ML20205T462

Supplemental Application for Amend to License DPR-28 to Incorporate Certain Changes to Section 6 of Ts.Submittal Supplements 990201 Request for Amend & Revises Portions of Proposed Change 208 as listed.Marked-up TS Pages Encl

ML20205T462
Person / Time
Site:	Vermont Yankee
Issue date:	04/19/1999
From:	Wanczyk R VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205T466	List: ML20205T462 ML20205T472
References
BVY-99-54, NUDOCS 9904270259
Download: ML20205T462 (13)

Text

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VERMONT YANKEE l (y

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NUCLEAR POWER CORPORATION 185 Old Ferry Road, Brattleboro,VT 05301 7002 (802) 257-5271 April 19,1999 ]

BVY 99-54 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Reference:

(a) Letter, VYNPC to USNRC, " Technical Specifications Proposed Change No. 208 - l Section 6 - Administrative Controls," BVY 99-20, dated February 1,1999.

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

Technical Specifications Proposed Change No. 208 - Supplement Secjiopn_6- Administrative Controls l In Reference (a) Vermont Yankee (VY) requested that Facility Operating License DPR-28 be amended to incorporate certain changes to Section 6 of the Technical Specifications. This submittal supplements Reference (a) and revises portions of that Proposed Change as described herein.

With respect to the determination of no significant hazards consideration provided in Reference (a), one difference should be noted. It was stated therein that portions of the current Technical Specifications are being relocated to the Technical Requirements Manual (TRM) and the Offsite Dose Calculation Manual (ODCM). That statement should be revised to include the Vermont Yankee Operational Quality Assurance Manual (VOQAM) as another licensee-controlled document for relocation of certain Technical Specifications provisions. Together with this supplement, the conclusions stated in Reference (a) remain unchanged in regard to the determination of no significant hazards consideration and the categorical exclusion from environmental review pursuant to 10CFR50.92 and 10CFR51.22, respectively.

Because of the extensive changes resulting from this complete re-write of Section 6 of the Technical Specifications, VY requests that a 60-day implementation period be granted from the date of NRC issuance of a license amendment.

The following Attachments are included in support of this supplement to the Proposed Change:

Attachment A - Supplemental Description and Bases for Changes Attachment B - Listing of Affected Technical Specifications Pages Attachment C - Supplemental Marked-Up Technical Specifications Pages Attachment D - Revised Technical Specifications Pages

" "f 99042702S9 990419 PDR P ADOCK 05000271 PDR

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i VERMONT YANKEE NUOLEAR POWER CORPORATION ,

4 BVY 99-54 Page 2 ,

If you have any questions regarding this matter, please contact Mr. Thomas B. Silko at (802) 258-4146.

l Sincerely, VERMONT YANKEE NUCLEAR POWER CORPORATION AMwn Robert J. W96c/>'k (/ g [,.. sM. l l Director of Santy and Regulatory Affairs //.{ 4 04l/Dg',s l STATE OF VERMONT )

)ss NOTAR)  ; .

WINDIIAM COUNTY )  !

• \ FUSUC  ;

Toen personally appeared before me, Robert J. Wanczyk, who being duly sworn, did sta ht.hDirecy f l Safety and Regulatory Affairs of Vermont Yankee Nuclear Power Corporation, that he is du prizedBTxecu '

and file the foregoing document in the name and on the behalf of Vermont Yankee Nuclear Po that the statements therein are true to the best of his knowledge and belief. gg/.,

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+ <d Sally A. Sandstrum, Notary Public My Commission Expires Februay 10,2003 Attachments: (as noted) cc: USNRC Region 1 Administrator USNRC Project Manager-VYNPS USNRC Resident Inspector-VYNPS Vermont Department of Public Service l

VERMONT YANKEE NUCLEAR POWER CORPOR ATION Docket No. 50-271 BVY 99-54 Attachment A Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 208 Section 6- Administrative Controls Supplemental Description and Bases for Changes

Vermont Yankea Nuclear Power Corp.

j Docket No. 50-271 ,

BVY 99-54, Attachment A Page 1 of 7 I

SUPPLEMENTAL DESCRIPTION AND BASES FOR CHANGES Attachment A to BVY 99-20, dated February 1,1999. provided the description and bases for the specific Technical Specification changes requested. Each proposed change was identified by an identifier number in brackets [ ]. The description and basis for items [2), [10), [17], [20), [23],

[30], [31], [32), [41), [43], [59), [61), [69] and [84] are hereby revised, and for completeness, are i replaced in their entirety as follows. j i

identifier Description and Basis j 2

[2] insert the following immediately after the Section 6.0 heading:

page 255 Section 6.0 6.1 RESPONSIBILITY A. The Plant Manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during absences.

