ML20206B140

Forwards Replacement of Section 3(a) of NSHC Determination Provided by Re TS Proposed Change 208,suppl Section 6

ML20206B140
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/23/1999
From:	Wanczyk R VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-99-61, NUDOCS 9904290165
Download: ML20206B140 (4)

Text

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VERMONT YANKEE y NUCLEAR POWER CORPORATION

'185 Old Ferry Road, Brattleboro, VT 05301 7002 (802) 257-5271 April 23,1999 BVY 99-61 U. S. Nuclear Regulatory Commission ATrN: Document Control Desk Washington, D.C. 20555

References:

(a) Letter, VYNPC to USNRC, " Technical Specifications Proposed Change No. 208 -

Section 6 - Administrative Controls," BVY 99-20, dated February 1,1999.

(b) Letter, VYNPC to USNRC, " Technical Specifications Proposed Change No. 208 -

Supplement Section 6 - Administrative Controls," BVY 99-54, dated April 19,1999.

Subject:

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

Technical Specifications Proposed Change No. 208 - Supplement to NSHC Section 6 - Administrative Controls

<l By Reference (a), as supplemented by Reference (b), Vermont Yankee (VY) requested that Facility Operating License DPR-28 be amended to incorporate certain changes to Section 6 of the Technical Specifications.

Reference (b) noted one change to the determination of no significant hazards consideration (NSHC) provided by Reference (a). That change deals with the relocation of certain Technical Specifications requirements to the Vermont Yankee Operational Quality Assurance Manual (VOQAM), as an additional licensee-controlled document for relocation of Technical Specifications provisions. In this regard, and for the sake of completeness, the Attachment to this letter provides a replacement of Section 3(a) of the NSiiC determination provided by Reference (a).

l Section 3(a) provides detailed safety considerations regarding the relocation of Technical Specifications requirements to licensee-controlled documents. The No Significant Hazards Consideration determination provided by Reference (a) and reaffirmed by Reference (b) remains valid with the replacement of Section 3(a).

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BVh 99-61 )Pa;;e 2 If you have any questions regarding this matter, please contact Mr. Thomas B. Silko at (802) 258-4146.

Sincerely, VERMONT YANKEE NUCLEAR POWER CORIORATION Robert J. Wpc/yk VU 4 Director of SVety and Regulatory AfTai -

STATE OF VERMONT ) j ,y ' y F.3L!:0"ll%'%

)ss 6 p/  % ;A,'k WINDHAM COUNTY ) 7 gg7;g: 9 "Y Then personally appeared before me, Robert J. Wanczyk, who being duly sworn, fi stah thQis;Dinoctop-or Safety and Regulatory Affairs of Vermont Yankee Nuclear Power Corporation, that duhputhorfzed tefexpt

, and file the foregoing document in the name and on the behalf of Vermont Yankee b ' PohCorp6~ ratio @

l that the statements therein are true to the best of his knowledge and belief.

4/ff CG;igt .ap f

u-- JC Sally A. Sandstrum, Notary Public My Cornmission Expires February 10,2003 Attachment cc: USNRC Region I Administrator USNRC Project Manager- VYNPS USNRC Resident inspector-VYNPS Vermont Department of Public Service r

. . .o Yl:H%l(INT YANiil:l; .W(:1.1;AH l'4 pwl;H CE)ltlat)HAl tipN BVY 99-61/ Attachment / Page I of 2 3(a) Changes which are deemed to be "less restrictive" based solely upon removal from the Technical Specifications and relocated la VYNPC-controlled documents:

NRC's Technical Specifications Branch has conducted reviews of the Administrative Controls section of Standard Technical Specifications and concluded that certain provisions historically contained in Technical Specifications can be relocated to other licensee documents for which changes to those provisions are adequately controlled by other regulatory requirements. In general, Administrative Controls are those requirements not covered by other Technical Specifications, but are considered necessary to assure operation of the facility in a safe manner. Application of this criterion can be based on two categories or requirements: (a) requirements not covered by other regulatory requirements, but are considered necessary to assure the safe operation of the facility or (b) specific (cquirements that are broadly covered by regulations or other regulatory controls, for which details need to be specified in the Technical Specifications to ensure safe plant operation. In general, however, Technical Specifications need not duplicate other regulatory requirements.

As identified in Attachment A hereto, certain portions of the current Technical Specifications are to be relocated to the Technical Requirements Manual (TRM), Offsite Dose Calculation Manual (ODCM), or the Vermont Yankee Operational Quality Assurance Manual (VOQAM) and removed from the Technical Specifications. As an initial step in this process, the subject requirements are being duplicated in the TRM, ODCM, or VOQAM. Removal from the Technical Specifications will occur upon NRC approval. The ability to relocate these requirements is based on regulations and standards that contain these provisions such that duplication in the Technical Specifications is not necessary.

The TRM is a FSAR level document and is incorporated by reference into the FSAR.

Changes to the TRM will be strictly controlled by the 10CFR50.59 process to ensure that proper reviews are conducted. The relocation of requirements to the VYNPC-controlled TRM will not diminish the effectiveness of compliance with the relocated provisions. Since any changes to the TRM will be evaluated per the requirements of 10CFR50.59, no increase (significant or insignificant) in the probability or consequences of an accident previously analyzed will be allowed. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Changes to the ODCM are controlled by current Technical Specifications and require the reposting to the NRC of changes to the ODCM with sufficient information to support the  !

changes together with appropriate analyses or evaluations justifying the changes. The relocation of these details to the ODCM is thus acceptable considering the controls provided by existing regulations and the controls remaining in Technical Specifications for ODCM changes. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Relocation of Technical Specification Administrative Controls related to quality assurance from the Technical Specifications to the VOQAM is consistent with the guidance provided by the NRC in Administrative Letter 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance." Changes to the VOQAM are subject to the change control process in 10CFR50.54(a). These provisions are adequate to ensure that quality assurance program commitments are not reduced without prior NRC approval.

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l* VI'HMON1 YANhl.l'. NITI 12.AH l' owl H COMPOH AllON l BVY 99-61/ Attachment / Page 2 of 2 Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

De proposed changes do not involve any physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods goveming normal plant operation. The proposed change will not impose or eliminate any requirements, and adequate control of the information will be maintained. nus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumption. In addition, the details to be transpesed from the Technical Specifications to the TRM, ODCM, and VOQAM are the same as the existing Technical Specifications. Since any future changes to these provisions in the TRM will be evaluated per the requirements of 10CFR50.59, and Technical Specifications already requires supporting information be submitted to the NRC for ODCM changes, no reduction (significant or insignificant) in a margin of safety will be allowed. The provisions of 10CFR50.54(a) are adequate to control changes to the VOQAM and maintain current margins l of safety.

Based on 10CFR50.92, the existing requirement for NRC review and approval of revisions (to the Technical Specifications provisions proposed for relocation) does not have a specific I margin of safety upon which to evaluate. However, since the proposed changes are l consistent with industry standards, approved by the NRC, revising the Technical Specifications to relocate these pmvisions will not diminish administrative controls necessary i to assure the safe operation of the facility, i i

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