ML20204E505

Requests NRC Review & Approval of Listed Mods to App a of Plant Possession Only License DPR-3

ML20204E505
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
ML20204E510	List: ML20204E505 ML20204E524
References
BYR-99-001, BYR-99-1, NUDOCS 9903250048
Download: ML20204E505 (11)

Text

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-o T3ephorn(508) 568-2233 Facsimile (508) 568-3703 YANKEE ATOMICELECTRIC COMPANY

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DON K. DAVIS March 17,1999 l CHIEF C ' OFFICER P.C. No. 262 United States Nuclear Regulatory Commission Document Control Desk 1 Washington, DC 20555 l l

Attention: Mr. Morton B. Fairtile Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Oflice of Nuclear Reactor Regulation

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References:

(a) License No. DPR-3 (Docket I4o. 50-29)  !

l (b) Yankee Decommissioning Quality Assurance Program, Rev. 28, October 16,1998 (c) Letter, D. Davis, YAEC, to M. B. Fairtile, USNRC, " Yankee Nuclear Power Station Change of Personnel," BYR 98-037, September 23, 1998 (d) NUREG-1625, " Proposed Standard Technical Specifications for Permanently Defueled Westinghouse Plants", USNRC, March 1998 (e) NUREG-1431, Rey,1, " Standard Technical Specifications -

Westinghouse Plants", April 1995 f (f) NUREG-1432, Rev.1, " Standard Technical Specifications -

., Combustion Engineering Plants", April 1995 n'it () 0 0,0 l

(g) Letter, M. K. Webb, USNRC, to M. J. Meisner, MYAPC, dated March 30,1998

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Subject:

Request for Modification of Yankee Nuclear Power Station's Defueled Technical Specifications to Consolidate Management Positions and to Transfer Review and Audit Functions to the Yankee Decommissioning Quality Assurance Program 9903250048 990317  !}

PDR ADOCK 05000029 1 W PDR b

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1 United States Nuclear Regulatory Commission March 17,1999 Attentioh: Mr. Morton Fairtile Page 2 l

Dear Mr. Fairtile:

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

PROPOSED CHANGES Due to the permanent cessation of power operations and the advanced state of decommissioning of YNPS, YAEC proposes to eliminate references to the positions of Manager of Operations and Plant Superintendent in the YNPS Technical Specifications and to assign the responsibilitic of these positions to the YAEC Decommissioning Manager. To effect this change it will be necessary to replace the reference to the Manager of Operations with a reference to the Decommissioning Manager in Se, tion 6.6.1 b of the Technical Specifications; references to the Plant Superintendent must be replaced with references to the Decommissioning Manager in Sections 6.1.1,6.2.2 f,6.7.2,6.7.4 c,6.12.1 b, and 6.13.1.b. Also, Section 6.1.2 of the Technical Specifications will read as follows:

6.1.2 in all matters relating to the operation of the facility and to these Technical Specifications, the Decommissioning Manager shall report to and be directly responsible to the President of Yankee Atomic Electric Company. l It should be emphasized that the proposed change would not eliminate any of the current duties and responsibilities of the Manager of Operations position and the Plant Superintendent position.

Section 6.5 of the YNPS Technical Specifications specifies the review and audit functions performed by the Plant Operation Review Committee (PORC) and the Nuclear Safety Audit and Review Committee (NSARC). YAEC proposes to replace the functions of the PORC with an Independent Safety Review and the NSARC with an Independent Review and Audit Committee (IRAC) as described in Attachment I, and to relocate these review and audit requirements from the YNPS Technical Specifications to the Yankee Decommissioning Quality Assurance Program (Reference (b)). Subsequent to approval of this transfer, the review and audit function will be maintained under the provisions of 10 CFR 50.54. In addition to the deletion of Section 6.5, this change will require modification of Technical Specification Sections 6.6.1 b,6.7.2,6.7.4 c, 6.12.1 b, and 6.13.1 b. References to PORC and NSARC are deleted and,' where appropriate, references to the new review and audit functions to be performed by the Independent Safety Review and the IRAC are introduced. Technical Specification Section 6.7.3 will be deleted from the Technical Specifications in its entirety as the review requirements mandated by this sectioa will be covered in the scope of activities described for the Independent Safety Review function in

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United States Nuclear Regulatory Commission March 17,1999 Attentioh: Mr. Morton Fairtile Page 3 the YDQAP (See Attachment I). It is also proposed that the present requirement in Technical Specification Section 6.9.2 k to retain the records of PORC and NSARC meetings be deleted from the Technical Specifications and transferred to the review and audit function program requirements described in Attachment I.

An annotated version of the present Technical Specification pages showing the proposed changes is provided in Attachment II to this letter. The proposed new pages of the Technical Specifications are provided in Attachment III.

