CY-99-105, Application for Amend to License DPR-61,incorporating Changes Into OL & Ts.Addl Clarifications & Retyped TS Replacement Pages,Included

Application for Amend to License DPR-61,incorporating Changes Into OL & Ts.Addl Clarifications & Retyped TS Replacement Pages,Included

ML20211G124
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	08/24/1999
From:	Mellor R CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20211G131	List: CY-99-105, Application for Amend to License DPR-61,incorporating Changes Into OL & Ts.Addl Clarifications & Retyped TS Replacement Pages,Included ML20211G134
References
CY-99-105, NUDOCS 9908310167
Download: ML20211G124 (8)

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CONNECTICUT YANKEE ATOMIC POWER COMPANY a

HADDAM NECK PLANT 362 INJUN HOLLOW ROAD

• EAST HAMPTON. CT 06424 3099 i August 24,1999 Docket No. 50-213 CY-99-105 Re: 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Haddam Neck Plant Clarifications to Supplemental Information for Pendina Technical Specification Chanae introduction Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPCO) proposes to amend its Operating License, DPR-61, by incorporating changes into the Haddam Neck Plant (HNP) Operating License and Technical Specifications. The proposed changes were submitted by CYAPCO letter dated August 13,1998.N Supplementalinformation in the form of a complete resubmission was provided by CYAPCO letter dated June 3,1999m. The purpose of this letter is to provide additional clarifications and retyped Technical Specification replacement pages.

Commitments The commitments listed in this letter (CY-99-105-01, CY-99-105-02 and CY-99-105-03) include more detailed information and completely replace the commitments included in our previous letter, CY-99-041 (CY-99-041-01, CY-99-041-02 and CY-99-041-03) dated June 3,1999.

31N M' (1) CYAPCO letter CY-98-003 from R. A. Mellor, to the U. S. Nuclear Regulatory Commission, " Proposed Revision To Operating License And Technical Specifications,"

dated August 13,1998.

(2) CYAPCO letter CY-99-041 from R. A. Mellor, to the U. S. Nuclear Regulatory Commission, " Supplemental Information for Pending Technical Specification Change to I Remove Additional Material," dated June 3,1999.

9908310167 990824 C(

PDR ADOCK 05000213 W PDR 1

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. U. S. Nucle:r Regul: tory Commission 1 CY-99-105/Page 2 l l

Supportina Information The following is provided in support of the clarifications:

Attachment 1 describes the proposed Technical Specification changes.

Attachment 2 contains the retyped Technical Specification pages which replace correspondingly numbered pages in CYAPCO letter dated June 3, 1999.

1 The clarifications provided in this letter do not alter the previous discussions or l conclusions with respect to the significant hazards consideration (SHC) or environmental consideration contained in CYAPCO letter dated June 3,1999.

State Notification l

In accordance with 10 CFR 50.91(b), CYAPCO is providing the State of Connecticut with a copy of this proposed amendment request.

Commitments The following commitments are contained within this letter. Other statements are for information only.

CY-99-105-01 When the proposed license amendment is approved by Concurrent with the NRC staff, CYAPCO will relocate the following implementation of requirements to Section 11 of the Haddam Neck Plant license Technical Requirements Manual; amendment

. Definition 1.4 Channel Calibration e Definition 1.5 Channel Check

. 3/4.3.3.4, Meteorological Instrumentation

. 3/4.7.5, Sealed Source Contamination e 3/4.9.12 Fuel Storage Building Air Cleanup System

. All subsections except 3.9.12.b; 4.9.12.a.2; 4.9.12.b; 4.9.12.e and Footnote.

