ML20206B918

Application for Amend to License DPR-3,requesting That Characterization of Revised Review & Audit Function Remain in Plant Defueled TS Rather than Being Transferred to Plant QA Plant

ML20206B918
Person / Time
Site:	Yankee Rowe
Issue date:	04/23/1999
From:	Desiree Davis YANKEE ATOMIC ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206B920	List: ML20206B918 ML20206B921
References
RTR-NUREG-1625 BYR-99-029, BYR-99-29, NUDOCS 9904300122
Download: ML20206B918 (4)

Text

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l Telephons(S08) 568-2233 YANKEEATOMICELEChilC COMPANY  %"E* L2CL

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lar 580 Main Street. Bolton, Massachusetts 01740-1398

v. 1 DON K. DAVIS CHIEF CUT 1 RCER April 23,1999 BYR 99-029 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

References:

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

(b) Letter, D. Davis, YAEC, to M.B. Fairtile, USNRC, " 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", BYR 99-001, March 17,1999 (c) NUREG-1625," Proposed Standard Technical Specifications for Permanently Defueled Westinghouse Plants", USNRC, March 1998

Subject:

Amendment of a Yankee Atomic Energy Company (Y AC) Regmot for Modification Of Yankee Nuclear Power Station's (YKrs) Defueled Technical Specifications In Reference (b), pursuant to 10 CFR Section 50.90 of the Commission's Rules and l Regulations, YAEC requested NRC approval of the following modifications to the YNPS l Defueled Technical Specifications: 1

1. Elimination of the positions of Manager of Operations and Plant Superintendent and assignment of the responsibilities of these positions to the i YAEC Decommissioning Manager; 1

2. Replacement of the review and audit functions performed by the Plant i Operation Review Committee (PORC) and the Nuclear Safety Audit and Review Committee (NSARC) with an Independent Safety Review and an 0 \

Independent Review and Audit Committee modeled directly on the approach endorsed by the NRC in Section 5.5 of NUREG-1625 (Reference (c));

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9904300122 990423 PDR ADOCK 05000029 W PDR _

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United States Nuclear Regulatory Commission April 23,1999 Attention: Document Control Desk Page 2 l 3. Transfer of the description of the activities and the responsibilities of the l review and audit function from the YNPS Defueled Technical Specifications to

!, the Yankee Decommissioning Quality Assurance Program (YDQAP). I

! l YAEC wishes to amend Reference (b) by retracting Item 3, the transfer of the description I

, of the activities and the responsibilities of the review and audit function from the YNPS

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Defueled Technical Specifications to the YDQAP; the proposed modification summarized briefly in Item 2 would be incorporated in the YNPS Defueled Technical Specifications.

l- MODIFICATION OF PROPOSED CHANGES All of the detailed changes to the YNPS Defueled Technical Specifications noted in Reference (b) which are necessary to eliminate the positions of Manager of Operations  !

l and Plant Superintendent (item 1 above) are unaffected by this amended request.  ;

The description in Section 6.5 of the YNPS Technical Specifications of the review and L audit functions performed by PORC and NSARC will be replaced with a new review and  !

l audit function to be implemented through an Independent Safety Review (ISR) and an I

. Independent Review and Audit Committee (IRAC). As noted above, this approach is modeled directly on Section 5.5 of the NRC's NUREG-1625 (Reference (c)). The YAEC ]

l proposal differs in only the following respects: l L

1, Section 5.5.1 of NUREG-1625 states: "An Independent Safety Review shall

be a thorough review conducted by a qualified independent Safety Reviewer."

YAEC has modified this statement to read: "An Independent Safety Review  !

shall be a thorough review conducted by one or more qualified Independent l Safety Reviewers." The reason for this change is that there is the possibility l that certain issues might be sufficiently complex to benefit from a i multidisciplinary review rather than relying on the expertise of a single reviewer.

l 2. Section 5.5.1 b. ofNUREG-1625 states:"In& pendent Safety Reviewers shall  !

j' '

have at least 5 years of professional expei en.e and either a Bachelor's Degree '

in Engineering or the Physical Sciences or shall have equivalent qualifications ;

in accordance with ANSI /ANS-3.1-1981." YAEC has modified this statement I to read: " 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 L ANSI 18.1-1971." The citation of ANSI 18.1-1971 is intended to provide I consistency with the personnel qualification requirements currently stated in l

YNPS Defueled Technical Specification Sections 6.3 and 6.4.

3. All references in Section 5.5 of NUREG-1625 to responsibilities of the Plant Superintendent have been replaced in YAEC's proposal with references to the  !

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l United States Nuclear Regulatory Commission April 23,1999 L Attention: Document Control Desk Page 3 l

l Decommissioning Manager. This is consistent with the proposed change deleting the positions of Plant Superintendent and Manager of Operations and assigning the responsibilities of these positions to the Decommissioning Manager.

4. Section 5.5.1 c. 2. of NUREG-1625 indicates that among the subjects to be independently reviewed by a qualified Independent Safety Reviewer are

" proposed changes to the programs required by Specification 5.7.2, 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 10 CFR 50.59".

(Specification 5.7.2 in NUREG-1625 deals exclusively with the Process l Control Program.) In YAEC's proposal, the scope of this requirement to review proposed program changes has been expanded to encompass all of the programs required by YNPS Defueled Technical Specification Section 6.7.

As originally noted in Reference (b), the modification of the review and audit function as described in Section 6.5 will necessitate minor revisions of Technical Specification Sections 6.6.1 b,6.7.2,6.7.3,6.7.4 c,6.12.1 b, and 6.13.1 b. References to PORC and NSARC are deleted and, as appropriate, references to the new review and audit functions to be performed by the ISR and IRAC are introduced.

l l To summarize, this amendment of the change request in Reference (b) simply seeks to l retain the modified review and audit function in the YNPS Defueled Technical Specifications and eliminate the request that this material be transferred to the YDQAP.

An annotated version of the present YNPS Defueled Technical Specification pages is provided in Attachment I to this letter. The proposed new pages of the Technical Specifications are provided in Attachment II. These attachments supercede Attachments II and III of Reference (b).

I REASON AND BASIS FOR CHA.NGE The reason and basis for change put forth in Reference (b) remains essentially unchanged. This amendment simply requests that the characterization of the revised review and audit function remain in the YNPS Defueled Technical Specifications rather than being transferred to the YDQAP. This minor administrative change to the original submittal is intended to simplify and expedite review and approval of the substantive elements of the proposed change.

SIGNIFICANT HAZARDS CONSIDERATION The evaluation provided in Reference (b) remains completely valid.

United States Nuclear Regulatory Commission April 23,1999 Attention: Document Control Desk Page 4 ENVIRONMENTAL IMPACT DETERMINATION The evaluation provided in Reference (b) remains completely valid.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY

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Don K. Davis, Chairman President and CEO Attachments C: USNRC, Region 1 M.B. Fairtile 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.

Wnunn klnumA Miaurien E. Maynard N6tary Public My Commission Expires August 28,2003

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