ML20204D868

Application for Amend to License DPR-3,proposing Deletion of Overtime Restrictions Currently Incorporated in Ynps TSs

ML20204D868
Person / Time
Site:	Yankee Rowe
Issue date:	03/17/1999
From:	Desiree Davis YANKEE ATOMIC ELECTRIC CO.
To:	Fairtile M NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20204D873	List: ML20204D868 ML20204D903
References
BYR-99-009, BYR-99-9, NUDOCS 9903240300
Download: ML20204D868 (8)

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Talephons(508) 568-2233 YANKE: ATOMICELECTRIC COMPANY 2C"' L'%'L 580 Main Street, Bolton, Massachusetts 01740-1398

.YANKEIE D s 1n March 17,1999 CHIEF EXECUTIVE OFFICER BYR 99-009 P.C. No. 265 United States Nuclear Regulatory Commission Washington, DC 20555 Document Control Desk Attention: Mr. Morton B. Fairtile Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management .

) Office of Nucleer Reactor Regulation

References:

(a) License No. DPR-3 (Docket No. 50-29)

Subje .. Request for Deletion of Overtime Restrictions from Yankee Nuclear Power Station's Defueled Technical Specifications

Dear Mr. Fairtile:

Pursuant to 10 CFR Section 50.90 of the Commission's Rules and Regulations, Yankee Atomic Electric Company requests Nuclear Regulatory Commission (NRC) review and approval of the following modification to Appendix A of the Yankee Nuclear Power Station (YNPS) Possession Only License (Reference (a)).

J30 POSED CIIANGE YAEC proposes that restrictions on the use of overtime currently incorporated in Section l 6.2.2 f of the YNPS Technical Specifications be deleted. An annotated version of the present Technical Specification page showing the proposed changes is provided in

.Attachmet I to this letter. The proposed new page of the Technical Specifications is provided in Attachment II.

I g 7 9903240300 990317 PDR ADOCK 05000029 W PDR

r United States Nuclear Regulatory Commission i March 17,1999 Attention: Mr. Morton Fairtile Page 2 l l

• REASON AND HASIS FOR CIIANGE l 1

1 On July 22,1993, the Commission issued its Final Policy Statement on Technical Specification Improvements, " Final Policy Statement on Technical Specification 4 Improvements for Nuclear Power Reactors"(58 FR 39132). In this policy statement the l Commission offered guidance concerning its expectations for the general content - l Technical Specifications. The Commission noted that it was adopting the qualitative l standard enunciated by the Atomic Safety and Licensing Board in Portland General

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Electric Co. (Trojan Nuclear Plant), ALAB-531,9 NRC 263,273 (1979). In this  !

proceeding, the Appeal Board observed: j i

There is neither a statutory nor a regulatory requirement that every operational l

detail set forth in r epplicant's safety analysis report (or equivalent) be subject to j a technical specituuon, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with  ;

specific Cornmission approval. Rather, as best we can discern it, the i contemplation of both the Act and the regulations is that technical specifications  !

are to be reserved for those matters as to which the imposition of rigid conditions j or limitations upon reactor operation is deemed necessary to obviate the j possibility of an abnormal situation er event giving rise to an immediate threat to )

the public health and safety.

YAEC does not believe that the overtime restrictions currently incorporated in Section 6.2.2 f of the YNPS Technical Specifications are in fact "necessary to obviate the l possibility of an abnormal situation or event giving rise to an immediate threat to the l public health and safety." The value of providing overtime controls for the staff of an operating facility where complex and demanding situations can arise that requires rapid ,

responses can be readily appreciated. However, the current situation at YNPS does not even remotely approximate the environment of an operating nuclear power plant.

l Since the permanent cessation of electric power generation at YNPS on February 26,  ;

1992, the majcrity of plant systemt and structures have been decontaminated and/or  !

dismantled.1 o support the decommissioning efforts and to eliminate potential problems l vAbh could arise from system interactions, those systems necessary for continued l opuation of the Spent Fuel Pit (SFP) were reconfigured to provide appropriate isolation from the balance of the plant. One significant resuh of this reconfiguration is that the  !

systems, which require monitoring by the operators, have been markedly reduced in i number and complexity. More specifically, the parameters of primary significance te the  ;

operato we the SFP water temperature, the SFP water level and the radiological  !

environment of the SFP Building.  !

