Text

Application for Amend to License DPR-36,consisting of Proposed TS Change 207,reflecting Permanently Defueled Status of Plant
	ML20212A602
Person / Time
Site:	Maine Yankee
Issue date:	10/20/1997
From:	Meisner M; Maine Yankee
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20212A610	List: ML20212A602; ML20212A621;
References
	MJM-97-18, MN-97-116, NUDOCS 9710240088
	Download: ML20212A602 (115)
	v • d • e

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MaineYankee Ef uADLE ELECTRICITY BINCE 1977 329 BATH ROAD

BRUNSWICK. MAINE 04011 * (M7) 798 4100 October 20, 1997 MN 97-116 MJM-97-18 Proposed Change No. 207 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, DC 20555

Reference:

(a)

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

(b)

Letter: M. B. Sellman to USNRC: Certifications of Permanent Cessation of Power Operation and Permanent Removal of Fuel From the Reactor: MN-97-89, dated August 7, 1997 (c)

Letter: M. J. Meisner to USNRC; Proposed Technical Specification l

Change No. 206 - Facility Staffing and Training MN-97-96, dated August 15, 1997 (d)

Letter: M. J. Meisner to USNRC: Request for Approval of the Certified Fuel Handler Training and Retraining Program: MN-97-95, dated August 15, 1997

Subject:

Proposed Technical Specification Change No. 207 - Permanently Defueled Technical Specifications 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 withdrdw Maine Yankee's authority to operate.

Therefore, Maine Yankee hereby submits, pursuant to 10 CFR Parts 50.90, this application to amend the Technical Specifications to reflect the permanently defueled status of the plant. This application is being submitted under the assumption that the NRC will have approved Reference (c) by the time NRC approval is obtained for this application. Maine Yankee has developed Permanently Defueled Technical Specifications (PDTS) for the Maine Yankee plant using NUREG-1432.

" Standard Technical Specifications Combustion Engineering Plants," as the basis for the PDTS scope and format.

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MaincYankee UNITED STATES NUCLEAR REGULATORY COMMISSION MN 97-116 Attention: Document Control Desk Page Two The improved Standard Technical Specifications contained in NUREG 1432 are the result of an extensive effort by the NRC staff, the Combustion Engineering Owners Group, and the Nuclear Energy Institute. These improved Standard Technical Specifications were developed based on the criteria set forth in the final Commission Policy Statement for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132). Since then, these criteria have been codified in NRC Regulation, 10CFR50.36(c)(2)(11).

Attachment I to this letter provides the background for and description of the proposed changes. Attachment 11 contains the Significant Hazards Evaluation. 11 to this letter provides a copy of the proposed PDTS. Attachment IV contains the proposed Bases for the PDTS. Attachment V contains the requirements which are proposed for relocation to the Quality Assurance Program to replace the Plant Operating Review Committee and the Nuclear Safety Audit and Review Committee, As discussed in the Attachment II, 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, will not ;mpact the health and safety of the public.

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 that the NRC approval of this proposed change include a provision that allows Maine Yankee to determine the date that the PDTS will be implemented. This flexibility in scheduling is being requested due to the number of proposed changes, the training required and the additional administrative controls which are to be implemented concurrently with the PDTS. Maine Yankee will notify the NRC of the proposed implementation date for the PDTS.

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MaineYankee UNITEDSTATESNUCLEARREGULATORYCOMMISSION-MN 97-116

_ Attention: Document Control Desk

.Page Three-

_ If-you have any questions, please contact us.

Ve truly rs.

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M ael

.'Meisner, Vice President iucle aafety & Regulatory Affairs Attachments c:

Mr. Hubert Miller Mr. D. H. Dorman Mr. Singh Bajwa Mr. R. A. Rasmussen Mr. Clough Toppan 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 Atomic Power Company, that he is duly authorized to execute and file the foregoing request in the name and on the behalf of Maine Yankee Atomic Power Company, and that the statements therein are true to the best of his knowledge and bel W.

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Notary Public Donna L Pelletier, Notary Public

-US Nuclear Regulatory Commission state of Maine Attn: Document Control Desk My CoWasbn % Ires 1U1W99

-Washington. DC 20555 0

i ATTACHMENT I Page 1 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 2E BACKGROUND On August 6, 1997, the Maine Yankee Atomic Power Company (MYAPC) Board of Directors decided to permanently cease further operation of the Maine Yankee Nuclear Plant.

As such, Maine Yankee has submitted by Reference (b) a certification of permanent cessation of operations and a certification of permanent removal of fuel in accordance with 10CFR50.82(a)(1). The purpose of this submittil is to propose revised technical specifications appropriate for the current status of the facility.

On July-29, 1996, the Nuclear Regulatory Commission issued a final rule (61 FR 39278) amending its regulations on decommissioning procedures. This rule was intended to provide licensees with simplicity and flexibility in implementing the decommissioning process, especially with regard to premature closure. No longer i st a licensee obtain a license amendment for possession-only status. However, ti.e G C acknowledged that as a reactor facility transitions from operational to decomnissioning status, numeroas changes to technical specifications are expected.

In order to provide a consistent framework for these expected changes, NRC is considering the development of additional guidance in the form of standard technical specifications for decommissioning. However, in the interim, it was expressed that licensees may apply for modification of their technical specifications on a case-by-case basis, in accordance with 10CFR50.36(c)(6).

Maine Yankee % wrrent Technical Specifications have been customized over the years to meet the specific needs of Maine Yankee. In the development of these proposed Technical Specifications, Maine Yankee used NUREG 1432, " Standard Technical Specifications Combustion Engineering Plants" dated April 1995 as the basis for scope and format, as modified by approved STS change travelers. Maine Yankee also reviewed the Technical Specifications of other plants which have previously decided to permanently shutdown, primarily th05e submitted by and approved for Portland General Electric Conpany's Trojan Nuclear Plant. The improved Standard Technical Specifications (STS) contained in NUREG-1,32 are the result of an extensive effort by the NRC staff, the Combustion Engineering Owners Group, and the Nuclear Energy Institute. These improved standard technical specifications were developed to meet the criteria set forth in the final Commission Policy Statement for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132).

Although the improved Standard Technical Specifications were developed primarily for operating plants, the improved STS also contains the latest approved NRC guidance on technical specifications for a plant with irradiated fuel in the spent fuel pool.

Since the safety function related to safe maintenance and storage of irradiated fuel at an operating plant is no different than the corresponding safety function at a permanently shutdown plant, the improved Standard Technical Specification provides an appropriate standard for comparison. Although we reviewed and considered the technical specifications submitted by and approved for the Trojan Nuclear Plant, we also recognize that the improved STS represents the latest NRC approved position.

Our review resulted in adding two specific.1tions (spent fuel pool boron concentration and water level). These requirements were in the improved STS but were not in Maine Yankee's custoa Technical Specification.

In general, requirements

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ATTACHMENT I Page 2 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 in our current T' Anical Specifications were either retained, deleted due to their inapplicability b a facility with a defueled reactor or relocated in accordance with NRC guidance, Unless otherwise indicated, the Technical Specification requirements designated for relocation will be relocated verbatim from the Technic:1 Specifications to the referenced licensee controlled documents. Therefore, the cumulative effect of the requirements in the Quality Assurance Program, the Final Safety Analysis Report (FSAR) Operating License, proposed Technical Specifications and other regulations continue to ensure safe maintenance and storage of irradiated fuel.

The criteria set forth in the final Commission Policy Statement described above, have since been codified in NRC Regulation 10CFR50.36(c)(2)(11).

In the statements of consideration that accompanied this rule (60 FR 36953), the NRC stated that the final policy statement is not being withdraw 1 "because it contains detailed discussions of the four criteria and guidance on how the NRC staff and licensees should apply the criteria."

The final Commission Policy Statement established these four criteria to define the scope of equipment and parameters to be included in the improved Standard Technical Specifications. These criteria were developed for licenses authorizing operating (ie. operating reactors) and focused on instrumentation to detect degradation of the reactor coolant system pressure boundary and on equipment or process variables that affect the integrity of fission product barriers during design bases accidents or transients. The fourth criterion refers to the use of operating experience and probabilistic risk assessment to identify and include in the Technical Specifications structures, systems and components shown to be significant to public health and safety. Nevertheless, these criteria, codified by 10CFR50.36, are the source of the technical specification requirements for safe storage of spent fuel.

Maine Yankee has given consideration to these criteria as they apply to a plant with a reactor which is permanently shutdown and defueled. A general discussion of these considerations is provided below.

10CFR50.36(c)(2)(11)(A) Criterion 1 states that technical specification limiting conditions for operation must be established for " installed instrumentation used to detect. and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary." Since no fuel is present in the reactor coolant system at the Maine Yankee facility, this criterion is not applicable.

10CFR50.36(c)(2)(11)(B) Criterion 2 states that technical specification limiting conditions for operation must be established for " process variables that are initial condit1 M s of a design basis accident (DBA) or transient analysis that either assume the failure of or present a challenge to the integrity of a fission product barrier " The purpose of this criterion is to capture those process variables that have initial values assumed in the design basis accident and transient analyses, and which are monitored and controlled during power operation. While this criterion was developed for operating reactors, there are some design basis accidents which

- continue to apply to a plant authorized only to handle, store and possess nuclear fuel. The scope of DBAs applicable to a plant with a reactor which is permanently shutdown and defueled 1s markedly reduced from those postulated for an operating plant. There are no transients which continue to apply. The scope of DBAs e,

ATTACHMENT I Page 3 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 applicable to the facility is discussed in more detail below.

10CFR50.36(c)(2)(ii)(C) Criterion 3 states that technical specification limiting conditions for operation must be established for structures, systems, or components (SSC's) that are part of the primary success path and which function or actuate to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The intent of this criterion is to capture into technical specifications only those SSC's that are part of the primary success path of a safety sequence analysis. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function. The primary success path of a safety sequence analysis consists of the combination and sequences of equipment needed to operate (including consideration of the single failure criterion), so that the plant response to design basis accidents and transients limits the consequences of these events to within the appropriate acceptance criteria. While there are no transients which continue to apply to Maine Yankee, there are some design basis accidents which continue to apply to a clant authorized only to handle, store and possess nuclear fuel. The scope of DBAs applicable to a plant with a reactor which is permanently shutdown and defueled is markedly reduced from those postulated for an operating plant and there are no transients which continue to apply. The scope of DBAs applicable to the facility is discussed in more detail below.

10CFR50.36(c)(2)(ii)(D) Criterion 4 states that technical specification limiting conditions for operation must be established for structures, systems, or components (SSC's) which operating experience or probabilistic risk assessment has shown to be significant to public hcalth and safety. The intent of this criterion is that risk insights and operating experience be factored into the establishment of technical specification limiting conditions for operation. This criterion was developed to cover those insights not fully recognized in the safety analysis report design basis accident or transient analysis. These insights are primarily employed to verify that none of the requirements to be relocated or eliminated from technical specifications contain constraints of prime importance in limiting the likelihood or severity of the accident sequences that are commonly found to dominate risk. All of the accident sequences that previously dominated risk at Maine Yankee tre no longer applicable with the reactor in the permanently shutdown and defueled condition.

Operating experience has been factored in as applicable to these proposed teuinical specifications.

Section 14 of the FSAR describes the DBA scenarios that were applicable to Maine Yankee Plant during power operations. However, as a result of the certifications (Reference b) submitted by Maine Yankee in accordance with 10CFR50.82(a)(1) and the consequent removal of authorization to operate the reactor or to place or retain fuel in the reactor in accordance with 10CFR50.82(a)(2), most of the accident scenarios postulated in the SAR are no longer possible. Maine Yankee is revising the SAR to reflect the current facility status. These postulated accidents are listed in the following table and discussed below.

ATTACHMENT I Page 4 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 FSAR Chapter 14 Safety Analysis Postulated Accident or Transient Current Applicability 14.2 Control Element Assembly (CEA)

Not Applicable Withdrawal Incident 14.3 Boron Dilution Incident 14.3.2.1 Dilution During Refueling Not Applicable 14.3.2.2 Dilution During Startup Not Applicable 14.3.2.3 Dilution at Hot Standby Not Applicable 14 1.2.4 Dilution at Power Not Applicable 14.3.2.5 Failure to Borate Prior Not Applicable to Cooldown 14.3.2.6 Dilution During Shutdown Not Applicable with RCS Filled 14.3.2.7 Dilution During Shutdown Not Applicable with RCS Drained 14.4 Control Element Assembly Drop Not Applicable Incident 14.5 Malpositioning of the Part-Length Not Applicable CEA's 14.6 Loss of Coolant Flow incident Not Applicable 14.7 Startup of an Inactive Reactor Not Applicable Coolant Primary Loop 14.8 Excess Load Incident Not Applicable 14.9 Loss of Load Incident Not Applicable 14.10 Loss of Fr.awater Flow Incident Not Applicable 14.11 Steam Line Rupture (SLR) Incident Not Applicable 14.12 Steam Generator Tube Rupture Not Applicable Incident 14.13 Control Element Assembly Ejection Not Applicable Incident 14.14 Loss-Of-Coolant Incident Not Applicable 14.15 Reactor Containment Pressure Not Applicable Analysis 14.16 Radiological Consequences of a SLR Not Applicable

ATTACHMENT I Page 5 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 FSAR Chapter 14 3afety Analysis Postulated Accident or Transient Current Applicability 14.17 Fuel Handling Incident Applicable 14.18 Radiological Consequences for the Not Applicable Hypothetical Accident 14.19 Waste Gas Decay Tank Rupture Not Applicable 14.20 Spent Fuel Cask Drop Applicable 14.21 Radioactive Liquid Waste System Applicable Leaks and Failures 14.22 Radiological Consequences Not Applicable Resulting From Loss of Feedwater During normal power operations, the forced flow of water through the reactor coolant system (RCS) removes the heat generated by the reactor. The RCS, operating at high temperatures and pressures, transfers this heat through the steam generator tubes to the secondary system. The most severe postulated accidents for nuclear power plants involve damage to the nuclear reactor core and the release of large quantities of fission products to the reactor coolant system. Many of the accident scenarios postulated in the FSAR involve failures or malfunctions in these systems that could affect the reactor core. With the termination of reactor operations at the Maine Yankee facility and the removal of authorization to operate the reactor or to place or retain fuel in the reactor such accidents are no longer possible. The reactor, RCS and secondary system are no longer in operation, The irradiated fuel is now stored in the spent fuel pool and these systems serve no function related to the storage of irradiated fuel in the spent fuel pool. Therefore, the postulated accidents involving failure or malfunction of these systems are no longer applicable. These include FSAR section 14.2 through 14.16 and Sections 14.18, 14,19 and 14.22 as indicated on the above table.

The postulated incident described in SAR section 14.3.2.1. " Dilution During Refueling' is not applicable since refueling operations are prohibiteo by 10CFR50.82(a)(2).

Section 14.17 discusses the design basis fuel handling incident. This incident is described below.

Section 14.18 defines the radiological consequences of the hypothetical loss-of-coolant accident. These consequences were baseu upon a hypothetical LOCA involving gross release of fission products from the core to the containment building without regard to the ability of the engineered safety systems to prevent such a release.

This postulated accident is no longer possible at Maine Yankee.

Section 14.19 provides an analysis of a postulated failure of the Waste Gas Decay Tanks (W3DTs). During reactor operations the WGDTs are used to store and permit the decay of radioactive gases to reduce or prevent the normal release of radioactive o

ATTACHMENT I Page 6 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES P30 POSED CHANGE NO. 207 materials to the atmosphere. The radioactive contents of the WGDis are principally the noble gases krypton and xenon, the particulate daughters of some of the krypton and xenon isotopes, and trace quantities of halogens. These noble gases were generated from fission during operation of the reactor. Since the reactor is permanently shutdown, such gases are no longer generated at the Maine Yankee facility. Further, the WGDT's are currently empty ano depressurized. Therefore, there is no possibility of a release from the WGDTs that would result in doses beyond the exclusion area exceeding a small fraction of the limits of 10 CFR 100.

Section 14.21 " Radioactive Liquid Waste System Leaks and Failures" involve the release of radioactive materials from systems other than the RCS and secondary system. This includes a leak in or failure of the liquid radioactive waste system and, in particular, the primary drain tank.

It is assumed that eighty percent of the primary drain tank capacity is filled with undecayed, undegassified primary reactor coolant with activity concentrations at the Technical Specification limits of 1.0 pCi/g Dose Equivalent 1-131 and 100/11 uC1/g. While the termination of reactor operations at the Maine Yankee facility did not eliminate the postulated failure of the primary drain tank, the production of radioactive liquids associated with reactor operation has ceased. Only the production of radioactive liquids resulting from such functions as the spent fuel pool purification or decommissioning activities remain. This FSAR accident continues to apply.

Section 14.17 discusses the design basis fuel handling incident. Fuel will no longer be handled in the containment at the Maine Yankee facility. The possibility of a fuel handling accident in the spent fuel pool is remote due to the many administrative controls and physical limitations imposed on fuel handling operations. Nonetheless, a postulated fuel handling accident in the fuel building remains applicable, fhe existing accident analysis for the fuel handling accident, as described in the FSAR, assumes two cases. The first case is the realistic case where the accident is assumed to occur one week after shutdown from operations and a decontamination factor for iodine of 500. The second case is the conservative case where the accident is assumed to occur seventy-two hours after shutdown from operations and a decontamination factor of 133 and 1 for inorganic iodine and organic iodine. For the purpose of establishing an upper limit on the amount of fuel damage resulting from a fuel handling accident. it is assumed that the fuel assembly is dropped during handling. The number of ruptured fuel rods which would result depends on several variables including the kinetic energy at impact and fuel assembly orientation during impact. The existing analyses indicate that if a fuel assembly were dropped to the bottom of the spent fuel pool and then rotated and struck a protruding structure, only the outer row of fuel rods would fail. However, to assure that the limiting case is considered, it is assumed that all rods in the dropped assembly fail upon impact. The resulting doses which are calculated for the fuel handling accident are below the values specified in 10CFR100. As described in the basis of the current TS 3.13, the analysis of the fuel handling accident conducted by the NRC assumed 23 feet of water and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of decay time. The NRC's analysis resulted in dose consequences limited to 10% of 10CFR100. Because almost nine months have elapsed since the last reactor operation, the consequences of a postulated fuel handling accident at the Maine Yankee facility will ba lower than l

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l ATTACHME4L1 Page 7 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGE _$

PROPOSED CHANGE NO. 207 l

were previously analyzed, in addition to the fuel handling accident, an analysis was performed to calculate the reactivity effects of a mispositioned fuel assembly. This analysis was performed to suppcrt Amendment 144 to the daine Yankee Technical Specifications.

The analysis considcred various misposition configurations including a fuel assembly laying horizontally en the top of the spent fuel racks, a fuel assembly placed adjacent to or on the outside corner of the fuel racks and a fuel assembly placed in the wror.g spent fuel rack. B80 d upon the most reactive condition, a boron concentration of 663 ppm was determined to be required to maintain a Stak/k safety margin to criticality.

Finally, the consequences of a loss of forced cooling to the spent fuel pool are also considered. The heat load in the spent fuel pool is much less than the design value due to the decay time that has elapsed since reactor shutdown (nine months) and the number of irradiated fuel assemblies stored in the pool (1432). A conservative analysis previously performed in support of Amendment 144 to the Maine Yankee Technical Specifications show that the boil off rate is approximately 50gpm.

This conservative analysis assumed a full core discharge case with a core unload beginning 6 days after reactor shutdown for the final (cycle 23) discharge up to the maxbnum of 2019 spent fuel assemblies. At this boil off rate, it would take more than a day to lose enough water from the spent fuel pool to end6nger uncovering irradiated fuel assemblies. NUREG/CR-6451 indicates that a total loss of cooling to the spent fuel pool would allow over 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months of boil off before any spent fuel l

would be exposed and potentially damaged. The NUREG agrees well with the Maine Yankee's conservative analysis. Even with this conservative analysis there is sufficient time to effect repairs to the cooling system or to establish makeup flow prior to uncovering the irradiated fuel, A number of sources of makeup to the spent fuel pool are available and methods of establishing makeup flow will be addressed in facility procedures, in summary, most of the accident scenarios described in FSAR Section 14 are no longer possible due to the terminatior af reactor operations and the removal of fuel from the reactor at the Maine Yankee facility. The remaining postulated design bases accidents used in the development of these t.roposed PDTS are a fuel handling accident in the spent fuel pool including a fuel misplacement accident, an extended loss of forced cooling to the spent fuel pool, a spent fuel cask drop and j

radioactive liquid waste system leaks and failures.

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ATTACHMENTJ Page 8 of 46 JACKGROUND AND OESCalPTION OF PROPOSED CHANFAS PROPOSED Cl[ANGE NO. 207 DESCRIPTIONOFCHANGES Maine Yankee reviewed each existing Maine Yankee Technical Specification (MY15) to determine if it should be retained in the Permanently Defueled Technical i

Specification (PDTS) in its present form, modified as appropriate for permanently j

defueled conditions, or deleted. The results of this evaluation are presented below on a section by section basis, i

MYTS Definitions Definitions are C rrently contained in the beginning of the MYT" The MiTS provides u

definitions for terminology that is unique to the technical specifications. The standard convention used in tae StanJard Technical Specification (STS) of indicating definitions throughout the text by show?ng the defined term in all capital letters has been t" opted in the PDTS. However, with the reduction in scope of the PDTS most of these terms are no longer applicable. For example, the definition of " Reactor Operating Conditions" are based on the conditions of the reactor and are no longer used. The following table shows a comparison of the existing MYTS definitions with those contained in the improved standard technical specifications and the proposed PDTS. The STS specifiestions that have not been retained in the proposed PDTS are discussed individually below.

