ML20210M580

Application for Amend to License DPR-36,consisting of TS Change 206,revising TS Re Facility Staffing & Training

ML20210M580
Person / Time
Site:	Maine Yankee
Issue date:	08/15/1997
From:	Meisner M Maine Yankee
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20210M584	List: ML20210M580 ML20210M587
References
MJM-97-11, MN-97-96, NUDOCS 9708220046
Download: ML20210M580 (7)

Text

I d' - vy, a MaineYankee EELIABLE ELECTRICITY SINCE 1972 e

329 BATH ROAD

• BRUNSWICK. MAINE 04011 * (207) 798-4100 August 15, 1997 MN 97-96 MJM 97-11 Proposed Change No. 206 UNITED STATES NUCLEAR REGULATORY COMMISSICIN Attention: Document Control Desk Washington, DC 20555

Reference:

(a) License No. DPR-36 (Docket No. 50 309)

(bl Letter: M. B. Sellman to USW: Certifications of Permanent Cessation of Power Operation and Permanent Removal of Fuel From the

% actor: MN-97 89, dated August 7, 1997 (c) Letter: M. J. Meisner to USNRC: Certified Fuel Handler Training and Retraining Program; MN-97-95, dated August 15, 1997

.(d) Letter: M. J. Meisner to USNRC: Request for Exemption from Certain Remirements of 10CFR50.54 Conditions of License: MN-97-97, dated August 15, 1997.

Subject:

Proposed Technical Specification Change No. 206 - Facility Staffing and Training Gentlemen:

In Reference (b), Maine Yankee informed the USNRC that the Board of Directors of Maine Yankee had decided to permanently cease operations at'the Maine Yankee Plant and that fuel had been permanently removed from the reactor. In accordance with 10CFR50.82(a)(2),

the certifications in the letter modified the Maine Yankee license. to permanently withdraw Maine Yankee's authority to operate. As a result, Maine Yankee is only authorized to possess special nuclear material.

Maine Yankee has determined that plant operating activities which require Licensed and Senior Licensed Operators will no longer be conducted. Therefore, Maine. Yankee hereby submits, pursuant to 10 CFR Parts 50.90, this application to amend the. Technical Specifications by revising the facility staffing and training requirements. This application is being submitted in concert with other separately filed requests including Reference (c), a request for approval of a certified fuel handler training and retraining program, and Reference (d), a request for exemption pursuant to 10 CFR 50.12.

The proposed Technical Specification changes are similar to those submitted and/or approved for other NRC licensees such as: Trojan Yankee Rowe, San Onofre 1. Connecticut Yankee and Rancho Seco.

A description of the proposed change and a sumary of the Significant Hazards Evaluation are presented in Attachment A. As discussed in the attachment, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any_ accident previously evaluated, or involve a significant reduction in the margin of safety. Based on our evaluation, we conclude there is reasonable assurance that the Maine Yankee plant activities, consistent with the proposed Technical Specifications, i will not impact the health and safety of the public.

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Attentioni Document Control Desk Page Two-Revised Technical Specification Pages 5.2-1 through 5.2 3. 5.3-1. 5.4-1 and 5 8 3 through 5.8-4 are included as Attachment B.

This' proposed change has been reviewed and approved by the Plant Operation Review-Committee, The Nuclear Safety - Audit and Review Committee has also reviewed this submittal. - A representative of the State of Maine is being informed of this request by a' copy of this letter.

We request this proposed change be made effective imediately upon issuance:

V y truly urs, j 1 -

M ael J. Meisner Vice President N. r Safety & Regulatory Affairs-c; Mr. Hubert Miller Mr. D. H. Dorman Mr. J. T. Yerokun Mr. Clough Toppan L Mr; Patrick.J.-Dostie Mr; Uldis Vanags

. STATE OF MAINE Then; personally appeared before me, Michael J. Meisner, who being duly sworn did state that he is:the Vice President. Nuclear Safety & Regulatory Affairs of Maine Yankee AtomicLPower Company, that he is duly authorized to execute and file the foregoing

< request in the name and on the behalf of Maine Yankee Ato;nic Power Company, and that.

-the statements therein are true to the best of~his knowledge'and belief.

Notary Public US Nuclear Regulator Comission Attn:LDocument Control Desk -

Washington, DC 20555 -

Monic1W. Fortler, Notary Public Stato of Mdna My Cbmmisclan r.xp;rea 5/3/98

ATTACHMENT A Page 1 of 5 DESCRIPTION AND SIGNIFICANT HAZARDS EVALUATION OF

- PROPOSED CHANGE NO. 206 BACKGROUND Maine Yankee Atomic Power Company (MYAPC) has decioed to cease further operation of the Maine Yankee Nuclear Plant. As such, Maine Yankee has submitted by Reference (b) a

] certification of pcrmanent cessation of operations and a certification of permanent removal of fuel in accordance with 10CFR50.82(a)(2).

