ML20211E516
| ML20211E516 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 05/30/1986 |
| From: | Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | Charemagne Grimes, Noonan V, Thadani A Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20211E520 | List: |
| References | |
| B12096, GL-82-21, TAC-61800, NUDOCS 8606160142 | |
| Download: ML20211E516 (4) | |
Text
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(203) % s-5000 May 30,1986 Docket Nos. 50-213 50-245 50-336 50-423 B12096 Office of Nuclear Reactor Regulation Attn:
Mr. Christopher I. Grimes, Director Integrated Safety Assessment Project Directorate Division of PWR Licensing - B Mr. Ashok C. Thadani, Director PWR Project Directorate //8 Division of PWR Licensing - B Mr. Vincent S. Noonan, Director PWR Project Directorate /i5 Division of PWR Licensing - A U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.1,2 and 3 Proposed Revision to Technical Specifications Fire Protection Audits Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) hereby propose to amend their Operating Licenses DPR-61; DPR-21; DPR-65; and NPF-49 by incorporating the attached proposed change into the Technical Specifications of the Haddar1 Neck Plant and Millstone Unit Nos.1,2 and 3.
By letter dated August 12, 1985,(1) CYAPCO and NNECO submitted a proposed license amendment to revise the Technical Specification on Fire Protection and Loss Prevention Audits for the Haddam Neck Plant and Millstone Unit Nos. I and
- 2. The proposed revision attempted to clarify that the term "outside firm" in the present Technical Specification could be fulfilled by qualified of f-site licensee personnel. This action was prompted by recent inspection (1) 3. F. Opeka letter to 3. A. Zwolinski and E. 3. Butcher, dated August 12, 1985.
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- reports (2)(3)(4)(5) that concluded the present audit program satisfied the Technical Specifications but questioned the degree of auditor independence afforded by our organizational structure.
By letter dated October 21, 1985,(6) the NRC Staff rejected the proposed revision to the subject Technical Specification due to a conflict with the guidance provided by Generic Letter 82-21.(7) The Generic Letter specifically states that a individual / group not associated with the utility should perform the fire protection audit at least once every 3 years. The October 21, 1985 letter further recommended we consider submitting revised Technical Specifications in conformance with Generic Letter 82-21 in order to resolve the open items of the previous inspection reports.
By letter dated January 30, 1986,(8) CYAPCO and NNECO stated that we would comply with the audit guidance of Generic Letter 82-21 beginning with the triennial fire protection program audit scheduled to begin in November,1986. A qualified outside fire protection consultant independent of Northeast Utilities will be utilized during this audit. The proposed Technical Specification revisions formalize this plan and are provided as Attachments I through 4 for the Haddam Neck Plant and Millstone Unit Nos.1,2 and 3.
CYAPCO and NNECO have reviewed the attached proposed changes pursuant to 10CFR50.59 and have determined that they do not constitute an unreviewed safety question.
The probability of occurrence or the consequences of a previously analyzed accident have not been increased and the possibility for a new type of accident has not been created. The proposed changes conform to the provisions of Generic Letter 82-21, which specifies a triennial fire protection and loss prevention inspection and audit utilizing an outside qualified fire consultant.
CYAPCO and NNECO have reviewed the proposed changes, in accordance with 10CFR50.92, and have concluded that they do not involve a significant hazards consideration in that these changes would not:
(2) T. T. Martin letter to W. G. Counsil, dated August 1,1984 transmitting I&E Inspection Report Nos. 50-245/84-15 and 50-336/84-15.
(3) S. D. Ebneter letter to 3. F. Opeka, dated August 20,1985 transmitting I&E Inspection Report No. 50-213/85-16.
(4) S. D. Ebneter letter to 3. F. Opeka, dated November 29,1985 transmitting I&E Inspection Report No. 50-423/85-68.
(5) S. D. Ebneter letter to W. G. Counsit, dated September 4,1985.
(6) 3. A. Zwolinski letter to 3. F. Opeka, dated October 21, 1985,
Subject:
Proposed Revision to Technical Specifications, Fire Protection and Loss Prevention Program Audits.
(7) D. G. Eisenhut letter to All Licensees forwarding Generic Letter 82-21,
" Technical Specifications for Fire Protection Audits."
(8) 3. F. Opeka letter to C. I. Grimes, et. al., dated January 30,1986, " Fire Protection and Loss Prevention Audits."
. 1.
Involve a significant increase in the probability or consequences of an accident previously evaluated. This change clarifies the frequency with which outside independent auditors are to be utilized in performing inspections and audits.
Therefore, this change cannot increase the probability or consequences of an accident.
2.
Create the possibility of a new or different kind of accident from any previously analyzed.
This change renders the fire protection audit process more conservative in that an outside contractor will be used. A greater degree of independence is anticipated.
3.
Involve a significant reduction in a margin of safety. The change to the use of an independent outside auditor experienced in nuclear fire protection requirements is intended to ensure the integrity of the audit process. Under this proposal, the expertise of an external organization would supplement the expertise available through in-house resources.
The Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (51FR7750, March 6,1986). The changes proposed herein are enveloped by example (ii), a change that constitutes an additional limitation, restriction or control not presently included in the technical specifications. The use of an independent outside auditor constitutes a more stringent surveillance requirement in that non-licensee personnel will be used to augment the audit process currently being conducted in-house.
It is reiterated that the proposed change conforms to NRC guidance as reflected in Generic Letter 82-21 and the referenced inspection reports.
The Haddam Neck Plant and Millstone Unit Nos.1, 2 and 3 Nuclear Review Boards have reviewed and approved the attached proposed revisions and have concurred with the above determinations.
In accordance with 10CFR50.91(b), we are providing the State of Connecticut with a copy of these proposed amendments.
Pursuant to the requirements of 10CFR170.12(c), enclosed with this amendment request is the application fee of $600.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY
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Senior Vice President
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Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 STATE OF CONNECTICUT )
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Then personally appeared before me J. F. Opeka, who being duly sworn, did state that he is Senior Vice President of Connecticut Yankee Atomic Power Company and Northeast Nuclear Energy Company, Licensees herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief, h5 JMir hFotary Puby My Commission Expires March 31,1988 L