CY-99-105-02 When the proposed license amendment is approved by Concurrent with the NRC staff, CYAPCO will relocate the following implementation of requirements to the Haddam Neck Plant REMODCM: license e Definition 1.2, Analog Channel Operational Test amendment

. Definition 1.4, Channel Calibration e Definition 1.5 Channel Check e Definition 1.12, Frequency Notation

. Definition 1.30, Source Check e Table 1.1

+ 3/4.3.3.7, Radioactive 1.iquid Effluent Monitoring instrumentation

. Table 3.3-9

. U. S. Nuclear Regulatory Commission CY-99-105/Page 3

. Table 4.3-7

. 3/4.3.3.8, Radioactive Gaseous Effluent Monitoring Instrumentation l

. Table 3.3-10

. Table 4.3-8 3/4.11 Radioactive Effluents (and all subsections)

CY-99-105-03 When the proposed license amendment is approved by Complete ( )

the NRC staff, CYAPCO will relocate the following requirements to the Connecticut Yankee Quality ,

Assurance Program:  !

. 6.5, Review and Audit (and all subsections)

. 6.10, Record Retention (and all subsections)

Prior Discussions The clarifications and retyped Technical Specification replacement pages contained in j this letter were discussed with the NRC Project Manager during his visit to Haddam (

Neck on August 11,1999 and in subsequent telephone discussions. )

Schedule Reauired for NRC Approval CYAPCO has completed the installation of the new Spent Fuel Building Ventilation System. System tests are expected to be completed by August 31,1999. Therefore, CYAPCO requests that the proposed Technical Specification changes be approved by the NRC before August 31,1999 to facilitate the implementation of the ventilation system modification.

If the NRC Staff should have any questions regarding this submittal, please contact Mr. G. P. van Noordennen at (860) 267-3938.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY I

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R. A. Meilor Vice President - Operations and Decommissioning Attachments (3) CYAPCO letter CY-98-142 from R. A. Mellor, to the U. S. Nuclear Regulatory Commission, " Proposed Revision 2 to the Quality Assurance Program," dated December 22,1998.

U. S. Nuclacr R:gulatory Commission CY-99-105/Page 4 cc: H. J. Miller, NRC Region 1 Administrator T. L. Fredrichs, NRC Project Manager, Haddam Neck Plant l

R. R. Bellamy, Chief, Decommissioning and Laboratory Branch, NRC Region I '

E. L. Wilds, Jr., Director, CT DEP Monitoring and Radiation Division Subscribed and sworn to before me ,

this dY day of vGo.5 T 1999 N M Y11K W t aCom ssion Expi  : 4!5/Sco'[

1 1

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Docket No. 50-213 CY-99-105 1

Attachment 1 Haddam Neck Plant Proposed Revision to the Technical Specifications t Description Of Changes 1

August 1999 1

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U. S. Nuclar Ragulntory Commission CY-99-105/ Attachment 1/Page 1 TECHNICAL SPECIFICATIONS CHANGES AND REASONS Subsection 6.2.2, Facility Staff

. Delete the phrase, "or movement of loads over storage racks containing fuel," from Paragraph 6.2.2.c and insert it after "All fuel handling operations"in Paragraph 6.2.2.d to correct a typographical error in the retyped Technical Specification pages transmitted by CYAPCO letter dated June 3,1999.

Section 6.5, Procedures and Programs (Subsections 6.5.2 and 6.5.3)

1. The wording of new Subsections 6.5.2 and 6.5.3 generally follows the wording of Proposed Standard Technical Specifications for Permanently Defueled Westinghouse Plants (Draft NUREG-1625, March 1998) with changes from the old ,

Subsections as discussed below. Such rewording is primarily editorial for clarity and consistency. The changes reflect the reduced scope of procedures covered in the new Subsections 6.5.2 and 6.5.3, from what was previously contained in old Subsections 6.8.2 and 6.8.3. With the termination of reactor operations and the removal of operating authority pursuant to 10 CFR 50.82 (a)(2), the scope and complexity of activities at the facility have been greatly reduced. The new wording also reflects the change to a permanently defueled status and is considered <

appropriate. Similar changes have recently been approved by the NRC for the Maine Yankee and Big Rock Point plants.

