ML20198D243

Forwards Yankee Nuclear Power Station Certified Fuel Handler Initial Certification Program & Yankee Nuclear Power Station Certified Fuel Handler Recertification Program to Replace 10CFR55 Licensed Operator Program

ML20198D243
Person / Time
Site:	Yankee Rowe
Issue date:	05/15/1992
From:	Thayer J YANKEE ATOMIC ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20198D246	List: ML20198D243 ML20198D248 ML20198D254
References
BYR-92-053, BYR-92-53, NUDOCS 9205190267
Download: ML20198D243 (10)

Text

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%  ? YANKEE ATOMIC ELECTRIC COMPANY "C"*,f%l,'f,"l"

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.wAN K .- EEj May 15, 1992 PC 245~

BYR 92-053

, United States. Nuclear Regulatory Commission Document Control Desk  :

Washington,. 00 20555

References:

(at License No OPk-3 (Docket No.-50-29)

(b) Letter, A. Kadak, Yankee Atomic Electric Company to' ,

-T. Murley, U.S. Nuclear Regulatory Commission, dated '

February 27, 1992 (c) Letter, J. Thayer, Yankee Atomic Electric Com?any to T. Murley, U.S. Nuclear Regulatory Commission, dated March 27,21992

, (d) Letter, T.- Murley, U.S. Nuclear Regulatory _ Commission to- A. Kadak, ~ Yankee Atomic' Electric Company,_- dated April 7,.1992

Subject:

MINIMUM SHIFT STAFFING FOR PERMAN".NTLY-SHUTDOWN AND DEFUELED STATUS

Dear Sir:

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Pursuant .to -10CFR,' Section -50.90, Yankee Atcmic Electric _ Company (YAEC)-

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hereby. requests Nuclear _ Regulatory Commission _(NRC) review .and approval of a-Certified Fuel-Handler Training Program'(Attachment A)'and changes to 4

EAppendix_'A of the facility license regarding staffing and training

'(Attachments:B and C); 'This request-is:in recognition of the fact that~the.

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Yankee Nuclear Power Station _:(YNPS)_ is permanently shutdown- and defueled.

10nf february 27,r1992, YAEC-informed NRC' of its decision to permanently

' cease power operation of YNPS-(Reference (b)). Reactor defueling had_been

- completed as ' of February -14,1992. _ On March;27,:1992,- YAEC: applied for '

u -authorization to amend its license'to=a-Possession-Only License (POL) status iReference (c)). On April 7. -1992, NRC confirmed that YNPS will remain in a permanently defueled ~ status (Reference' (d)).

_. ;Because YNPS is permanently shutdown-and defueled, all activities for ,

,l _ which 10CFR Part 50.54 requires hRC licensed operators have' ceased.

j' t Therefwe. , Yankee proposes' to replace the 10CFR Part 55 NRC licensed operator . -

E  ! program with-an.NRC? approved Certified Fuel Handler (CFH)' Training Program. -

L In conjunction with NRC approval of the CFH Training Program, the' following changes.~ to the Administrative Section of the YNPS Technical Specifications are appropriate, f 3 f\

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United States Nuclear RegulatoryJCommission May-15, 1992

0ocument. Control Desk Page 2 BYR 92-053 .

ProDosed Change Reference is made to the~ Technical-Specifications of YNPS, License l No.-DPR-3. Due to the permanent cessation of power operations and in conjunction with the anticipated approval of the CFH Training Program, we

propose to modify the' shift staffing requirements in the Administrative Controls section of the YNPS Technical Specifications. Specifically, we propose:to:

-1. ' Replace the 10CFR Part' 55 tr51ning requirements for licensed

. operating-personnel with-the CFH Training Program [TS 6.4.1).