The current regulations in Parts 50 and 55 of Title 10 of the Code of Federal Regulations (10 CFR 50 and 55) provide, in part, rules governing the training, qualification and staffing requirements for licensed operators. These requirements assume licensed operators would be controlling an operating facility that would experience transients and malfunctions from routine startup through full power operations.

In the defueled condition, there are no longer any credible design basis accidents associated with an operating plant f rom startup through full power operation. The design basis accidents relative to a defueled facility are a small subset of those considered for an operating facility. This subset of design basis accidents would include the following: Fuel Handling Incident Spent Fuel Cask Drop and Radioactive Liquid Waste System Leaks and Failures. The operators will primarily monitor and maintain the spent fuel storage facility to ensure that the public health and safety are not compromised. As such, the operators do not require training and qualification in areas that would be of benefit only during power operations. In light of this, Maine Yankee is subinitting, separately, a certified fuel handler training and retraining program for Nuclear Regulatory Commission (NRC) approval. This program will provide the training necessary for operators at a defueled facility. In this application, Maine Yankee is proposing to revise selected portions of Technical Specification Section 5.0, Administrative Controls, to define the facility staffing rid training requirements for a defueled facility.

In order to make the changes proposed herein, it has also been determined to be necessary to obtain an exemption in accordance with 10 CFR 50.12. Specific Exemptions, from specific provisions to 10 CFR 50.54, Conditions of Licenses.

DESCRIPTION AND REASON FOR SPECIFIC CHANGES The proposed changes to the Maine Yankee Technical Specifications are as follows:

1. Section 5.2.1 Onsite and Offsite Organization Subsection d. - The references to " operating staff" and "cperating responsibilities" have been reworded to relate to the certified fuel handlers and the non-operating condition of the plant.

2. Section 5.2.2. Facility Staff, Subsection a. - Table 5.2-1. Minimum Operating Shift Crew Composition - The minimum operating shift crew composition is being revised to indicate the position requirements for a permanently defueled condition. A shift manager and a non-certified operator will be required on each crew. Since the plant will not be operating, there is no longer a need

v Page 2 of 5 for licensed operators. This table is not consistent with the minimum staffing requirements found in 10 CFR 50.54(m).

=. therefore, this proposed change is being submitted in concert with a request for exemption pursuant to 10 CFR 50.12. A footnote has been added to the table indicating - that the minimum shift crew composition represents a specific exemption to 10 CFR 50.54(m). The title to this table has been revised to delete the word " operating" since the plant will no longer be operating.

3. Section 5.2.2. Facility Staff. Subsection b. - The wording is being revised to require one individual qualified to stand watch in the control room be in the control room when fuel is in the spent fuel pool. The control room watch can be either a non-certified operator or a certified fuel handler. Since the reactor will not be operated there is no need for an operator licensed in accordance with 10 CFR 55.

4. Section 5.2.2. Facility Staff. Subsection c. - This subsection requires two licensed operators to be in the control room for certain evolutions. Since these evolutions will no longer be conducted. this requirement is being eliminated,

5. Section 5.2.2. Facility Staff. Subsection e. - This subsection addresses supervision requirements during CORE ALTERATIONS. Since CORE ALTERATIONS will no longer occur due to the reactor being defueled, the requirement is-being revised to state that fuel handling operations shall be directly . supervised by a certified fuel handler. This change will ensure fuel handling is performed under qualified supervision. A definition of fuel handling operations is being added.

6. Section 5.2.2. Facility Staff. Subsection g. - This subsection is being revised to eliminate the requirement for a Shift Technical Advisor, since a Shift Technical Advisor is not required for a defueled reactor. A statement is added to this subsection requiring the Shift Manager to be a certified fuel handler.

In addition, a sentence is being added to this subsection to indicate that an operator holding a license as a Senior Reactor Operator in accordance with 10 CFR 55 is qualified as a certified fuel handler. This prcvision will allow-senior licensed operators to fill the certified fuel-handler positions until the certified-fuel handler training and retraining program is implemented and personnel are trained.

7. Section 5.2.2. Facility Staff. Subsection h. - This subsection dictates which positions required operator licenses. This subsection is being revised to eliminate the operator licenses and to require the Shift Manager to report to an individual who is qualified as a certified fuel handler.

8. Section 5.2.2. Facility Staff. Subsection i. - This section is being revised to delete the reference to subsection g of Section 5.2.2 which is being deleted.

9. Section c 3. Facility Staff Qualifications. Subsection 1.a. - This subsection establishes qualification requirements for a Shift Technical Advisor. This

Page 3 of 5 subsection is being deleted since a Shift Technical Advisor is not required for a defueled reactor.