B. The Plant Manager or designee shall approve, prior to implomentation, each proposed test, experiment, or modffication to systems or equipment that affect nuclear satiety.

1 C. The ShlN Supervisor shall be responsib!e for the control room command function. During any absence of the ShlN Supervisor from the control room while the unit is in plant startup or normal operation, an Individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function. During any absence of the ShlN Supervisor from the controlroom while the unitis in cold shutdown or tofueling with fuelin the reactor, an Individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.

This change provides a new section heading (6.1, " Responsibility") and additional requirements. The addition of a new heading is an administrative change of preference and does not chcnge any technical requirements.

The requirement to delegate succession of responsibility is relocated to revised Technical Specification 6.1.A from current Technical Specification (CTS) paragraph 6.1.B. (See item [6] below.)

Revised Technical Specification 6.1.B also adds the new requirement that the plant manager or the plant manager's designee is responsible for approving, prior to

F' Vermont Yankee Nuclear Power Corp.

Docket No. 50-271 BVY 99-54, Attachment A Page 2 of 7

[2] implementation, each test, experiment or modification to equipment or systems (cont.) affecting nuclear safety. This change ensures that the plant manager, or plant manager's designee, is aware of all changes having the potential to affect nuclear safety. Because the latter change adds additional requirements, it constitutes a more restrictive change.

Revised Technical Specification 6.1.C adds specificity to the responsibilities of the Shift Supervisor and retains the requirement in CTS Table 6.1.1 that a senior licensed operator be in the control room during plant startup and normal operation and either an SRO or licensed Reactor Operator be in the control room during cold shutdown or refueling with fuelin the reactor it also adds the requirement that during the absence of the Shift Supervisor from the control room, his/her qualified replacement be designated to assume the command function. Shift manning is  :

unaffected by this change; however, the additional specification concerning Shift Supervisor responsibilities represents a more restrictive change.

[10] Replace Specification 6.1.D.2 with the following new Specifications 6.2.B.1-4:

page 255 Section 1. A non-Ilconsed operator shall be assigned when the reactor 6.1.D.2 contains fuel and an additional non-Ilcensed operator shall be l assigned during Plant Startup and Normal Operation.

2. At least one licensed Reactor Operator (RO) or one licensed Senior Reactor Operator (SRO) shall be present in the control room when 1 fuelis in the reactor. l

3. When the unit is in Plant Startup or Normal Operation, at least one licensed Senior Reactor Operator (SRO) and one licensed Reactor Operator, gr two Ilcensed Senior Reactor Operators, shall be presentin the controlroom.

4. Shift crew composition shall meet the requirements stipulated herein andin 10 CFR 50.54(m). ShlN crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(l) and i Specifications 6.2.B.1 and 6.2.B.C for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shlN crew members provided immediate action is taken to restore the shlN crew composition to within the minimum ree;uirements.

Details of the minimum shift crew requirements and operator license requirements located in CTS 6.1.D.2 and Table 6.1.1 will be relocated to the Vermont Yankee Nuclear Power Station (VYNPS) Technical Requirements Manual (TRM). The minimum shift crew requirements for licensed operators and senior operators are also contained in 10CFR50.54(k), (1), and (m) and do not need to be repeated in the Technical Specifications to provide adequate protection of the public health and safety.

Vermont Yankee Nuclear Power Corp.

Docket No. 50-271 BW 99-54, Attachment A Page 3 of 7

[10) The relocation of details of the minimum shift crew requirements and operator license (cont.) requirements to the TRM is acceptable considering the controls provided by existing regulations, the remaining requirements of the Technical Specifications, and the FSAR and TRM change control program. Since the TRM is incorporated by reference into the FSAR. it is maintained under the FSAR change control program which strictly conforms to the provisions of 10CFR50.5g.

The minimum shift crew requirements for non-licensed operators (currently called

" Auxiliary Operstor" in CTS Table 6.1.1) are transferred from CTS Table 6.1.1 to revised Technical Specification 6.2.B.1. This is an administrative change since there is no change to technical requirements, but merely results in changes in nomenclature and format.