2. Modify titles of senior operating personnel to Certified fuel Handlers [TS 6.2.2.b. 6.2.2.e. 6.2.2.f. 6.2.2,g, Table 6.2-1, and 6.3,4.b],

3. -Define the minimum fuel handling staff [TS 6.2.2.c and 6.2.2.r',

. 4.. Define,the_ minimum shift crew staff [TS Table _6.2-1],

5.- Define the minimum control room staff-[TS 6,2.2.b], and

6. Delete all references to' power operation from the pages affected Lby these> changes.

- Modified-Technical Specification-pages 6-la, 6-2, 6-5, 6 6 and 6 14 are contained in Attachment B.

Reason and Basis for Change

- YAEC permanently ceased'. power operations'of YNPS on February 26, 1992.

. Reactor defueling had been compieted as:of February- 14, 1992. On MarchL27,'1992, Yankee requested NRC to amend the Facility Operating License Eto a- POL status. _ Thel changes proposed- herein. reflect shif t staffing requirements appropriate-tolthe permanently shutdown and defueled condition-of YNPS, including training, titles, minimum. staff sizes and the deletion of references to' power _ operation. The reasons and. bases for each change are as-follows:

1. Technical Specification 6.4.1 addresses retraining and replacement training programs for the NRC Licensed Operators. it currently specifies programs that meet the requirements of 10CFR Part 55.

However, Part 55 addresses operational-evolutions ranging from

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-United States-Nuclear Regulatory Commission May 15, 1992-i

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startup to refueling. These evolutions no longer apply to YNPS.

In Reference (d). NRC has in effect acknowledged the cessation of activities for which 10CFR Section 50.54 requires licensed

. operators.

Upon NRC approval, training requirements will be defined by the

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CFH-Training Program.

The proposed CFH Training Program for YNPS is presented in l Attachment A. It was developed from YNPS's currently accredited NRC Licensed Operator Training Program. In the CFH Training Program. -the Certified Fuel Handler under the permanently shutdown and defueled condition is analogous to a t 4vnsed Senior Operator J under an Operating License

.Upon approval of the CFH Training Program, holders of current NRC

-Senior Operator Licenses will automatically be considered Certified Fuel' Handlers. They will also remain licensed until such-time as'the 1 1ses may be canceled. The proposed Technical Specification 6.4.1 Las.been modified to specify the new CFH Training Program instead of a 10CFR Part 55 Program. s

2. Technical Specifications 6.2.2.b 6.2.2.e 6.2.2.f. 6.2.2.g, 6.4.1. 6.8.4.b. and Table 6.2-1 refer to various- shift senior

._ operating personnel duties and minimum staffing requirements using

titles which specifically reflect'their 10CFR i-art 55 NRC Senior Operator Licenses.

With NRC approval of the CFH Training Program as described.in item ,

1 above, the appropriate title for minimum senior operations staffing in'the Technical Specifications should be " Certified Fuel Handler". -The Certified fuel Handler under the permanently shutdown and defueled condition is analogous to a Licensed Senior . .

0perator under an Operating License. >

, In e6ch of; the proposed Technical Specifications, the titles of the senior. operating personnel have been changed to " Certified

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Fuel 'Han'dl er",

i-L '3. Provis' ions for additional staffing to. support particularly L important evolutions such as, start-up, shutdown. trip recovery and ~ core alterations, as specified in Tech ical Specifications 6.2.2.c and 6.2.2.e, are no longer appreoriate

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v i 4 l United States. Nuclear Regulatory Commission May 15. 1992 Document-Control Desk- Page 4 BYR 92 053 since YNPS is~in a permanently shutdown and defueled-status, fuel

-handling is not currently specified as'such, but remains the sole activity of this nature which will continue in the future.

Therefore. the proposed Specification 6.2.2.e has been. altered to

-reflect " fuel handling" instead of

• core alterations *. >

Technical Specification 6.2.2.c is no longer applicable because it addresses only operating events. However, it has been replaced witn an additional-requirement for=a Radiation Protection

-individual to be on site for fuel handling. This will serve to differentiate.between the' Radiation Protection stti f required for - ,

fuel handling versus radiation protection skills required of the shift crew as specified in-Technical Specification 6.2.2.d.

