ML20247G879

Application for Amend to License DPR-28,eliminating cycle-specific Parameter Limits from Tech Specs,Per Generic Ltr 88-16.Rev 0 to Vermont Yankee Cycle 14 Core Operating Limits Rept, Encl

ML20247G879
Person / Time
Site:	Vermont Yankee
Issue date:	05/12/1989
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247G885	List: ML20247G879 ML20247G903 ML20247G990
References
BVY-89-43, GL-88-16, NUDOCS 8905310096
Download: ML20247G879 (5)

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VERMONT YANKEE NUCLEAR POWER CORPORATION Proposed Change No. 150 l

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.r Ferry Road, Brattleboro, VT 05301-7002 (802) 257 5271 1989 BVY 89-43 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

References:

a) License No. DPR-28 (Docket No. 50-271) b) Letter, USNRC to VYNPC, Generic Letter 88-16, NVY 88-224, dated 10/4/88

Subject:

Proposed Change to Eliminate the Cycle-Specific Parameter Limits from the Vermont Yankee Technical Specifications (Generic Letter 88-16)

Pursuant to Section 50.90 of the Commission's Rules and Regulations, Vermont Yankee Nuclear Power Corporation (VYNPC) hereby proposes the following change to Appendix A of the Operating License [ Reference a)).

PROPOSED CHANGE Vermont Yankee proposes to change its Technical Specifications by elimin-ating the cycle-specific parameter limits from various sections of the Vermont Yankee Technical Specifications; listing the approved methods in the Technical Specifications; and describing the Core Operating Limits Report (COLR) which will contain the cycle-specific limits. These changes are consistent with the guidance provided in NRC Generic Letter 88-16 [ Reference b)) which encouraged all licensees and applicants to eliminate the cycle-specific limits from the Technical Specifications. The proposed section changes and revised pages are listed in Attachment 2. Attachment 3 contains the revised pages. ]

l REASON FOR CHANGE '

By Generic Letter 88-16, dated October 4, 1988 [ Reference b)), the NRC I recommended that all licensees eliminate the cycle-specific limits from their Technical Specifications. Accordingly, Vermont Yankee proposes these changes in conformance with the recommendations in Reference b).

8905310096 890512 PDR P ADOCK 05000271 /

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I VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission .

May 12, 1989 I Page 2 BASES FOR CHANGE The cycle-specific limits being removed by these proposed changes are:

a) Maximum Average Planar Linear Heat Generation Limit (Section 3.11.A);

b) Maximum Linear Heat Generation Rate Limit (Section 3.11.B); and c) Minimum Critical Power Ratio (Section 3.11.C).

These operating limits will still be calculated for each cycle using the approved methods specified in Attachment 1. The approvals will now be listed in the proposed Technical Specification Section 6.7.A.4. The cycle-specific limits will be provided to the plant and to the NRC in the Core Operating Limits Report (COLR) which will be described in the proposed Section 1.0,NN of the Technical Specifications. Attachment 4 provides a sample format for this report. The Cycle 14 (the current operating cycle) COLR will be provided following approval of these proposed changes. The Technical Specifications will still require the plant to operate within these limits and to take the appropriate action should the limits be exceeded.

SAFETY CONSIDERATIONS These proposed changes do not present any unreviewed safety questions as defined in 10CFR50.59(a)(2). The proposed changes are consistent with the requirements of 10CFR50, Part 50.36 and the staff's proposed policy for improving Technical Specifications, delineated in SECY-86-10, " Recommendations for Improving Technical Specifications." The policy allows that process variables such as core operational limits be controlled by specifying them numerically in the Technical Specifications or by specifying the method of calculating their numerical values if the staff finds that the correct limits will be followed in operating the plant. The proposed revision references the approved core reload design methodolgy for the current cycle and future Vermont Yankee reloads. The cycle-specific operating limits will be defined using approved methods which will be listed in Section 6.7.A.4 of the Technical Specifications. The Technical Specifications will continue to require operation within the cycle-specific limits for each cycle. The limits will be listed in the COLR for each cycle and will be provided to the NRC prior to each cycle's operation or the applicable part of the cycle. These changes have been reviewed by the Plant Operations Review Committee (PORC) and the Nuclear Safety Audit and Review Committee (NSARC).

SIGNIFICANT HAZARDS CONSIDERATION 10CFR50.92(c) states that a proposed amendment will not involve a signifi-cant hazards consideration if the proposed amendment does not: (i) involve a significant increase in the probability or consequences of an accident pre-viously evaluated; or (ii) create the possibility of a new or different kind of accident from any accident previously evaluated; or (iii) involve a significant reduction in a margin of safety. The discussion below addresses these standards and demonstrates that operating the facility with these proposed changes involves no significant hazards considerations:

1J- e VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission May 12, 1989 Page 3-

1. The proposed changes do not involve a significant increase in.the probabi-lity or consequences of an accident previously evaluated because the cycle-specific limits will still be determined by analyzing the same postulated events previously analyzed. The removal of the cycle-specific limits from the Technical Specifications has no influence or impact on a Design Basis Accident occurrence. Each accident analysis previously addressed will be

- examined with respect to changes in the cycle dependent parameters using the NRC-approved reload design methodologies to ensure that the transient evaluation of new reloads are bounded by previously accepted analyses.