Definitions Current MYTS Improved STS Proposed PDTS REACTOR OPERAT]N3 CONDITIONS Refueling Shutdown Condition Table 1.1 1 Definitions Not Applicable (Condition 1)

Refueling Operations Table L1-1 Definitions Not Applicable Condition (Condition 2)

Cold Shutdown Condition Table 1.1 1 Definitions Not Applicable (Condition 3)

Transthermal Condition Table 1.1-1 Definitions Not Applicable (Condition 4)

Hot Shutdown Condition Table 1.1-1 Definitions Not Applicable (Condition 5)

Hot Standby Condition Table 1.11 Definitions Not Applicable (Condition 6)

Power Operation Condition Table 1.1 1 Definitions Not Applicable (Condition 7)

Higher Operating Condition Addressed in STS 3.0.4 Not Applicable REACTOR STATUS

ATTACHMENT I Page 9 of 46 BACKGROUND AND..DESCRIPl10N OF PROPOSED CIRNGES PROPOSED CFRNGE NO. 207 Definitions Current MYTS Improved STS Proposed PDTS Refueling Boron Not included Specified in Section Concentration 3.1.2 Cold shutdown Boron Not included Not included Concentration Reactcr Critical Not included Not Included Shutdown Margin 1.1 Definitions Described in the basis for Section 3.1.2 Low Power Physics Testing 1.1 De/1nitions Not Applicoble Power Range Physics Testing 1.1 Definitions Not Applicable Rated Power 1.1 Definitions Not Applicable Quadrant Power Tilt 1.1 Definitions Not Applicable AdjustedReference Not included Not included l

Temperature (ART) l Lowest Service Temperature Not included Not included Minimum Boltup Temperature Not included Not included REACTOR PROTECTIVE SYSTEM instrument Channels Not included Not included Reactor Trip Not included Not included Trip Module Not locluded Not included ENGINEERED SAFEGUARDS SYSTEMS Subsystem Not included Not included Degree of Redundancy Not included Not included MISCELLANEOUS DEFINITIONS Operable 1 1 Definitions Not Applicable Operating Not included Not included Control Element Assemblies Not included Not included Partial length Control Not included Not included Element Assemblies O

ATTACHMENT I Page 10 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE N0_._202 Definitions Current MYTS Improved STS Proposed PDTS Fire Suppression Water Not included Relocate to the FSAR

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Core Operating Limits Report 1.1 Definitions Not Applicable Radio Isotope Release Limits Not included Not included B - Average D1sintegration 1.1 Definitions Not Applicable Energy Dose Equivalent 1-131 1.1 Definitions Not Applicable Reportable Event Not Inchmd Not included Remedial Action 1,1 Definit 1ons 1.1 Definitions Noncompliance Not included Not included Nonconformance Not included Not included frequency Notation 1.4 Frequency 1.4 frequency Table 0.1 Minimum Pressurization Not included Not included Temperature Off Site Dose Calculation Program included in Program includeo in Manual (ODCM)

Section 5.5.1 Section 5.6.3 Member (s) of the Public Not Ircluded Not included Site Boundary 4.1 Site Location Described in Section 4.1.1 Gaseous Radwaste Treatment Not included Not included System Process Control Program Not included Relocate to the FSAR (PCP)

Ventilation Exhaust Not included Relocate to the FSAR Treatment System Unrestricted Area Not included Not included As indicated in the table, most of the definitions of the current MYTS are no longer applicable to the Maine Yankee facility or are not included in the improved Standard Technical Specifications. The definition of " Remedial Action" has been retitle

" Actions" and has been redefined and included in Section 1.1 of the PDTS. A new definition, " Certified Fuel Handler", has been adJed. The basis for the definition of a Certified Fuel Handler is discussed in more detail in the description of administrative controls, in Reference (c). Maine Yankee asserted that an operator

ATTACINENT I Page 11 of 46 BACKGROUND AND_ DESCRIPTION OF PROPOSED CHANGES PROEOSED CHANGE NO. 207 holding a license as a Senior Reactor Operator in accordance with 10CFRS5 is qualified as a certified fuel handler. This continues to be true, however the assertion has been removed from the proposed PDTS. Section 1 of the proposed PDTS also includes expanded information and examples related to the use of log 1 cal connectors (Section 1.25, the interpretation of completion times (Section 1.3), and I

the interpretation of surveillance frequencies (Section 1.4).

This expanded l

information is consistent with the 1mproved Standard Technical Specifications, and has been simplified as appropriate to the reduced scope of the proposed PDTS.

I All of the reactor operating condition definitions are no longer applicable since the reactor has been permanently shutdown and defueled. Other definitions such as cold shutdown boron concentration, reactor critical, low power physics testing, power range physics testing, rated power, quadrant power tilt, core operating limits report, G - Average Disintegration Energy, dose equivalent 1 131 are no longer applicable since they relate to operations that will no longer be conducted at Maine Yankee or to Technical Specifications which no longer apply and are not being retained in the proposed PDTS. The definitions of refueling boron concentration and the shutdown margin are implicitly incorporated into PDTS 3.1.2.

The definition of fire suppression water system, process control program and ventilation exhaust treatment system will be relocated to the FSAR in accordance with the improved Standard Technical Specification which does not include these definitions. The remaining definitions are not retained in the proposed PDTS in accordance with the improved Standard Technical Specifications.

ATTACHMENT I Page 12 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGE.S PROPOSED CHANGE NO. 207 MYTS Section 1 I

Section 1 describes the design features of the Maine Yankee facility. In accordance with 10 CFR 50.36(c)(4). this section is intended to describe features of the facility such M materi61s of construction or geometric arrangement that. if altered, woulo significantly affect safety and are not covered in other sections of the technical specifications. The current MYTS contain the design features in four areas. These specifications are listed in the table below with the corresponding sections of the improved Standard Technical Specifications and the PDTS.

Design Features Current MYTS Improvrd STS Proposed PDTS 1.1 Fuel Storage 4.3 Fuel Storage 4.2 fuel Storage 1.2 Site Description 4.1 Site Location 4.1 Site 1.3 Reactor 4.2 Reactor Core Not Applicable l

1.4 Containment Not included Not Applicable Of these current sections. Section 1.1 describing spent fuel storage and Section 1.2 describing the site have been retained and modified as appropriate. T ese specifications are now located in PDTS Section 4.0 Design features in accordance with the numbering system in the improved Standard Technical Specifications as PDTS 4.1 Site and PDTS 4.2 - Fuel Storage. The description of the site contained in PDTS 4.1 has been retained as worded in the current MYTS.

Most of the provisions of MYTS Section 1.1 have been transferred to PDTS Section 4.2.

Maine Yankee proposes to relocate MYTS 1.1.A to the Final Safety Analysis Report in accordance with the criteria of 10CFR50.36. MYTS 1.1.B describes a reactivity design objective of the spent fuel storage racks and has been reworded and transferred to PDTS 4.2.1.1.b.

MYTS 1.1.C specifies the minimum boron concentration in the spent fuel pool and has been reworded and transferred to PDTS 3.1.2 Spent Fuel Pool Boron Concentration. MYTS 1.1.0 prohibits spent fuel shipping casks from being lifted over the spent fuel storage pool. Maine Yankee proposes to relocate MYTS 1.1.D to the FSAR in accordance with the criteria of 10CFR50.36. MYTS 1.1.E specifies the locacion and maximum number of spent fuel assemblies to be stored in the spent fuel pool. 1he maximum number of spnt fuel assemblies has been retained and transferred to PDTS 4.2.3.a.

MYTS 1.1.F specifies the location and maximum number of spent fuel assemblies which may be stored in a temporary spent fuel storage rack to be located in the spent fuel cask laydown area. Maine Yankee does not intend to use this option and has therefore deleted this specification from the PDTS. MYTS 1.1.G specifies the maximum number of fuel assemblies which may be in consolidated form. This specification has been transferred to PDTS 4.2.3.b.

MYTS Sections 1.3 and 1.4 described the design features of the reactor core, reactor coolant system, emergency core cooling system and the containment. These structures

ATTACHMENT I Page 13 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 and systems served to prevent or mitigate the consequences of postulated accidents involving the release of fission products in the containment. Since the Maine Yankee reactor is permanently shutdown and defueled, there is no longer the need to maintain these design features for the protection of the general public. Therefore, these sect. ions are not retained in the PDTS.

ATTACHMENT I Page 14 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 HYTS Section 2 Safety Limits and Limitina System Settinas Sectica 2 of the MYTS contains " safety limits" and " limiting safety system settings." In accordance with 10 CFR 50.36(c)(1), safety limits are limiting parameters necessary to protect the physical barriers that guard against the uncontrolled release of radioactivity from a nuclear reactor.

If a parameter exceeds the specified safety limit, the reactor must be shutdNo and operation may not resume until authorized by the Commission, Limiting safety system settings are values of various parameters associated with the nuclear steam supply system (NSSS) at which automatic protective action is needed during normal operations or anticipated transients to prevent violation of the safety limits. MYTS Section 2 specifications are listed in the table below w1th the corresponding sections of the improved Standard Technical Specifications and the PDTS.

Safety Limits and Limiting System Settings Current MYTS Improved STS Proposed PDTS 2.0 Safety Limit 2.2 Safety L1mit Not Applicable Violations Violations 2.1 Limiting Safety System 3.3.1 Reactor Protective Not Applicable Setting Reactor System (RPS)

Protection System Instrumentation 2.2 Safety Limit - Reactor 2.1.1 Reactor Core Safety Not Applicable Core Limit 3.2 Power Distribution Limits 2.3 Safety Limit - Reactor 2.1.2 Reactor Coolant Not Applicable Coolant System Pressure System (RCS) Pressure Safety Limit The current MYTS contain two safety limits. MYTS 2.2 sets limitations on the departure from nucleate boiling heat flux ratio (DNBR) and fuel centerline melting temperature. These limits prevent damage to the fuel cladding during reactor operation that could result in the release of fission products to the reactor coolant syste'. MYTS 2.3 places a limitation on the pressure in the reactor coolant system. This limitation prevents potential damage to the reactor coolant system pressure boundary that could result in the release of fission products in the reactor coolant system to the containment atmosphere. The limiting safety system settings are contained in MYTS 2.1. This specification establishes limits on the setpoints of the reactor protection system (RPS). The RPS monitors various parameters associated with reactor operation and initiates a shutdown of the reactor if the settings are exceeded during normal operation or anticipated operational occurrences. Examples of the parameters included within the scope of the RPS include reactor trips based on neutron flux, reactor coolant system temperature, pressurizer pressure, reactor coolant system flow rate, steam generator pressure.

ATTACHMENT I Page 15 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 202 steam generator level, and containment pressure. The Maine Yankee facility is permanently shutdown and fuel has been removed from the reactor vessel and ph ced in the spent fuel storage pool.

In accordance with 10CFR50.82(a)(2), the facility operating license no longer authorizes operation of the reactor or placement or retention of fuel in the reactor. Since the reactor is not in operation at the Maine Yankee facility and the regulations prohibit such operation in the future.

MYTSs 2.2 and 2.3 are no longer applicable and are deleted n this proposed amendment. Since there is no longer an operating reactor at the Maine Yankee facility. the RPS no longer serves a useful function. Therefore. MYTS 2.1 is also deleted in this proposed amendment. Finally, since there are no safety limits that apply to Maine Yankee, there can be no Safety Limit violations. Therefore. MYTS 2.0 Safety Limit Violation is deleted.

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ATTACHMENT I Page 16 of 46 lLACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 HYTS Section 3 Limitina Conditions for Ooerations in accordance with 10 CFR 50.36(c)(2), limiting conditions for operation (LCO's) specify the bwest functional capability or performance levels of equipment required for safe operation of the facility. The LCO's typically place restrictions on the availability of safety equipment needed to prevent or mitigate a postulated DBA or on process variables necessary to preserve the initial conditions assumed in analyses of postulated design basis events. 10CFR50.36(c)(2)(ii) define four criteria for establishing limiting conditions for operations. Associated surveillance requirements help to ensure that the specified equipment and parameters are maintained within the limits specified in the LC0's.

As discussed previously, only a limited set of postulated design basis accidents remain applicable to the Maine Yankee facility with its reactor in the permanently defueled state. As a result, most of the LCO's and accompanying surveillance requirements contained in the current MYTS were determined to be inappropriate for retention in the proposed PDTS. The following table shows a comparison between the provisions of the current MYTS, the corresponding sections of the Improved Standard Technical Specifications and the proposed PDTS.

Limiting Conditions for Operation Current MYTS Improved STS Proposed PDTS 3.0 Limiting Condition for 3.0 Limiting Condition for 3.0 Limiting Condition for Operation Operation (LCO)

Operation (LCO)

Applicability Applicability 3.1 Reactor Core 3.2 Power Distribution Not Applicable Instrumentation Limits 3.2 Reactor Coolant System 3.4.16 RCS Specific Not Applicable Activity Activity 3.3 Reactor Coolant System 3.4 Reactor Coolant System Not Applicable Operational Components (RCS) 3.4 Combined Heatup.

3.4 Reactor Coolant System Not Applicable Cooldown and Pressure Temperature Limitations 3.5 Chemical and Volume Not included Not Applicable Control System 3.6 Emergency Core Cooling 3.5 Emergency Core Cooling Not Applicable and Containment Spray System (ECCS)

Systems 3.7 Boron and Sodium 3.5 Emergency Core Cooling Not Applicable Hydroxide Available for System (ECCS)

Containment Spray System j

s

ATTACHMENT I Page 17 of 46 BACKGROUND AND DESCRIPTION OF IROPOSED CHANGES PROPOSED CHANGE NO. 207 Limiting Conditions for Operation Current MYTS Improved STS Proposed PDTS 3.8 Reactor Core Energy 3.4 Reactor Coolant System Not Applicable Removal (RCS) 3.7 Plant Systems 3.9 Operational Safety 3.3 Instrumentation Not Appl 1 cable Instrumentation. Control l

System and Accident Monitoring Instrumentation i

3.10 CEA Group, Power 3,2 Power Distribution Not Appl 1 cable I

Distribution Moderator limits l

Temperature Coeff1cient Limits and Coolant Conditions 3.11 Containment 3.6 Containment Systems Not Applicable 3.12 Station Service Power 3.8 Electrical Power Not Applicable Systems 3.13 Refueling and Fuel 3.9 Refueling Operations Mostly not applicable Consolidation Operations 3.1 Defueled Systems 3.14 Primary System 3.4 Reactor Coolant System Not Applicable Leakage (RCS) 3.15 Reactivity Anomalies 3.1 Reactivity Control Not Applicable Systems 3.16 Deleted N/A Not Applicable 3.17 Gaseous Raoicactive Program Required by 5.5 Not Applicable Waste Storage 3.18 Reactor Coolant Not included 3 Not Applicable System Oxygen and Chlorine / Fluoride Concentration 3.19 Safety injection 3.4 Reactor Coolant Sy, stem Not Applicable System (RCS) 3.20 Shock Suppressors Not included Not included (Snubbers) 3.21 Deleted Not Applicable Not Applicable 3.22 Feedwater Trip System 3.3 Instrumentation Not Applicable 3.7 Plant Systems 3.23 Deleted Not Applicable Not Applicable

ATTACHMENT I BACKGROUND AND DESCRIPTION OF PROPOSED C M GES PROPOSED CHANGE NO 207 Limiting Conditions for Operation Current MYTS Improved STS Proposed PDTS 3.24 Secondary Coolant 3.7 Plant Systems Not Applicable Activity i

3.2S Installed Ventilation Program Required by S.S Not Applicable and Filter Systems l

3.26 Reserved Not Applicable Not Applicable 3.27 Reserved Not Applicable

.Not Applicable l

3.28 Deleted Not Applicable Not Applicable l

l Each subsection of MYTS Sections 3 is discussed in more detail below.

HYTS Subsection 3.0 - This subsection contains specifications that have generic applicability to the LCO's and surveillance requirements. Due to the limited number of LCO's remaining in the proposed PDTS a number of the MYTS provisions in this section are no longer necessary for or applicable to the Maine Yankee facility as indicated in the following table. The STS specifications that have not been retained in the proposed PDTS are discussed individually below.

3.0 Limiting Conditions for Operation Current MYTS Improved STS Proposed PDTS A. Nonconformances with 3.0.3 Exceeding LCO Mostly Not Applicable LC0's Actions or None Provided 3.0.2 Implementation of LC0 Actions B. Entry into a Higher 3.0.4 Changes in Modes or Not Applicable Operating Condition Conditions C. Operabihty of Safety-3.0.6 Support System Not Applicable Related Components with 3.8 Electrical Power Emergency Power Sources MYTS 3.0.A contains requirements to be implemented when an LC0 is not met. MYTS 3.0.A 1 directs the performance of any specified remedial action as the first step in the sequence of responses to an LC0 not being met. This direction is reworded and retained in PDTS 3.0.2.

MYTS 3.0.A.2 and 3 direct the reactor shutdown actions to be taken when an LC0 and its associated remedial action statements cannot be satisfied, notwithstanding specified exceptions. MYTS 3.0.A.2 and 3 are not relevant with the plant in the permanently shutdown condition. Therefore, since this specification would be meaningless in the PDTS. it has not been retained.

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ATTACHMENT I Page 19 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 l

MYTS 3.0.B contains restrictions on entry into a higher operating condition or specified condition when the LCO is not met withcut reliance upon the provisions contained in certain specified remedial actions statements. The LCO's retained in the proposed PDTS are applicable whenever irradiated fuel is stored in the spent fuel pool. Therefore, this specificatinn is not applicable

,d has not been retained in the proposeo PDTS.

l MYTS 3.0.C addresses the effect of the availability of emergency power sources on the operability of other equipment. As discussed in the following sections, the proposed LC0's in the PDTS do not cover operability of any electrically powered equipment. Therefore, this specification is not applicable and has not been retained in the proposed PDTS.

STS 3.0.5 permits equipment removed from service or declared inoperable to comply with action statements to be returned to service under administrative control to I

perform test 1ng required to demonstrate its operability or the operability of other equipment. The scope of LCO's specified in the PDTS are sufficiently reduced to make this provision unnecessary.

STS 3.0.7 allows specified Technical Specifications requirements to be changed to permit performance of special tests and operations. Since no special test exceptions are specified in the PDTS for the performance of special tests and operations, this provision is unnecessary.

MYTS Subsection 3,1 Reactor Core Instrumentation MYTS 3.1 contains LC0's which must be satisfied for the in core instrumentation system to be considered operable as required for calibrating the ex-core symmetric offset protection system and for other purposes as required by MYTS 3.10.

The in-core instrumentation system functioned to monitor the spatial distribution of neutron flux in the reactor core.

The ex-core symmetric offset protection system is only applicable in the Power Operation Condition. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, these systems are no longer required and the specification has been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(14) criteria for inclusion into the technical specifications as discussed under the Background section above.

HYTS Subsection 3.2 Reactor Coolant System Activity - The LC0's in this specification apply to the measured maximum activity in the reactor coolant system.

These limits ensure that the resulting 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months doses at the site boundary will not exceed an appropriately small fraction of the Part 100 limit following a steam generator tube rupture. Since the reactor has been permanently shutdown and defueled, the steam generator tube rupture incident can no longer occur at Maine Yankee. Therefore, this specification has been deleted from the PDTS. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(11) criteria for inclusion into the technical oecifications as discussed under the Background section above.

1 ATTACMENT I Page 20 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CH M S l

l PROPOSED CHANGE NO. 207 l

l HYTS Subsection 3.3 Reactor Coolant System Operational Components - These LC0's l

specify the requirements for reactor coolant system components to assure 1) adequate l

core heat transfer capability under all operating, transient and emergency conditions 2) uniform RCS boron concentration during boration or dilution evolutions, and 3) overpressure protection. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the functions of the reactor coolant system are no longer required to prevent or mitigate the consequences of a postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50,36(c)(2)(ii) criteria discussed under the Background section above.

MYTS Subsection 3,4 Combined Heatup Cooldown and Pressure. Temperature Limitations -

These LCO*S specify temperature and pressure related conditions during RCS heatup-and cooldown to assure protection of the reactor coolant pressure boundary. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the functions of the reactor coolant system are no longer-required to prevent or mitigate the consequences of a postulated accident. Furthermorec these specifications are based upon assuring compliance with 10CFR50 Appendix G, as-invoked by 10CFR50.60. On July 29, 1996, the NRC issued the final decommissioning rule and amended 10CFR60 to categorically exempt facilities which have submitted 10CFR50.82(a)(1) certifications from 10CFR50 Appendices G and H.

Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condit,an, the specifications meet none of the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above.

MYTS Subsection 3,5 Chemical and Volume Control System These LCO's specify requirements woich ensure adequate boration capability. These specifications apply whenever there is fuel in the reactor. Since the reactor at the Maine Yankee faci? ty has been permanently shutdown and defueled, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria discussed under the Background section above.