- 4. -Technical Specification Table 6.2-1 currently lists the minimum

-shift crew composition for the six operating modes defined in an ,

Operating License. The proposed _new table defines the minimum shift composition for' the permanently shutdown and defueled condition.

The proposed total shift crew complement is comprised of two positions' the Certified Fuel Handler and an Equipment Operator, This-staff size is idequate to safely maintain the facility. Note that the proposed Technical Specification 6.2.2.e- provides an additional _ Certified fuel Handler on site during fuel handling.

?The crew; size is one less than the current Modes 5 and 6 requirement of three. positions. The difference reflects the greatly reduced number of systems and components in operation and

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the very:long response time associated with restoring. decay heat removal -in the spent -fuel pit.

The- required Certified Fuel _ Handler is also the Shift Supervisor.

The function of this individual is analogous to the current "SR0",-

l except for the title and training program as described above.

The position lof Equipment.0perator combines eleme its of the former positions of-R0 and Non Licensed Auxiliary Operator. The

. Equipment Operator is subject to a formal training program which also has its origins in the current NRC Licensed Operator and non-licensed operator traini-ng programs.

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United States Nuclear Regulatory Commission May 15, .1992-Document Control-Desk Page 5 BYR 92 053 Attendant to-the revised shift crew composition, several administrative changes are proposed for Table 6.21 for

. consistency. They are.as follows:

a. The columns have been- relabeled.- The new labels are in Standard Technical- Specification format and reflect the requirements of the Possession Only License.

b. The position of Shift Technical Advisor has been deleted-entirely. Itz is currently "not required" in modes 5 or 6 and is also not required in'a permanently defueled condition.

c.- The single asterisk footnote has been revised. It currently requires an independent SR0 for CORE ALTERATIONS and has been. revised-to require a' Certified Fuel Handler during fuel handling,

d. The double asterisk footnote-requiring an additional R0 in Mode 2 only has been deleted. It is only applicable to.

startup and not applicable to the permanently defueled >

condition.

5. -The control room at YNPS is currently staffed by NRC Licensed Operators in accordance with Technical Specification 6.2.2.b.

m However, with. NRC approval of the CFH Training Program and termination of NRC llcenses.-the need to change this specification to reflect the appropriate minimum control room staffing is apparent.

The. proposed Technical Specificatinn 6.2.2.b would require at least one ind'vidual, qualified to stand watch in the control room, to be present in the control room when there is fuel in the spent -fuel pit. :This function could be fulfilled either by a Certified Fuel Handler or a control room qualified Equipment-Operator (E0h There are'two changes involved in this revision:

a. First there are title' changes-. Since both the Certified Fuel Handler:and E0 training programs include control room training analognus. to the previously licensed control room L operators, the title changes are essentially-administrative.

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United States Nuclear Regulatory Commission May 15, 1992 Document Control. Desk- Page 6-SYR 92 053

b. _ Secondly, the change in applicability from "when there is fuel in the reactor" to "when there is fuel in the spent fuel pit" simply reflects the.ph.vsical aspects of the change in Yankee's license from an Operating License to a permanently shutdown and defueled condition.

6. With_the permanently shutdown and defueled condition of the reactor at'YNPS, references to power operation and fuel in the reactor are not necessary in the Technical Specifications.

Therefore, one such reference has been modified simply because it resides on the pages affected by the other changes in this submittal. Specifically, in 6.2.2.d. the phrase " fuel is in the reactor" has been charged to " fuel is in the spent fuel pit".

This change is purely administrative.

SAFETY CONSIDERATIONS YNPS is now permanently shutdown and~defueled. YNPS has ceased any '

-activities-for which 10CFR Part 50.54 would require NRC Licensed Operators.

Therefore, the appropriate training basis for YNPS requires an NRC approved Certified Fuel Handler Training Program (Attachment A).