REASON AND llASIS FOR CIIANGE Since the permanent cessation of electric power generation at YNPS on February 26,1992, most dismantlement and decontamination activities have been completed in areas outside of the Vapor Container not associated with fuel storage. The entire decommissioning task is estimated to be more than 80% complete. The removal of the remaining systems and components and the decontamination of buildings not associated with fuel storage is currently scheduled to be finished this year. Based on the remaining scope of work necessary to complete the decommissioning of YNPS, YAEC has determined that it is possible to streamline the YAEC/YNPS management structure without impacting the efficiency or the safety of the remaining work. Elimination of the Manager of Operations and Plant Superintendent positions will not eliminate any of the responsibilities or functions currently assigned to these positions.

These responsibilities and functions will be reassigned to the Decommissioning Manager. (In fact, as noted to the Commission in Reference (c), the YAEC Decommissioning Manager is also currently the acting Manager of Operations.) Also, this proposal is consistent with the facility management structure proposed in NUREG-1625, " Proposed Standard Technical Specifications for Permanently Defueled Westinghouse Plants." (Reference (d))

The proposal to replace the review and audit functions of the PORC and the NSARC with an Independent Safety Review function and an Independent Review and Audit Committee is .

justified for essentially the same reasons cited above for the proposed streamlining of the YNPS l I

management structure: the scope and complexity of activities at YNPS have been greatly reduced. This reduced scope of activities combined with a commensurate decrease in facility stalf makes continued operation of both the PORC and the NSARC impracticable and unnecessary. The responsibilities of the proposed review and audit function will encompass the j majority of he functions currently performed by the PORC and the NSARC with selected functions modified to be consistent with the scope of activities at a permanently defueled facility which is in an advanced stage of decommissioning. The proposal is modeled directly on the ,

approach endorsed by the NRC in Reference (d). The proposal to transfer the description of the l activities and the responsibilities of the review and audit function from the YNPS Technical )

Specifications to the Yankee Decommissioning Quality Assurance Program (YDQAP) is {

consistent with the treatment of this issue in NUREG-1431, Rev.1, Standard Technical j

c United States Nuclear Regulatory Commission March 17,1999 Attentioh: Mr. Morton Fairtile Page 4 Specifications, Westinghouse Plants (Reference (e)) and NUREG-1432, Rev.1, Standard Technical Specifications, Combustion Engineering Plants (Reference (f)). It should also be noted that the Commission has approved a aimilar review and audit program and a transfer of the program description from the Technical Specifications to the Quality Assurance program for Maine Yankee (Reference (g)).

- SIGNIFICANT HAZARDS CONSIDERATION The proposed changes are administrative in nature and reflect a streamlining of the YAEC/YNPS management structure and procedures consistent with the on-going requirement to complete the remaining scope of YNPS decommissioning safely and efficiently. As such, the changes will not:

.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 possibility 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. Elimination of the Manager of Operations position and the Plant Superintendent position will not eliminate any of the responsibilities or functions currently assigned to these positions. These responsibilities and functions will be reassigned to an appropriately qualified YAEC/YNPS manager, i.e., the Decommissioning Manager. This change and the replacement of the PORC and the NSARC review and audit functions with an Independent Safety Review and an IRAC are consistent with the significant reduction in the scope and the complexity of activities at YNPS as the facility moves into th'e later stages of the decommissioning effort; 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.

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United States Nuclear Regulatory Commission March 17,1999

Attentioh: Mr. Morton Fairtile Page 5 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 contained in this section 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 or significant increase in the amounts of any effluents that may be released offsite. The amendment deals solely with administrative issues.

3. - There is no significant increase in individual or cumulative occupational radiation worker exposure. Again, the amendment deals solely with administrative issues completely unrelated to individual or cumulative occupational radiation worker

. exposure.

Based on the foregoing, it is concluded that the proposed amendment meets the criteria for categorical exclusica 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.

The proposed changes have been reviewed by the PORC and the NSARC.

If United States Nuclear Regulatory Commission March 17,1999 Attentioh: Mr. Morton Fairtile Page 6 SCHEDULE OF CHANGE

. The proposed change will be implemented upon approval by the Commission.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY neJ -

Don K. Davis, Chairman President and CEO i f

Attaclunents C: USNRC, Region I 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, l

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n-Kathryn Gatef Notary Public I My Commission Expires January 1,2004

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f ATTACHMENTI i Review and Audit Functions f

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E i Attachment I Page I-2 independent Safety Review An Independent Safety Review shal'1 be a thorough review conducted by one or more qualified Independent Safety Reviewers. Persons performing these reviews shall be knowledgeable in the subject area being reviewed. Independent Safety Reviews must be completed prior to implementation of proposed activities.

a. Independent Safety Reviewers shall be individuals without direct responsibility for the performance of the activities under review; these reviewers may be from the same functionally cognizant organization as the individual or group performing the original work.

b. Independent Safety Reviewers shall have at least 5 years of professional experience and either a Bachelor's Degree in Engineering or the Physical Sciences or shall have equivalent qualifications in accordance with ANSI 18.1-1971. The Decommissioning Manager (or a designee) shall document the appointment ofIndependent Safety Reviewers.

c. The following subjects shall be independently reviewed by a e,ualified Independent Safety Reviewer: 1

1. safety evaluations for changes in the facility as described in the Final Safety Analysis Report (FSAR), changes in procedures as described in the FSAR, and tests or experiments not described in the FSAR to venfy that such actions do not involve a change to the Technical Specifications or will involve an unreviewed safety question as defined in 10CFR50.59;

2. proposed changes to the programs required by Technical Specification 6.7, to verify that such changes do not involve a change to the Technical Specifications ,

and will not involve an unreviewed safety question as defined in 10CFR50.59; l and  !

