ML20210F369

Submits Response to NRC Request for Clarification of Certain Details of Yaec Proposed Mods to Yankee Nuclear Power Station Defueled TS

ML20210F369
Person / Time
Site:	Yankee Rowe
Issue date:	07/21/1999
From:	Atkins M YANKEE ATOMIC ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BYR-99-051, NUDOCS 9907300097
Download: ML20210F369 (3)

Text

' YANKEE ATOMIC ELECTRIC COMPANY 2'C,",'yyj %'%%

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Lp y. Suite 200,19 Midstate Drive, Aubum, Massachusetts 01501 Y m ,me . 1

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1 July 21,1999 BYR 99-051

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United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 l

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References:

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

(b) letter, D. Davis, YAEC, to M. B. Fairtile, USNRC, " Amendment of a Yankee Atomic Energy Company (YAEC) Request for Modification of Yankee Nuclear Power Station's (YNPS) Defueled Technical Specifications," BYR 99-029, dated April 23,1999 (c) NUREG-1625," Proposed Standard Technical Specifications for Permanently Defueled Westinghouse Plants", USNRC, March 1998 i (d) Letter, M.K. Webb, USNRC, to M.J. Meisner, MYAPC, dated I March 30,1998

Subject:

Additional Information Concerning Yanke-e Atomic Electric Company's Request for Modification of Administrative Elements of Yankee Nuclear Power Station's Defueled Technical Specifications O

In Reference (b), Yankee Atomic Electric Company (YAEC) requested a modification of Yankee Nuclear Power Station's Defueled Technical Specifications to eliminate references to the positions of Manager of Operations and Plant Superintendent and to assign the responsibilities of these positions to the YAEC Decommissioning Manager.

The requested modification also proposes to replace the review and audit functions performed by the Plant Operation Review Committee (PORC) and the Nuclear Safety

^0 0 Audit and Review Committee (NSARC) with an Independent Safety Review function and an Independent Review and Audit Committee modeled on References (c), and (d). As noted in Reference (b), YAEC believes that the responsibilities of the proposed review and audit function will encompass the majority of the functions currently performed by the PORC and the NSARC with selected functions modified to be consistent with the 9907300097 990721 l

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. Unit:d States Nuclear Regulatory Commission July 21,1999 J

, A,ttention: Mr. Morton Fairtile Page 2 i

scope of activities at a permanently defueled facility which is in an advanced stage of i decommissioning.

As a result of the NRC staff's review of the proposed modification of the YNPS Defueled j Technical Specifications, clarifi, cation of certain details of the YAEC proposal have been

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requested. As a result YAEC now provides the following points of clarification.

1. Yankee has modified the YDQAP to be compatible with the proposed Technical Specification changes in Revision 29 of the Quality Assurance Program which was '

submitted to the NRC on July 9,1999. Yankee will further revise the YDQAP,if required, following receipt of the NRC approved Tech. Spec. Amendment. Any required changes to YDQAP will be in accordance with 10CFR50.54a. It is anticipated that these additional changes will be provided to the Commission in Revision 30 to the YDQAP.

2. Yankee has committed to ANSI 18.7 (1976). Yankee will ensure independence through explicit administrative controls. These controls will be comparable to the controls currently in place to ensure the appropriate independence of members of 1 PORC and NSARC. The Decommissioning Manager (or his designee) will be j responsible for the assignment of personnel to perform the IR function. The Decommissioning Manager and the members ofIRAC report to the President of YAEC.

3. ANSI 18.7 requires compliance with all 18 Criteria in 10CFR50 Appendix B. YAEC currently complies with and will continue to meet all Appendix B requirements as i applicable to a defueled facility in an advanced stage of decommissioning.

4. Revised Technical Specification Section 6.5.2 indicates that the IRAC advises the i President of YAEC. Section 6.5.2(e) requires the IRAC to advise the i Decommissioning Manager. The IRAC is responsible for advising both the i Decommissioning Manager and the President of YAEC. There is an additional requirement that in the event of a disagreement between the IRAC and the j Decommissioning Manager concerning a safety issue, the President of YAEC is to be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and is the ultimate authority concerning resolution of the issue.

5. ANSI 18.7 lists 10 disciplines required by the IRAC while Section 6.5.2(b) only lists

5. This is consistent with the guidance provided in NUREG-1625 and the expertise will be sufficient based on the current risks YAEC. There are no longer any safety-related structures, systems and components at the facility. Maintainine, spent fuel radiological safety is the key area of risk at YNPS and thus the IRAC should maintain expertise consistent with these risks. The proposed membership and expertise of the IRAC is consistent with this philosophy.

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.. 1 L . United St tes Nuclear Regul

tory Commission July 21,1999 i: Attention: Mr. Morton Fairtile Page 3

6. Section 6.5.l(b) allows YAEC to determine an equivalent to a Bachelor of Science.

I' Standards for equivalency will be addressed in appropriate administrative controls.

These standards will be based on the guidance provided in ANSI 18.1-1981 concerning this specific issue.

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D .7. ANSI 18.7 requires IRAC to address reportable events. Section 6.6.l(b) of the proposed Technical Specification modification requires that "Each REPORTABLE EVENT shall be reviewed by the IRAC and the results of this review shall be submitted to the Decommissioning Manager."

i If you have any questions concerning the responses provided above, please contact me at (978)568 - 2156.

L t-Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY

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fff -f A Merrill J. Atkins Decommissioning Licensing Manager

'C: USNRC, Region I M.B. Fairtile I

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