1 I i The temperature of she SFP increases very slowly. Although it is important to prevent a j loss of spent fuel cooling capability, the consequences of such a circumstance are not  !

severe and appropriate corrective actions can be readily implemented. The YNPS FSAR l notes that with the h. vel of decay heat in the SFP as of Januacy 1994, more than four l

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i United States Nuclear Regulatory Commission March 17,1999 l Attention: Mr. Morton Fairtile Page 3

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I weeks would have to elapse without re-establishing cooling or adding make-up water before the water remaining in the SFP would not be sufficient to provide shielding adequate for operator response in the SFP Building. Even after a lapse of more than four 1 weeks in cooling or adding make-up water, a make-up water flow of approximately one j gallon per minute would suffice to replace water lost through evaporation. Diverse sources of make-up are available including deminerali7ed water, fire water, auxiliary (

service water, or water from Sherman Reservoir. Water may be injected into the SFP J

through installed or portable pumps as well as by gravity feed. Therefore, continuous monitoring of the SFP water temperature by the operators is not required. Periodic surveillance performed in accordance with plant procedures is more than adequate to ensure that any meaningful changes in the SFP water temperature will be identified in a

, timely manner and appropriate corrective actions implemented.

In the absence of the movement of camponents either within or over the SFP, rapid change in the water level of the SFP is highly improbable. In compliance with Technical Specification 5.2.2, the SFP is designed and maintained to prevent inadvertent draining of the SFP, e.g., there are no physical features which would permit inadvertent lowering of the SFP water level by a siphoning action. All loads permitted over the Pool are either suspended anc' transported by a sin ( " .re-proof crane or are analyzed to demonstrate that a postulated drop of the load v tot be capable of affecting the capacity of the SFP to retain water. Therefore, the fechnical Specification surveillance interval for checking the SFP water level of once every seven days is more than adequate for ensuring that the appropriate water level is maintained c.nd continuous monitoring of the water level by an operator in the control room is unnecessary.

Radiological incidents within the SFP Building are very unlikely when fuel is not being moved or loads are not being carried over the spent fuel. The only plausible events which could change radiological conditions in the SFP Building would be a decrease in the SFP's water level or a sustained loss of cooling of the SFP.  !

For the reasons noted previously, the loss of SFP cooling or a decrease in the SFP water  !

level would be expected to be detected well in advance of a situation developing which would lead to a challenge of the Spent Fuel Storage Area Radiation Monitor set points;  ;

however, if the alarm point were to be reached, the local area alarm would provide appropriate warning to any individual in the immediate vicinity of the SFP. The passive design of the SFP for level protection and the extremely slow heat-up rate of the SFP l provide ample time for the operator to assess the problem and take the appropriate l corrective actions. l The YNPS FSAR discusses a number of potential events in the accident analysis (Section 400). The analysis for the subject events utilizes conservative assumptions and demonstrates that the worst case scenarios would result in releases significantly less than l the Environmental Protection Agency (EPA) Protective Action Guideline (PAG) limits.

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I' j United States Nuclear Regulatory Commission March 17,1999 l Attention: Mr. Mortan Fairtile Page 4 The' analyzed events include:

Decommissioning activity events including: decontamination, dismantlement, packaging, storage, and materials handling; Loss of support system events including: loss of off-site power, loss of cooling water, and loss of compressed air; Fire and explosion events; External events; and Spent fuel storage events including: a fuel handling event, loss of spent fuel cooling capability, and bteractions betwom spent storage and decommissioning

activities.

l For each of these postulated events (including the fuel handling event), the scenario projected a maximum release of activity and no prompt mitigation actions. None of the analyzed scenarios resulted in a situation which could significantly affect the public health and safety. Prompt response to a high radiation signal in the control room does not l

change the activity released in the postulated event. Protection to plant personnel is afforded by the local radiation monitor alarms and does not depend upon operator response.