MYTS Subsection 3,6 Emergency Core Cooling and Containment Spray Systems These LCO's are concerned with the operation of various emergency core cooling systems.

These systems include the safety injection tanks, high pressure safety injection pumps, low pressure safety injection pumps, service water pump';, component cooling pumps, containment spray pumps and residual heat removal heat exchangers, associated valves, and the refueling water storage tar.k. The limitations on the operation of this equipment ensure that cooling can be provided to the reactor following a postulated loss of coolant accident, Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, a loss of coolant from the reactor coolant system is no longer of concern and the reactor coolant system no longer serves any function to prevent or mitigate the consequences of any postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in t% permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria discussed under the Background section above.

ATTACHMENT I Page 21 of 46 MCKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 4

HYTS Subsection 3,7 Boron and Sodium Hydroxide Available for the Containment Spray System These LC0's are concerned with the availability of borated water for boron injection, core cooling and containment spray and the availability of sodium hydroxide solution for iodine adsorption. These LCO's specify concentration and volume inventory requirements for borated water and spray chemical water. These requirements ensure that cooling can be provided to the reactor and radioactive iodine can be adsorbed to limit the release radioactive material to the environment following a postulated loss of coolant accident. Since the reactor at the Maine Yankee _ facility has been permanently shutdown and _defueled, a loss of coolant from the. reactor coolant system is no longer of concern, the reactor coolant system no longer serves any function to prevent or mitigate the consequences of any postulated accident and there are no remaining postulated accidents which require the integrity of the primary containment to be maintained, Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria discussed under the Background section above.

MYTS Subsection-3,8 Reactor Core Energy Removal These LCO's are concerned with ensuring the capability to remove energy from the reactor core under normal operations and transient and accident conditions. LCO's covering the operation of the steam generators ensure the ability _to remove heat generated by the reactor from the reactor coolant systems. These LCO requirements do not apply when there is no fuel in the reactor. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled

-condition. the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria discussed under the Background section above.

MYTS Subsection 3,9 Operational Safety Instrumentation, Control Systems, and Accident Monitoring Systems The subsection of the MYTS contains LC0's related to a wide variety of instrumentation systems, Tne following table lists the various specifications in the MYTS Subsection.

3.9 Operational Safety Instrumentation, Control Systems, and Accident Monitoring Systems l

Current MYTS Improved STS Proposed PDTS A. Reactor Protection 3,3.1 Reactor Protective Not Applicable System System (RPS)

Instrumentation-Operating 3.3.2 Reactor Protective System (RPS)

Instrumentation Shutdown 3.3.3 Reactor Protective System (RPS) Logic and Trip Initiation 4

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AllACHMENT I Page 22 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGLS PROPOSED CHANGE NO. 207 3.9 Operational Safety Instrumentation, Control Systems, and Accident Monitoring Systems Current HYTS Improved STS Proposed PDTS B. Engineered Safeguaros 3.3.4 Engineered Safety Not Applicable features Actuation System features Actuation System (ESFAS) Instrumentation 3.3.5 Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip C. Accident Monitoring 3.3.11 Post Accident Not Applicable System Monitoring (PAM)

Instrumentat1on MYTS 3.9,A and 3.9.B cover the instrumentation associated with the reactor trip system and the engineered safety features actuation system. These systems are desighed to shutdown the reactor or initiate automatic protective actions when parameters exceed selected limits. The systems function to prevent or mitigate the consequences of postulated accidents that could result in damage to the reactor fuel cladding or the reactor coolant pressure boundary. Reactor operations have been terminated at the Maine Yankee facility and the reactor has been permanently defueled.

Therefore, the postulated accident scenarios requiring actuation of these systems are no longer possible at the Maine Yankee facility and these specifications have not been retained in the proposed PDTS.

MYTS 3.9.C contains LCO's for accident monitoring instrumentation. This instrumentation is intended to provide information on selected plant parameters to monitor and assess variables during and following an accident that causes damage to the reactor core and/or a breach of the reactor coolant pressure boundary. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, such postulated accidents are no longer possible and the functions of this instrumentation are no longer required. Therefore, this specification has not been l

retained in the PDTS, With the reactor in the permanently shutdown and defueled condition, the specifications of MYTS Subsection 3.9 meet none of the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above.

HYTS Subsection 3.10 CEA Group, Power Distribution, Moderator Temperature Coefficient Limits and Coolant Conditions These LC0's restrict the allowable spatial distribution of nuclear and thermal power generation within the reactor core. LCO's in this section include limitations on control element assemblies (CEA's), shutdown margin, linear heat rate, radial peaking factor, symmetric of fset and azimuthal power tilt, moderator temperature coefficient and reactor coolant conditions. These 11mitations ensure that the integrity of the fuel cladding is maintained during normal reactor operations and anticipated transients and that the initial conditions assumed in the analyses of postulated accidents affecting the

t ATTACHMENT I Page 23 of 46 BACKGROWD AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 reactor core remain valid. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, these specifications are no longer applicable and-have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above.

MYTS Subsection 3.11 Containment These LC0's requirements serve to ensure the integrity of the primary containment. The primary containment serves to limit the release of radioactive mater 1al to the environment in the event of postulated accidents that release radioactive materials from the reactor coolant system. Since i

the reactor at the Ma1ne Yankee facility has been permanently shutdown and defueled, there are no remaining postulated acc1 dents which require the integrity of the primary containment to be maintained. Therefore, the specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above.

MYTS Subsection 3.12 Station Service Power - This MYTS subsection contains LC0's associated with the AC and DC power sources and distribution systems.

The LCO's are intended to ensure that sufficient nower is available to supply the safety related equipment required for tne safe shutdown of the facility, the mitigation of accident conditions, and the monitoring of the facility status. These LCO's are not applicable, in the current Maine Yankee Technical Specifications, with the reactor in the permanently shutdown and defueled condition. The proposed PDTS do not contain LCO's for active safety systems. The limited set of remaining LC0's consists of limitations on selected parameters associated with the storage of irradiated fuel in the spent fuel pool (i.e., water level and boron concentration).

These parameters are not subject to rapid change and do not require continuous monitoring. NUREG/CR 6451 indicates that a total loss of cooling to the spent fuel pool would allow over 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months of boil off before any spent fuel woula be exposed and potentially damaged. There is sufficient time to effect repairs to the cooling system or to establish makeup flow prior to uncovering the irradiated fuel.

Since active safety systems are not contained in the proposed PDTS and since the electrical power specifications meet none of the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above, the specifications covering electrical power to support such spent fuel related systems have not b y retained in the proposed PDTS.

MYTS Subsection 3,13 Refueling and Fuel Consolidation Operations - This MYTS subsection contains a number of specifications related to refueling operations.

Since refueling operations are no longer conducted at the Maine Yankee facility.

most of these specifications are not applicable to the storage of irradiated fuel in the spent fuel pool. The limited set of remaining LC0's consists of limitations on selected parameters associated with the storage of irradiated fuel in the spent fuel pool (1.e., water level and boron concentration). The specifications contained in this MYTS section are listed in the following table and are discussed separately below.

ATTACHMENT _1 Page 24 of 46 BACKGROUND _AND D[$CRIPTION OF___ PROPOSED CHANGES PROPOSED CHANGE N0m 207 3.13 Refueling and fuel Consolidation Operations Current MYTS Improved STS Proposed PDTS A. Fuel Handling Crane -

Not included Relocate to the FSAR Load Test B. Decay Time - Irradiated Not included Not lncluded Fuel C. Refueling Boron 3.9.1 Boron Concentration 3.1.2 Spent Fuel Pool Concentration Baron Concentration D. Core Alterations or Movement of Irradiated Fuel within Containment D.1 Decay Time -

3.9.3 Containment Not Applicable Containment Equipment Penetrations Hatch D 2 Decay Time - Personnel 3.9.3 Containment Not Applicable Airlock doors Penetration D.3 Containment Venting 3.9.3 Containment Not Applicable and Purging Penetrations 3.3.7 Containment Purge Isolation Signal D.4 Radiation 3.9.3 Containment Not Applicable Instrumentation for Penetrations Containment Ventilation 3.3.7 Containment Purge isolation Isolation Signal D.5 Containment Purge Trip 3.9.3 Containment Not Applicable Valve Testing Penetrations 3.3.7 Containment Purge Isolation Signal D.6 Radiation Monitoring Not Included Relocate to the FSAR D.7 Neutron Flux 3.9.2 Nuclear Not Applicable Instrumentation Instrumentation 0,8 Residual Heat Removal 3.9.4 Shutdown Cooling and Not Applicable Coolant Circulation - High Water Level D.9 Residual Heat Removal 3.9.5 Shutdown Cooling and Not Applicable

- Low Water Level Coolant Circulation - Low Water Level D.10 Minimum Water Level 3.9.6 Refueling Water 3.1.1 Spent Fuel Pool Level Water Level

ATTACHMENT I Page 25 of 46 MCKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 3,13 Refueling and fuel Consolidation Operations Current MYTS Improved STS Proposed PDTS D.11 Connunication Not included Not Applicable E. Spent Fuel Storage Rack Not included Relocate to the FSAR Movement F Decay Time Fuel Not included Relocate to the FSAR Consolidation MYTS Suosection 3.13.A contains requirements related to the testing : 1 the fuel handling cranes prior to each refueling. Since the Maine Yankee reactor has been permanently shutdown and defwled, there will no longer be any refuelings. Crane design, inspection and testing along with detailed fuel handling instructions help to prevent the occurrence of fuel handling accidents. While the fuel handling accident in the spent fuel pool remains a valid DBA for the Maine Yankee facility, this specification meets none of the 10CFR50.36(c)(2)(1i) criteria discussed under the Background section above and is not included in the Standard Technical Specif1 cations. Therefore, this specification has not been retained in the proposed PDIS. Maine Yankee proposes to relocate MYTS 3.13.A to the FSAR, MYTS Subsection 3.13.B specifies a minimum decay time prior to the movement of irradiated fuel assemblies in the reactor pressu, vessel. This decay time ensures

)

that short lived fission products are allowed to decay such that the remaining inventory of fission products in a fuel assembly 15 consistent with the assumptions of the accident analyses for a fuel handling accident. Since the reactor has been permanently defueled end approximately nine months have elapsed since final reactor operation, this specification is no longer necessary to protect the initial conditions of any DBA. Therefore, this specification has not been retained in the proposed PDTS, MYTS Subsection 3.13.C sets limits on the soluble boron concentration in the reactor coolant system and refueling canal, The limits ensure that the reactor remains subtritical whenever the reactor vessel head is removed and there is fuel in the reactor. Since the reactor has been permanently defueled, this specification is no longer applicable to the Maine Yankee facility and has not been retained in the proposed PDTS. However, a specification for boron concentration in the Spent Fuel Pool is included in the PDTS.

MYTS Subsection 3.iJ.D specifies conditions to be satisfied during core alterations or movement of 1rradiated fuel within the containment. Since the reactor has been permanently defueled and irradiated fuel 1s no longer located in the containment, this spec 1fication, as written, is no longer applicable to the Maine Yankee facility. However, the continued applicability of each subsection of this specification is described below.

MYTS Subsections 3.13.D.1, 2. 3, 4 and 5 contain requirements related to the containment building penetrations and containment ventilation and purge 1 solation.

These requirements ensure that radioactive materials released to the environment due

ATTACHMENT 1 Page 16 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CMLS PROPOSED CH&NGE NO. 207 to a postulated fuel handling acc1 dent in the containment are limited. Since the reactor has been permanently defueled and irradiated fuel is no longer located in the containment, this specification is no longer applicable to the Maine Yankee facility and has not been retained in the proposed P015.

MYTS Subsection 3.13.D.6 contains a requirement to continuously monitor radiation levels in the containment and spent fuel storage areas. This monitoring requirement provided for innediate indication of an unsafe condition related to core alterations and fuel handling. Since the reactor has been permanently defueled and irradiated fuel is no longer located in the containment, the requirement to monitor radiation levels in containments as an indicator of an unsafe condition related to core alterations or fuel handling no longer applies.

While the fuel handling accident in the spent fuel pool remains a valid DBA for the Maine Yankee facility, this l

specification meets none of the 10CFR50.36(c)(2)(ii) criteria discussed under the Background section above and is not included in the Standard Technical Specifications. Therefore, this specif1 cation has not been retained in the proposed PDTS. This is consistent with the improved Standard Technical Specifications contained in NUREG 1432. Maine Yankee proposes to relocate MYTS 3.13.D.6 to the FSAR.

MYTS Subsection 3.13.D.7 contains requirements related to the source range neutron flux monitors.

This instrumentation is used to detect changes in the reactivity of the reactor core. Since the reactor has been permanently defueled, this specification is no longer applicable to tho Maine Yankee facility and has not been retained in the proposed PDTS.

MYTS Subsections 3.13.D.8 & 9 contain requirements related to the operation of the residual heat removal system to prcvide cooling to the fuel in the reactor vessel during refueling operations and under different water levels. Since the reactor has been permanently defueled, the residual heat removal system is no longer required to perform this function and this specification has not been retained in the proposed PDTS.

MYTS Subsection 3.13.D.10 specifies the minimum water icvel above the top of the core whenever irradiated fuel is being moved. The specified water level helped to limit the consequences of a fuel handling accident. Since the reactor has been permanently defueled and irradiated fuel is no longer located in the containment, there is no longer a potential for a fuel handling accident in the containment. A potential fuel handling event in the spent fuel pool remains a valid DBA for the Maine Yankee facility. Therefore limitation on minimum water level in the spent fuel pool has been retained as PDTS 3.1.1 and revised to be consistent with the improved Standard Technical Specifications. PDTS 3.1,1 requires that the spent fuel pool le :1 be maintained within limits during the movement of irradiated fJel in the spent fael pool, A verification of compliance at a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months frequency is required Lenev& the LC0 applies. The actions associated with this LCO require immediate suspenr,on of movement of irradiated fuel. This period is appropriate since the immediate actions preclude the possibility of a fuel handling accident or the loss of water shielding during fuel movement. The Bases for PDTS 3.1.1 include the function of the spent fuel pool coolant inventory in providing shielding during the movement of irradiated fuel.

ATTACfMNT I Page 27 of 46 BACKGROUNQED_DESCRIPTIONOEPROPOSEDCHANGES PROPOSED CIMNGE NO. 207 MYTS Subsection 3.13.D.11 requires comunications capability such that refueling station personnel can be itformed of significant changes in the facility status or core reactivity conditions oping core alterations. Since the reactor has been permanently defueled, this spec:fication is no longer applicable to the Maine Yankee l

facility and has not been retained in the proposed PD15.

l MYTS Subsection 3.13.E contains a requirement to move spent fuel storage racks only in accordance with approved procedures which ensure that no rack modules are moved over fuel assemblies. This specification prevented the unnecessary risk of spent fuel damage caused by dropping spent fuel racks. This requirement will continue to be maintained at Maine Yankee. However. Since the specification meets none of the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above and is not included in the Standard Technical Specifications it has not been retained in the PDTS. Maine Yankee proposes to relocate MYTS 3.13.E to the FSAR.

MY15 Subsection 3.13.F contains a requirement to prohibit 1rradiated fuel consolidation until after a cooling period has elapsed. This prohibition ensured that the dose consequences of a consolidated spent fuel handing accident are bounded by the consequences of the design basis spent fuel drop accident.

It also ensured that the maximum outlet temperatures for the limiting fuel assembly and the consolidated fuel storage bundle are both well below the saturation temperature at the cell outlet for any storage array. All but the irradiated fuel discharged from the last cycle has completed the cooling period. Maine Yankee proposes to relocate MY1S 3.13 F to the FSAR to preserve the option of future fuel consolidation up to the limit of 20 consolidated assemblies as specified in PDTS 4.2.3.

HYTS Subsection 3,14 Primary System Leakage - This MYTS subsection contains limitations on the operation of the plant under varying rates and conditions of reactor coolant (primary) system leakage. Since the reactor at ' < 3 Maine Yankee facility has been permanently shutdown and defueled, the functions of the reactor --

coolant system are no longer required to prevent or mitigate the consequences of a postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutoown and defueled condition the specifications meet none of the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above.

HYTS Subsection 3.15 Reactivity Anomalies This MYTS subsection contains requirements to periodically compare the actual reactor coolant system boron concentration to the predict (d value. This specification provides for the detection of reactivity anomalies with m the reactor. Since the reactor at the Maine Yankee fac111tj has been permanently shutdown and defueled, this spec 1fication is no longer applicabit. it meets none of the 10CFR50.36(c)(2)(ii) criteria discussed under the Background action above and has been deleted.

MYTS Subsection 3.16 - Previously Deleted MYTS Subsection 3.17 Gaseous Radioactive Waste Storage - This M(TS subsection contains requirements related to gaseous waste stored in the Radioactive Waste Gas Storage Drums. Limits were specified for the quantity of radioactivity and the concentration of explosive gas contained in the drums. These limitations were

ATTACHMENT I Page 28 of 46 BACKGRQUND AND_ DESCRIPTION OF PROPOSED CHANGES PROPOSED CIRNGE NO. 207 established to minimize the possibility of drum rupture and assure that all releases would be within the dose limits specified in 10 CFR Part 20. With the reactor permanently defueled, there is no longer a need to degasify primary coolant. The contents of the waste gas decay tanks have been purged. This system will not be used to support decontamination /decomissioning and will not be used in any gaseous radioactive waste crocessing functions. Therefore, this specif1 cation does not meet any of the 10CFR50.36(c)(2)(ii) criteria discussed under the Background section above and has not been retained in the PDTS.

MYTS Subsection 3,18 Reactor Coolant System Oxygen and Chloride / Fluoride Concentration This subsection contains limitations on the maximum oxygen and chloride / fluoride concentrations in the reactor coolant system. These limitations assure protection of the functional integrity of the material in the reactor coolant system. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the functions of the reactor coolant system are no longer I

required to prevent or mitigate the consequences of a postulateo accident.

Therefore, these specifications are no longer applicable and have been deleted.

With the reactor in the permanently shutdown and defueled condit1on, the specifications meet none of the 100FR50.36(c)(2)(11) criteria :.3 cussed under the Background section above.

MYTS Subsection 3,19 Safety Injection System This subsection contains requirements related to the condition of safety injection system isolation and loop stop valves, These requirements assure that plant operation is restricted to conditions considered in the loss of coolant accident analysis and valve failure does not result in a : ate of flow which would exceed the pressure relief capacity of certain systems which interface with the reactor coolant system. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, a loss of coolant from the reactor coolant system is no longer of concern ano the reactor coolant system no longer serens any function to prevent-or mitigate the consequences of any postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above.

HYTS Subsection 3,20 Shock Suppressors (Snubbers)

MYiS Section 3.20 contains LC0's associated with snubbers, Functional snubbers were required to ensure the structural integrity of the reactor coolant system and other safety-related systems following a seismic or other dynamic load. This specification is not included in the improved Standard Technical Specifications. Snubbers do not meet the 10CFR50.36 criteria for inclusion in technical specifications and are not retained in the improved Standard Technical Specifications. Therefore, this specification is not retained in the proposed PDTS.

MYTS Subsection 3,21 Previously Deleted HYTS Subsection 3,22 Feedwater Trip System This subsection specifies the conditions of the feedwater trip system necessary to ensure the steam generator cooldown potential remains acceptable in the event of a main steam line break.

Limiting the reactor coolant system cooldown limits the reactivity insertion

ATTACHMENT I Page 29 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 associated with a negative reactivity temperature coefficient during the cooldown associated with the main steam line break. 51nce the reactor at the Maine Yankee facilltv has been permanently shutdown and defueled, the effects of a cooldown on reactivity resulting from a main steam line break are no longer of concern and the feedwater trip system no longer serves any function to mitigate the consequences of any remaining postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specificat% mect none of the 10CFR50.36(c)(2)(ii) criteria discussed under the PSckground section above.

MYTS Subsection 3.23 Previously Deleted HYTS Subsection 3.24 Secondary Coolant Activity - MYTS subsection 3.24 contains LCO's associated with the maximum activity in the secondary coolant system. These limitations insure that the resultant offsite radiation dose is limited to a small fraction of 10 CFR Part 100 following a steam line rupture. The activity limit applies to Dose Equivalent lodine 131. Since the reactor has been shutdown and permanently defueled, this system is no longer pressurized and no longer has a significant source of lodine-131. Therefore this specification has not been retained in the proposed PDTS. With the reactor in the permanently shutdown and defueled condition, the specification meets none of the hUR50.36(c)(2)(11) criteria discussed under the Background section above.

MYTS Subsection 3.25 Installed Ventilation and Filter Systems - MYTS subser, tion 3.?5 defines the required operating status of installed ventilation and filter systems.