It should be noted that the old Subsections 6.8.2 and 6.8.3 will not be combined as stated in CYAPCO letter dated June 3,1999.

2. The new Subsection 6.5.2 deletes the requirements of old Subsection 6.8.2 for periodic review of procedures. This is consistent with the draft NUREG-1625. This is acceptable because CYAPCO continues to be committed to ANSI 18.7 which requires periodic review of procedures as clarified in Connecticut Yankee Quality ,

Assurance Program (CYQAP) Exception No.8.

3. The new Subsection 6.5.2 replaces the requirement for PORC review of procedures and changes, with a requirement that procedures and changes be " independently reviewed in accordance with administrative procedures". This is consistent with the draft NUREG-1625. Administrative requirements will be implemented which will ensure appropriate technical reviews are performed by individuals who are qualified and are independent from the individuals who developed the documents. This is acceptable because the intent of the change is to continue to ensure that independent review of programs and processes are performed consistent with ANSI 18.7.

. ' U. S. Nuciser Regulatory Commission CY-99-105/ Attachment 1/Page 2

4. The new Subsection 6.8.2 allows the Unit Director to designate someone to approve procedure changes, in addition to himself. This is consistent with the draft NUREG-1625. This is acceptable because administrative controls will be implemented to ensure that the Unit Director designee functioning in this capacity meets the appropriate predetermined qualifications.

5. The new Paragraph 6.8.3.c deletes the requirement for PORC approval of temporary procedure changes. This is consistent with the draft NUREG-1625. It is acceptable because the change is still reviewed and approved by three knowledgeable individuals, a member of plant management, a CERTIFIED FUEL HANDLER, and the Unit Director or designee. Also, this section only allows non-intent changes to be implemented. Risk significant changes could not be made through this process. The elimination of the PORC review recognizes that the importance of the procedures to which the new Subsection 6.5.3 applies has been greatly reduced from that of the old Subsection 6.8.3, and the remaining procedures are within the area of expertise of the approvers.

6. New Paragraph 6.5.3.c allows the Unit Director to designate someone to approve temporary procedure changes. This change, and similar changes to new Paragraphs 6.6.2.b and 6.6.3.b, are being made for consistency of review requirements throughout Section 6. This is acceptable for the reasons given in Paragraph 4 above.

Subsection 6.6.3, Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)

. In Paragraph 6.6.3.a.2 of the retyped Technical Specification pages transmitted by CYAPCO letter dated June 3,1999, replace "10 CFR 20.106" with "10 CFR 20.1302" to be consistent with the current numbering of 10 CFR 20 subsections.

Subsection 6.6.4, Radioactive Effluent Controls Program .

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. In Paragraph 6.6.4.c of the retyped Technical Specification pages transmitted by CYAPCO letter dated June 3,1999, replace "10 i CFR 20.106" with "10 CFR 20.1302" to be consistent with the current numbering of 10 CFR 20 subsections.

. In Paragraph 6.6.4.J of the retyped Technical Specification pages transmitted by CYAPCO letter dated June 3,1999, insert '

" MEMBER OF THE PUBLIC" after the phrase " Limitations on the annual dose or dose commitment to any" to correct a typographical error.

. 1 U. S. Nucl:ar Regulatory Commission l CY-99-105/ Attachment 1/Page 3 Section 6.8, High Radiation Area 1

In Subsection 6.8.3 of the retyped Technical Specification pages transmitted by CYAPCO letter dated June 3, replace the entire section with the wording in the existing Technical Specifications (Subsection 6.12.2, second paragraph) with corrected unit for the l radiation level (replacing "mR/h" with " mrem /h"). The new l Subsection 6.8.3 will read as follows: For individual high radiation i areas accessible to personnel with radiation levels of greater than l 1000 mrem /h that are located within large areas, such as PWR l containment, where no enclosures exists for purposes of locking, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device or continually guarded.

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