ML20044F472
| ML20044F472 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 05/19/1993 |
| From: | Debarba E, Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20044F473 | List: |
| References | |
| REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI, TASK-070, TASK-094, TASK-70, TASK-94, TASK-OR B14462, GL-90-06, GL-90-6, NUDOCS 9305280168 | |
| Download: ML20044F472 (12) | |
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NORTHEAST UTILITIES cener.i Omce. s.een sir..t. somn. Connecticut I
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'ac P.O. BOX 270 --
HARTFORD. CONNECTICUT 06141-0270 L
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(203) 665-5000 May 19, 1993 Docket No. 50-213 B14462 Re:
10CFR50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:
Haddam Neck Plant Proposed Revision to Technical Specifications Generic letter 90-06 Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPCO) i hereby proposes to amend Facility Operating License DPR-61 by' incorporating the changes identified in the Attachments into the Technical Specifications of-i the Haddam Neck Plant.
Backoround i
On June 25, 1990, the Staff issued Generic letter (GL) 90-06,"3
" Resolution of Generic Issue 70,
' Power-0perated Relief Valve and Block Valve Reliability,' and Generic Issue 94, ' Additional Low-Temperature Overpressure j
Protection for Light-Water Reactor,' Pursuant to 10 CFR 50.54(f)."
The GL represented the technical resolution of the. above-mentioned generic issues.
Generic Issue 70, " Power-Operated Relief Valve and Block Valve ' Reliability,"
involves the evaluation of the reliability of pressurizer power-operated relief valves (PORVs) and block valves and their safety significance in pressurized water reactor plants. The GL discussed how PORVs are increasingly i
being relied on to perform safety-related functions, and the corresponding need to - improve the reliability of both PORVs and their associated block -
valves.
Proposed Staff positions and improvements to the plant's technical specifications were recommended to be implemented at all affected facilities'.
This issue is applicable to all Westinghouse, Babcock & Wilcox,-and Combustion Engineering design facilities with PORVs.
Generic Issue 94, " Additional Low-Temperature Overpressure Protection for Light-Water Reactors," addresses. concerns with the implementation of the guidance set forth in the resolution of Unresolved Safety Issue A-26, " Reactor 1
-(1)
J.
G.
Partlow Letter to All Pressurized Water Reactor Licensees and Construction Permit Holders, " Generic Letter 90-06," dated June 25, 1990.
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U.S. Nuclear Regulatory Commission B14462/Page 2 May 19, 1993 Vessel Pressure Transient Protection (Overpressure Protection)."
The GL discussed the continuing occurrence of overpressure events and the need to further restrict the allowed outage time for a low-temperature overpressure protection (LTOP) channel in operating MODES 4, 5, and 6.
This issue is only applicable to Westinghouse and Combustion Engineering facilities.
By letters dated December 21, 1990,i2' March 21, 1991, August 20, 1992,"'
and October 1,1992,* CYAPCO, on behalf of the Haddam Neck Plant, submitted initial and revised responses to the NRC Staff.
In those responses, CYAPC0 indicated that the proposed technical specification changes regarding PORV operability will be based on the model technical specification provided as Attachment A-1 of Enclosure A to GL 90-06.
The proposed technical specification changes regarding LTOP will be based on the model technical specification provided as Attachment B-1 to Enclosure B of GL 90-06, but will reflect the fact that, at the Haddam Neck Plant, the LTOP system consists of two relief trains, each with two motor-operated isolation valves and one spring-loaded relief valve all in series.
The LTOP system, in conjunction with a reactor coolant system (RCS) vent opening of at least 7 square inches, ensures that the RCS will be protected as required by 10CFR50, Appendix G.
The model technical specification for this configuration is not provided in GL 90-06.
Therefore, proposed changes to technical specifications will be based upun the model technical specification provided in GL 90-06, but will reflect the fact that the Haddam Neck Plant has a unique LTOP system.
Description of the Proposed Chanaes The proposed amendment revises Technical Specifications 3.4.4 and 3.4.9.3 to address the issues raised in GL 90-06. provides a markup of the proposed changes and Attachment 2 provides retyped pages of the Haddam Neck Plant's Technical Specifications.