With the reactor in the permanently shutdown and defueled condition nore of these specifications apply. The disposition of these specifications is desr. ib in the table below:

3.25 Installed Ventilation and Filter Systems Current MYTS Improved STS Proposed PDTS A. Containment Hydrogen 3.6.8 Hydrogen Recombiners Not Applicable Purge 3.6.9 Hydrogen Mixing Systems B. Control Room 3.7.11 Control Room Not Applicable Ventilation System Emergency Air Cleanup System 3.7.12 Control Room Air Temperature Control System 3.3.8 Control Room Isolation Signal C. Spent Fuel Pool 3.7.14 Fuel Building Air Relocate to the FSAR Ventilation System Cleanup System MYTS Subsection 3.25.A contains a requirement to maintain the containment hydrogen purge system operable whenever the reactor is critical. This system serves to

ATTACHMENT _1 Page 30 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 l

detect and control the concentration of hydrogen within the containment to keep it i

below its flammable limit following a loss of coolant accident, thus preserving the function of the containment system. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, a loss of coolant accident is no longer of concern and there are no remaining postulated accidents which require the integrity of the primary containment to be maintained. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50,36(c)(2)(ii) criteria discussed under the Background section above.

MYTS substetion 3.25.B contains LCO's associated with the control room ventilation system. The control room ventilation system ensures that the control room i

temperature does not exceed the duty rating of equipment and instrumentation cooled by this system and ensures that the control room will remain habitable for personnel during and following credible accidents involving the release of radioactive materials or toxic gases. The specification requires one train of control room l

ventilation to be operable whenever the reactor coolant system temperature and pressure exceed 210'F and 400psig. Two trains are required whenever the reactor is critical. This specification is no longer applicable for Maine Yankee since the reactor is permanently shutdown and defueled. This system does not n,eet the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above.

Therefore, this specification has not been retained in the proposed PDTS.

MYTS Section 3.25.C contains LCO's related to the spent fuel pool ventilation system. This system provides filtration for radioactive material released from an 1rradiated fuel assenAly as a result of a postulated fuel handling accident. The specification requir y the spent fuel pool ventilation system to be operating and discharging through the HEPA and charcoal filter train when irradiated fuel which has decayed less than 60 days 1s in the spent fuel pool and either fuel is being moved in the spent fuel pool or the crane is being-operated with loads over the spent fuel pool. Since, all of the fuel in the spent fuel pool has decayed greater than 60 days, the specification is no longer applicable.

In accordance with the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above, this specification has not been retained in the proposed PDTS. However, because the spent fuel pool ventilation system is associated with the safe storage of spent fuel, Maine Yankee proposes to relocate MYTS 3.25.C to the FSAR.

HYTS Subsection 3.26 - Previously Deleted HYTS Subsection LD - Previously Deleted HYTS Subsection 3.28 - Previously Dele +ed

ATTACHMENT I Page 31 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 HYTS Section 4 Surveillance in accordance with 10 CFR 50.36(c)(3), surveillance requirements are related to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operations will be met. The surveillance requirements for the PDTS are provided for each LC0 directly following that LCO rather thar. being contained in a separate section like the MYTS. This format change is consistent with the STS.

Since there are no safety limits which apply to Maine Yankee with the reactor in the shutdown and permanently defueled condition and since there are relatively few remaining LCO, the number of surveillance requirements have been greatly reduced.

The following table shows a comparison between the provisions of the current MYTS.

the corresponding sections of the improved Standard Technical Specifications and the proposed PDTS.

Surveillance Current MYTS Improved STS Proposed PDTS 4.0 Surveillance SR 3.0 Surveillance SR 3.0 Surveillance Requirements Requirement (SR)

Requirement (SR)

Applicability Applicability 4.1 Instrumentation and SR 3.3 Instrumentation Mostly Not Applicable.

Control Relocate certain radiation monitors to the FSAR 4.2 Equipment and Sampling SR 3.4 Reactor Coolant Mostly Not Applicable Tests System except for:

SR 3.S Emergency Core SR 3.1.2 Spent Ft.el Pool Cooling System Boron Concentration SR 3.6 Containment Systems and the following:

SR 3.7 Plant Systems 4 2 Table 4.2-1 Item 8 Not included Relocate to the Liquid Radwaste Radioactive Effluents Radioactivity Analysis Control Program 4.2 Table 4.2-1 Item 11 hot included Relocate to the FSAR Sealed Source Leakage 4.2 Table 4.2-1 Item 18 Not included Relocate to the Incinerated 011 Principal Radioactive Effluents Gama Control Program 4,3 Reaccor Coolant System Not included Not Applicable Leak Tests 4.4 Containment Testing 3.6 Containment System or Not Applicable Program Required by 5.5 I

ATTACHMENT I Page 32 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES ER0 POSED CHANGE NO. 20Z Surveillance Current MYTS Improved STS Proposed PDTS 4.5 Emergency Power System 3.8 Electrical Power Not Applicable Periodic Testing Systems 4.6 Periodic Testing SR 3.5 Emergency Core Not Applicable Cooling System SR 3.6 Containment Systems SR 3.7 Plant Systems Programs Required by 5.5 4.7 Inservice Inspection Program Required by 5.5 5.6.5 Inservice Testing and Testing of Safety Program Class Components 4.8 Deleted Not Applicable Not Applicable 1

4.9 Shock Suppressors Not included Not included (Snubber) Surveillance Testing 4.10 Steam Generator Tube Program Required by 5.5 NM Applicable Surveillance 4.11 Ventilation Filter Program Required by 5.5 Not Applicable System Surveillance Testing 4.12 Deleted Not Applicable Not Applicable 4.13 Deleted Not Applicable Not Applicable NYTS Subsection 4.0 Surveillance Requirements - This section contains specif_ications that have generic applicability to the surveillance requirements. The disposition of these specifications is described in the table below:

4.0 Surveillance Requirements Current MYTS Improved STS Proposed PDTS A. Maximum Allowable SR 3.0.2 25% Extent of SR 3.0.2 25% Extent of Surveillance Interval Surveillance frequencies Surveillance Frequencies Extension B. Applicability of SR 3.0.1 Applicability of SR 3.0.1 Applicability of Surveillance Requirements Surveillance Requirements Surveillance Requirements MYTS 4.0.A and 4.0.B are reworded to be consistent with the improved Standard Technical Specifications. Additional applicability requirements have been added to MYTS 4.0.A to specify the conditions when a surveillance requirement applies and the consequences of a failure to meet or perform a surveillance requirement.

ATTACHMENT I Page 33 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 PDTS SR 3.0.3 has been added to allow for the possibility of the discovery that a surveillance has not been performed. This specifications permits a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months delay in declaring the LCO not met in order to allow performance of the surveillance after it is discovered that a surveillance was not performed. This specification is consistent with the improved Standard Technical Specifications.

STS 3.0.4 prohibits entry into an operating mode or other specified condition 1n the applicability of an LCO unless the surveillances have been met within their specified frequency. This prohibition is subject to certain conditions. Since the reactor at the Maine Yankee facil1ty is permanently shutdown and defueled, there will no longer be any changes in operating condition or mode, Therefore, this specification is unnecessary and has not been included.

MYTS 4.1 Instrumentation and Control - This subsection specifies the minimum frequency and type of surveillance to be applied to critical plant instrumentation and controls. These surveillance requirements apply primarily to equipment specified in MYTS 3.9.

Tables 4.1 1 and 4.1 2 specify the calibration, testing cnd checking of instrument channels associated with the reactor trip system and the l

engineered safety features actuation system. As described above for MYTS 3.9. the postulated accident scenarios requiring actuation of these systems are no longer possible at the Maine Yankee facility and these specifications have not been retained in the proposed PDTS. Therefore the surveillance requirements in Tables 4.1 1 and 4.1-2 have not been retained in the proposed PDTS.

l Table 4.1-3 specifies the calibration, testing and checking of miscellaneous instrumentation systems. As described abcVe for MYTS 3.9.C most of these instrumentation systems are intended to provide information on selected plant parameters to monitor and assess variables during and following an accident that causes damage to the reactor core and/or a breach of the reactor coolant pressure boundary. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, such postulated accidents are no longer possible and the functions of these instrumentation systems are no longer required. Other instrumentation is associated with systems which are no longer required by the proposed PDTS as described above for MYTS Section 3.

MYTS 4.1. Table 4.1-3, item 3 Radiation Area Monitors This instrumentation monitors areas for increasing radiation and radioactivity in plant areas and gives early warning of possible plant malfunctions. MYTS 4,1, Table 4.1-3. Item 18 Radiation Process and Effluent Monitors This instrumentation gives early warning of plant malfunctions by monitoring various process streams. Since the reactor has been permanently shutdown and defueled and the irradiated fuel storage limited to the Fuel Building, the number of accidents which could result in significant changes in radiological conditions or radioactive effluents have been greatly reduced.

While there are acc1 dents, including the fuel handling accident in the spent fuel pool, that remain valid DBA's for the Maine Yankee facility, this specification meets none of the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above and is not included in the improved Standard Technical Specifications.

Therefore, Maine Yankee proposes to relocate MYTS 4.1 Table 4.1-2. Item 3 to the FSAR.

1

ATTACHMENT I Page 34 of 46 BACKf/101)ND AND DESCRIPTION OF PROPOSED CHANZS P30 POSED CHANGE NO. 207 MYTS Subsection 4,2 Equipment Sampling Tests - This subsection specifies the minimum frequency and type of surveillance to be @ plied to critical plant equ1pment and conditions. Table 4.2 1 specifies the minimum frequency for sampling tests of various system contents including the reactor coolant system, refueling water tank, boric acid storage tank, safety injection tanks, spent fuel pool, secondary coolant, liquid radwaste, radioactive gas decay tanks, spray chemical addition tank, sealed sources and oil targeted for incineration. The tyne of sampling tests performed include radioactivity, isotopic analysis, chnical concentration and contamination leakage. Most of these systems are no long. required by the proposed PDTS as described above for MYTS Section 3.

All of the sampling tests listed in Table 4.2-1 have been eliminated from the PDTS for this reason with the exception of the following items:

MYTS 4.2, Table 4.2-1, Item 6 Spent Fuel Pool Boron Concentration - The current sa ipling frequency listed in MYTS for boron concentration in the spent fuel pool is monthly.

The proposed PDTS 3.1.2 requires the sampling frequency to be every seven days whenever fuel is stored in the spent fuel pool and a fuel pool verification has not been performed tince the last movement of fuel assemblies in the spent fuel paol. These sampling frequencies ensure that the accident analysis assumptions are mal'tained with sufficient confidence as described below for PDTS 3.1.2.

MYTS 4.2. Table 4.2 1, item 8 Liquid Radwaste Radioactivity Analysis - The current MYTS require radioactivity analysis of liquid radwaste prior to celease from the test tank. This specification does not meet the 50.36(c)(2)(11) criteria discussed in the Background section above and is not included in the improved Standard Technical Specifications. Maine Yankee proposes to relocate MYTS 4.2, Table 4.2 1, item 8 to the Radioactive Effluent Controls Program.

MYTS 4.2, Table 4.2 1. Item 11 Sealed Source Leakage - The current MYTS require radioactive sealed sou ces to be leak tested for contamination semiannually. This requirement was intended to ensure that radiation dose relating from ingestion or inhalation of source material do not exceed allowable limits. This specification does not meet the criteria listed in 10CFR 50.36(c)(2)(ii) for inclusion in the Technical Specifications nor is this specification included in the improved Standard Technical Specifications. This specification does not involve instrumentation used to detect a significant abnormal degradation of the reactor coolant pressure boundary.

It does not involve initial conditions assumed in any design basis analyses.

It does not involve the function of any equipnent or structure needed to prevent or mitigate any DBA. Finally, the specification does not involve any structure, system or component which has been shown to be significant to public health and safety. Maine Yankee proposes to relocate MYTS 4.2. Table 4.2-1. Item 11 to the FSAR.

MYTS 4.2. Table 4.2-1, Item 13 Incinerated Oil Principle Gama -

The current MYTS require a grab sample of oil, in liquid form, prior to incineration. This specification does not meet the 50.36(c)(2)(ii) criteria discussed in the Background section above and is not included in the improved Standard Technical Specifications.

Mdine iankee proposes to relocate MYTS 4.2, Table 4.2-1, Item 13 to the Radioactive Effluent Controls Program, o

ATTACHMENT I Page 35 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 MYTS 4.2. Table 4.2-C specifies the minimum frequencies of equipment tests of various systems and components including control element assemblies, safety valves, refueling system interlocks, diesel fuel supply, reactor coolant system leakage, turbine valves, post-accident containment vent system, pressurizer level and relief valves. None of these systems or components are included in the proposed PDTS as described above for MYTS Section 3.

Therefore, the related surveillance requirements have baen eliminated from the proposed PDTS.

MYTS Subsection 4,3 Reactor Coolant System Leak Tests - This subsection specifies the tests for reactor coolant system integrity after the system is closed following norma' opening, modification or repair. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the functions of the reactor coolant system are no longer required to prevent or mitigate the consequences of a pertulated accident. Therefore, this specification is no longer applicable and has been deleted.

MYTS Subsection 4,4 Containment Testing - These surveillance requirements serve to ensure the integrity of the primary containment. The primary containment serves to limit the release of radioactive material to the environment in the event of l

postulated accidents that release radioactive materials from the reactor coolant system. Since the reactor at the Maine Yankee facility has been permancntly shutdown and defueled, there are no remaining postulated accidents which require the integrity of the primary containment to be maintained. Therefore, the specifications are no longer applicable and have been deleted.

MYTS Subsection 4.5 Emergency Power System Testing - This MYTS subsection contains surveillance requirements associated with the AC and DC power sources and distribution systems.

The surveillances are intended to ensure that sufficient power is' available to supply the safety-related equipment required for the safe shutdown of the facility, the mitigation of accident conditions, and the monitoring of the facility status. The proposed PDTS do not contain LCO's for active safety systems. Since active safety systems are not contained in the proposed PDTS and since LCO's covering electric 31 power to m pport such spent fuel related systems have not been retained in the proposed PDTS, the related surveillance requirements have been celeted.

MYTS Subsection 4,6 Periodic Testing - This MYTS subsection contains surveillance requirements ascociated with various engineered safety features including the safety injection system, the containment spray system, a ntainment isolation, emergency feedwater system, main steam excess flow check valves, feedwater trip system and rn ctor coolant system emergency ventilation system. The surveillances involve a variety of ficw tests, valve exercises, valve position verifications, flow balances and automatic tctuations and are intended to verify that the subject systems or components will respond promptly to the applicable postulated accident condition and perform their intended func ions. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, such postulated accidents are no longer possible. The systems ad components included in the specification are no longer I

required to be operable in the proposed PDTS as described above for MYTS Section 3.

Therefore, the related surveillance requirements have been deleted.

4 ATTACHMENT I Page 36 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES SQPOSED CHANGE N0; 207 LHYTS Subsection 4.7 Inservice Inspection and Testing of Safety Class Components -

This subsection specifies the inservice testing and inspection of safety class 1. 2.

and 3 components as required t>y 10 CFR 50.55a(g). With the Maine Yankee reactor permanently shutdown and defueled many, if not all, of the components are no longer required to be tested and inspected. Maine Yankee is currently reviewing the' scope of the ISI and IST programs. The disposition of this review and any cor" quent revision to the ISI and IST programs will be addressed separately. In.the interim, the-lST portion of this specification has been transferred as a program requirement to PDTS 5.6.5.

This is consistent with the improved Standard Technical Specifications.

MYTS Subsection 4.8 - Previously Deleted HYTS Subsection 4.9 Shock Suppressor (Snubbers) Surveillance Testing - This subsection contains surveillance requirements associated with snubbers. MYTS subsection 3.20 contains LCO's associated with snubbers.

As described above, functional snubbers were required to ensure the structural integrity of the reactor

coolant system and other safety related systems following a seismic or other dynamic load. The LC0 subsection was not retained in the proposed PDTS. therefore, the related surveillance requirements in this subsection were also not retained in the prooosed PDTS.

MYTS Subsection 4.10 Steam Generator Tube Surveillance - This subsection contains surveillance requirements-necessary to demonstrated the operab'tiity of the steam generators. The surveillance requirements specify the selection of steam generators, tube sample size, inspection result classification, acceptance criteria.

inspection frequencies and reporting requirements. Since the reactor at the Maine TYankee facility has been permanently shutdown and defueled, the functions of the steam generators are no longer required to remove heat from the reactor coolant system or to prevent sr mitigate the consequences of a postulated accident.

Therefore. these specifications are no longer applicable and have been deleted.

MYTS Subsection 4.11 Ventilation Filter System Surveillance Testing - This subsection contains surveillance requirements (4.11.A. B. D. and a portion of 4.11.E) necessary to demonstrate the oper6bility of ventilation and filter systems including the containment hydrogen purge system, the control room recirculation and breathing system.-and the containment ventilation / purge system._ The LC0's for these systems are specified in MYTS 3.13.0.3 and 3.25. A. B. 'None of these LCO's were retained in the proposed PDTS. Therefore, the related surveillance requirements in this specification have not been retained in the proposed PDTS.

i MYTS 4.11.C and a portion of MYTS 4.11.E contain surveillance requirements necessary

~

to demonstrate the operability of the spent fuel pool ventilation system. The LC0 associated with this system is specified in MYTS 3.25.C. Maine Yankee proposes to-relocate.MYTS 3.25.C to the FSAR. Accordingly. Maine Yankee proposes to relocate the related surveillance requirement (MYTS 4,11.C and part of 4.11.E) to the FSAR.

MYTS Subsection 4.12 - Previously Deleted HYTS Subsection 4.13 - Previously Deleted

ATTACHMENT I Page 37 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 202 HYTS Section 5 Administrative Controls In accordance with 10 CFR 50.36(c)(5), administrative controls are the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

Although toe facility operating license no longer authorizes operation of the reactor in accordance with 10CrR 50. Q a)(2), certain administrative cont nis will continue to be required to provide for the safe storage and handling of spent fuel.

In Reference (c) Maine Yankee submitted a proposed change to the administrative controls section of the Technical Specifications. This application is being submitted under the assumption that the NRC will have approved Reference (c) by the time NRC approval is obtained for this application. Therefore, the basis for the changes submitted under Reference (c) are not repeated herein.

Consistent with the forrrJt of NUREG 1432 (STS), the administrative controls section is located in Section 5 n of the proposed PDTS. Where practicable, the individual specifications in the prc>osed PDTS have also been patterned after those contained in the STS. Some deviations from the standard technical specifications have been included as appropriate to the unique status of the Maine Yankee facility. The scope and complexity of activities, and consequently the size of the staf f, at the Maine Yankee facility is greatly reduced from those required for an operating power plant. Therefore some administrative controls have been simplified as appropriate for the permanently defueled status of the reactor. Also, as demonstrated in the discussions above the potential impact on the health and safety of the public due to postulated act ents is much lower that at an operating power plant. Therefore, some administrative provisions have been simplified as appropriate. The specific provisions of the current MYTS are listed in the following table along with the corresponding sections of the improved standard technical specifications and proposed Maine Yankee PDTS. These specifications are discussed separately below.

Administrative Controls Current MYTS Improved STS Proposed PDTS 5.1 Responsibility 5.1 Responsibility 5.1 Responsibility 5.2 Organization 5.2 Organization 5.2 Organization 5.3 Facility Staff 5.3 Unit Staff 5.3 Unit Staff Qualifications Qualifications Qualifications 5.4 Training Not Included 5.4 Training 5.5 Review and Audit Not Included Relocate to the Quality Assurance Program 5.6 Reportable Event Not Included Not Included Action 5.7 Safety Limit Violation Not Included Not Applicable Report

AUACHMENT I Page 38 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 Administrative Controls Current MYTS Improved STS Proposed PDTS 5.8 Programs and 5.4 Procedures 5.5 Prccedures Procedures 5.5 Programs and Manuals 5.6 Programs and Manuals 5.9 Reporting Requirements 5.6 Reporting Requirements 5.7 Reporting Requirements 5.10 Record Retention Not included Relocate to the Quality Assurance Program 5.11 Radiation Protection 5.5 Programs and Manuals 5.6 Programs and Manuals Program 5.12 High Radiation Area 5.7 H1gh Radiation Area 5.8 High Radiation Area l

MYTS subsection 5,1 Responsibility - This subsection defines the individual with the l

overall responsibility for operation of the Maine Yankee facility as the Plant Manager. The content of subsection 5.1 has been augmented in the proposed PDTS to be consistent with the content of improved Standard Technical Specification.

The shift manager on-site has been designated with responsibility for the command function. The improved Standard lechnical Specifications require that the command function be maintained in the control room. This requirement is based on the centralized nature of the controls of an operating reactor and the rapid response necessary to command thase controls in an abnormal or accident situation. With the Maine Yankee reactor permanently shutdown and defueled and the irradiated fuel safely stored in the spent fuel pool, the number of relevant controls located in the t

control room and the gradual nature of abnormal and accident situations do not warrant that this command function remain in the control room. Capability is provided to maintain ready communication between the control room and the shift manager at all times. This ready communication capability includes: pagers, walkie-talkies and/or the plant paging system. The individual qualified to stand watch in the control room will be provided with the training necessary to take the appropriate initial responses as described in procedures.

A provision is added to utilize generic titles in the PDTS for members of the staff as provided in Regulatory Guide 1.8 - 1975 and/or ANSI N18.1 - 1971, unless otherwise defined in the technical specifications. Plant-specific Maine Yankee titles for the functions and responsibilities associated with these generic titles are identified in the FSAR and/or 0A program. This provision allows functions and responsibilities to be specified without constraining the nomenclature of the plant-specific titles. Changes to the plant-specific titles may be handled in accordance with the controlling regulatory process such as 10CFR50.54(a) or 10CFR50.59 as appropriate.

