ML20205M988

Application for Amend to License DPR-61,revising Sections 1.0,3/4.2,3/4.9,3/4.10,3/4.11,5.0 & 6.0 of Tech Specs

ML20205M988
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	10/26/1988
From:	Mroczka E, Sears C CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20205M993	List: B13056, Proposed Tech Specs Amending Sections 1.0,3/4.2,3/4.9, 3/4.10,3/4.11,5.0 & 6.0 ML20205M988
References
B13056, NUDOCS 8811030387
Download: ML20205M988 (6)

Text

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N UTILITIES con.r.i oti.c. . seiden street. Bernn. connect'cui RTF RD CONNECTICUT 061414270 L t T;  ;;:r.:C," =.',"~~ (2m> 6em October 26, 1988 Docket No. 50-213 B13056 Re: 10CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 205S5 Gentlemn:

Haddam Neck Plant Amendment Request for Sections 1.0, 3/4.2, 3/4.9, 3/4.10, 3/4.11, 5.0 and 6.0 of the Revised Technical Soecificatin i

! Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPCO) hereby proposes to amend its Operating License, DPR 61, by including the attached proposed changes as part of a new improved set of Technical l Specifications which will be forwarded for your review piecemeal.

l Discussion l The purpose of this submittal is to provide the first in a series of submittals forwarding amendment requests which will ultimately comprise an

, improved set of Technical Specifications for the Haddam Neck Plant. Along with amendment requests for Sections 1.0, 3/4.2, 3/4.9, 3/4.10, 3/4.11, 5.0 and 6.0 (the numbering and format is consistent with Westinghouse Standard Technical Specifications (STS), Rev. 5) supporting documentation has bean included. Also, included below is a discussion of CYAPCO's intended review process.

CYAPC0 acknowledges the receipt of your letter dated September 22, 1987.III We believe that the review method sugp,ested by this letter for our amendment request does not represent the optimum approach to amending our License.

(1) See the F. H. Akstulewicz letter to J. F. Opeka, dated September 22, 1987.

8811030387 881026 p\ 5' PDR ADOCK 05000213 i N t P PDC Q ( 7]

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ J

U.S. Nuclear Regulatory Comission B13056/Page 2 October 26, 1988 As a matter of interest, we are providing a comparison gtrix which compares the amendment requests to the Westinghouse STS, Rev. 5 as well as to our current Technical Specifications.

Benefits of Amendina Technical Soecifications Revisions to the current Technical Specifications utilizing the Westinghouse STS will provide comon benefits to CYAPC0 as well as the NRC. From our perspective the revised specifications will:

o Provide a set of Technical Specifications with concise action statements and a complete set of surveillance requirements that complement the limiting conditions for operation, o Utilize a standard format that will be a benefit from a training perspective by providing a more consistent organization when considering training of operators transferring from other plants.

o Improve the development of more consistently formatted station surveillance procedures through the review and, in some cases, rewriting or originating procedures needed because of the revised surveillance requirements.

o Reduce the number of future amendment requests by making a one time improvement of Technical Specifications.

From the NRC's perspective, we believe the benefits include:

o Easter familiarization with the plant's Technical Specifications.

o More concise Technical Specifications with less ambiguities.

o A convenient mechanism for closure of all outstanding comitments associated with:

-NUREG 0737 Technical Specifications,

-Systematic Evaluation Program (SEP), and

-Various Generic letter Recomendations o Ultimate elimination of the "administrative" Technical Specifica-tions.

(2) This Revision 5 version of the Westinghouse STS was the draft version used in the development of Millstone Unit No. 3 Technical Specifications.

i U.S. Nuclear Regulatory Commission B13056/Page 3 October 26, 1988 t

To these ends, working towards the implementation of a revised set of Technical Specifications for the Haddam Neck Plant is a worthwhile  ;

undertaking for both organizations. '

Review and Imolementation CYAPC0 views the proposed Technical Specifications update process as one '

which can be. reviewed in a step wise fashion and implemented at an agreed u)on time upon completion of all reviews and approvals. Overall, we expect  ;

t1e entire set of specifications to be submitted over a three nonth period ,

beginning with this submittal. With this submittal, six sections are being '

forwarded. Our intent is to conduct a review process similar to the one utilized for the Cycle 15 Reload Technical Specifications. Any ['

clarification meetings needed to facilitate the NRC's evaluation tsf our amendment requests are welcome on an as needed basis.  ;

i With respect to the actual review process, CYAPCO does not perceive the l process as any different than that required to approve an amendment request r i.e., staff conclusions need to be made on the adequacy of our 50.92 ,

evaluations. This process is distinctly different from that used for the i development of Technical Specifications for a near-term operating license  ;

(NTOL) apolicant where significant applicant / staff interaction occurs to '

ensure standard Technical Specifications are tailored to reflect the design  !

basis of a new unit. In contrast, the approval process of an amendment request for a License concentrates on verifying the changes from the '

approved Technical Specifications do not constitute a significant hazards consideration and are consistent with the plant's design basis. A NUREG is i not issued upon completion of review. Further, the Licensee is not expected  ;

to sign a sworn statement that the revised Technical Specifications reflect l the plant's design basis. CYAPC0 believes such a statement would be  :

redundant to the signed oath that omendment requests are forwarded under.

