B11621, Application to Amend Licenses DPR-61,DPR-21 & DPR-65, Revising Tech Spec Section 6.5 Re Fire Protection & Loss Prevention Program Audits & Clarifying Term Outside Firm. Fee Paid

Application to Amend Licenses DPR-61,DPR-21 & DPR-65, Revising Tech Spec Section 6.5 Re Fire Protection & Loss Prevention Program Audits & Clarifying Term Outside Firm. Fee Paid

ML20134D298
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	08/12/1985
From:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Butcher E, Zwolinski J Office of Nuclear Reactor Regulation
Shared Package
ML20134D301	List: B11621, Application to Amend Licenses DPR-61,DPR-21 & DPR-65, Revising Tech Spec Section 6.5 Re Fire Protection & Loss Prevention Program Audits & Clarifying Term Outside Firm. Fee Paid ML20134D324
References
B11621, TAC-59489, NUDOCS 8508190178
Download: ML20134D298 (3)

Text

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• Selden Street, Berlin, Connecticut vo- b* HARTFORD. CONNECTICUT 06141-0270 L L TJ "O.', C,7 "O,~_~ (203) 665-5000 August 12,1985 Docket Nos. 50-213 50-245 50-336 Bil621 Director of Nuclear Reactor Regulation Attn: Mr. John A. Zwolinski, Chief Operating Reactors Branch #5 Mr. Edward 3. Butcher, Jr., Chief Operating Reactors Branch #3 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

References:

1) T. T. Martin letter to W. G. Counsil, dated August 1,1984 transmitting I&E Inspection Report Nos. 50D4'5/84-15 and 50-336/84-15.

2) W. G. Counsil letter to Dr. T. E. Murley, dated August 30, 1984.

Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Proposed Revision to Technical Specifications Fire Protection and Loss Prevention Program Audits Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) hereby propose to amend their Operating Licenses, Nos. DPR-61, DPR-21, and DPR-65 for the Haddam Neck Plant and for Millstone Nuclear Power Station, Unit Nos. I and 2, respectively, by incorporating the attached changes into the plant Technical Specifications. The proposed changes revise Technical Specification Section 6.5.2.7.1 for Haddam Neck and Section 6.5.4.7.e for Millstone Unit Nos. I and 2,

" Fire Protection and Loss Prevention Program Audits" and clarify the term "outside firm" in the present Technical Specifications.

I&E Inspection Report Nos. 50-245/84-15 and 50-336/84-15 transmitted by Reference (1) expressed a concern that the relationship between the auditors and those audited may not meet the wording of the present Technical Specification requirement that an outside firm perform the annual fire protection and loss prevention program audits. NNECO responded to this concern by Reference (2) which stated our long-standing position that the Generation Fire Protection Engineering Group within Northeast Utilities (NU) qualifies as an outside firm and that this position was previously determined by the NRC Staff to be consistent with the language and intent of the current Technical Specification.

However, in recent discussions with the Region I Staff, we were requested to y ff I lB8838sE SSSSh %s I Yl5 51

either clarify the current Technical Specification term "outside firm" by submitting a proposed Technical Specification change or commence contracting with a firm independent of NU. The purpose of the proposed Technical Specification changes is to resolve this open item.

CYAPCO and NNECO have reviewed the attached proposed changes pursuant to the requirements of 10CFR50.59 and have determined that they do not constitute an unreviewed safety question. The basis for this determination is that the proposed changes are purely administrative, do not increase the probability or consequences of any accident previously evaluated in the plant safety analysis reports, do not create the possibility of an accident or malfunction of a different type than previously evaluated in the safety analysis reports, and do nat reduce the margin of safety as defined in the basis for any Technical Specification. The proposed changes more clearly indicate that our current practice in performing fire protection and loss prevention program audits is acceptable.

In accordance with 10CFR50.92, CYAPCO and NNECO have reviewed the attached proposed changes and have concluded that they do not involve a significant hazards consideration. The basis for this conclusion is that the three criteria of 50.92(c) are not compromised, a conclusion which is supported by our determination made pursuant to 10CFR50.59. The Commission has provided guidance concerning the application of the standards in 10CFR50.92 by providing certain examples (April 6,1983,48FR14870) of amendments that are considered not likely to involve significant hazards considerations. Example (i) relates to a purely administrative change to Technical Specifications: for example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature. The changes discussed above provide a change in nomenclature and thus are similar to example (i) of 48FR14870. Based on the above considerations, CYAPCO and NNECO have determined that the changes do not involve a significant hazards consideration.

In accordance with the requirements of 10CFR50.91(b), a copy of this document is being provided to the State of Connecticut.

The Connecticut Yankee Nuclear Review Board and the Millstone Site Nucle.r Review Board have reviewed and approved the proposed amendments and have concurred with the above determinations.

Pursuant to the requirements of 10CFR170.12(c), enclosed with this amendment request is the application fee of $150.00 for each plant for a total of $450.00.

A copy of this proposed change is also being sent directly to Region I to confirm that their concern is addressed by this change.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY

. % F. Oah.

J. F. Opek'a u Senior Vice President I

.. .o cc: Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection State Office Building Hartford, Connecticut 06116 Dr. Thomas E. Murley Regional Administrator Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 STATE OF CONNECTICUT )

) ss. Berlin COUNTY OF HARTFORD )

Then personally appeared before me 3. F. Opeka, who being duly sworn, did state that he is a Senior Vice President of Northeast Nuclear Energy Company and Connecticut Yankee Atomic Power Company, Licensees herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.

AhhdixL potary Publ

/$ pth My Commission Expires March 31,1988