-Maintenance of.the facility has also been significantly simplified with the reduction in the numbers of systems, structures, and components required for a permanently shutdown and defueled condition, ln addition, the reaction time required:of. operators to restore deca / heat removal to the spent- fuel pit is very long, measur ed in days. Therefore, the minimum shift crew composition required to safely maint3in the facility has been reduced by one.

With the CFH Training Program reviewed and approved, the changes described above.will more-clearly' reflect the facility staffing requirements

' and improve Technical Specification clarity and readability. Except for the reduction by one individual of the minimum shift _ crew composition, the remaining changes are -3dm.ristrative in nature. As such, these changes will not:

1. Involve a significant-increase in the probability or consequence of an accident previously evaluated. This change reflects staffing requirements appropriate to the permanently shutdown and defueled status of YNPS. 2* pecifically, the changes clarify the training, titlas minimum staff requirements for fuel handling.

l' normal' shift crew composition and minimum staff requirements for

! the control room.

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United States Nuclear Regulatory, Commission- May 15, 1992 Document Control Desk Page 7 BYR 92 053 l i

Without fuel in the reactor, the probability-_and consequences of most design basis accidents are reduced to zero. Only a fuel handling accident remains possible. However, this change does not affect-the Limiting Conditions for Operations associated with handling fuel and the staffing requirements are clarified for title changes. The new minimum shift crew composition is commensurate with the reduction in operating systems and components and is-adequate to safely maintain the facility.

Therefore, there is no increase in the probability or consequences of an accident previously evaluated in the SAR as a result of this change.

2. Create the pessibility of a new or different accident from any previously evaluated. The changes described in this proposal do not modify any plant systems or components and-will not create the possibility of a new or diff rent accident from any previously evaluated.

3. Involve a significant reduction in a margin of safety. The reduction of the minimum shif t crew site is connensurate with the significant ' increase in the margin of safety associated with the

' cessation of power operations, The adm? istrative changes are consistent with the existing personnel qualifications and staffing

-practices and will not involve a significant reduction in a margin ,

of-safety.

Based on the above considerations,-it is concluded that there is reasonable assurance that the maintenance of Yankee Nuclear Power Station.

consistent with-the proposed change, will not endanger _the health and safety of_the public.

fThisproposedchangehasbeenreviewedbytheNuclearSafetyAuditand' Review Committee.

SCHEDULE OF-CHANGE

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These page changes to the.YNPS Technical Specifications will be made upon the Commission's approval ~and enrollment of the Shift Supervisors in._the-CFH Requalification Program.

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. 7 United States Nuclear Regulatory Commission May 15, 1992 Document Control Desk Page 8  ;

BYR 92-053 l We trust you will find this submittal satisf actory; however should you desire additional information, please contact us.

Very Truly Yours, YANKEE ATOMIC ELECTRIC COMPANY

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. K. Thayer Vice President and Manager of Operations JKT/sf c: USNRC Region i USNRC Resident Inspector, YNPS R. Dudley, NRC, NRR Attachments i enua L

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4-- g United States Nuclear: Regulatory Commission May 15, 1992-

-- Document ~ Control . Desk _ Page 9 BYR 92 053 COMMONWEALTH OF MASSACHUSETTS)

.)ss WORCESTER COUNTY )

Then personally appeared before me, J. K. Thayer. who, being duly sworn,-

did-state that he is a Vice President and Manager of Operations-of Yankee

- Atomic Electric Company, that he is duly authorized to execute and file the foregoing document in-the name and on the behalf of Yankee Atomic-Electric Cotpany and_that.the statements therein-are true to the best of his knowledge and belief.-

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(tncn mcce Helen D. 52mmarco Notary Public My Commission Expires October 16, 1998 i.

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~ ATTACHMENT A.

Certified Fuel Handler Training Proaram

_ Certified-fuel Handler Initial--Certification Program Certified' Fuel. Handler Recertification Program

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CT?\l26

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