Etgg d Rules Because of the intended scope of this Technical Specification improvement project and the fact that Revision 5 to the Westinghouse STS is being used  !

cxtensively as a guide to model the new specifications, it is important to  :

reiterate some important ground rules that have always been our  !

understanding. CYAPC0 believes that the Westinghouse STS should be adopted  !

except when: l (1) Plant-specific design considerations would dictate othenvise, or l (2) Hardware, structural, or organization changes from previously approved [

conditions would be required to conform to the Westinghouse STS, or l

(3) Based on past operating experience, the existing plant-specific L requirement can be shown to provide an equivalent degree of protection to that provided by the Westingheuse STS.

U.S. Nuclear Regulatory Commission B13056/Page 4 October 26, 1988 It is important that implementation take place during a mutually agreed upon time frame with careful consideration given to the implementation of new '

surveillance requirements.

A logistical detail which we believe needs to be agreed upon by both the NRC i and CYAPC0 is as follows: ,

o For those sections which have been approved but not yet implemented, a mechanism should be established to make revisions.

CYAPC0 believes this can be accomplished through the normal amendment process whereby your review would concentrate on any  ;

proposed revisions to a section without the need to reopen the '

review of an entire section that has already been approved but not yet implemented.

Eggoortina Documentation In support of tile amendment requests for Sections 1.0,3/4.2,3/4.9,3/4.10, 3/4.11, 5.0 and 6.0 four attachments are being provided as described below:

o Attachment I forwards the revised Technical Specification pages, o Attachment 2 provides a description of the changes from the ,

existing Technical Specifications. CYAPC0 has reviewed the prososed revised Technical Specification changes in accordance witi 10CFR50.92 and has determined that they do not involve a significant hazards consideration. The basis of this  !

determination is discussed in Attachment 2.  !

o Attachment 3 provides a comparison matrix as described in the i preface to that attachment. [

o Attachment 4 provides a commitment summary of outstanding open issues intended to be resolved through the implementation of the revised Technical Specifications. This listing is cross referenced to the revised Technical Specifications.

Moreover, the Commission has provided guidance concerning the application of the standards in 10CFR50.97. by providing certain examples (March 6,1986, FR7751) of amendments that are considered not likely to involve a significant hazards consideration. The changes proposed herein are enveloped by example (ii), a change that constitutes an additional limitation, restriction or control not previously included in the Technical Specifications. These proposed changes would add Limiting Conditions for Operation and Surveillance Requirements for the systems covered under the proposed revised Technical Specification sections. This will help ensure the operability and reliability of the systems covered under the proposed revised Technical Specification sections. Therefore, the proposed changes do not impact the consequences of any design basis accident.

i l

i U.S. Nucioar Regulatory Commission B13056/Page 5 October 26, 1988 Based upon the information in this submittal, there are no significant radiological or nonradiological impacts associated with the proposed changes, and the proposed license amendment will not have a significant effect on the quality of the human environment. The Haddam Neck Nuclear Review Board has reviewed and approved the proposed changes and has c concurred with the above determination.

In accordance with 10CFR50.91(b), CYAPC0 is providing the State of Connecticut with a copy of this proposed amendment.

Pursuint to the requirements of 10CFR170.12(c), enclosed with this amendment request is the application fee of $150.00.

Should you have any questions on the attached amendment request and/or feel a meeting would help clarify the attached material please contact our licensing representative directly.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY ti. S .%h E. J. Mroczka "

Senior Vice President By: C. F. Sears Vice President ec: Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, CT 06116 W. T. Russell, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shediosky, Senior Resident Inspector, Haddam Neck Plant

U.S. Nuclear Regulatory Commission

~B13056/Page 6 October 26, 1988 STATE OF CONNECTICUT ss. Berlin COUNTY OF HARTFORD Then personally appeared before me C. F. Sears, who being duly sworn, did state that he is Vice President of Connecticut Yankee Atomic Power Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensee herein and that the statements contained in said information are true and correct to the best of his knowledge and belief, i saUu%. (%el

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