Revised Specification 6.2.B.2 contains minimum requirements for licensed operators and senior operators to be in the control room and retains the requirements contained in note (2) of CTS Table 6.1.1. This revised Technical Specification does not change any technical requirement, and as such, is an noministrative change l representing wording and formatting preferences.

Revised Technical Specification 6.2.B.3 retains the requirements contained in note (1) of CTS Table 6.1.1 for licensed operators in the control room during plant startup and normal operation. This revised Technical Specification does not change any technical requirement, and as such, is an administrative change representing wording preferences.

{

Revised Technical Specification 6.2.B.4 reinforces the minimum shift staffing requirements and provides for the conditional short-term absence of shift personnel.

10CFR50.54(m)(2)(i) contemplates temporary deviations from shift manning requirements for licensed personnel and provides flexibility in accordance with Technical Specifications. This Specification would allow temporary deviation from ,

shift manning requirements for licensed operators, non-licensed operators (see  !

revised Specification 6.2.B.1), and Shift Engineers (see revised Specification 6.2.B.8 and item [20) below). This temporary deviation from shift manning requirements for up to two hours provides for unexpected absences. Industry standards and NRC requirements now recognize the need for such provisions to allow for temporary j deviations of shift manning requirements for such personnel. This provision will have  !

an insignificant impact, if any, on plant safety since 10CFR50.54(m)(ii) and (iii) still require the presence of licensed operators and senior operators under appropriate operating conditions.

i Vermont Yankee Nuclear Power Corp.

Docket No. 50-271 BVY 99-54, Attachment A Page 4 of 7 )

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[17] (Not used-there '.s no change identified by this number.)

[20] in CTS Table 6.1.1 move the requirement for the Shift Engineer to new Specification page 257 6.2.B.8 and clarify its applicability. New Specification 6.2.B.8 is added as follows:

Section 6.1.D.2 8. While the unit is in Plant Startup or Normal Operation, the ShlN Engineer Table 6.1.1 shallprovide advisory technical support to the ShlN Supervisor (SS).

This change does not modify any requirement and rather clarifies the responsibilities of the Shift Engineer. As such, this is an administrative change representing wording and formatting preferences that do not represent technical changes (either actual or interpretational).

[23] Relocate CTS Section 6.2 from the Technical Specifications to the Vermont Yankee pages 258- Operatiot.01Quality Assurance Manual (VOQAM). The details of CTS 6.2.A (Plant 261 Operations Fwview Committee) and CTS 6.2.B (Nuclear Safety Audit and Review Section 6.2 Committee) do not need to be repeated in the Technical Specifications to provide adequate protection of the public health and safety. The review and audit activities performed by these committees are required by ANSI N18.7-1976. Additional audit requirements are contained in 10CFR50.54(p),10CFR50.54(t), Criterion XVill of Apoendix B to 10CFR50,10CFR73, and ANSI N45 ?-1971.

The relocation of these details to the VOQAM is acceptable considering the controle provided by existing regulations, the remaining requirements of Technical Specifications, and the quality assurance program. NRC Administrative Letter 95-06 provides guidance on the relocation of Technical Specification administrative controls related to quality assurance and advises that these review and audit requirements may be relocated to the quality assurance plan. Since changes to the VOQAM fall under a strict quality assurance change control process in accordance with 10CFR50.54(a), adequate controls are in place for future changes.

[30] (Not used-there is no change identified by this number.)

[31] (Not used-there is no change identified by this number.)

[32] Remove from Technical Specifications the introductory paragraph of CTS 6.5.B.

page 263 The requirements contained in CTS 6.5.B, related to the radiation protection Section program, will be relocated to the Vermont Yankee Operational Quality Assurance 6.5.B Manual (VOQAM). CTS 6.5.B requires procedures to be prepared for personnel radiation protection consistent with 10CFR20. These procedures are for nuclear plant personnel and have no impact on nuclear safety or tM health and safety of the public. Requirements to have procedures to implement 10tJ;N we contained in 10CFR20.1101(b). Periodic review of these procedures is addressed in 10CFR20.1101(c). Since these requirements are contained in the regulations, there is no need to repeat them in the Technical Specifications to provide adequate protection of the public health and safety. The relocation of these details to the

Vermont Yankee Nuclear Power Corp.