The proposed technical specification changes are described below-i (2)
E. J. Hroczka letter to the U.S. Nuclear Regulatory Commission, "Haddam Neck Plant, Hillstone Nuclear Power Station Unit Nos. 2 and 3, Generic t
Letter 90-06, Resolution of Generic Issue 70,
' Power-0perated Relief Valve and Block Valve Operability,' and Generic-Issue 94, ' Additional Low-Temperature Overpressure Protection for Light-Water Reactors,'
Pursuant to 10CFR50.54(f)," dated December 21, 1990.
(3)
E. J. Mroczka letter to the U.S. Regulatory Commission, " Generic Letter 90-06," dated March 21, 1991.
l (4)
J. F. Opeka letter to the U.S. Nuclear Regulatory Commission, " Generic Letter 90-06," dated August 20, 1992.
(5)
J. F. Opeka letter to the U.S. Nuclear Regulatory Commission, " Generic Letter 90-06," dated October 1, 1992.
U.S. Nuclear Regulatory Commission B14462/Page 3 May 19, 1993 i
A.
Section 3/4.4.4 Relief Valves The following changes are proposed to Technical Specification Section 3/4.4.4, Reactor Coolant System, Relief Valves.
These changes are consistent with GL 90-06.
In addition, changes proposed to ACTION Statements a,
b, and c are consistent with the Improved Standard Technical Specification (i.e., NUREG-1431).
The proposed changes are described below.
1.
Clarify the limiting condition for operation (LCO) and ACTION Statements by replacing 'all' with 'both' to reflect the Haddam Neck Plant design.
2.
ACTION Statement a:
Replace "because of excessive seat leakage" with "and capable of being manually cycled." Although a PORV may be designated inoperable, it may be able to be manually opened and closed, and therefore, able to contribute to the performance of a safety-related function.
PORV inoperability may be due to seat leakage, instrumentation problems, automatic control problems, or other causes that do not prevent manual use and do not create a possibility for a small break loss-of-coolant accident (LOCA).
In addition, a requirement is included to maintain power to closed block valve (s), since at the Haddam Neck Plant, the block valves receive an open signal with the PORVs. Therefore, the PORV function remains even with the block valves closed.
Removal of power would render the block valve inoperable and the requirements of ACTION Statements e or f would apply.
At present, at the Haddam Neck i
Plant, as a matter of practice, power is not removed from a PORV block valve when in Modes 1, 2, and 3.
Power is maintained to the block valve (s) which are maintained closed so that it is operable l
and may be subsequently opened concurrent with the PORV.
In addition, change " COLD" to " HOT" and "30" to "6" to agree with the guidance provided in Attachment A of GL 90-06.
3.
ACTION Statement b and c:
Replace "due to causes other than excessive seat leakage on low emergency control air supply pressure" with "and not capable of being manually cycl ed. "
This will differentiate these ACTION Statements from ACTION a.
In addition, change " COLD" to "H0T" and "30" to "6" to agree with the guidance provided in Attachment A of GL 90-06.
4.
ACTION Statement c:
Replace "each of the" with "at least one."
i This proposed change, which will make Action Statement
'c' i
consistent with Action 'c' proposed in GL 90-06, is considered a minor change.
In addition, replace "their associated" with "both."
This editorial change better defines the action to be taken.
With the existing technical specification words or new proposed words, the required actions are not changed.
For example, if one PORV is restored and one PORV remains inoperable, then the plant will be in
i U.S. Nuclear Regulatory Commission B14462/Page 4 May 19, 1993 Action
'b' with the LCO tima clock started at the original declaration of having two PORVs inoperable.
If no PORVs are i
restored within the completion time, then the plant must be brought to a mode in which the LC0 does not apply.
5.
ACTION Statement d: Change " COLD" to " HOT" and "30" to "6" to agree i
with the guidance provided in Attachment A of GL 90-06.
6.
ACTION Statement e:
This statement has been modified to establish remedial measures that are consistent with the function of the block valves when the block valve'is not capable of being manually cycled.
l The prime importance for the capability to close the block valve is to isolate a stuck-open PORV.