During fuel handling operations, a qualified operator will be in the control room and a Certified Fuel Handler who has no concurrent responsibilities will directly supervise the l SFP activities. Therefore, the appropriate oversight and operational staff will be l available for any fuel manipulations.

In summary, the current situation at YNPS is such that there is no possibility of"an abnormal situation or event giving rise to an immediate threat to the public health and safety." Furthermore, Section 6.2.2 f of the YNPS Technical Specifications deals specifically with limiting "the working hours of the unit staff who perform safety-related functions." The current situation at YNPS is such that there are no longer " safety-i related" functions being performed by the unit staff. Therefore, there is no longer any basis for the inclusion of the overtime restrictions in YNPS Teuhnical Specifications Section 6.2.2 f. It should be stressed that YAEC sees no benefit and has no intention of imposing excessive overtime on its personnel. Ilowever, YAEC believes that it is much

, more efficient and effective to address this issue in its Admirdstrative Procedures than to continue to be held to the potentially confusing restrictions in the present Technical Speci'ications. Therefore, YAEC will provide appropriate coratraints on the imposition of excessive overtime in its Administrative Procedures.

United States Nuclear Regulatory Commission March 17,1999 j Attention: .Mr. Morton Fairtile Page 5

_S.lGNIFICANT HAZARDS CONSIDERATION I The proposed changes are administrative in nature and simply eliminate outdated  ;

requirements from the YNPS Technical Specifications. As such, the changes will not: I

1. - Involve a significant increase in the probability or consequences of an

- accident previously evaluated. The administrative nature of the changes will not affect safety-related systems or components or their mode of operation and therefore, will not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Create the porsibility of a new or different accident from any previously evaluated. The proposed changes do not modify any plant systems or components and therefore, will not create the possibility of a new or different accident from any previously evaluated.

3. Involve a significant reduction in the margin of safety. The changes are administrative in nature involving the deletion of outdated requirements in the Technical Specifications; therefore, there will be no significant reduction in the margin of safety.

Based on the considerations noted above, it is concluded that the proposed changes will not endanger the public health and safety.

ENVIRONMENTAL IMPACT DETERMINATION This amendment request meets the criteria specified in 10 CFR 51.22 (c)(9) for categorical exclusion or otherwise not requiring environmental review. Specific criteria i contained in this section of the regulations are discussed below:

1. The amendment involves no significant hazards consideration. As demonstrated above, this requested amendment does not involve any significant hazards considerations.

2. There is no significant change in the types er significant inn c.ise in the amounts of any effluents that may be released offsite. The amendment deals solely with administrative issues.

3. There is no significant ir. crease in individual or cumulative occupational radiation exposure. Again, the amendment deals solely with administrative issues completely unrelated to individual or cumulative occupational radiation expos. ire.

United States Nuclear Regulatory Commission March 17,1999 I Attention: Mr. Morton Fairtile Page 6 Basbd on the foregoing, it is concluded that the propox. ;* endment meets the criteria for categorical exclusion set forth in 10 CFR 51.22 (c)(9) and therefore, no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

PORC AND NSARC REVIEW The Plant Operation Review Committee (PORC) and the Nuclear Safety Audit and Review Committee (NSARC) have reviewed the proposed changes and have determined that they are appropriate.

SCHEDULE OF CHANGE The proposed changes will be implemented upon approval by the Commission.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY Don K. Davis, Chairman President and CEO Attachments C: USNRC, Region I

@' i United States Nuclear Regulatory Commission March 17,1999 Attention: Mr. Morton Fairtile Page 7

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COMMONWEALTH OF MASSACHUSETTS WORCESTER COUNTY Then personally appeared before me, Don K. Davis, who, being duly sworn, did state that he is Chairman, President, and Chief Executive Officer of Yankee Atomic Electric Company, that he is duly authorized to execute and file the foregoing document in the name and on behalf of Yankee Atomic Electric Company and that the statements therein are true to the best of his knowledge and belief.

Kathryn Gates # ' Notary Public My Commission Expires January 1,2004

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ATTACHMENT I Revised Technical Specification Paces Annotated Version

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