ML20207Q452

Suppl 1 to Application to Amend License DPR-28,consisting of Proposed Change 131 to Radiological Effluent Tech Specs, Adding Reporting Level for Co-60 Sediment Samples Taken from North Storm Drain Outfall

ML20207Q452
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
ML20207Q453	List: ML20207Q452 ML20207Q457
References
FVY-87-11, NUDOCS 8701270348
Download: ML20207Q452 (4)

Text

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VERMONT YANKEE NUCLEAR POWER CORPORATION FVY 87-11

. RD 5, Box 169 Ferry Road, Brattleboro, VT 05301 ,,,Ly y, ENGINEERING OFFICE 1671 WORCESTER ROAD

• FRAMINGHAM, MASSACHUSETTS 01701

• TELEPHONE 617-872-8100 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, VYNPC to USNRC, FVY 86-09, " Proposed Change No. 131," dated January 24, 1986 (c) Vermont Yankee Plant Information Report 83-06 (LER 83-23/3L), dated October 7, 1983 (d) Letter, VYNPC to USNRC, FVY 86-42, dated May 13, 1986 (e) Letter, VYNPC to USNRC, FVY 86-53, dated June 9, 1986

Subject:

Supplement 1 of Proposed Change No. 131 to the Vermont Yankee Radiological Effluent Technical Specifications (RETS)

Dear Sir:

Pursuant to Section 50.59 of the Commission's Rules and Regulations, and as a supplement to Proposed Change No. 131 (Reference (b)], Vermont Yankee Nuclear Power Corporation hereby proposes the following changes to the Radiological Effluent Technical Specifications (RETS):

Proposed Change By References (b), (c), and (d), Vermont Yankoe cubmitted and clarified a proposed license amendment to the Vermont Yankee Radiological Effluent Technical Specification (RETS). This request was noticed in Federal Register Volume 81, No. 158, Page 20,014, dated August 13, 1986.

This submittal supplements the referenced proposed change by the following:

1. We propose adding a reporting level to the RETS for Co-60 in sediment samples taken from the north storm drain outfall.

Specifically, a reporting level of 3,000 pCi/kg (dry) is being proposed for inclusion in Table 3.9.4, on Page 172c. The reporting level is intended to apply only to individual grab samples.

Accordingly, we requent that Page 172c of the Vermont Yankoo Technical Specifications be replaced with the attached Page 172c.

DR 870127034887OOO271 p ADOCK 03 PDR 00 %

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United States Nuclear Regulatory Commission January 16, 1987 Attention: Mr. H. R. Denton,' Director Page 2 a

2. We request a change to Section 6.13.A.1.a of the Technical Specifications to require the inclusion of the revision number on each page of the Off-Site Dose Calculation Manual (ODCM) in place of an approval and date box on each page. Accordingly, we request that Page 221 of the Technical Specifications be replaced with the attached Page 221.

Reason and Basis for Change The change requested for Table 3.9.4 (page 172c) represents the addition of a reporting level for Co-60 in sediment grab samples taken at the north storm drain outfall. The reporting level would require a 30-day special report to the NRC whenever the concentration of co-60 in a sample from this location exceeds 3,000 pCi/kg (dry). This reporting level results in a conservatively estimated dose to the maximum exposed individual of less than the 3 meem per year objective of 10CFR50, Appendix I. The addition of this specific sediment reporting level is an enhancement to the Vermont Yankee Radiological Environmental Monitoring Program associated with reporting levels for samples taken pursuant to Table 3.9.3 of the Vermont Yankee Technical Specifications.

The change requested for Section 6.13.A.1.a (page 221) would replace the requirement for a signature and date block on each updated page of the ODCM with the requirement for a revision number block to be placed on each updated page. This change is designed to achieve consistency with Vermont Yankee's practices for updating controlled documents.

Safety Considerations The proposed modification to the Reporting Level Tablo (Table 3.9.4) will result in a more restrictive surveillance requirement for sediment sampling and will not otherwise impact the Radiological Environmental Surveillance Program. The proposed modification to the ODCM Control requirement (Section 6.13.A.1.a) is administrative in nature and will not change the content of the manual or its review and approval procedure.

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 Committeo.

Significant Hazards Consideration The standards used to arrive at a determination that a request for amendment involves a 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.

.1 United States Nuclear Regulatory Commission January 16, 1987 Attention: Mr. H. R. Denton, Director Page 3 The discussion below addresses both of the supplemental. proposed changus with-respect to these three criteria and demonstrates that the proposed amendment involves a no significant. hazards consideration.

The~ change proposed to Table 3.9.4 involves the addition of a sediment reporting. level requirement which enhances the Vermont Yankee Radiological Environmental Monitoring Program. As described in the referenced amendment request [ Reference (b)], enhancements to the Environmental Monitoring Program

'as described in NRC guidance and requested in this supplemental 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 previously considered. Since the change concerns only environmental monitoring reporting levels, no change in any plant safety margin is required.

The change proposed to Section 6.13.A.1.a involves a change to achieve consistency with Vermont Yankee's practices for updating controlled documents. As such,-this change is purely administrative and thus creates no significant change in the probability or consequences of an accident previously evaluated, nor creates a new or different accident. No significant changes in any plant operating or design basis safety margins are required by this administrative change.

Accordingly, we conclude that the proposed changes involve a no significant hazards consideration, as specified in 10CFR50.92, in that the proposed changes do 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.

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

one of these examples (ii) states that a change which constitutes an additional'1 imitation, restriction, or control not presently included in the Technical Specifications, for example, a more stringent surveillance requirement, does not involve a significant hazards consideration. As described above, the change being proposed for Table 3.9.4 constitutes an additional limitation and control not presently included in the Technical  :

Specifications for Vermont Yankee.  !

Another of the Commission'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 change proposed for Section 6.13. A.l.a ['

constitutes an administrative change to achieve consistency.

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United States Nuclear Regulatory Commission January 16, 1987 Attention: Mr. H. R. Denton, Director Page 4 I

Therefore, we conclude that these proposed changes do not constitute a significant hazards consideration, as defined in 10CFR50.92(c).

Fee Determination We request that the application fee of $150.00, enclosed with Reference (b) in accordance with the provisions of 10CFR170.12, be applied to this supplemental submittal.

Schedule of Change These changes will be incorporated into the Technical Specifications as soon as practical 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 u

Vice President and ager of Operations RWC/bil Enclosure cc: Vermont Department of Public Services 120 State Street Montpelior, Vermont 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 Vice President and Manager of Operations of Vermont Yankee Nuclear Power Corporation, that he is duly authorized to 4

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.

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Diano McCue '

Notary Public gg MyCommissionExpires["

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