Therefore, if the block valve (s) cannot be restored to operable status within one hour, the remedial l
action is to place the PORV in manual control (i.e., the control switch in the 'close' position) to preclude its automatic opening for an overpressure event and to avoid the potential of a stuck-open PORV at a time that the block valve is inoperable.
The time allowed to restore the block valve (s) to operable status is based upon the remedial action time limits for inoperable PORVs per ACTION Statements b and c.
The modified ACTION Statement does not specify closure of the block valve when the block valve is inoperable.
7.
ACTION Statement f:
This has been modified to establish remedial measures that are consistent with the function of the block valves should they be capable of being manually cycled.
The prime importance for the capability to close the block valve is to isolate a stuck-open PORV. Therefore, if the block valve (s) can be manually controlled, the remedial action is to place the PORV in manual control within one hour (i.e., the control switch in the 'close' position) to preclude its automatic opening for an overpressure event and to avoid the potential of a stuck-open PORV at a time that the block valve is inoperable.
8.
Surveillance 4.4.4.1.b:
A requirement to operate the PORV(s) through one complete cycle of full travel during Modes :3 or 4 has been added.
9.
Surveillance 4.4.4.6:
This surveillance has been revised to show l
air and. resent' operability of the PORVs and their block valves.
The p surveillance requires transferring motive power, control power for these valves - from normal to emergency power and air supplies and then stroking these valves through one complete cycle.
The PORV block valves are powered from MCC5, which can be powered from either of two safety-related buses.
The requirement to manually transfer the power source for MCC5 from one train to the l
other assures these valves will operate from either power source.
l The requirement to manually transfer control power for the PORVs from the normal supply to the emergency supply (which transfers the
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q U.S. Nuclear Regulatory Commission B14462/Page 5 May 19, 1993 i
source for semi-vital power from MCC5 to MCCl2) assures control power is available from either power source. Testing the PORVs with semi-vital power fed from its normal supply is no different than testing the valves with semi-vital power fed from its emergency supply.
The testing of the power supplies is covered by other technical specification surveillances (4.8.1.1.?.f) and is not repeated here. -The present requirement to manually transfer the air supply from the normal to the emergency air supplies is maintained.
- 10. Bases Section 3/4.4.4:
This section has been revised to reflect 1
changes to the ACTION Statements. The added discussion will provide the operators with additional information on acceptable plant configurations and what action is required to be taken when an inoperable PORV or block valve is discovered.
B.
Section 3.4.9.3 Low-Temperature Overoressure Protection Systems At the Haddam Neck Plant, the LTOP system consists of two relief trains, each with two motor-operated isolation valves and one spring-loaded relief valve (SLRV) all in series. The LTOP system, in conjunction with a vent opening of at least 7 square inches, ensures that the RCS will be protected as required by 10CFR50, Appendix G.
The model technical specification for this configuration is not provided in GL 90-06.
Therefore proposed changes to the technical specifications are based upon the model technical specification provided in GL 90-06, but reflect the fact that the Haddam Neck Plant has a unique LTOP system.
Limitino Condition for Operation The elements of the LCO _that provide LTOP mitigation through pressure relief are:
'y 1.
Two LTOP SLRVs with a lift setting of 380 psig with their respective motor-operated isolation valves in the open position.
2.
A depressurized RCS and an RCS vent.
An P,CS vent is OPERABLE when open with an average area of greater than or equal to 7 square inches.
Aeolicability: The applicability.section follows the general guidsnce of GL 90-06, Attachment B, except that additional descriptions are provided due to the uniqueness of the Haddam Neck Plant design.
ACTION Statement:
1.
ACTIC1 a follows the general guidance of Attachment B to GL 90-06 e' ept that it has been customized to reflect the Haddam Neck Plant
U.S. Nuclear Regulatory Commission BI4462/Page 6 May 19, 1993 use of SLRVs.
In addition, clarification has been added to assist plant operators in the actions to be taken.
2.
A new ACTION b has been added to be consistent with Attachment B to l
This has been further customized to reflect the Haddam Neck Plant's unique design.
3.
ACTION b has been renamed Action c and has been customized to reflect the Haddam Neck Plant's unique design.
This action follows the guidance of Attachment B to GL 90-06.
l 4.