HYTS subsection 5.2 Organization - This subsection defines the general organizational requirements for the Maine Yankee facility. This subsection has been reworded and retained in PDTS 5.2.

This PDTS section is patterned after the format and wording of the improved Standard Technical Specifications. The provisions of

ATTACHMENT I Page 39 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 Proposed Change No. 206 to the Technical Specifications to address the permanently defueled condition have been retained. These provisions include the minimum shift crew composition and the requirements related to certified fuel handlers. MYTS 5.2.2.d has been deleted since there is no longer any fuel in the reactor.

Radiation protection requirements including the presence of on-shift individuals qualified in radiation protection procedures will be described in the Radiation Protection Program specified in PDTS 5.6.1.

The assertion of MYTS 5.2.2.g stating that an operator holding a Senior Reactor Operator (SRO) license is qualified as a certified fuel handler has been deleted as the SR0 licenses at the Maine Yankee facility will no longer be maintained once Proposed Change No. 206 is approved and implemented. However, the assertion continues to be correct. M(TS Table 5.2-1 has been redesignated as PDTS Table 5.2.2-1.

MYTS 5.2.2.i has been transferred to this table and augmented to be consistent with the wording in the improved Standard Technical Specifications. The provisions contained in MYTS 5.8.5 on unit staff working hours have been transferred to PDTS 5.2.2.e and reworded to be consistent with the wording of the improved Standard Technical Specifications to the extent consistent with the permanently shutdown and defueled status of the reactor.

MYTS subsection 5.3 Facility Staff Qualifications This subsection specifies the requirements for qualifications of the facility staff. This specification has been retained as worded in the current Maine Yankee Technical Specifications (MYTS). The specification of Technician qualifications in MYTS 5.3.1.c has been deleted. This specification was an exception to the ANSI standard which is endorsed by Regulatory Guide 1.8 - 1975. Maine Yankee proposes to relocate this exception to the Quality Assurance Program.

MYTS subsection 5.4 Training - This subsection specifies the requirements for training. This subsection was proposed for modification in Proposed Change No. 206 to specify the training requirements for certified fuel handlers. This Proposed Change was submitted to the NRC by Reference (c) to address facility staff and qualifications appropriate to the permanently defueled status of the Maine Yankee reactor. This subsection has been retained.

MYTS subsection 5.5 Review and Audit - This subsection specifies the review and audit functions performed by the Plant Operating Review Committee (PORC) and the Nuclear Safety Audit and Review Committee, Maine Yankee proposes to replace the review and audit functions of the PORC and the NSARC with the review and audit requirements identified in Attachment V.

With the termination of reactor operations at the Maine Yankee facility and the removal of operating authority pursuant to 10CFR50.82(a)(2). the scope and complexity of activities at the facility have been greatly reduced. Consequently, the permanent staff supporting the Maine Yankee facility will also be much smaller than those required to support an operating plant. The reduced scope of activities and limited staff make operation of two review committees impracticable and unnecessary. The responsibilities associated with the new review requirements will encompass the majority of the functions previously performed by the PORC and NSARC. Selected functions have been modified consistent with the scope of activities at a permanently defueled, facility.

In order to be consistent with the CLntent of the improved Standard Technical Specifications. Maine Yankee proposes to relocate these requirements to the Quality Assurance Program. This review and audit function will be maintained under the

ATTACHMENT I Page 40 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 provisions of 10CFR50.54 MYTS subsection 5.6 Reportable Event Action - This subsection covers requirements for events that are reportable per 10 CFR 50.73. Consistent with the content of the improved Standard Technical Specifications. these provisions are not included in the proposed PDTS. The requirements for reporting of events are specified in the applicable regulations and additional detail is not necessary in the PDTS.

MYTS subsection 5.7 Safety Limit Violation Report - This subsection specifies the actions to be taken if a safety limit specified in MYTS Section 2 is violated. As noted in the discussion of MYTS Section 2 above. the safety limits are no longer applicable and have not been retained in the proposed PDTS. Therefore, the provisions of MYTS Section 5.7 are unnecessary and have not been retained in the proposed PDTS.

MYTS subsection 5.8 Programs and Procedures - This subsection specifies requirements for programs and procedures. This specification has been retained, with appropriate modifications. as proposed PDTS 5.5 and 5.6.

The centents of MYTS subsection 5.8 has been addressed as indicated in the following table:

5.8 Programs and Procedures Current MYTS Improved STS Proposed PDTS 5,8.1.a Radioactive 5.5.4 Radioactive Effluent 5.6.3 Radioactive Effluent Effluent Controls Program Controls Program Controls Program 5.8.1.b Radiological Not included but referred Relocate to the ODCM Environmental Monitoring to in 5.5.1 Offsite Dose Program Calculation Manual 5.8.2 Procedures 5.4 Procedures 5.5 Procedures 5.8.2.g Process Control Not included Relocate to the FSAR Program Procedures 5.8.2.h Offsite Dose 5.5.1 Offsite Dose 5.6.2 Offsite Dose Calculation Manual Calculation Manual Calculation Manual Procedures 5.8.3 Procedure Review Not included Relocate to the Quality Assurance Program 5.8.4 Temporary Procedure Not Included Relocate to the Quality Changes Assurance Program 5.8.4.d Process Centrol Not Included Relocate to the FSAR Program Changes 5.8.4.e Offsite Dose 5.5.1 Offsite Dose 5.6.2 Offsite Dose Calculation Mandal Changes Calculation Manual Calculation Manual 5.8.5 Working Hours 5.2.2.e Working Hours 5.2.2. Working Hours

ATTACHMENT I Page 41 cf 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 MYTS 5.8.1.a contains the program requirements for the Radioactive Effluent Controls Program. This program has been retained as PDTS 5.6.3.

Amendment No. 125 to the

{

Maine Yankee Facility Operating License approved the incorporation of programmatic l

controls for the Radiological Effluent Technical Specifications which were submitted i

by Maine Yankee based upon the guidance provided by the NRC in Generic Letter 89-01.

The wording of MYTS 5.8.1.a has been retained as approved in Amendment No. 125.

MYTS 5.8.1.b contains the program requirements for the Radiological Environmental Monitoring Program. This program is included in the Offsite Dose Calculation Manual.

In order to be consistent with the improved Standard Technical Specifications Maine Yankee proposes to relocate MYTS 5.8.1.b to the Offsite Dose Calculation Manual.

MYTS 5.8.2 specifies the establishment, implementation and maintenance of procedures covering various activities. MYTS 5.8.2.a referred to activities for which procedures were recormlended in Appendix A of Regulatory Guide 1.33, (rev. 2),

February 1978. This wording has been modified to clarify that only procedures applicable to the safe storage of irradiated fuel are included in this item (PDTS 5.5).

MYTS 5.8.2.b refueling operations, has been deleted in the proposed PDTS since refueling operations will no longer be conducted at the Maine Yankee facility.

MYTS 5.8.2.c covering procedures for surveillance and test activities of safety-related equipment has also been deleted consistent with the scope of procedures included in the improved Standard Technical Specifications. This provision is redundant to MYTS 5.8.2.a which is included in the PDTS as noted above.

l MYTS 5.8.2.9 includes the Process Control Program (PCP) as an activity for which I

procedures are required to be established, implemented and maintained.

In order to be consistent with the improved Standard Technical Specifications, Maine Yankee proposes to relocate MYTS 5.8.2.9 to the FSAR. MYTS 5.8.2.h specifies the Off-site Dose Calculation Manual (ODCM) as an activity for which procedures are required to be established, implemented and maintained. This is subsumed in PDTS 5.5.1.f since the Off-site Dose Calculation Manual (00CM) is a program specified in PDTS 5.6.

MYTS subsections 5.8.3 and 5.8.4 contain requirements associated with permanent and temporary change,, to procedures. Except for the ODCM portion, the provisions of these sections have not been retained in the proposed PDTS consistent with the improved Standard Technical Specifications. The provisions addressing changes to the ODCM (MYTS 5.8.4.e) are covered by PDTS 5.6.2.

Maine Yankee proposes to relocate MYTS 5.8.4.d. the provisions addressing changes to the PCP, to the FSAR.

Maine Yankee proposes to relocate the remaining requirements of 5.8.3 and 5.8.4 to the Quality Assurance Program.

As indicated above, MYTS subsection 5.8.5 Working Hours has been transferred to PDTS 5.2.2.e.

Additional Programs Included in PDTS 5,6 Programs and Manuals - This subsection of the proposed PDTS also incluoes the following programs:

5.6.1 Radiation Protection Program - This program is transferred in its entirety from MYTS 5.11.

5.6.2 Off-site Dose Calculation Manual - This program is transferred in

ATTACHMENT I Page 42 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 its entirety from the MYTS Definition Section and MYTS 5.8.4.d, The wording of this specification is consistent with the improved Standard Technical Specifications.

5.6.4 Technical Specification (TS) Bases Control Program - This is a new program being 6dded consistent with the improved Standard Technical Specification.

5.6.5 Inservice Testing Program - This is a new program being added consistent with the improved Standard Technical Specification.

It replaces the inservice testing portion cf MYTS 4.7.

STS 5.5 Programs Not Included in PDTS 5.6 - There are some programs specified in the improved Standard Technical Specifications which do not apply to a facility with a permanently shutdown and defueled reactor. These programs have not been included in the proposed PDTS. These STS programs consist of the following:

STS 5.5.2 Primary Coolant Sources Outside Containment:

STS 5.5.3 Post Accident Sampling:

STS 5.5.5 Component Cyclic or Transient Limit:

STS 5.5.6 Pre-Stressed Concrete Containment Tendon Surveillance Program:

STS 5.5.7 Reactor Coolant Pump Flywheel Inspection Program:

STS 5.5.9 Steam Generator (SG) Tube Surveillance Program:

STS 5.5.10 Secondary Water Chemistry Program:

STS 5.5.11 Ventilation Filter Testing Program (VFTP):

(

STS 5.5.12 Explosive Gas and Storage Tank Radioactivity Monitoring Program; l

STS 5.5.13 Diesel Fuel Oil Testing Program; and STS 5.5.15 Safety Functions Determination Program (SFDP)

STS 5.5.2 and 5.5.3 requires controls for monitoring and preventing the relec e of highly radioactive fluids generated from design basis accidents. However, since the reactor has been permanently shutdown and defueled, the limiting design basis accidents no longer have the potential for generating highly radioactive fluids.

Therefore, these programs have not been specified in the proposed PDTS.

STS 5.5.5. 5.5.6. 5.5.7. 5.5.9. 5.5.10, 5.5.11 and 5.5.13 requires controls for monitoring. tracking or inspection activities associated with systems, structures

.and components which either do not apply to Maine Yankee or are no longer required with the reactor in a permanently shutdown and defueled condition.

STS 5.5.12 requires monitoring of explosive gas and radioactivity cantained in gas storage tanks and systems and radioactivity in unprotected outdoor liquid storage tanks. The provisions of STS 5.5.12 associated with gas storage have not been adopted because the activities at Maine Yankee will no longer result in the generation of gasses to be stored in the radioactive gas storage system. The provisions of STS 5,5.12 associated with outdoor tanks has not been adopted for the following reason. The basis on this portion of STS 5.5.12 is to limit potential releases to less than 10CFR20 limits at the nearest potable water supply and the nearest surface water supply. Maine Yankee is located on a point of land on a salt water estuary and there are no downstream water supplies that could be affected.

In the 1980's when Maine Yankee was converting the Radiological Environmental Technical Specifications (RETS) to the Offsite Dose Calculation Manual, the need for a storage tank monitoring program was raised by the NRC as an issue and subsequently dropped

ATTACHMENT I Page 43 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 becease it did not apply. Since the basis for the STS does not apply to Maine Yankee, the specification has not been adopted.

STS 5.5.15 requires a program to ensure that any loss of safety function is detected and appropriate action taken. The program consists of safety function evaluations, cross train checks and evaluation to determine the impact on supported system's operability and required action completion times. With the Maine Yankee reactor permanently shutdown and defueled, the complexity of determining safety functions normally associated with operating reactors is greatly reduced. As a result, the LCO section of the proposed PDTS is very straightforward making a Safety Functions Determination Program unnecessary.

The applicable programs included in the standard technical specifications have been l

incorporated in the proposed PDTS. These include PDTS 5.6.1, radiation control program; PDTS 5.6.2, off site dose calculation manual; PDTS 5.6.3, radioactive effluent controls program; PDTS 5.6.4, technical specification basis control program; and PDTS 5.6.5, inservice testing program.

MYTS subsection 5,9 Reporting Requirements - This subsection contains requirements for submitting various reports. This subsection has been retained, with appropriate modifications, as proposed PDTS 5.7.

The wording is consistent with the improved STS to the extent consistent with the permanently shutdown and defueled status of the reactor. Several reports listed in MYTS Section 5.9 are no longer appropriate for a permanently defueled facility and have been deleted in the proposed PDTS 5.7.

These include:

Startup Reports required by MYTS 5.9.1.1 & 5.9.1.2; Monthly Operating Reports required by MYTS 5.9.1.4; Special Reports MYTS 5.9.1.7; and Core Operating Limits Report required by MYTS 5.9.1.7.

MYTS 5.9.1.7 requires special reports for: (a) Reactivity anomalies, MYTS 3.15; (b).

Excessive radioactive release. 00CM; (c) Plans for restoration of 115 u service, MYTS 3.12; and (d) Total Dose. ODCM. MYTS 5.9.1.7(a) and (c) have been deleted because the related MYTS has been deleted. Maine Yankee proposes to relocate MYTS 5.9.1.7(b) and (d) to the 00CM.

STS 5,6 Reporting Requirements Not Included in PDTS 5,7 - There are some reporting requirements specified in the improved Standard Technical Specifications which do not apply to a facility with a permanently shutdown and defueled reactor. These reporting requirements have not been included in the proposed PDTS. These STS reporting requirements consist of the following:

STS 5.6.6 Reactor Coolant System Pressure and Temperature Limits Report (PTLRh STS 5.6.7 EDG Failures Report:

STS 5.6.8 Post Accident Monitoring Report:

STS 5.6.9 Tendon Surveillance Report; and STS 5.6.10 Steam Generator Tube Inspector Report These reporting requirements are associated with systems, structures and components which either do not apply to Maine Yankee or are no longer required with the reactor in a permanently shutdown and defueled condition.

ATTACHMENT I Page 44 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207 MYTS Section 5.10 Record Retention - This subsection contains requirements for the retention of various types of records. Maine Yankee proposes to relocate the record retention requirements to the Quality Assurance Program where they will be maintained pursuant to 10CFR50.54(a). This relocation is consistent with the s

improved STS. Therefore the record retention requirements of MYTS 5.10 have not been retained in the proposed PDTS.

Some record types have not been retained in the relocation to the Quality Assurance Prograt,' as they are no longer applicable as demonstrated by the discussions of specific MYTS sections. These include:

MYTS 510.2.f covering records of transient or operational cycles.

MYTS 5.10.2.i covering records of inservice inspections and HYTS subsection 5.11 Radiation Protection Program - This subsection specifies the requirement for a radiation protection program. This specification has been retained without modification as PDTS 5.6.1.

MYTS subsection 5.12 High Radiation Areas - This subsection specifies requirements for the control of high radiation areas. The provisions of this MYTS subsection are included in proposed PDTS 5.8.

Additional provisions contained in the improved Standard Technical Specifications have also been inciuded in this PDTS section. The scope and content af PDTS 5.8 are consistent with the improved Standard Technical Specifications co.. ained in NUREG-1432. The determination of radiation surveillance frequency spec 1fied in PDTS 5.8.1.c by Radiation Protection personnel or, when appropriate, by the Radiation Protection Manager.

MYTS subsection 5.13 - Previously Deleted HYTS subsection 5.14 Core Operating Limits Report - This subsection specifies core operating limit parameters to be established and implemented in the Core Operating Limits Report (COLR) by specified analytical methods which have been previously reviewed and approved by the NRC. With the Maine Yankee reactor permanently shutdown and defueled, these parameters and related analytical methods no longer apply. Therefore this subsection has not been retained in the proposed PDTS.

I

ATTAC}NENT I Page 45 of 46

-BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES PROPOSED CHANGE NO. 207

_Soecification Included in the PDTS Two LC0's and associated surveillance requirements are contained in the proposed

-PDTS. These specifications were determine to be necessary to meet 10CFR50.36(c)(2)(ii)(B) Criterion 2. in that they cover limits that are initial conditions for design bases accidents. These specifications are discussed separately below.

-PDTS 3.1.1 Spent Fuel Pool Water Level-- This specification requires that the spent fuel pool water level be maintained within limits during fuel movement and requires I

verification of' compliance at a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months frequency. The actions associated with this LCO require immediate suspension of movement of irradiated fuel assemblies-in the fuel storage pool. The immediate actions minimize the potential for a fuel handling accident or a loss of shielding during fuel movement. Restrictions on crane operation-with loads over the spent fuel pool are not included in the LC0.

consistent with the improved Standard Technical Specification. These restrictions will be described in the FSAR.

The minimum water level in the fuel storage-pool meets the assumptions of iodine decontamine. tion-factors following a fuel handling accident. Even though the spent fuel fiso on products have actually decayed at least nine months, the proposed LC0 is based upon the existing analysis which assumes a one week and/or 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months decay period. The resulting doses which are calculated for.the fuel handling accident are below the values specified in 10CFR100. The specified water level also shields and minimizes the general area dose.during fuel movement.

PDTS 3.1.2 Spent Fuel Boron Concentration - This specification places a limit on the minimum soluble boron concentration in the ' spent fuel pool. This limit applies i

_whenever fuel assemblies are stored in the spent fuel pool and a fuel storage pool

--verification has not been performed since the last movement of fuel assemblies in the spent fuel pool. The design of the spent fuel pool is based on the use of unborated water, which maintains a subcritical condition (Km < 0.95) during normal-operation with the spent fuel racks fully loaded.

However, the water in the spent fuel pool normally contains soluble boron. This results in large subcriticality margins under normal conditions. The presence of this soluble boron is credited in

'the analyses of abnormal conditions. Credit for soluble boro under abnormal or accident conditicns is allowable since only a single accident need be considered at one-time.

PDTS 3.1.2 limits the boron concentration to no less_than 1000 ppm to preserve. with operating margin, the initial conditions assumed in the accident analyses. - An analysis value for boron concentration of 663 ppm, assumed in the analysis for the postulated misplaced fuel assembly, was determined to be required to maintain a 5% Ak/k safety margin to criticality. The LC0 is applicable whenever fuel assemblies are stored in the spent _ fuel pool and a spent fuel pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool. When the concentration of boron in the spent fuel pool is less than required, the LCO requires immediate action to minimize the potential for misplacement an fuel assembly. Immediate actions are also required to either initiate action to= restore o

ATTACHMENT I Page 46 of 46 BACKGROUND AND DESCRIPTION OF PROPOSED CHANGES l

PROPOSED CHANGE NO. 207 fuel storage pool boron concentration to within limit or initiate action to perform a fuel storage pool verification.

The surveillance requirements verify that the concentration of boron in the spent fuel pool is within the required limit when the LC0 is applicable, As long as this condition is met, the analyzed accidents are fully addressed, The 7 day frequency is appropriate duririg the movement of fuel assemblies because no major replenishment of pool water that could result in a dilution of the boron concentration is expected to take place over such a short period, Specification not included in the PDTS Spent Fuel Pool Temperature The permanently defueled technical specifications (P315) for the Trojan plant contain a specification for maximum spent fuel pool temperature. The Trojan submittal indicates that this specification is based upon an initial max 1 mum pool temperature assumed in the analyses of a prolonged loss of forced cooling to the spent fuel pool. This specification does not exist in the current MYTS or the improveu Standard Technical Specifications (NUREG 1432 dated April 1995), The maxNn spent fuel pool temperature at Maine Yankee is limited because its relation to the structural integrity of the spent fuel pool and the time to boll.

Since the maximum spent fuel pool temperature is important to the structural integrity of the spent fuel pool and related to the time to boil, the Maine Yankee FSAR will include the appropriate limits along with a basis. This is consistent with the improved Standard Technical Specifications.

D

ATTACHMENT II Page 1 of 65 SIGNIFICANT_ HAZARDS EVALUATION PROPOSED CHANGE NO. 207 SIGNIFICANT HAZARDS EVALUATION The proposed change to the Technical Specifications, has been evaluated against the standards of 10 CFR 50.92 and has bec @termined not to involve a signific3nt hazards consideration. An evaluation against these standards is provided below for each of the specific proposed changes.

HYTS Definitions Definitions are provided in the MYTS for terminology unique to the technical specifications. With the reduction in scope of the PDTS as discussed in the evaluation of the remaining MYTS sections, most of these unique terms are no longer applicable.

For example, the definition of " Reactor Operating Conditions" are based on the conditions of the reactor and are no longer used in the permanently l

defueled condition of the Maine Yankee facility. The definition of " Action" from the improved Standard Technical Specifications has been adopted in Section 1.0 of

'the PDTS and a new definition of " Certified Fuel Handler" has been added to the PDTS. The basis for the definition of a Certified Fuel Handler is provided in Reference (c) and (d). Section 1 of the proposed PDTS also includes expanded information and examples related to the use of logical connectors (Section 1.2), the interpretation of completion times (Section 1.3), and the interpretation of surveillance frequencies (Section 1.4).

