ML20211K732

Application for Amend to License DPR-3,changing Tech Specs to Allow Performance of 10CFR50.59 Reviews for Future Core Reloads.Fee Paid

ML20211K732
Person / Time
Site:	Yankee Rowe
Issue date:	06/24/1986
From:	Heider L YANKEE ATOMIC ELECTRIC CO.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20211K736	List: ML20211K732 ML20211K750
References
DCC-86-074, DCC-86-74, FYR-86-057, FYR-86-57, NUDOCS 8606300238
Download: ML20211K732 (4)

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,i 2.C15 1 June 24, 1986 FYR 86-057 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Office of Nuclear Reactor Regulation

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) YAEC Letter to USNRC, dated August 30, 1985 (FYR 85-91)

Subject:

Core Operating Limits Report

Dear Sir:

Pursuant to Section 50.59 of the Commission's Rules and Regulations, the Yankee Atomic Electric Company (YAEC) hereby requests the authorization to make the following changes:

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Proposed Change Reference is made to the Technical Specifications and the " Yankee Nuclear Power Station Core XVIII Performance Analysis," (Reference (b)) of License No. DPR-3.

We propose to modify the Technical Specifications as described below.

The proposed Technical Specification changes are given in Attachment A.

1. Change the figure references to refer to the Core Operating Limits Report (COLR) on the following pages: 3/4 1-28, 3/4 2-1, 3/4 2-2, B3/4 1-1, B3/4 2-1, and B3/4 2-2.

2. Modify Page 3/4 2-2 by replacing existing cycle specific values in Technical Specification 4.2.1.2.b with a generic description consistent with the proposed modification of Technical Specification 3.1.3.5.

3. Delete the following figures:

3.1-2, Page 3/4 1-29, 3.2-1 Page 3/4 2-4, 3.2-3, Page 3/4 2-6, 3.2-4, Page 3/4 2-7.

4. Modify Page 5-1. The Fuel Assembly Description, to allow for a maximum nominal enrichment of 4.0 weight percent U-235.

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s United States Nuclear Regulatory Commission June 24, 1986 Attention: Office of Nuclear Reactor Regulation Page 2 FYR 86-057

5. Modify Pages 6-14 and 6-14A by inserting the description of the COLR as Specification 6.9.1.1 and reformat the existing sections to allow this insertion.

6. Modify Page 6-27 by inserting Specification 6.17, Analytical Methods.

7. Modify Pages B3/4 1-1 and 6-14A to correct typographical errors.

A copy of the proposed Cycle 18 COLR is included as part of this proposed change as Attachment B.

Regnon and Ranla for Change The reason for this proposed change is to allow for the performance of 10CFR50.59 reviews for future core reloads. Presently, NRC approval for each core reload is obtained through a submittal of a Core Performance Analysis Report (CPAR) and the amended Technical Specifications. Changing the specifications has become fairly routine with the same specifications being changed only slightly from cycle to cycle. The above mentioned modifications remove specific figures from the Technical Specifications and include them instead in a COLR, or, in the case of fuel enrichment, as a bounding upper limit. Adequate controls are retained by referencing the COLR in the Technical Specifications, Specification 6.9.1.1, and by referencing the analytical methods used to generate the information contained in the COLR, Specification 6.17.

It should be noted that among the Technical Specification changes proposed is the change to include reference to the analytical methods used to generate the COLR. Specification 6.17 provides administrative control of the analytical methods, which were reviewed and approved by the staff pursuant to approving previous Technical Specifications changes. The Yankee Nuclear Power Station Core XVIII Performance Analysis Report contains references and summary descriptions of the analytical methods which have previously been reviewed and approred by the NRC for reload licensing. Reference to our analytical methods provides an additional control mechanism regarding the use of 10CFR50.59 to assure that the curves presented in the COLR are determined with methods previously approved by the staff.