A new ACTION d has been added to reflect the guidance in GL 90-06, f
Attachment B, but has been customized to reflect the Haddam Neck
-l Plant's unique design.
5.
ACTION c has been renamed ACTION e and has been customized to i
reflect the Haddam Neck Plant's unique design.
The action follows the guidance of Attachment B to GL 90-06.
Surveillance Reouirements Surveillance Requirements 4.4.9.3.1, 4.4.9.3.2, 4.4.9.3.3, and 4.4.9.3.4 have been revised to follow the guidance of GL 90-06, Attachment B, but have been customized to reflect the Haddam Neck Plant's unique design.
-I Safety Assessment l
Section 3/4.4.4. Relief Valves
'I The proposed changes to Technical Specification 3/4.4.4, " Relief Valves" increase availability of the PORVs for the RCS pressure transient mitigation.
ACTION Statements >, b, and c distinguish various types of inoperability of the PORV.
ALfl0N statements e and f distinguish the various types of block valve inoperability.
Specifically, a PORV or -
block valve may be designated inoperable, but they may be able to be manually opened and closed, and therefore, able to contribute to the-performance of the safety function.-
PORV or block valve inoperability l
may be due to seat leakage, instrumentation problems, automatic control.
-l problems, or other causes that do 1 not prevent manual use and do not create a possibility of a small break LOCA. -For these reasons, the block valve may be closed but the action requires power to be maintained to the i
block valve.
This allows quick access to the PORY for pressure control.
On the other hand, if a PORV is inoperable and not capable of being manually cycled, it must be either restored or isolated byl closing the associated block valve and removing power.
If the block valves are inoperable, the proposed changes preclude the potential for having a stuck-open PORV that could not be isolated because of an inoperable block valve, yet - maintains the ability to use the PORVs for RCS pressure
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1 U.S. Nuclear Regulatory Commission B14462/Page 7 May 19, 1993 transient control by placing the associated PORV in manual control (i.e.,
the control switch in the 'CLOSE' position).
The proposed changes require that PORVs be cycled only during Modes 3 or 4 and not during power operation to simulate the temperature and environmental effects on the PORVs. No credit for automatic PORY operation is taken in the safety analysis for a Mode 1, 2, or 3 transient.
Safety-related overpressure protection for the RCS in Modes 1,
2, and 3 is provided by the pressurizer code safety valves.
There is no change proposed to the PORV and block valve actuation circuitry or to the PORV or block valve power supply configuration.
The proposed changes will increase the availability of the PORVs to mitigate an RCS pressure transient and will, therefore, enhance safe operation.
Section 3/4.9.3. Overoressure Protection System Specification 3/4.9.3 provides requirements for the LTOP system.
The APPLICABILITY statement has been changed slightly for clarification purposes with no change in intent and no safety implications.
ACTION a for one LTOP inoperable has been changed to make it applicable for Mode 4 only, versus the present applicability in Modes 4, 5, and 6.
It also clarifies what actions must be performed when Mode 5 is entered during the required cooldown, thus eliminating the potential for confusion with the requirements of new ACTION b.
New ACTION b for one LTOP inoperable in Modes 5 and 6 is more restrictive than present requirements since its allowable time for corrective action is considerably shorter.
These changes are safe and conservative since the time permitted in Modes 5 and 6 with only one train of LTOP protection is significantly reduced.
A new ACTION d has been added which requires periodic surveillance of the vent path opened in response to ACTIONS a,
b, or c.
Surveillance 4.4.9.3.2 has been changed to make the surveillance of a vent path opened per the requirements of LC0 3.4.9.3.b consistent with the requirements of ACTION d.
The new surveillance requirements are more conservative than the present ones since they require locked open valves used in a vent path to be verified open at least once per 31 days where no requirement for locked open valves presently exists.
D.
Sionificant Hazards Consideration In accordance with 10CFR50.92, CYAPC0 has reviewed the attached proposed changes and has concluded that the changes do not involve a significant hazards consideration (SHC).
The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised.
The proposed changes do not involve an SHC because the changes would not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
I J
U.S. Nuclear Regulatory Commission B14462/Page 8 May 19, 1993 The proposed changes only address the operability and surveillance requirements for the PORVs, block valves, and the LTOP systems. The changes were proposed mainly to reflect the guidance of GL 90-06.
