures. As such, this change does not increase in the probability or consequences of accidents previously evaluated. Similarly, no new or different kinds of accidents involving safety-related systems are created by this change, nor are any changes required in plant operating or design safety margins.

Proposed Change II involves the modification of the torus water level instrumentation range to envelop, with margin, the Emergency Operating Procedure requirement to measure at least 22.4 feet in the torus. The torus water level instrumentation is redundant, environmentally, and seismically qualified analog instrumentation. The change assures that qualified instrumentation will operate properly following a LOCA or HELB and will support operator procedural steps. As such, this chango does nottimpact the probability or consequences of accidents previously evaluated. Similarly, no new or different kinds of accidents are created by this change, nor is any plant safety margin impacted.

Proposed Change III involves corrective updates to Table 3.2.6.

As such, there is no incresco in the probability or consequences of accidents previously evaluated. Similarly, no new or different kinds of accidents are created by this change, nor is any margin of safety reduced.

The Commission has 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 (vii) is a change to make a license conform to changes in the regulations where the license change results in very minor changes to facility operations clearly in keeping with the regulations. Proposed Changes I and II involve instrumentation enhancements resulting from NUREG-0737, Supplement 1, requirements and, thus, fall within the Commission's example (vil). Another of the examples (1) is a purely administrative change to the Technical l

Specifications; for example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature.

Proposed Change III clearly falls within the scope of this Commission example.

l Therefore, we conclude that these proposed changes do not constitute a l

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.

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Schedule of Change This change to the Vermont Yankeo Technical Specifications will be l

implemented as soon as practicable following receipt of your approval, r

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4 United States Nuclear Regulatory Conuaission January 12, 1987 Attention: :Mr. M. R. Denton, Director Page 5 We trust that the information provided above adequately supports our request; however, should you have any questions in this matter, please contact us.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION d.46--

ts4 Warren P. Murp y Vice President an nbger of Operations DOC No. 1717c MPS/js1 Enclosures cc: Vermont Department of Public Services 120 State Street Montpelier, VT 05602 Attention:

Mr. G. Tarrant, Chairman STATE OF VERMONT )

)ss OF 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 Yankee Nuclear Power Corporation and that the statements therein are true to the best of his knowledge and belief.

O DiaTie McCue Notary Public l

My Commission Expires February 10, 1987 j

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