According to 10CFR50.59 of the Commission's regulations, changes may be made without prior Commission approval unless the change involves a change in the Technical Specifications incorporated in the license or an unreviewed safety question. Changes in analytical methods previously approved by the Commission have been treated as an unreviewed safety question. Thus, referencing the analytical methods in the Technical Specifications provides assurance that the curves presented in the COLR are constructed with methods previously approved by the staff. If a change in methods is deemed nccessary, Yankee will submit a description of the change to the NRC for their 12 View and approval prior to its use in the reload analysis.

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s United States Nuclear Regulatory Commission June 24, 1986 Attention: Office of Nuclear Reactor Regulation Pege 3 FYR 86-057 The technical information contained in the COLR will be used by the plant in the same manner that the information presently contained in the Technical Specifications is now used. Currently, the information contained in the Technical Specifications is incorporated into plant controlled documents.

Compliance to the limits provided in the Technical Specifications is shown via periodic surveillances. Removal of the information from the Technical Specifications will not change the way the information is incorporated into plant operating procedures, or the way compliance to operation within thesa limits is now performed. Compliance and verification of the proper use of this information can be accomplished through normal inspection and audit processes as currently performed by the Inspection and Enforcement (I&E) and Regulatory (NRR) branches of the Commission.

The change to the fuel assembly description is being submitted to provide a bound on fuel enrichment for future Yankee cycles of operation. previous Yankee operation has utilized up to 4.0 w/o U-235 Zircaloy clad fuel as a fuel assembly design enrichment.

SAFETY CONSIDERATION This change is requested in order to reduce the USNRC and Yankee Staff review time and related costs associated with the amendment process. Yankee views this proposed change to be purely administrative. As such, this proposed change would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated. This change merely modifies the manner in which analysis results are referenced in the Technical Specifications, as well as correcting typographical errors.

Therefore, the change cannot increase the probability or consequences of an accident.

2. Create the possibility of a new or different kind of accident from any previously analyzed. This modification of changing the referencing of analysis results and correcting typographical errors is administrative in nature. Therefore, it does not create the possibility of a new or different kind of accident since it does not impact the plant analysis methods, operation, or plant components.

3. Involve a significant reduction in a margin of safety. This modification of changing the referencing of analysis results and correcting typographical errors does not modify any analysis assumptions, methodologies, or results. Thus, this change does not impact the safety margins which currently exist.

Based on the consideration contained herein, it is concluded that there is reasonable assurance that operation of the Yankee plant consistent with the proposed Technical Specifications will not endanger the health and safety of the public. This proposed change has been reviewed by the Nuclear Safety Audit and Review Committee.

United States Nuclear Regulatory Commission June 24, 1986 Attention: Office of Nuclear Reactor Regulation Page 4 FYR 86-057 Fee An application fee of $150.00 is enclosed in accordance with 10CFR170.21.

Schedule of Channe These changes to the Yankee Technical Specifications will be implemented upon Conunission approval. A timely review and approval of this submittal to be consistent with our plans for the Cycle 19 reload analysis would be appreciated. Approval of this submittal is requested by September 15, 1986.

Our intention is to implement the use of the COLR during Cycle 18.

Future reloads will be done under 10CFR50.59. Copies of the CPAR and the COLR will be sent to the NRC for your information 60 days before startup of each subsequent cycle.

We trust that you will find this submittal satisfactory; however, should you desire additional information, please contact us.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY f

,N/I d bL.H.Heider Vice President / Manager of Operations LHH/dps Attachments COMMONWEALTH OF MASSACHUSETTS)

)ss MIDDLESEX COUNTY )

Then personally appeared before me, L. H. Heider, who, being duly sworn, did state that he is Vice President of Yankee Atomic Electric Company, that he is duly authorized to execute and flie the foregoing document in the name and on the behalf of Yankee Atomic Electric Company and that the statements therein are true to the best of his knowledge and belief.

Rdbert H. Groce Notary Public

j. My Commisslon Expires August 29, 1991 l

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