The changes are more restrictive than present requirements.
- Also, the changes provide the operator with additional guidance that was not previously available.
Therefore, the changes will not impact the probability of occurrence or consequences of an accident previously analyzed.
The proposed changes to Technical Specification 3.4.4a, which requires that power be maintained to the closed block valve (s),
allows the valve (s) to be operable and opened to allow the PORV to be used to control RCS pressure.
Maintaining power to the block valve cannot result in an initiating event for any previously analyzed accidents.
t The proposed changes to Technical Specification 3.4.4 e and f establish remedial measures that are consistent with the function of the block valves.
The prime importance for the capability to close the block valve is to isolate a stuck-open PORV.
Therefore, if the block valve (s) cannot be restored to operable status within one hour, the remedial action is to place the PORV in manual control (i.e.,
the control switch in 'close' position) to preclude its automatic opening for an overpressure event and to avoid the potential for a stuck-open PORV at a time that the block valve is inoperable.
This change cannot result in an initiating event for the accidents previously evaluated.
The proposed change to Technical Specification Section 3.4.4 e and f to maintain the power i.o the block valve will not increase the dose consequences.
No credit is taken for block valve closure in the analysis of an inadvertent opening of the PORV.
Since the proposed-change to Technical Specification 3.4.4 e and f to place the PORV in manual control (i.e., the control switch in 'close' position) will avoid the potential for a stuck-open PORV, there will be no effect on the dose consequences.
At present, once per 18 months, the Haddam Neck Plant's PORVs are cycled at cold shutdown conditions.
The proposed change will require that once per 18 months PORVs be cycled during Modes 3 or.4 and not during power operation to simulate the temperature and environmental effects on the PORV.
The proposed changes to Technical Specification 3/4.9.3 provide' enhanced operational flexibility through the use of a SLRV or RCS vent.
The APPLICABILITY statement has been changed for clarification purposes with no change in intent and no safety implications.
It should be noted that the Haddam Neck Plant's LTOP l
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U.S. Nuclear Regulatory Commission B14462/Page 9 May 19, 1993 system is unique and cannot directly use standard industry proposed specifications.
As recommended in GL 90-06, the applicability for Mode 6 was clarified as "when the head is on the reactor vessel" rather than
" Mode 6 with the reactor vessel head on."
ACTION a for one LTOP inoperable has been changed to make it applicable for Mode 4 only, versus the present applicability in Modes 4, 5, and 6.
It also clarifies what actions must be performed when Mode 5 is entered during the required cooldown, thus eliminating the potential for confusion with the requirements of new ACTION b.
ACTION b was added as stated in Attachment B-1 of GL 90-06 for one LTOP inoperable in Modes 5 or 6.
A new ACTION d has been added which requires periodic surveillance or a vent path opened in response to ACTIONS a,
b, or c.
Surveillance 4.4.9.3.2 has been changed to make the surveillance of a vent path opened per the requirements of LC0 3.4.9.3.b consistent with the requirercents of ACTION d.
2.
Create the possibility of a new or different kind of accident from any previously analyzed.
The proposed changes to Technical Specification 3/4.4.4 do not create the possibility of an accident of a different type than previously evaluated, since there is no change to the design of the plant and plant operations are only being altered enough to allow a block valve and PORV to be placed in conditions which allow them to better perform their safety functions.
The proposed changes to Technical Specification 3/4.4.9.3 do not create the possibility. of an accident of a different type than previously evaluated, since there is no change to the design of the plant and the way the plant is operated.
3.
Involve a significant reduction in a margin of safety.
The change in ACTION statement a for Specification 3.4.4.4 will-instruct the operator to maintain power to the block valve when it is required to be closed because of' excess PORV seat leakage.
This change is acceptable and safe because the PORVs and block valves will still be available to manually function as required by emergency operating procedures.
In addition, the automatic opening function of the PORVs - and block valves is to open preemptively to prevent the pressurizer code safety valves from ope'ning; however, i
they are not credited in the safety analysis as a means of overpressure protection.