This examination, which will be performed per requirements of 10CFR50.59, ensure that future reloads will not involve a significant increase in the probability or consequences of an accident previously evaluated. The plant will continue to operate within the limits specified in the COLR and to take the same actions when, or if, the limits are exceeded as required by the current Technical Specifications,

2. The proposed changes do not create the possibility of a new or different kind of accident previously evaluated because no p',sical alterations of plant configuration, changes to setpoints, or saf'ey limits are proposed.-

1 As stated above, the removal of the cycle-specific limits does not

-influence, impact, nor contribute in any way to the probability or con-sequences of any accident. The cycle-specific limits will be calculated using the NRC-approved methods. The Technical Specifications will continue to require operation within the required core operating limits and approp,riate actions will be taken when, or if, limits are exceeded.

3. The proposed changes do not involve a significant reduction in a safety

1. . margin because they do not affect any operating practices, limits, or P

safety-related equipment. The margin of safety presently provided by the current Technical Specifications remains unchanged. The proposed amendment still requires operation within the core limits as obtained from the NRC-approved reload design methodologies and appropriate actions to be tsken when, or if, limits are violated remain unchanged. The development of the limits for future reloads will continue to conform to those methods described in the NRC-approved documentation. In addition, each future reload will involve a Part 50.59 safety review to assure that operation of the plant within the cycle-specific limits will not involve a significant reduction in a margin of safety.

SCHEDULE FOR CHANGES We request that your review and approval of these proposed changes be completed within three months of the submittal date. These changes can be incor-porated into the Vermont Yankee Technical Specifications within 30 days following receipt of your approval.

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. h, e-VERMONT YANKEE NUCLEAR POWER CORPORATION U.S.-Nuclear Regulatory Commission May 12,-1989:

Page 4.

We trust.that.the information 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 W M Warren P. M rphy Vice President and Manager of Operations

/dm cc: USNRC Regional Administrator, Region I USNRC Resident. Inspector, VYNPS Vermont Department of Public Service STATE OF, VERMONT)

)ss WINDHAM COUNTY )

Then personally appeared before me, Warren P. Murohy, who, being duly sworn, did state that he.is 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 t: the best of his knowledge and belief.

~UN 0 N %, e m. .

Diane M. McCue Notary Public My Commission Expires Februar 1 1991 i

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s e ATTACHMENT 1 Approved Methodologies for Generating Vermont Yankee Cycle-Specific Limits (a) Report, E. E. Pilat, Methods for the Analysis of Boiling Water Reactors Lattice Physics, YAEC-1232, December 1980 l

(b) Report, D. M. VerPlanck, Methods for the Analysis of Boiling Water

- Reactors Steady State Core Physics, YAEC-1238, March 1981 l

l (c) Report, J. M. Ilolzer, Methods for the Analysis of Boiling Water Reactors Transient Core Physics, YAEC-1239P, August 1981 (d) Report, S. P. Schultz and K. E. St. John, Methods for the Analysis of Oxide Fuel Rod Steady-State Thernal Effects (FROSSTEY) Code /Model Description Manual, YAEC-1242P, April 1981 1

(e) Report, S. P. Schultz and K. E. St. John, Methods for the Analysis of Oxide Fuel Rod Steady - State-Thermal Effects (FROSSTEY): Code Qualification and Application, YAEC-1265P, June 1981 l

l l (f) Report, A. A. F. Ansari, Methods for the Analysis of Polling Water Reactors: Steady-State Core Flow Distribution Code (FIBWR), YAEC-1234, December 1980 l (g) Report, A. A. F. Ansari and J. T. Cronin, Methods for the Analysis of Boiling Water Reactors: A System Transient Analysis Model (RETRAN1, YAEC-1233, April 1981 (h) Report, A. A. F. Ansari, K. J. Burns, and D. K. Beller, Methods for the Analysis of Boiling Water Reactors: Transient Critical Power Ratio Analysis (RETRAN-TCPYA01), YAEC-1299P, March 1982 (i) Report, Loss-of-Coolant Accident Analysis for Vermont Yankee Nuclear ,

Power Station, NEDO-21697, August 1977, as amended l (j) Report, General Electric Standard Application for Reactor Fuel (CESTARIIl, NEDE-24011-P-A-9, GE Company Proprietary, September 1988, as amended (k) Letter, USNRC to VYNPC, SER, November 27, 1981 (1) Letter, USNRC to VYNPC, SER, NVY 82-157, September 15, 1982 (m) Letter, USNRC to VYNPC, SER, NVY 85-205, September 27, 1985 (n) Lettor, USNRC to VYNPC, SER, November 30, 1977 1

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