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3. proposed changes to the Technical Specification Bases.

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1 Indenendent Review and Audit Committee (IRAC) ]

I The IRAC is responsible for reviewing, auditing, and advising the President of Yankee Atomic j Electric Company (or a designee) on matters related to the safe storage ofirradiated fuel. This  :

review and audit function is independent ofline organization responsibilities. l l

a. The IRAC shall include a minimum of five members. Alternates may be substituted for regular members. The licensee shall designate in writing the chairman, the members, and l

alternates for the IRAC. The chairman shall not have management responsibilities for, or l 4

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Attachment I Page I-3 report to, the line organizations responsible for operation or maintenance of the fuel storage facility.

b. The IRAC shall collectively have experience and knowledge in the fobowing functional areas:

1. fuel handling and storage (including the potential for criticality),

2. chemistry and radiochemistry,

3. engineering,

4. radiation protection, and j

5. quality assurance.

c. The IRAC shall hold at least one meeting per quarter.

d. A quorum shall consist of three regular members or their duly appointed alternates.

Those members representing the line organizations responsible for the eneration and maintenance of the facility shall not constitute a majority of the quoru At least one member of the quorum shall be the chairman or the chairman's designated alternate.

e. As a minimum, the IRAC shall perform the following fun:tions:

1. advise the Decommissioning Manager (or a designee) on all matters related to safe storage ofirradiated fuel;

2. advise the management of the audited organization and the Decommissioning Manager (or a designee) of audit results as they relate to safe storage of irradiated fuel;

3. recommend to the management of the audited organization, and its management, any corrective action to improve the safe storage of irradiated fuel; and

4. notify the President of Yankee Atomic Electric Company of any safety significant disagreement between the IRAC and the Decommissioning Manager withm 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

f. The IRAC shall be responsible for reviewing:

1. the safety evaluations for procedures, and changes thereto, completed under the provisions of 10 CFR 50.59 to verify that such actions do not involve an unreviewed safety question as defined in 10 CFR 50.59. This review may be completed after implementation of the affected procedure;

2. changes to structures, systems, or components important to the safe storage of irradiated fuel to verify that such changes do not involve an unreviewed safety question as defined in 10 CFR 50.59. This review may be completed after ,

implementation of the change; l l

Attachment I Page I-4 3' tests or experiments involving the safe storage of irradiated fuel to verify that such tests or experiments do not involve an unreviewed safety question as defined in 10 CFR 50.59. This review may be completed after performance of the test or experiment;

4. proposed changes to the YNPS Technical Specifications or the license;

5. violations of codes, regulations, orders, license requirements, or internal procedures / instructions having nuclear safety significance;

6. indications of unanticipated deficiencies in any aspect of design or operation of structures, systems, or components that could affect safe storage of irradiated fuel;

7. significant accidental, unplanned, or uncontrolled radioactive releases, including corrective action (s) to prevent recurrence;

8. significant operating abnormalities or deviations from normal and expected performance of equipment that affect safe storage of irradiated fuel;

9. the performance of the corrective action system; and

10. internal and external experience information related to the safe storage of irradiated fuel that may indicate areas for improving facility safety.

Reports or records of these reviews shall be forwe ded to the Decommissioning Manager within 30 days after completion of the review.

g. The IRAC's audit responsibilities shall encompass:

1. conformance of irradiated fuel storage to provisions contained within the YNPS Technical specifications and applicable license conditions;

2. the training and qualifications of facility staff;

3. ' implementation of all programs required by YNPS Technical Specification 6.7,

4. actions taken to correct deficiencies occurring in structures, systems, components, or methods of operation that affect safe storage of irradiated fuel;

5. facility operations, modifications, maintenance, and Surveillance related to the safe storage of irradiated fuel to verify independently that these activities are performed safely and correctly; and

6. other activities and documents as requested by the Decommissioning Manager (or a designee).

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Reports of records of these audits, including any recommendations for improving the safe storage of irradiated fuel, shall be forwarded to the Decommissioning Manager (or a ,

designee) within 30 days after completion of the audit. l 1

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h. Records  !

Written records of reviews and audits shall be maintained. As a miniinum, these records l shallinclude:

1. Results of the activities conducted under the provisions of items a. through g.

indicated above;

2. ' Recommendations to the management of the audited organization;

3. An assessment of the safety significance of review or audit findings;

4. Determination of whether each item considered under f.1 through f.3 involves an unreviewed safety question as defined in 10 CFR 50.59.

5. Records of the Plant Operational Review Committee (PORC) and the Nuclear l Safety Audit and Review Committee (NSARC), the review and audit functions l which preceded the Independent Safety Review function and IRAC.

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