The new ACTION statecents e and f for-Specification 3/4.4.4 will place the plant in essentially the same
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U.S. Nuclear Regulatory Commission l
B14462/Page 10 l
May 19, 1993 condition, in the same time frame, as would a failed PORV(s).
This change is safe and also provides the operators with additional guidance that was previously not available.
The change for Surveillance 4.4.4.6 assures the PORVs will operate from either air supply.
The change clarifies the testing performed presently.
The new ACTION b of Specification 3/4.9.3 for one LTOP inoperable in Modes 5 or 6 is more restrictive than present requirements since its allowable time for corrective action is considerably shorter.
This change is consistent with GL 90-06.
The new surveillance requirement (4.4.9.3.2), which requires locked open valves used in a vent path to be verified open at least once per 31 days, is more restrictive since no requirement presently exists.
There is no degradation in the operability and surveillance requirements for the PORVs and block valves and the LTOP systems.
There will be no change in actual practice for, or resulting i
performance of, these systems.
All other changes are proposed mainly to clarify each requirement.
For Modes 1, 2, and 3, safety-related overpressure protection is provided by the pressurizer code safety relief valves. Therefore, there will be no adverse impact on i
the margin of safety as defined in the bases of 'any technical i
specification.
Moreover, the Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (March 6,
- 1986, 51FR7751) of amendments that are considered not likely to involve an SHC. The proposed changes to Technical Specification Sections 3/4.4.4 and 3/4.4.9.3 are similar to example '(ii); a change which constitutes an additional limitation, restriction, or control not presently included in the technical specifications. The proposed changes to Section 3/4.4.4 require that power be maintained to block valves which are closed to isolate a PORV which may be inoperable but capable of being manually cycled.
Removal of power would render the block valve inoperable and the requirements of - ACTION' c would apply.
Power is maintained to the block valve (s) so that it is operable and may be subsequently opened to allow the PORY to be used to manually control RCS pressure.
The proposed changes require that PORVs be cycled only during i
Modes 3: or 4 and not during power operation to simulate the temperature and environmental affects on the PORVs. The changes proposed to Section 3/4.4.9.3 provides additional assurance of overpressure protection. system availability by the addition of further system availability requirements.
CYAPC0 has reviewed the proposed license amendment against the. criteria of 10CFR51.22 for environmental considerations.
The proposed: changes do not
.t involve a SHC, nor increase the types and amounts of effluents that may be released off site, nor significantly increase individual or cumulative-occupational radiation exposures.
Based on the foregoing, CYAPC0 concludes 9
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U.S. Nuclear Regulatory Commission B14462/Page 11 4
May 19, 1993 that the proposed changes meet the criteria delineated in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an environmental impact statement.
- presents the marked-up version of the technical specifications.
The retype of the proposed changes to the technical specifications in reflect the currently ise,ued version of technical specifications.
Pending technical specification changes, or technical specification changes issued subsequent to this submittal, are not reflected in the enclosed retype.
The enclosed retype should be checked for continuity with technical specifications prior to issuance, i
Revision bars are provided in the right-hand margin to indicate a revision to the text.
No revision bars are utilized when the page is changed solely to accommodate the shifting of text due to additions or deletions.
i The Haddam Neck Plant Nuclear Review Board has reviewed and approved this proposed amendment and concurs with the above determination.
In accordance with 10CFR50.91(b), we are providing the State of Connecticut with a copy of this proposed amendment.
i Regarding our proposed schedule for this amendment, we request issuance at your earliest convenience with the amendment effective as of the date of issuance, to be implemented within 30 days of issuance.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY 1
FOR:
J. F. Opeka l
Executive Vice President BY:
0 Ou/%ts/m E. A. DeBarba Vice President
!l cc:
T. T. Martin, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant 1
W. J. Raymond, Senior Resident Inspector, Haddam Neck Plant Mr. Kevin McCarthy, Director l
Radiation Control Unit Department of Environmental Protection i
Hartford, CT 06116 i
U.S. Nuclear Regulatory Commission B14462/Page 12 May 19, 1993 Subscribed and sworn to before me this17 day of M O Ll 19.2_3 h
. b h An lio ry Public DateCommissionExpires:6/4/f95
)
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