ML20080K045

Application to Amend License DPR-28,consisting of Proposed Change 117 to Tech Specs,Replacing Pages Covering safety- Related Shock Suppressors

ML20080K045
Person / Time
Site:	Vermont Yankee
Issue date:	02/07/1984
From:	Heider L VERMONT YANKEE NUCLEAR POWER CORP.
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML20080K046	List: ML20080K045 ML20080K054
References
FVY-84-8, NUDOCS 8402150278
Download: ML20080K045 (4)

Text

VERMONT YANKEE NUCLEAR POWER CORPORATION Proposed Change No. 117 RD 5, Bor 169, Ferry Road, Brattleboro, VT 05301 y ,g g g-g ENGINEERING OFFICE 1671 WORCESTEH ROAD

• FRAMINGHAM. MASSACHUSETTS 01701

• TELEPHONE 617-872-6100 February 7,1984 FVY 84-8 United States Nuclear Regulatory Commissicn Washingtoa, D. C. 20555 Attention: Office of Nuclear Reactor Regulation Mr. D. G. Eisenhut , Direc' or Division of Licensing

References:

(a) License No. DPR-28 (Docket No. 50-271)

(b) Amendment No. 64, Calvert Cliffe-Unit 1 (c) Letter, USNRC to VYNPC, Inspection Report 50-271/83-13, dated May 26, 1983 (d) Letter, U3NRC to All Power Reactor Licensees, dated November 20, 1960 (e) Letter, VYNPC to USNRC, dated April 7,1981

Subject:

Request for License Ameudment - Safety-Related Shock Suppressors

Dear Sir:

Pursuant to Section 50.59 of the Commission's Rules and Regulations, Vermont Yankee Nuclear Power Corporation hereby proposes the following modification to Appendix A of the Operating License:

Proposed Change:

Replace Pages 110a, 110b, 110c, 125, and 125a of the Vermont Yankee Technical Specifications with the attached revised Pages 110a,110b,110c, 110d, 110e, 310f, and 125. These pages have been revised to more closely match limiting conditions for operation and surveillance requirements contained in the Commission's Standard Technical Specifications.

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United States Nuclear Regulatorv Commission February 7, 1984 Attention: Mr. D, G. Eisenhut Page 2 Reason for Change:

In 1980, the NRC transmitted revised guidelines for snubbers to licensees and requested that licensees submit amendm&at application incorporating the appifcable portions of the model Technical Specificction. At t! 't time, we concluded that there was insuf ficient justification for implement'.ng the

] additional requirements and formally took issue [ Reference (e)] with the request.

On May 3,1983, an NRC inspector, Mr. J. T. Wiggans, in company with the Senior Resident Inspector, Mr. W. Raymond, met with Vermont Yankee management personnel.

At that meeting, the NRC inspector discussed the bases for the new specifications. Further, the inspector discussed those areas in which the current Vermont Yankee Technical Specifications differ from Standard Technical Specifications (STS). These areas included:

1. The operat ility requirements for snubbers in those systems required to be operable during cold shutdown and refueling modes

2. The required actions when inoperable snubbers are identified l 3. The visual inspection acceptance criterion associated with snubbers whose finid reservoire are found drained 4 .- _ The STS guidance regarding functional testing eample selection

5. The need to retest, at the next functional testing period, those unubbers which have failed a functional test 4 6. The need for an engineering evaluation to be performed to determine the effects of inoperable snubbers on the performance of safety related systems

7. The need for a snubber service life monitoring program At that time, it was agreed that we would review our position and program.

Based on our review, we have concluded that certain changes should be

' uade to enhance our existing program. These changes are reflected in the attached revised pages.

Standard Technical Specificatione, the existing Technical Specifications, ,

and a' licensing amendment [ Reference '(b)], previously found acceptable by the NRC, were reviewed and form the bases for this proposal.

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United States Nuclear Regulatory Commission February 7,1984 Attention: Mr. D. G. Eisenhut Page 3 Each of the seven differences listed above has been carefully looked at -

and, with the exception of Item #7, we are proposing changes which we feel meet the intent of the Commissions' Standard Technical Specification. With regard to Item #7 (the need for a service life monitoring program), we remain convinced that our preventive maintenance program, as ~ described in Reference (e), is sufficient to monitor snubber performance. Further, we question the bases for requiring this program in the snubber section of the Technical Specifications, when it is not required in other more important

! areas of the Technical Specifications.

Safety Onnsiderations:

The changes proposed in this submittal are intended to bring the Vermont Yankee Technical Specifications into conformance with NRC guidance. The

, changes enhance the current specification by clarifyf tg: 1) operability requirements, 2) inspection criteria, 3) retest requirements, and 4) requiring engineering evaluations should degraded conditions be found.

As discussed above, these changes are consistent with those previously approved by the NRC for another facility.

! We have concluded that the probability of previously evaluated accidents would not be increased by this change. The possibility of a different type of accident is not created nor are the margins of safety. as defined in the basic of the Technical Specifications, reduced by this change. Therefore, we have determined that this change does not constitute an unreviewed safety questions, as defined in 10CFR50.59(a)(2).

This submittal has been reviewed by the Vermont Yankee Nuclear Safety Audit and Review Committee.

Significant Hazards Consideration:

The NRC has provided guidance concerning the application of standards for coaclusions regarding "Significant Hazards Consideration" [48FR14870]. The examples of actions involving no significant hazards consideration include: a enange that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications (for example, a more stringent surveillance requirement).

As discussed above, . this proposed change enhances the current Technical Specifications by clarifying snubber operability requirements, inspection criterie, retest requirements, and the need for engineering evaluation should degraded conditions be found. Since the proposed specifications are more restrictive than those in the present Technical Specifications, we have concluded that this change does not constitute a significant hazards consideration, as defined in 10CFR50.92(c).

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United States Nuclear Regulatory Commission February 7, 1984 Attention: Mr. D, G. Eisenhut Page 4 Fee Determination:

This proposed change requires an approval that involues a single safety issue and is deemed not to involve a significant hazards consideration. For these reasons, Vermont 'lankee Nuclear Power Corporation proposes this as a Class III Amendment. A payment of $4,000.00 is enclosed.

Schedule of Change:

The change described above will be incorporated into the Vermont Yanko Technical Specifications as soon as reasonable upon receipt of your approval; however, ne sooner than startup from the 1984 refueling outage (presently expected in mid-August 1984).

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

, &bd L. H. Heider Vice President JBS/smh

- Attachments cc: Vermont Department of Fublic Services 120 State Street Montpelier, Vermont 05602 Attention: Mr. Richard Saudek, Chaf rman COMMONWEALTH OF MASSACHUSETTS)

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Then personally appeared before me, L. H. Heider, who, being duly sworn, did state that he is a Vice President 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. <'~>".

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