The defined terms are indicated throughout the text of the technical specifications by showing the terms in all capital letters. This expanded information is consistent with the improved Standard Technical Specifications, and has been modified as appropriate to the reduced scope of the proposed PDTS.

The proposed change does not:

1.

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

The removal of the defined terms that no longer appear in the body of the proposed PDTS has no impact on facility structures or equipment or on the methods of operation of such structures or equipment. Further, the expanded explanatory information that has been added to this section is consistent with the improved Standard Technical Specifications and adds to the clarity and ease of use of the proposed PDTS. Therefore, the proposed changes to this MYTS section do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The removal of the defined terms that no longer appear in the body of the proposed PDTS has no impact on facility structures or equipment or j

ATTACHMENT II Page 2 of 65 SIGNIFICANT HAZAPsDS EVALUATION PROPOSED CHANGE NO. 207 on the methods of operation of such structures or equipment. Further, the expanded explanatory information that has been added to this section is consistent with the improved standard technical specifications and adds to the clarity and u se of use of the proposed PDTS. Therefore, the proposed changes to this MYTS section would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The removal of the defined terms that no longer appear in the body of the proposed PDTS has no imLact on facility structures or equipment or on the methods of operation of such structures or equipment. Further, the expanded explanatory information that has been added to this section is consistent with the unproved standard technical specifications and adds to the clarity and ease of use of the proposed PDTS. Therefore, the proposed changes to this MYTS section would not involve any reduction in a margin of safety.

l l

_-___J

ATTACHMEIL11 Page 3 of 65 SIGNIFICANT HAZARLS EVALUATION PROPOSED CHAN01 NO, 207 MYTS Section 1 Desian Features l

MYTS Section 1 describes design features of the facility.

In accordance with 10 CFR 50,36(c)(4), this section is intended to describe features of the facility such as materials of construction or geometric arrangement that, if altered, would have a significant effect on safety and are not covered in other sections of the technical specifications. The current MYTS contain the design features in the following areas:

1.1 Fuel Storage 1.2 Site Description 1.3 Reactor 1.4 Containment Section 1.2 describing the site and Section 1.1 describing fuel storage have been retained. These specifications are now located in Section 4.0 " Design Features" in accordance with the numbering system in the improved Standard Technical Specifications as PDTS 4.1 - Site and PDTS 4.2 - Fuel Storage. The description of the site contained in MYTS 1.2 has been retained as PDTS 4.1 as worded in the MYTS.

MYTS Section 1.1 describes the design features of the facility related to the storage of new and irradiated fuel. Most of the provisions of MYTS Section 1.1 have been transferred to PDTS Section 4.2.

Design descriptions, including seismic design, which exist in the Final Safety Analysis Report have been deleted from the PDTS. Maine Yankee has retained in the PDTS and reworded, as appropriate, the reactivity design objective of the spent fuel storage racks, the location and maximum number of spent fuel assemblies to be stored in the spent fuel pool and the maximum number of fuel assemblies which may be in consolidated form. The minimum boron ccncentration in the spent fuel pool has been reworded and transferred to PDTS 3.1.2 Spent Fuel Pool Boron Concentration. Maine Yankee proposes to relocate the-prohibition of lifting a spent fuel shipping casks over the spent fuel storage pool to the Final Safety Analysis Report. The specification limiting the location and maximum number of spent fuel assemblies which may be stored in a temporary spent fuel storage rack in the spent fuel cask laydown area has been deleted since Maine Yankee does not intend to use this option.

MYTS Section 1.3 and 1.4 described the design features of the reactor and the containment. These st uctures and systems served to prevent or mitigate the consequences of postulated accidents involving the release of fission productc in the containment. Since the Maine Yankee reactor is permanently shutdown and defueled, there is no longer the need to maintain these design features for the protection of the general public. Therefore these sections are not retained in the PDTS.

The proposed change does not:

1.

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

The proposed deletion of the description of design features not m

ATTACHMENT II Page 4 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 applicable to the permanently shutdown and defueled status of the Ma W V60kee reactor has no impact on the probability or consequences of the remaining applicable design basis accidents. This deletion is consistent with the scope of the improved Standard Technical Specifications. The seismic design features affecting the safe storage of irradiated fuel and the cask movement restrictions will be described in the FSAR. Therefore, the proposed changes to this MYTS section do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The changes to this section do not involve changes to any structure or equipment affecting the safe storage of irradiated fuel or the methods of handling or storing such fuel, Therefore, the proposed changes to this MYTS Section would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The deletion of the description of design features which are not related to the storage of irradiated fuel or which are inconsistent with the scope of the improved Standard Technical Specifications of NUREG-1432, will not affect the analyses of the design basis accidents remaining applicable to the Maine Yankee facility. Therefore, the proposed changes to this MYTS section would not involve a reduction in any margin of safety, i

ATTACFMENT II

-SIGNIFICANT HAZARDS EVALilATION..

Page5ofl65 PROPOSED CHANGE NO. 207 MYTS Section 2 Safety Limits'? rid Limitina System Settinas Sect 1o' n 2 of'the MYTS contains _" safety limits and " limiting safety system settings." In accordance with 10 CFR 50.36(c)(1), safety limits are intended to be

-limits on parameters necessary to protect the physical barriers that guard against a

the uncontrolled release of radioactivity from a nuclear reactor.

If the specified safety limits are violated, the reactor must be shutdown and operation may not resume until authorized by the Commission.. Limiting safety system settings are values of various parameters associated with the nuclear steam supply system (NSSS)

.at which automatic protective action is needed during normal operations or anticipated transients to prevent violation of the safety limits.

-The current MYTS contain two safety limits. MYTS 2.2 sets limitations on the ccTbination of reactor thermal power reactor coolant system flow, temperature and pressure expressed in the form of departure from nucleate boiling heat flux ratio (DNBR) and fuel centerline melting temperature. These limits prevent damage to the

. fuel cladding during reactor operation that could result in the release of fission products to the reactor coolant system. MYTS 2.3 places a limitation on the

-pressure in the reactor-coolant system. This limitation is intended to prevent

--damage to the reactor coolant system pressure boundary that could result in the release of fission products in the reactor coolant system to the containment atmosphere.

The limiting safety system settings are contained in MYTS 2.1.

This specification establishes limits on the setpoints of the reactor protection system (RPS). The RPS-monitors various_ parameters associated with reactor operation and_ initiates a

-shutdown of the reactor in the event that the settings are exceeded during normal operation or anticipated operational occurrences.

Examples of the parameters -

s included within the scope-of the RPS include reactor trips based on neutron flux, reactor coolant system temperature, pressurizer pressure. reactor. coolant system i

flow rate, steam generator level, steam generator pressure and containment pressure.

The Maine Yankee facility is permanently shutdown and fuel'has been removed from the reactor vessel and placed in the spent fuel storai ?ool, in accordance with 10CFR50'82(a)(2), the facility operating license no longer authorizes operation of the:ieactor or emplacement'or retention of fuel into the reactor vessel Since there is no longer an operating reactor at the Maine Yankee facility, the functions of the RPS.no longer serve a useful function and MYTS 2.1 is ' deleted in this proposed amendment. Since no reactor is in operation at the Maine facility and the license no longer authorizes such operation in the future, the safety limits g

specified in MYTSs 2.2 and 2.3 are no longer applicable and are also deleted in this proposed amendment.

The proposed change does not:

1.

-Involve a significant increase in the probability or consequence of an accident previously evaluateo.

The provisions of this section are solely related to the operation of

ATTACHMENT II Page 6 of 65 SIGNIFICANL HAZARDS EVALUATION PROPOSED CHANGE NO. 202 the nuclear reactor. The postulated design basis accidents involving the reactor are no longer possible due to the permanently shutdown and defueled status of the Maine Yankee reactor. The design basis accidents that remain applicable to the Maine Yankee facility are not affected by these provisions. Therefore, the proposed changes to this MYTS section do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The provisions of this section are solely related to the operation of the nuclear reactor. The postulated design basis accidents involving the reactor are no longer possible due to the permanently shutdown and defueled status of the Maine Yankee reactor. The design basis accidents that remain applicable to the Maine Yankee facility are not affected by these provisions. Therefore, the proposed changes to this MYTS section would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3, involve a significant reduction in a margin of safety.

The provisions of this section are solely related to the operation of the nuclear reactor. The postulated design basis accidents involving the reactor are no longer possible due to the permanently defueled status of. the Maine Yankee reactor. The design basis accidents that remain applicable to the Maine Yankee facility are not affected by these provisions. Therefore, the proposed changes to this MYTS section would not involve a reduction in any margin of safety.

ATTACHHENT 11 Page 7 of 6S SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 MYTS Section 3 Limitina Conditions for ODeration Each subsection of MYTS Section 3 is evaluated below:

MYTS Subsection 3.0 Limiting Conditions for Operations This section contains specifications that have generic applicability to the LC0's and surveillance requirements. Due to the limited number of LCO's remaining in the proposed PDTS, a number of the MYTS provisions in this section are no longer necessary for or applicable to the Maine Yankee facility. The specifications that have not been retained in the proposed PDTS are discussed individually below.

MYTS 3.0.A.2 and 3 direct the reactor shutdown actions to be taken when an LC0 and its associated remedial action statements cannot be satisfied, notwithstanding specified exceptions. MYTS 3.0.A.2 and 3 are not relevant with the plant in the permanently shutdown condition. Therefore, since this specification would be meaningless in the PDTS, it has not been retained.

MYTS 3.0.8 contains restrictions on entry into a higher operating condition or specified condition when the LC0 is not met without reliance upon the provisions contained in certain specified remedial actions statements. The LC0's retained in the proposed PDTS are applicable whenever irradiated fuel is stored in the spent fuel pool. Therefore, this specification is not applicable and has not been retained in the proposed PDTS.

I MYTS 3.0.C addresses the effect of the availability of emergency power sources on the operability of other equipment. As discussed in the following sections, the proposed LCO's in the PDTS do not cover operability of any electrically powered equipment. Therefore, this specification is not applicable and has not been retaintd in the proposed PDTS.

STS 3.0.5 permits equipment removed from service or declared inoperable to comply with action statements to be returned to service under administrative control to perform testing required to demonstrate its operability or the operability of other equipment. The LCO's specified in the PDTS are sufficiantly simplified to make this provision unnecessary.

STS 3.0.7 allows specified Technical Specifications requirements to be changed to permit performance of special tests and operations. Since no special test exceptions are specified in the PDTS for the performance of special tests and operations, this provision is unnecessary.

The proposeo s 'nge does not:

1.

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

The generic actions that are no longer applicable due to the reduction in scope of the proposed PDTS have no impact on facility structures or

ATTACHMENT II Page 8 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 equipment or on the methods of operation of such structures or equipment. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The generic actions that are no longer applicable due to the reduction in scope of the proposed PDTS have no impact on facility structures or equipment or on the methods of operation of such structures or equipment. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

i The generic actions that are no longer applicable due to the reduction in scope of the proposed PDTS have no impact on facility structures or l

equipment or on the methods of operation of such structures or equipment or on the results of any accident analyses. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3.1 Reactor Core Instrumentation This subsection contains LC0's which must be satisfied for the in core instrumentation system to be considered operable as required for calibrating the ex-core symmetric offset protection system and for other purposes as required by MYTS 3.10. The in-core instrumentation system functioned to monitor the spatial distribution of neutron flux in the reactor core. The ex-core symmetric offset protection system is only applicable in the Power Operation Condition. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, these systems are no longer required and the specification has been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

The proposed change does not:

1.

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

These specifications are solely related to instruments used to monitor the operation of the nuclear reactor to prevent or diagnose accidents involving the reactor. Since the reactor _at the Maine Yankee facility has been permanently shutdown and defueled any previously evaluated accidents involving the reactor are no longer possible. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

ATTACHMENT II Page 9 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 2.

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

These specifications are solely related to the operation of the nuclear reactor. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the previously evaluated accidents involving the reactor are no longer possible. The deletion of these specifications does not affect any structures or equipment necessary for the safe storage of irradiated fuel in the spent fuel pool or alter any method of operation related to storage of irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different k;nd of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

These specifications are solely related to the operation of the nuclear reactor. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the previously evaluated accidents involving the reactor are no longer possible. Therefore the deletion of these specifications has no impact on the analyses of postulated design basis accidents that remain opplicable to the Maine Yankee r

facility. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3,2 Reactor Coolant System Activity The LCO's in this specification apply to the measured maximum activity in the reactor coolant system. These limits ensure that the resulting 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months doses at the site bouadary will not exceed an appropriately small fraction of the Part 100 limit following a steam generator tube rupture. Since the reactor has been permanently shutdown and defueled, the steam generator tube rupture incident no longer applies to Maine Ysnkee. Therefore, this specification has been deleted from the PDTS.

With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

The proposed change does not:

1.

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

The postulated accidents involving rupture of steam generator tubing and the subsequent release of radioact ve materials are no longer possible at the Maine Yankee facility. These activity limits have no impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel pool. Therefore, the proposed changes to this MYTS subsection does not involve any increase in the

ATTACHMENT II Page 10 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 probability or consequences of any accident previously evaluated.

2.

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

The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a s1gnificant reduction in a margin of safety.

The systems affected by these specifications have no impact on the analyses of any postulated accident applicable to the Maine Yankee facility with its reactor in the permanently defueled state.

Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety, NYTS Subsection 3.3 Reactor Coolant System Operational Components This subsection specifies the requirements for reactor coolant system components to assure 1) adequate core heat transfer capability under all operating, transient and emergency conditions 2) uniform RCS boron concentration during boration or dilution i

evolutions, and 3) overpressure protection. Since the reactor at the Maine Yankee I

facility has been permanently shutdown and defueled, the functions of the reactor coolant system are no longer required to perform its normal functions or to prevent or mitigate the consequences of a postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition. the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

The proposed change does not:

1.

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

The postulated accidents involving loss of core heat removal, uncontrolled core reactivity, and overpressurization of the reactor coolant system are no longer possible at the Maine Yankee facility.

The systems / components specified in this subsection have no impact on any design basis accident innlving the safe storage of irradiated fuel in the spent fuel storage pool. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

l

ATTACHMENT II Page 11 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHA %E NO. 207 i

The deletion of this subsection does not involve any change in the structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no impact on the analyses of any postulated accident applicable to the Maine Yankee facility with the reactor in the permanently shutdown and defueled state. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3,4 Combined Heatup, Cooldown and Pressure Temperature Limitations This subsection specifies temperature and pressure related conditions during RCS heatup and cooldown to assure protection of the reactor coolant pressure boundary.

Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the functions of the reactor coolant system are no longer required to prevent or mitigate the consequences of a postulated accident. Furthermere, these specifications are based upon assuring compliarce with 10CFR50 Appendix G as invoked by 10CFR50.60. On July 29, 1996, the NRC issued the final decommissioning rule and amended 10CFR60 to categorically exempt facilities which have submitted 10CFR50.82(a)(1) certifications from 10CFR50 Appendices G and H.

Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

The proposed change does not:

1.

In"olve a significant increase in the probability or consequence of an accident previously evaluated.

The postulated accidents involving damage to the reactor coolant system, damage to the reactor core and the subsequent release of radioactive materials to the containment are no longer possible at the Maine Yankee facility. These systems have no impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel storage pool. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of these specifications does not involve any change in the

ATTACHMENT II Page 12 of 65 SIGNIFICANT HAZARDS EVALUATI@

PROPOSED CHANGE NO. 207 structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no impact on the I

analyses of any postulated accident applicable to the Maine Yankee facility with its reactor in the permanently shutdown and defueled state. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3.5 Chemical and Volume Control System These LCO's specify requirements which ensure adequate boration capability. These specifications apply whenever there is fuel in the reactor. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, these spec 1fications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

The proposed change does not:

1.

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

The postulated accidents involving loss reactor shutdown capability and uncontrolled core reactivity are no longer possible at the Maine Yankee facility. The systems / components specified in this subsection have no impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel pool. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no impact on the

ATTACHMENT II Page 13 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 l

analyses of any postulated accident applicable to the Maine Yankee facility in its permanently defueled state. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3,6 Emergency Core Cooling and Containment Spray Systems These LCO's are concerned with the operation of various emergency core cooling systems. These systems include the safety injection tanks, high pressure safety injection pumps, low pressure safety injection pumps, service water pumps, component cooling pumps, containment spray pumps and residual heat removal heat exchangers, associated valves, and the refueling water storage tank. The limitations on the operation of this equipment ensure that cooling can be provided to the reactor following a postulated loss of coolant accident. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, a loss of coolant from the reactor coolant system is no longer of concern and the reactor coolant system no longer serves any function to prevert or mitigate the consequences of any postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled conditions, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

Some of the components covered by this subsection are used to provide cooling for the spent fuel storage pool. These components are not required to be operable in the MYTS with the reactor shutdown and defueled. Comensurately, these components are not now being proposed for addition to the PDTS with the reactor in the permanently shutdown and defueled condition.

As noted in the discussion of the loss of forced cooling to the spent fuel pool, the heat load in the spent fuel pool is much less than that assumed in the existing analysis due to the decay time that has elapsea since reactor shutdown and the actual number of fuel assemblies stored in the pcol. Even using the boil-off rate resulting from the existing, conservative analysis, it would take more than a day to lose enough water from the spent fuel pool to endanger uncovering irradiated fuel assemblies. This extended period provides ample time for actions to effect repairs to the cooling system or to establish alternate sources of makeup water to the spent fuel pool. Therefore, it is not necessary to specify technical specification requirements to maintain active cooling systems immediately operable for cooling of the irradiated fuel in the spent fuel storage pool.

Given the time available to respond to incidents of loss of spent fuel cooling, specific restrictions on cooling water systems or sources of makeup are not necessary and the systems do not meet the screening criteria for 1riclusion in the PDTS. Specifically, these cooling systems do not meet 10CFR50.36(c)(2)(ii)(A)-

Criterion One since they do not serve to detect degradation of the integrity of the reactor coolant pressure boundary or the spent fuel pool.

10CFR50.36(c)(2)(ii)(B) -

Criterion Two is not met since the systems do not involve initial conditions assumed in any design basis analyses. 10CFR50.36(c)(2)(ii)(C) - Criterion Three is not met since the systems are not part of the primary success path and do not function or actuate to mitigate a Design Basis Accident that either assumes the failure of or

ATTACHMENT 11 Page 14 of 65 i

SIGNIFICANT HAZARDS EVALUATION l

PROPOSED CHANGE NO. 207 presents a challenge to the integrity of a fission product barrier. 10 CFR. 50.36(c)(2)(11)(D) - Criterion Four is not met since the systems are not significant to the public health and safety given the extended time available to restore cooling. The fire protection system provides a source of makeup to the spent fuel pool in the event of a loss of forced cooling. However, since time is availab'e before this event presents any challenge to the integrity of a fission product barrier this other source of make up has not been included in the proposed PDTS.

The proposed change does not:

1.

Involve a significent increase in the probability or conse G ence of an accident previously evaluated.

The postulated accidents involving damage to the reactor coolant system, main steam lines, main feed lines, steam generators or the reactor core and the subsequent release of radioactive materials are no longer possible at the Maine Yankee facility. These systems have no adverse impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel storage pool. The cooling water systems contained in this section are used to provide a source of cooling and/or makeup water to the spent fuel pool. However, the time available to establish makeup to the spent fuel pool following a loss of forced cooling make it unnecessary to require the continuous or immediate availability of such systems. Therefore. the addition of these specifications is not necessary. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no adverse impact on the analyses of any postulated accident applicable to the Maine Yankee facility with its reactor in the permanently defueled state.

Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3,7 Boron and Sodium Hydroxide Available for the Containment Spray System l

ATTACHMENT II Page 15 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 These specifications are concerned with the availability of borated water for boron injection, core cooling and containment spray and the availability of sodium hydroxide solution for iodine adsorption. These LC0's specify concentration and volume inventory requirements for borated water and spray chemical water. These requirements ensure that cooling can be provided to the reactor and radioactive iodino can be absorbed to limit the release radioactive material to the environment following a postulated loss of coolant accident. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, a loss of coolant from the reactor coolant system is no longer of concern, the reactor coolant system no longer serves any function to prevent or mitigate the consequences of any postulated accident and there are no remaining postulated accidents which require the integrity of the primary containment to be maintained. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

The proposed change does not:

1.

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

The postulated accidents involving damage to the reactt-core and the l

subsequent release of radioactive materials to the containment are no longer possible at the Maine Yankee facility. These systems have no

(

impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel pool. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no impact on the analyses of any postulated accident applicable to the Maine Yankee facility with its reactor in the permanently defueled state.

Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

i l

l

l ATTACHMENT Il Page 16 of 65 SIGNIFICANT HAZARDS EVALUAT[QN fRQEQ5fD CHANGE NO. 207

(

MYTS Subsection 3.8 Reactor Core Energy Removal These specifications are concerned with ensuring the capability to remove energy from the reactor core under normal. transient and accident conditions. LC0's covering the operation of the steam generators ensure the ability to remove heat generated by the reactor from the reactor coolant systems. These LC0 requirements do not apply when there is no fuel in the reactor. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition. the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

The proposed change does not:

1.