Docket No. 50-271 BVY 99-54, Attachment A Page 5 of 7

[32] VOQAM is acceptable considering the controls provided by existing regulations, the

- (cont.) remaining requirements of Technical Specifications, and the quality assurance program. Since changes to the VOQAM fall under a strict quality assurance change control process in accordance with 10CFR50.54(a), adequate centrols are in place for future changes.

(The following item [33] replaces the relocated introductory paragraph.)

[41] Remove CTS 6.5.C 6.5.D, and 6.5.E from the Technical Specifications. The details page 264 of procedure approval and temporary changes in CTS 6.5.C,6.5.D and 6.5.E will be Sections relocated to the Vermont Yankee Operational Quality Assurance Manual (VOQAM).

6.5.C The ability to relocate these requirements is based on regulations and standards that 6.5.D contain these provisions such that duplication in the Technical Specifications is 6.5.E unnecessary. The requirements for the establishment, maintenance, and implementation of procedures related to activities affecting quality are contained in 10CFR50, Appendix B, Criterion 11 and Criterion V; ANSI N18.7-1976 and ANSI N45.2-1971. In accordance with these requirements, the VOQAM will include adequate detail with respect to the administrative control of procedures related to activities affecting quality and nuclear safety. In addition, changes to the VOQAM will be controlled in accordance with the requirements of 10CFR50.54(a) to ensure proper reviews of activities affecting dafe operation of the plant. Additionally, NRC Administrative Letter 95-06 specifies that details regarding review and approval of proc,edures may be adequately addressed outside the Technical Specifications. The relocation of these details to the VOQAM is acceptable considering the controls provided by existing regulations, the remaining requirements of Technical l Specifications, and the quality assurance program. Since changes to the VOQAM fall j under a strict quality assurance change control process in accordance with i 10CFR50.54(a), adequate controls are in place for future changes. j l

[43) Remove CTS Section 6.6 " Plant Operating Records" from the Technical 1 pages 265- Specifications.

266 The details contained in CTS 6.6 are to be relocated to the Vermont Yankee Section 6.6 Operational Quality Assurance Manual (VOQAM). The requirement for retention of records related to activities affecting quality is contained in 10CFR50, Appendix B, Criterion XVil and other sections of 10CFR50 that are applicable to VYNPS (i.e.,

10CFR50.71,10CFR73, etc.). These record retention requirements provioe a record  !

of certain activities important to plant safety, but the records themselves do not  ;

assure safe operation of the facility since review of these records is a post-  !

compliance review. Relocation of these Technical Specifications provisions to the j VOQAM will provide adequate controls over record retention requirements for i VYNPS. The VOQAM will be revised to contain adequate detail with respect to these requirements to ensure record-keeping is implemented in an appropriate manner. As such, the relocated details do not need to be duplicated in the Technical Specifications to provide adequate protection of the public health and safety. The relocation of these details to the VOQAM is acceptable considering the controls provided by existing regulations, the remaining requirements of Technical ,

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Vermont Yankee Nuclear Power Corp.

Docket No. 50-271 BVY 99-54, Attachment A Page 6 of 7

[43] Specifications, and the quality assurance program. Since changes to the VOQAM fall (cont.) under a strict quality assurance change control process in accordance with 10CFR50.54(a), adequate controls are in place for future changes.

[59] Relocate CTS Section 6.7.C.1 intact to the Offsite Dose Calculation Manual and  !

pages replace it with the following (after the new heading as described in item (58) above):

270a-272 Section The Radioactive EMuent Release Report covering the operation of the 6.7.C.1 unit shall be submitted by May 15 of each year and in accordance with 10 CFR 50.36a. The report shallinclude a summary of the quantitles of radioactive IIquid and gaseous eMuents and solid waste released from the unit. The materialprovidedshall be consistent with the objectives outilnedin the Offsite Dose Calculation Manual (ODCM) and Process Control Program andin conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

CTS 6.7.C.1.a and 6.7.C.1.b provide requirements concerning the annual submittal of a report regarding radioactive effluents.10CFR50.36a already contains the requirement for annually reporting radionuclide releases. The CTS is therefore duplicative in nature. This change imposes a more restrictive requirement that this i report be consistent with the objectives outlined in the ODCM and be submitted per relevant sections of 10CFR50. The revised Specification now prescribes a submittal date (i.e., no later than May 15) for the Radiological Effluent Release Report that is consistent with acceptable industry practice. These requirements are also based on NRC Generic Letter 89-01 regarding the removal of Radiological Effluent Technical Specifications from the Technical Specifications. The relocation of these details to the ODCM is acceptable considering the controls provided by existing regulations and the controls remaining in Technical Specifications for ODCM changes.