10. Section 5.3. Facility Staff Qualifications, Subsection 1.b. - This subsection establishes qualification requirements for a combined Senior Reactor Operator / Shift Technical Advisor (SR0/STA). This subsection is being deleted since licensed cperators and Shift Technical Advisors are not required for a defueled reactor.

11. Section 5.3, Facility Staff Qualifications. Subsection 1.d. - This subsection is being revised to eliminate the reference to Section 5.2.2. subsection (h) related to the Senior Reactor Operator license requirements for Operations Department management personnel, since these requirements were eliminated.

Remaining facility staff members will meet or exceed the qualifications in Regulatory Guide 1.8 - September 1975 unless other wise noted in the Techncial Specifications. Once the Reactor Operator and Senior Reactor Operator Licenses are terminated, any references to Operator Licenses in RG 1.8 - 9/75 or ANSI ,

N18.7 - 1971 will not apply to Maine Yankee.

12. Section 5.4. Training Subsection 1. - This subsection is being revised to eliminate the requirement for a retraining and replacement training program in accoraarce with Section 5.5 of ANSI N18.1-1971 and 10 CFR 50 and 55 and instead a NRC app;oved certified fuel handler training and retraimng program will be conducted.

13. Section 5.8, Programs and Procedures. Subsection 4 b. - This subsection is being revised to require a Shift Manager to approve temporary changes to pr]cedures rather than a Senior Reactor Operator.

14. Section 5.8, Programs and Procedures, Suu3ection 5 - The applicability of this subsection is being revised to apply to personnel whose functions are important to the safe storage of irradiated fuel assemblies rather than those who perform safety-related functions. References to extended shutdown periods and refueling are being deleted since they no longer apply. >

SIGNIFICANT HAZARDS EVALUATIQM The proposed change to the Technical Specifications, has been evaluated against the star.dards of 10 CFR 50.92 and has been determined to not involve a significant hazards consideration. The proposed change does not:

1. Involve a significant increase in the probability or consequence of an accident previously evaluated.

The purpose of the proposed change is to eliminate the requirements for Nensed operators and a licensed operator training program and to replace those with certified fuel handlers and a certified fuel handler training and retraining program. Since the plant has permanently ceasd operation and will be maintained in a defueled condition, the range of accidents for which an operator needs to be trained has significantly diminished sJch that a training program of the depth and breadth of that required by 10 CFR 55 is no longer needed. In lieu of a 10 CFR 55 licensed operator training program, a NRC-

T= .

Page 4 of 5 approved certified fuel handler training and retraining program will be implemented. Since this trair,ing program will adequately equip eppropriate operations personnel for fuel handling operations, including responses to abnormal events / accidents there will be no increase in the probability of these events occurring or in the consequences of these events. The proposed changes do not affect plant equipment or the procedures for equipment operation or response to abnormal events / accidents. ,

2. Create the possibility of a new or different kind of accident from any accident previously evaluated.

The purpose of this proposed change 15 tc eliminate the requirements for  ;

licensed operators and a licensed operator training program a 4 to replace those with certified fuel handlers and a certified fuel handler training and retraining program. This change ensures the qualifications of operations personnel dre commensurate with the tasks to be performed and the conditions to be responded to. This change does not affect plant equipment or the procedures for operating plant equipment and, therefore does not create tha possibility of a new or different kind of accident from any accident previously evaluated.

3. Involve a significard reduct.xn in a margin of safety.

The proposed change is to eliminate the requirements for licensed operators and a licensed operator training program to replace those with certified fuel handlers and a certified fuel handler training and retraining program. This change ensures the qualifications of the operations personnel are comensurate with the tasks to be performed and the conditions to be responded to. The assumptions for a fuel handling accident in the Fuel Building are not affected by the proposed changes. Therefore, the proposed amendment does not involve a reduction in a margin of safety.

Maine Yankee has concluded that the proposed change to the Technical Specifications does

- not involve a significant hazards consideration as defined by 10 CFR 50.92.

ENVIRONMENTAL IMPACT DETERMINATION An Environmental Assessment is not required for the Technical Specification changes proposed by this Proposed Change because the requested changes to the Maine Yankee Technical Specifications meet the criteria for " actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9). The requested changes will have no impact on the - environment. The changes do not involve a Significant Hazard Consideration as discussed in the preceding section. The requested changes do not involve a significant change in the types or significant increase in the amounts of any effluent that may be released off-site. Also, the requested changes do not involve a s,gnificant increase in individual or cumulative occupational radiation exposure.

Page 6 'f 5 SCHEDULE CONSIDERATION It is requested that 30 days be provided for implementation of the changes resulting from this amendment.

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