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

The systems designed to remove heat from the reactor are no longer applicable to the Maine Yankee facility with its reactor in the permanently defueled state. Removal of these systems from the technical specifications has no effect on the remaining applicable accidents previously evaluated. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of this MYTS subsection does not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. These changes will not result in any modification to structures or equipment needed for the safe storage of irradiated fuel or affect the methods of handling or storing irradiated fuel. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The deletion of this MYTS subsection does not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

1

ATTAtit4ENT II Page 17 of 65 SIGNIFICANT HAZARDSl yALUA110N EROPOSEO CHANGE NO. 202 MYTS Subsection 3,9 Operational Safety Instrumentation, Control System, and Accident Monitoring Systems The subsection of the MYTS contains ICO's related to a wide variety of instrumentation systems. MYTS 3.9. A and 3.9.B cover the instrumentation associated with the reactor trip system and the engineered safety feateres actuation system.

These systems are designed to shutdown the reactor or initiate automa;1c protective actions when parameters exceed selected limits. The systers function to prevent or mitigate the consequences of postulated accidents that cod d result in damage to the reactor fuel cladding or the reactor coolant pressure boeidary. MYTS 3.9.C contains LCO's fo: accident monitoring instrumentation. This ins *rumentation is intended to provide information on selected plant par 6 meters to mon'cor and assess variables during and following an accident that causes damage to the reactor core and/or a breach of the reactor coolant pressure boundary. With the reactor in the permanently shutdown and defueled cond1 tion, the postulated accident scenarios associated with the i'istrumentativ specified in this MYTS subsection are no longer possibic at the Maine Yankee facility and these spec 1fications meet none of the 10CFR50.36(c)(2)(11) criteria. Therefore these specifications have not been retained in the proposed PDTS.

The proposed change does not:

1.

Involve a significant increase in the probability or consequenc0 of an accident previously evaluated.

Most of the design basis accidents postulated in the FSAR are no longer possible due to the permanently shutdown and defueled status of the reactor. The instrumentation covered by MYTS subsection 3.9 is not necessary for the safe storage of irradiated fuel. Specifically, this instrumentation is not necessary to monitor any potential degradation I

of the integrity of the spent fuel pool and is not needed to function to prevent or mitigate the consequences of any DBA remaining applicable to the Maine Yankee facility. Therefore, the proposeo changes to this M1TS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of this subsection does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the spent fuel pool or the analysis of any design bases accident remaining cpplicable to the Maine Yankee facility, Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

ATTACHMENT 11 Page 18 of 65 SIGNIFICA4T HAZARDS EVALUATION PROPOSED CHANGE NO. 207 3.

Involve a significant reduction in a margin of safety.

The deletion of this subsection does not impact the assumptions or l

methodology assumed in the analyses of any design bases accident remaining applicable to the Maine Yankee facility. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

1 MYTS Subsection 3.10 CEA Group, Power Distribution, Moderator Temperature Coefficient limits and Coolant Conditions These specifications restrict the allowable spatial distribution of nuclear and thermal power generation within the reactor cnre. These lim 1tations ensure that the integrity of the fuel cladding 1s maintained during normal reactor operations and anticipated transients and that the init1al cordit1ons assumed in the analyses of postulated ac:1 dents affecting the reactor core remain valid. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, these specifications are no longer applicable and have been deleted. With the reactor in the permanertly shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

The proposed change does not:

1.

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

These specifications are solely related to the operation of the nuclear reactor. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the previously evaluated accidents involving the reactor are no longer possible. Ther? fore, the proposed changes to this MYTS subsection do not involve any increase in the l

probability or consequences of any accident previously evaluated.

2.

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

These specifications are solely related to the operation of the nucle),'

reactor. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the previously evaluated accidents involving the reactor are no longer possible. The deletion of these specifications does not affect any structures or equipment necessary for the safe storage of irradiated fuel in the spent fuel pool or alter any method of operation related to storage of irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

ATTACHMENT 11 Page 19 of 65 SIGNIFICANT HAZ/EDS EVALUATION PROPOSED CHANGE NO. 207 Involve a significant reduction in a margin of safety.

These specifications are solely related to the operation of the nuclear reactor. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the previously evaluated accidents involving the reactor are no longer possible. Therefore the deletion of these specifications has no impact on the analyses of postulated design basis accidents that remain applicable to the Maine Yankee facility. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3.11 Containment These specifications serve to ensure the integrity of the primary containment. The primary containment serves to limit the release of radioactive material to the environment in the event of postulated accidents that release radioactive materials from the reactor coolant system. Since the reactor at the Meine Yankee facility has been permanently shutdown and defueled. there are no remaining postulated accidents which require the integrity of the primary conta1nment to be maintained. Therefore.

the specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(11) criterio.

The proposed change does not:

1.

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

The postulated accidents involving damage to the reactor core and the subsequent release of radioactive materials to the containment are no longer possible at the Maine Yankee facility. These systems have no impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel storage pool. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

ATTACHMENT 11 Pege 20 of 65 SIGNIFICANT HAZARDS EVALU M E8020$ED CHANGE NO. 207 3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no impact on the analyses of any postuidted accident applicable to the Maine Yankee facility with its reactor in the permanently defueled state.

Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3.12 Station Service Power

.This MYTS subsection contains LCO's associated with the AC and DC power sources and distribution systems.

The LCO's are intended to ensure that sufficient power is available to supply the safety related equipment required for the safe shutdown of the facility, the mitigation of accident conditions, and the monitoring of the facility status. These LCO's are not applicable, in the current Maine Yankee Technical Specifications, with the reactor in the permanently shutdown and defueled condition. The proposed PDTS do not contain LCO's for (,ctive safety systems. The

(

limited set of remaining LC0's consists of limitations on selected parameters associated with the storage of irradiated fuel in the spent fuel pool (1.e., water level and boron concentration). These parametert are not subject to raoid change and do not require continuous monitoring. NUREG/CR 6451 indicates that a total loss of cooling to the spent fuel pool would allow over 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months of boil off before any spent fuel would be exposed and potentially damaged. There is sufficient time to effect repairs to the cooling system or to establish makeup flow prior to uncovering the irradiated fuel. Since active safety systems are not contained in the proposed PDTS and since the electrical power specifications meet none of the 10CFR50.36(c)(2)(ii) criteria with the reactor permanently shutdown and defueled, the specifications covering electrical power to support such spent fuel related systems have not been retained in the proposed PDTS.

The proposed change does not:

1 Involve a signifi: ant increase in the probability or consequence of an accident previously evaluated.

The electric power systems contained in this specifications are no longer required to be continuously available with the Maine Yankee reactor in its permanently shutdown and defueled condition. The effects of a prolonged loss of cooling and mckeup flow (e.g. loss of electrical power) to the spent fuel pool using actual heat loads result in an extended time period available to effect repairs or establish alternate sources of makeup flow in accordance with facility procedures.

In addition, the effect of raoicactive decay since the shutdown of the reactor has reduced the consequences of the design basis accidents to levels well below those previously analyzed.

Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

ATTACHMENT 11 Page 21 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 2.

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

The delet1on of this MYTS subsection does not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. These changes will not result in any modification to structures or equipment needed for the safe storage of irradiated fuel or affect the methods of handling or storing irrad1ated fuel. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

Involve a significant reduction in a margin of safety.

3.

l The deletion of this MYTS subsection does not affect any of the assumptions credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3,13 Refueling and Fuel Consolidetion Operations l

This MYTS subsection contains a number of specifications related to refueling operations. Since refueling operations are no longer conducted at the Maine Yankee facility, most of these specifications are not applicable to the storage of irradiated fuel in the spent fuel pool. The limited set of remaining LCO's consists of limitations on selected parameters associated with the storage of irradiated fuel in the spent fuel pool (i.e., water level and boron concentration).

Maine Yankee proposes to relocate the requirements related to the testing of the fuel handling cranes prior to each refueling to the FSAR. Since the Maine Yankee reactor has been permanently shutdown and defueled, there will no longer be any refuelings.

While the fuel handling accident in the spent fuel pool remains a valid DBA for the Maine Yankee facility, this specification meets none of the 10CFR50.36(c)(2)(11) criteria The minimum decay time prior to the movement of irradiated fuel assemblies in the reactor pressure vessel ensures that short-lived fission products are allowed to decay such that the remaining inventory of fission products in a fuel assembly is consistent with the assumptions of the accident analyses for a fuel handling accident. Since the reactor has been permanently defueled and approximately nine months have elapsed since final reactor operation, this specification is no longer necessary to protect the initial conditions of any DBA and has not been retained.

The limits on the soluble boron concentration in the reactor coolant system and refueling canal ensure that the reactor remains subcritical whenever the reactor vessel head is removed and there is fuel in the reactor. Since the reactor has been permanently defueled, this specification is no longer applicable to the Maine Yankee facility and has not been retained in the proposed PDTS. However, a specification

ATTACHMENT 11 Page 22 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 for boron concentration in the Spent fuel Pool is included in the PDTS.

Several LCO's are specified to be applicable during core alterations or movement of irradiated fuel within the containment. These LC0's include requirements related to containment, radiation monitoring, reactor neutron flux monitoring, reactor heat removal, reactor water level and communication during core alterations, Since the reactor has been permanently defueled and irradiated fuel is no longer located in the containment, this specification, as written, is no longer applicable to the Maine Yankee facility. While the fuel handling accident in the spent fuel pool remains a valid DBA for the Maine Yankee facility, the requirement for radiation monitoring in the fuel storage building meets none of the 10CFR50.36(c)(2)(11) criteria and is not included in the Standard Technical Specifications. Therefore, these LCO's have not been retained in the proposed PDTS, Maine Yankee proposes to relocate to the FSAR the requirement (3.13.D.6) for radiation monitoring in the spent fuel storage area.

Maine Yankee proposes to relocate, to the FSAR, the requirement to move spent fuel storage racks only in accord 6nce with approved procedures which ensure that no rack modules are moved over fuel assemblies. This specification prevented the unnecessary risk of spent fuel damage caused by dropping spent fuel racks.

However, since the specification meets none of the 10CFR50.36(c)(2)(ii) criteria discussed under the Background section above and is not included in the Standard Technical Specifications, it has not been retained in the PDTS.

The requirement to prohibit irradiated fuel consolidation until after a cooling period has elapsed ensured that the dose consequences of a consolidated spent fuel handling accident are bounded by the consequences of the design basis spent fuel drop accident.

It also ensured that the maximum outlet temperatures for the limiting fuel assemtly end the consolidated fuel storage bundle ars both well below the saturation temperature at the cell outlet for any storage array. All but the irradiated fuel discharged from the last cycle have completed the cooling period.

The specification meets none of the 10CFR50.36(c)(2)(ii) criteria discussed under the Background section above since it is relates primarily to an administrative control in the work control process. Therefore, Maine Yankee proposes to relocate this specification to the FSAR.

The proposed change does not:

1 1.

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

The provisions of this section have been evaluated as discussed above and either found to be no longer applicable to the Maine Yankee facility or not to meet the criteria established by the NRC for inclusion in technical specifications modeled after the improved Standard Technical Specifications contained in NUREG-1432. The deleted specifications do not affect the storage of irradiated fuel and do not involve any accident analyses remaining applicable to thc Maine Yankee facility. Therefore, the proposed changes to this MYTS subsection does

ATTACHMENT 11 Page 23 of 65 SIGNIFICANT HAZARDS EVA'UATION PROPOSED CHANGE NO. 207 not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The changes proposed in this section do not involve any changes to structures or systems necessary for the storage of irradiated Tuel or the prevention or mitigation of design basis accidents remaining applicable to the Maine Yankee facility. Further, these changes do not alter the methods of storage or handling of irrad1ated fuel in the spent fuel pool. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind l

of accident from any accident previously evaluatea.

l 3.

Involve a significant reduction in a margin of safety.

The provisions deleted from this MYTS subsection do not affect the analyses of any design basis accident remaining applicable to the Maine Yankee facility. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MY15 Subsection 3,14 Primary System Leakage This MYTS sub;ection contains limitations on the operation of the plant under varying rates and conditions of reactor coolant (primary) system leakage. These limits are based on a conservative evaluation of the postulated release resulting from a steam line break accident. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the functions of the reactor coolant system are no longer required to limit primary leakage and prevent or mitigate the consequences of a postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(11) criteria.

The proposed change does not:

1.

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

The postulated acc1denu involving damage to the reactor coolant system, damage to the main steam lines and the subsequent relene of radioactive materials are no longer possible at the Maine Yankee facility. These systems have no impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel pool.

Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or com equences of any accident previously evaluated.

i m

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ATTACHMENT 11 Page 24 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 2.

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

The deletion of this subsection does not involve any change in the structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no impact on the analyses of any postulated accident applicable to the N ine Yankee facility with its reactor in the permanentiy shutdown and defueled

state, Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

HYTS Subsection 3.15 Reactivity Anomalies Tnis MYTS subsection contains requirements to periodically compare the actual reactor coolant system boron concentration to the predicted value. This specification provides for the detection of reactivity anomalies within the reactor.

Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, this specification is no longer applicable, it meets none of the 10CFR50.36(c)(2)(ii) criteria and has not been retained in the proposed PDTS.

The proposed change does not:

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

These specifications are solely related to the operation of the nuclear reactor, Since the reactor at the Maine Yankee facility has been permanently shutdow'1 end defueled, the previously evaluated accidents involving the reactor are no longer possible and reactor reactivity anomalies can not exist. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

These specifications are solely related to the operation of the nucleat reactor. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the previously evaluated accidents involving the reattor are no longer possible and reactor reactivity anomalies can not exist. The deletion of this subsection does not affect any structures or equipment necessary for the safe storage of

ATTACINENT 11 Page 25 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 1rradiated fuel in the spent fuel pool or alter any method of operation related to storage of irradiated fuel. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

These specifications are solely related to the operation of the nuclear reactor. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the previously evaluated accidents involving the reactor are no longer possible and reactor reactivity anomalies can not exist. Therefore the deletion of these specifjcations has no impact on the analyses of postulated design basis accidents that remain applicable to the Maine Yankee facility, Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety MYTS Subsection 3.16 Previously Deleted - No Evaluation Necessary MYTS Subsection 3.17 Gaseous Radioactive Waste Storage This MYTS subsection contains requirements related to gaseous waste stored in the Radioactive Waste Gas Storage Drums. Limits were spec 1fied for the quantity of radioactivity and the concentration of explosive gas contained in the drums. These limitations were established to minimize the possibility of drum rupture and assure that all releases would be w1 thin the dose limits specified in 10 CFR Part 20, With the reactor permanently defueled, there is no longer a need to degasify primary coolant. The contents of the waste gas decay tanks have been purged. This system will not be used to support decontamination / decommissioning and will not be used in any gaseous radioactive waste processing functions. Therefore, this specification does not meet any of the 10CFR50.36(c)(2)(ii) criteria and has not been retained in the proposed PDTS, The proposed change does not:

1.

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

With the gas decay ta.ks purged and with the function of degasifying primary coolant no longer needed with the reactor in the permanently shutdown and defueled conditions, the radioactivity and explosive gas concentration limits required by this specification are no longer required to prevent or mitigate the consequences of any DBA. The deleted specifications do not affect the storage of irradiated fuel and do not involve any accident analyses remaining applicable to the Maine Yankee facility. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

ATTACHMENT 11 Page 26 of 65 SIGNIFICANT HAZARDS EVALUATION B0P.QSED CHANGE NO. 207 2.

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

The changes proposed in this section do not involve any changes to structures or systems necessary for the storage of irradiated fuel or the prevention or mitigation of design basis accidents remaining applicable to the Maine Yankee facility. Further there changes do not alter the methods of storage or handling of irradiated fuel in the spent fuel pool. Therefore, the proposed changes to this MYTS subsection t;ould not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The provisions deleted from this MYTS subsection do not affect the analyses of any design basis accident remaining applicable to the Maine Yankee facility. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3.18 Reactor Coolant System Oxygen and Chloride / Fluoride l

This subsection contains limitations on the maximum oxygen and chloride / fluoride concentrations in the reactor coolant system. These limitations assure protection of the functional integrity of the material in the reactor coolant system. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the functions of the reactor coolant system are no longer required to prevent or mitigate the consequences of a postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

The proposed change does not:

1.

Involve a significant increase in the probability or consequence of e,)

accident previously evaluated.

The postulated accidents involving damage to the reactcr coolant system and the subsequent release of radioactive materials to the containment are no longer possible at the Maine Yankee facility. These systems have no impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel storage pool. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated, j

2.

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

The deletion of these specifications does not involve any change in the a

1

ATTACHMENT 11 Page 27 of 65 ilGNIFICANT HAZARDS EVALUATION PROPOSED C W GE NO. 207 structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling 1rradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any acc1 dent previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no impact on the analyses of any postulated accident applicable to the Maine Yankee facility with its reactor in the permanently shutdown and defueled state. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3.19 Safety Injection System This subsection contains requirements related to the condition of safety injection system isolation and loop stop valves. These requirements assure that plant operation is restricted to conditions considered in the loss of-coolant accident analysis and that valve failure does not result in a rate of flow which would exceed the pressure relief capacity of certain systems which interface with the reactor coolant system. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, a loss of coolant from the reactor coolant system is no longer of concern and the reactor coolant system no longer serves any function to prevent or mitigate the consequences of any postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50,36(c)(2)(ii) criteria.

The proposed change does not:

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

The postulated accidents involving damage to the reactor coolant system pressure boundary and the subsequent release of radioactive materials are no longer possible at the Maine Yankee facility. These systems have no impact on any design basis accident involving the safe storage of 1rradiated fuel in the spent fuel pool. Therefore, the proposed changes to this MYTS sut,section do not involve any increase in the probability or consequences of any accident previously evaluated.

(

2.

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

The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling 1rradiated fuel.

Therefore, the proposed changes to this MYTS subsection wouid not

ATTACHMENT 11 Page 28 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 2_07 create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no impact on the analyses of any postulated accident applicable to the Maine Yankee facility with its reactor in the permanently shutdown and defueled state. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3,20 Shock Suppressors (Snubbers)

MYTS Section 3.20 contains LCO's associated with snubbers.

Functional snubbers were required to ensure the structural integrity of the reactor coolant system and l

other safety-related systems following a seismic or other dynamic load. This specification is not included in the improved Standard Technical Specification.

Snubbers do not meet the 10CFR50.36 criteria for inclusion in technical specifications and are not retained in the improved Standard Technical Specifications. Therefore, this specification is not retained in the proposed PDTS.

The proposed change does not:

1.

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

Shock suppressors (snubbers) were designed, installed and maintained to ensure the structural integrity of the reactor coolant system and other safety related systems following a seismic or other dynamic load.

These systems are either no longer required for the safe storage of irradiated fuel or are v longer required to be continuously available.

These systems have no adver w impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel storage pool and are not included in the proposed PDTS for reasons provided in the discussion of the applicable MYTS. Thus, the snubbers associated with these systems are not included in the proposed PDTS. Therefore, since this proposed change does not adversely affect any design basis accident, the proposed changes to this MYTS '.ubsection do not involve any increase in the probability or consequer.ces of any accident previously evaluated.

2.

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

The celetion of this MYTS subsection does not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. These

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ATTACHMENT II Page 29 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 changes will not result in any modification to structures or equipment needed for the safe storage of irradiated fuel or affect the methods of handling or storing irradiated fuel. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated. p 3.

Involve a significant reduction in a margin of safety.

The deletion of this MYTS subsection does not affect any of the systems credited in the existing analysi! for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

HYTS Subsection 3.21 - Previously Deleted - No Evaluation Necessary HYTS Subsection 3.22 Feedwater Trip System This subsection specifies the conditions of the feedwater trip system necessary to ensure stear generator cooldown potential remains acceptable in the event of a main steam line Dreak. Limiting the reactor coolant system cooldown limits the reactivity insertion associated with a negative reactivity temperature coefficient during the cooldown associated with the main steam line break, Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the effects of a cooldown on reactivity resulting from a main steam line break are no longer of concern and the feedwater trip system no longer serves any function to mitigate the consequences of any postulated accident. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(11) criteria The proposed change does not:

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

The postulated accidents involving damage to the main steam systems and the subsequent effect on reactor core reactivity and its consequences are no longer possible at the Maine Yankee facility. These systems have no adverse impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel storage pool. Therefore.

the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

Create the possibility of a new or different kind of accident from any accident previously evaluated, The deletion of these specifications does not involve any change in the

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ATTACHMENT II Page 30 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handl1ng irradiated fuel.

Therefore, the proposcd changes to this MrTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no edverse impact on i

the analyses of any remaining postulated accidents applicable to the Maine Yankee facility with its reactor in the permanently defueled state. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of sefety.

HYTS Subsection 3.23 Previously Deleted - No Evaluation Necessary HYTS Subsection 3.24 Secondary Coolant Activity MYTS subsection 3.24 contains LCO's associated with the maximum activity in the secondary coolant system. These limitations insure that the resultant isite radiation dose is limited to a small fraction of 10 CFR Part 1T.' following a steam line rupture. The activity limit applies to Dose Equivalent lodi.ne-131. Since the reactor has been shutdown and permanently defueled, this system is no longer pressurited and no longer has a significant source of lodine 131. Therefore this specification has not been retained in the proposed PDTS. With tte reactor in the permanently shutdown and defueled condition, the specification ineets none of the 10CFR50.36(c)(2)(ii) criteria discussed under the Background section above.