[61) (Not used-there is no change identified by this number.)

(69] Remove CTS 6.8, " Fire Protection inspection from the Technical Specifications.

page 276 CTS 6.8 establishes requirements regarding periodic external inspections and audits Section 6.8 of fire protection activities. These audit requirements are to be relocated to the Vermont Yankee Operational Quality Assurance Manual (VOQAM). These activities are not required to assure safe operation of the unit; rather, they are post-compliance audit functions subject to review, but not approval. Accordingly, the details to be relocated are not required to be in the Technical Specifications to provide adequate protection of the public health and safety. The relocation of these details to the VOQAM is acceptable considering the controls provided by existing regulations, the remaining requirements of Technical Specifications, and the quality assurance program. Since changes to the VOQAM fall under a strict quality assurance change control process in accordance with 10CFR50.54(a), adequate controls are in place for future changes.

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Vermont Yankee Nuclear Power Corp.

Docket No. 50-271  !

BVY 99-54, Attachment A Page 7 of 7 l

[84] The changes identified in item [84] have resulted from the extensive changes to pagesI, Technical Specifications Section 6 as described above. As a consequence, 5,55, conforming changes are necessary to these other sections of the Technical j 145a,182, Specifications that are affected by the changes to Section 6. These additional 184,191, changes to the Technical Specifications add consistency within the Technical 192,201, Specifications, remove references to Specifications no longer remaining in the 208,227 Technical Specifications, and revise the designation of references to Section 6 to reflect the changes. These conforming changes are purely administrative in nature Sections: and do not constitute changed technical requirements.

TOC,1.0, Table 3.2.6, Bases 3.6 &

l 4.6, '

Table 4.8.1, Table 4.8.2, 4.9.D, 4.9.E, Table 3.9.3, Table 4.9.3, Bases 3.11 i i

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i VERMONT YANKEE NUCLEAR POWER CORPORATION l Docket No. 50-271 !

BVY 99-54 l i

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l Attachment B Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 208 i

Section 6- Administrative Controls Listing of Affected Technical Specification Pages l

Vepcont Yankee Nuclear Power Station Dockv No. 50-271 BVY 99 54, Attachment B Page1ofI l

Listine of Affected Technical Snecifications Pares Replace the Vermont Yankee Nuclear Power Station Technical Specifications pages listed below with the revised pages in Attachment D. The revised pages contain vertical lines in the left margin indicating the areas of change.

Remove Insert Remove Insert i i 263 263 5 5 264 264 55 55 265 265 145a 145a 266 266 182 182 267 267 l

184 184 268~ ---

191 191 269 ---

192 192 270 ---

201 201 270a ---

208 208 271 --

227 227 272 ---

255 255 273 --

256 256 274 ---

257 257 275 ---

258 258 276 ---

259 259 277 ---

260 260 278 ---

261 261 279 ---

262 262 i

Notes:

1. Technical Specifi:ations Section 6," Administrative Controls," is being replaced in its entirety. Due  ;

to these changes, current pages 255 through 279 are being revised with pages 255 through 267.

2. For the sake of completeness, this listing encompasses all of the pages being changed under Proposed f i

Change 208, as supplemented. j f

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VERMONT YANKEE NUCLEAR POWER CORPORATION Docket No. 50-271 BW 99-54 Attachment C Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 208 Section 6 - Administrative Controls Supplemental Marked .Up Technical Specifications Pages Notes:

1. The attached pages only replace pages of the same page number, which were previously submitted as Proposed Change 208, BW 99-20, dated February 1,1999.

Not all of the pages previously submitted are affected by this supplement; consequently, they are not being re-submitted, but remain part of this Proposed Change.

2.' Due to the issuance of license amendments 167 and 168, certain marked-up pages provided by BW 99-20, dated February 1,1999, are being replaced with the attached.

The affected pages are numbered 5,256,259,262,270,270s, and 275. In addition,

. marked-up pages 240,241,242,245,246, and 247 that were provided as part of BW 99-20 should be deleted from this change package since the administrative changes requested to these'pages are now unnecessary as a result of amendment 168.

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