The proposed change does not:

1.

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

The postulated accidents involving damage to the main steam systems and the subsequent release of radioactive material are no longer possible at the Maine Yankee facility. These systemt have no adverse impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel storage pool. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of these specifications does not involve any change in the structures or equiptrent necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any

ATTACHMENT 11 Page 31 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CMNGE NO. 207 accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no adverse impact on the analyses of any postulated accident applicable to the Maine Yankee facility with its reactor in the permanently defueled state.

Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3.25 Installed Ventilation and Filter System This subsection defines the required operating status of installed ventilation and filter systems. With the reactor in the permanently shutdown and defueled condition, none of these specifications currently apply.

l The requirement to maintain the containment hydrogen purge system operable whenever

{

th0 reactor is critical serves to detect and control the concentration of hydrogen witnin the containment to keep it below its flammable limit following a loss-of-coolant acciosat. thus preserving the function of the containment systems. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, a loss-of-coolant accident is no longer of concern and there are no remaining postulated accidents which require the integrity of the primary containment to be maintained. Therefore, these specifications are no longer applicable and have been deleted. With the reactor in the permanently shutdown and defueled condition, the specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

MYTS subsection 3.25.B contains LCO's associated with the control room ventilation system. The control room ventilation system ensures that the control room temperature does not exceed the duty rating of equipment and instrumentation cooled by this system and ensures that the control room will remair habitable for personnel during and following credible accidents involving the release of radioactive materials or toxic gases. The specification requires one train of control room vtntilation to be operable whenever the reactor coolant system temperature and pressure exceed 210'F and 400psig. Two trains are required whenever the reactor is critical, This specification is no longer applicable for Maine Yankee since the reactor is permanently shutdown and defueled. This system does not meet the 10CFR50.36(c)(2)(11) criteria discussed under the Background section above.

Therefore, this specification has not been retained in the proposed PDTS, MYTS Section 3.25.C contains LCO's related to the spent fuel pool ventilation system. This system provides filtration for radioactive material released from an irradiated fuel assembly as a result of a postulated fuel handling accident. The specification requires the spent fuel pool ventilation system to be operating and discharging through the HEPA and charcoal filter train when irradiated fuel which has decayed less than 60 days is in the spent fuel pool and either fuel is being moved in the spent fuel pool or the crane is being operated with loads over the spent fuel pool. Since, all of the fuel in the spent fuel pool has decayed greater

ATTACHMENT 11 Page 32 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 than 60 days, the specification is no longer applicable, in accordance with the 10CFR50.36(c)(2)(ii) criteria discussed under the Background section abcVe, this specification has not been retained in the proposed PDTS. However, because the spent fuel pool ventilation system is associated with the safe storage of spent fuel Maine Yankee proposes to relocate MYTS 3.25.C to the FSAR.

The proposed change does not:

1.

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

The ventilation systems covered in these technical specification subsection were reviewed and evaluatad as discussed above and found either to no longer be applicable tu the Maine Yankee facility with its reactor in the permanently shutdown and defueled state, or not to meet the criteria established by the NRC for inclusion in technical specifications modeled after the improved Standard Technical Specifications contained in NUREG-1432. The function of the spent fuel l

pool ventilation system is no longer needed to limit the consequences of a postulated fuel handling accident. The effect of radioactive decay since the permanent shutdown of the reactor has reduced the~

consequences of this event to levels below those previously analyzed.

Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaJated.

2.

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

The deletion of this MYTS subsection ices not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. These changes will not result in any modification to structures or equipment needed for the safe storage of irradiated fuel or affect the methods of handling or storing irradiated fuel. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The deletion of this MYTS subsection does not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 3.26 - Previously Deleted - No Evaluation Necessary HYTS Subsection 3.27 - Previously Deleted - No Evaluation Necessary I

ATTACINENT 11 90 of 65 ilGNIFICANT HAZARDS EVALUATION EROPOSED CHANGE NO. 207 NYTS Subsection 3.28 - Previously Deleted No Evaluation Necessary i

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ATTACHMENT 11 Page 34 of 65 51GNIflCANT HAZARDS EVALUATJJ)N PROPOSED CHANGE NO. 207 MYTS Section 4 Surveillance Each subsection of MYTS Section 4 is evaluated below:

HYTS Subsection 4.0 Surveillance Requirements This section contains specifications that have generic applicability to the surveillance requirements. The existing specifications are reworded in the proposed PDTS to be consistent with the improved Standard Technical Specifications.

Additional applicability requirements have been added to specify the conditions when a surveillance requirement applies and to specify the consequences of a failure to meet or perform a surveillance requirement. A specification was added, consistent with the improved Standard Technical Sir ',fications, to allow for the possibility of the discovery that a Surveillance has not been performed. The specification l

contained in the STS prohib1 ting entry into an operating mode or other specified condition unless the surveillances have been met was not adopted since the reactor at the Maine Yankee facility is permanently shutdown and defueled and there will no longer be any changes in operating condition or mode.

The proposed change does not:

1.

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

The surveillance requirements that are no longer applicable due to the reduced scope of the proposed PDTS have no impact on facility structures or equipment or on the methods of operation of such structures or equipment. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The surveillance requirements that are no longer applicable due to the reduced scope of the proposed PDTS have no impact on facility structures or equipment or on the methods of operation of such structures or equipment. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The surveillance requirements that are no longer applicable due to the reduced scope of the proposed PDTS have no impact on facility structures or equipment or on the methods of operation of such structures or equipment or on the results of any accident analyses.

Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

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ATTACHMENT 11 Page 35 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CMNGE NO. 202 HYTS Subsection 4.1 Instrumentation and Control This subsection specifies the minimum frequency and type of surveillance to be applied to critical plant instrumentation and controls. These surveillance requirements apply primarily to equipment specified in MYTS 3.9.

Tables 4.1 1 and 4.1 2 specify the calibration, testing and checking of instrument channels associated with the reactor trip system and the engineered 50fety features actuation system. As described above for MYTS 3.9, the postulated accident scenarios requiring actuation of these systems are no longer possible at the Maine Yankee facility and these specifications have not been retained in the proposed PDTS.

Therefore the surveillance requirements in Tables 4.1 1 and 4.1 2 have not been retained in the proposed PDTS.

Table 4.1-3 specifies the calibration. testing and checking of miscellaneous instrumentation systems. As described above for MYTS 3.9.C most of these instrumentation systems are intended to provide information on selected plant parameters to monitor and assess variables during and following an accident that causes damage to the reactor core and/or a breach of the reactor coolant pressure boundary. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, such postulated accidents are no longer possible and the functions of these instrumentation systems are no longer required. Other instrumentation is associated with systems which are no longer required by the proposed PDTS. All of the instrumentation systems listed in Table 4.1 3 have been eliminated from the proposed PDTS for one or both of the above two reasons except for the Radiation Area Monitors and the Radiation Process and Effluent Monitors.

These systems give early warning of plant malfunctions by monitoring areas for increasing radiation and radioactivity and by monitoring various process streams, respectively.

Since the reactor has been permanently shutdown and defueled and the irrad1ated fuel storage limited to the Fuel Building, the number of accidents which could result in significant changes in radiological conditions or radioactive effluents have been greatly reduced. While there are accidents including the fuel handling accident in the spent fuel pool that remain valid DBA's for the Maine Yankee facility, this specification meets none of the 10CFR50.36(c)(2)(11) criteria and is not included in the improved Standard Technical Specifications. Therefore, Maine Yankee proposes to relocate, to the FSAR, the specification requirements for the Radiation Area Monitors and the Radiation Process and Effluent Monitors.

The proposed change does not:

1.

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

Most of the design basis accidents postulated in the SAR are no longer possible due to the permanently shutdown ano defueled status of the reactor. The instrumentation covered by MYTS subsection 4.1 was l

reviewed and discussed above and found either to be unnecessary for the

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ATTACHMENT 11 Page 36 of 65 SIGNIFICANT HAZMQS EVALUATION PROPOSED CHANGE NO. 207 safe storage of irradiated fuel or not to satisfy the criteria established by the NRC for inclusion in the scope of technical specifications modeled after the improved Standard Technical Specifications of NUREG 1432. Specifically, this instrumentation is not necessary to monitor any potential degradation of the integrity of the spent fuel pool and is not needed to function to prevent or mitigate the consequences of any DBA remaining applicable to the Maine Yankee facility. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of th's specif1r.ation does not involve any change to the structures or equipment or methods of operation affecting the safe-storage of irradiated fuel in the spent fuel pool or the analysis of i

I any design bases accident remaining applicable to the Maine Yankee l

facility. Therefore, the proposed changes to this MYTS subsection would not crea'oe the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The deletion of these provisions from the technical specifications does not impact the assumptions or methodology assumed in the analyses of any design bases accident remaining applicable to the Maine Yankee facility. Therefore, the proposed changes to this MYTS subsection would not involve a reduction 1n any margin of safety.

MYTS Subsection 4.2 Equipment Sampling Tests This subsection specifies the minimum frequency and type of surveillance to be applied to critical plant equipment and conditions. Table 4.2 1 specifies the minimum frequency for sampling tests of various system contents including the reactor coolant system, refueling water tank, boric acid storage tank, safety injection tanks, spent fuel pool, secondary coolant, liquid radwaste, radioactive i,,as decay tanks, spray chemical addition tank, sealed sources and oil targeted for incineration. The type of sampling tests performed include radioactivity, isotopic analysis, chemical concentration and contamination leakage. Most of these systems are no longer required by the proposed PDTS as described above in MYTS Section 3.

All of the sampling tests listed in Table 4.2-1 have been eliminated from the PDTS for this reason with the exception of spent fuel pool boron concentration, liquid radwaste radioact1vity analysis, sealed source leakagd and incinerated oil principle gamma. Spent fuel pool boron concentration sampling is reworded and retained in proposed PDTS 3.1.2.

Maine Yankee proposes to relocate, to The Radioactive Effluent Controls Program to be established and implemented as described in PDTS 5.6.4, the specification requirements encompassing liquid radwaste radioactivity analysis and incinerated oil sampling. Sealed source leakage testing does not meet the criteria i

ATTACHMENT II Page 37 of 65 SIGNIFICANT HAZARDS EVAL.UATION PROPOSED CHANGE NO. 207 listed in 10CFR 50.36(c)(2)(" for inclusion in the Technical Specifications nor is this specifiration include' the improved Standard Technical Specifications.

Therefore. Maine Yankee i aes to relocate sealed source leakage testing reau1rements to the FSAR.

MYTS 4.2. Table 4.2 2 specifies the minimum frequencies of equipment tests of various systems and components including control eiement assemblies, safety valves, refueling system interlocks, diesel fuel supply, reactor coolant system leakage, turbine valves, post accident containment vent system, pressurizer level and relief valves. None of these systems or components are included in the proposed PDTS.

Therefore, the related surveillance requirements have been eliminated from the proposed PDTS.

The proposed change does not:

l 1.

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

The samplin; frequencies and equipment tests to be eliminated from the technical specifications have been evaluated as discussed above and found either to no longer be applicable to the Maire Yankee facility with its reactor in the permanently defueled state, or not to meet the criteria estabilshed by the NRC for inclusion in technical specifications modeled after the improved Standard Technical Specifications contained in NUREG 1432. Most of the systems to be sampled or tested are no longer required by the proposed PDTS. The accidents these systems were designed to prevent or mitigate are no longer possible at Maine Yankee with the reactor in the permanently shutdown and defueled condition. Therefore, the proposed changes to this MYTS subs'.-ction do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of this MYTS subsection does not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently detueled state of the Maine Yankee reactor. These changes will not result in any modification to structures or equipment needed for the safe storage of irradiated fuel or affect the methods of handling or storing irradiated fuel. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The deletion of this MYTS subsection does not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. Therefore.

I

ATTACHHENT 11 Page 38 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 4.3 Reactor Coolant System Leak Tests This subsection specifies the tests for reactor coolant system integrity after the system is closed following normal opening, modification or repair, Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the functions of the reactor coolant system are no longer required to prevent or mitiaate the consequences of a postulated accident. Therefore, this specification is no longer applicable and has been deleted.

The proposed change does not:

1.

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

The postulated at:1 dents involving damage to the reactor coolant system and the subsequent release of radioactive materials to the containment are no longer possible at the Maine Yankee facility. These systems have no impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel pool, Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the propsed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no impact on the analyses of any postulated accident applicable to the Maine Yankee facility with its reactor in the permanently defueled state.

Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 4.4 Containment Testing These surveillance requirements serve to ensure the integrity of the primary containment. The primary containment serves to limit the release of radioactive material to the environment in the event of postulated accidents that release radioactive materials from the reactor coolant system. Since the reactor at the

ATTACHMENT II Page 39 of 6S SIGNIFICANT HAZARDS E ALUATION PROPOSED CHANGE NO. 207 Maine Yankee facility has been permanently shutdown and defueled, there are no remaining postulated accidents which require the integrity of the primary containment to be maintained. Therefore, the specifications are no longer applicable and have been deleted.

The proposed change does not:

1.

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

The postulated accidents involving damage to the reactor coolant system and the subsequent release of radioactive materials to the containment are no longer possible at the Maine Yankee facility. These systems have nn impact on any design basis accident involving the safe storage of irrad1ated fuel in the spent fuel storage pool. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

Create the possibility of a new or different kind of acc1 dent from any accident previously evaluated.

The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage of 4rradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected be these specifications have no impact on the analyses of any 4 aed accident applicable to the Maine Yankee facility in its permanently defueled State. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 4.5 uergency Power System Testing This MYTS subsection contains surveillance requirements associated with the AC and DC power sources and distribution systems. The surveillances are intended to ensure that sufficient power is available to supply the safety-related equipment required for the safe shutdown of the facility the mitigation of accident conditions, and the monitoring of the facility status. The proposed PDTS do not contain LCO's for active safety systems. The limited set of remaining LC0's consists of limitations on selected parameters associated with the storage of irradiated fuel in the spent fuel pool (i.e., water level and boron concentration). These parameters are not subject to rapid change and do not require continuous monitoring. Since active safety systems are not contained in the proposed PDTS and since LCO's covering electrical power to support such spent fuel related systems have not been retained

ATTACHMENT II Page 40 of 65 SIGNIFICANT HAZARDS EVALUATIOh PROPOSED CHANGE NO. 207 in the proposed PDTS, the related surveillance requirements have been deleted.

The proposed change does not:

1.

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

The electric power systems contained in this specifications are no longer required to be continuously available with the Maine Yankee reactor in its permanently shutdown and defueled condition. Thus, the surveillance requirements for the electric power systems are not retained in the proposed PDTS. The effects of a prolonged loss of cooling and makeup flow (e.g.. loss of electrical power) to the spent fuel pool using a:tual heat loads 'temonstrate that time is available to effect repairs or establish alternate sources of makeup flow in accordance with facility procedures.

In addition, the effect of radioactive decay since the pennanent shutdown of the reactor has reduced the consequences of the design basis accidents to levels below those previously analyzed. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

Create the possibility of a new or d1fferent kind of accident from any accident previously evaluated.

The deletion of this MYTS subsection does not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. These changes will not result in any modification to structures or equipment needed for the safe storage of irradiated fuel or affect the methods of handling or storing irradiated fuel. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The deletion of this MYTS subsection does not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 4,6 Periodic Testing This MYTS subsection contains surveillance requirements associated with various engineered safety features including the safety injection system, the containment spray system, containment isolation, emergency feedwater system, main steam excess flow check valves, feedwater trip system and reactor coolant system emergency ventilation system. The surveillances involve a variety of flow tests, valve

ATTACHMENT 11 Page 41 of 65 SIGNIFICANT HAZARDS EVALUATION Pf0 POSED CHANGE NO 207 exercises, valve position verifications, flow balances and automatic actuations and are intended to verify that the subject systems or components will respond promptly to the applicable postulated accident condition and perform their intended functions. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, such postulated accidents are no longer possible. The systems and components included in the specification are no longer required to be operable in the proposed PD15. Therefore, the related surveillance requirements have been deleted.

The proposed change does not:

1.

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

The postulated accidents involving damage to the reactor coolant system, main steam lines, main feed lines, steam generators or the reactor core and the subsequent release of radioactive materials are no longer possible at the Maine Yankee facility. These systems have no adverse impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel storage pool. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

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

l The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage of irradiated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no adverse impact on the analyses of any postulated accident applicable to the Maine Yankee facility with its reactor in the permanently defueled state.

Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 4.7 Inservice Inspection and Testing of Safety Class Components This subsection specifies the inservice testing and inspection of safety class 1, 2, and 3 components as requir9d by 10 CFR 50.55a(g). With the Maine Yankee reactor permanently shutdown and def eled many, li not all, of the components are no longer required to be tested and inspected. Maine Yankee is currently reviewing the scope of the ISI and IST programs. The disposition of this review and any consequent revision to the submitted ISI and IST programs will be addressed separately.

In the

ATTACHMENT 11 Page 42 of 65 SICtNIFICANT RAZARDS EVALUATION PROPOSED CHANGE NO. 207 interim. the IST portion of this specification has been transferred as a program requirement to PDTS 5.6.5.

This is consistent with the improved Standard Technical Specifications.

The proposed change does not:

1.

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

'In accordance with 10CFR 50.36(c)(3) surveillance requirements are requirements relate to test calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The Sroposed PDTS do not contain safety limits or LCO's for any systems or components. The limited set of remaining LCO's consists of limitations on selected parameters associated with the storage of irradiated fuel in the spent fuel pool (i.e.. water level and boron concentration). However, to be consistent l

with the improved Standard Technical Specifications the IST portion of this specification has been transferred as a program requirement to PDTS 5.6.5.

Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any

[

accident previously evaluated.

I 2.

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

The proposed specifications do not involve any change in the structures or equipment necessary for the safe stoi ege of irradiated fuel or affect the methods of storing or handling irradiated fuel. Therefore, the propoJed changes to this MY15 subsection would not create the possibility of a new or different kind of accident from anv accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no adverse impact on the analyses of any postulated accident applicable to the Maine Yankee facility with its reactor in the permanently defueled state.

Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 4.8 - Previously Deleted - No Evaluation Necessary MYTS Subsection 4.9 Shock Suppressor (Snubber) Surveillance Testing This subsection contains surveillance requirements associated with snubbers. MYTS subsection 3.20 contains LCO's associated with snubbers.

As described above, i

ATTACHMENT 11 Page 43 of 65 SIQilFICANT HAZARDS EVAltlATION PROPOSED CHANGE NO. 207 functional snubbers were required to ensure the structural integrity of the reactor coolant system and other safety related systems follow W a seismic or other dynamic load. The LCD subsection was not retained in the propscj PDTS. therefore, the related surveillance requirements in this subsection were also not retained in the proposed PDTS.

The proposed change does not:

1.

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

Shock suppressors (snubbers) were designed installed and maintained to ensure the structural integrity of the reactor coolant system and other safety related systems following a seismic or other dynamic load.

These systems are either no longer required for the safe storage of irradiated fuel or are no longer required to be continuously available.

These systems have no adverse impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel storage pool are not included in the proposed PDTS for reasons provided in the discussion of the applicable MYTS. Thus, the snubbers associated with these systems are not included in the proposed PDTS. Therefore, since this proposed change does not adversely affect any design basis accident, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of this MYTS subsection does not affect any of the systems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. These changes will not result in any modification to structures or equipment needed for the safe storage of irradiated fuel or affect the methods of handling or storing irradiated fuel. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The deletion of this MYTS subsection does not affect any of the cystems credited in the existing analysis for accidents remaining applicable to the permanently defueled state of the Maine Yankee reactor. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 4.10 Steam Generator Tube Surveillance

ATTACHMENT 11 Page 44 of 65 SIGNIFICANT HAZARDS EVALUA11DH PROPOSED CHANGE NO. 207 This subsection contains surveillance requirements necessary to demonstrated the steam generators operable. The su'veillance requirements specify the selection of steam generators, tube sample size, inspection result classification, acceptance criteria, inspection frequencies and reporting requirements. Since the reactor at the Maine Yankee facility has been permanently shutdown and defueled, the functior.s of the steam generators are no longer required to remove heat from the reactor coolant system or to prevent or mitigate the consequences of a postulated accident.

Therefore, these specifications are no longer applicable and have been deleted.

The proposed change does not:

l 1.

Involve a significant increase in the p, bability or consequence of an accident previously evaluated.

The postulated accidents involving damage to the steam generators and the subsequent release of radioactive materials are no longer possible at the Maire Yankee facility. The functions of the steam generators to remove heat and maintain the integrity of the reactor coolant pressure boundary are no longer required with the reactor permanently shutdown and defueled. These systems have no adverse impact on any design basis accident involving the safe storage of irradiated fuel in the spent fuel storage pool. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage of irrad1ated fuel or affect the methods of storing or handling irradiated fuel.

Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The systems affected by these specifications have no adverse impact on the analyses of any postulated accident applicable to the Maine Yankee-facility with its reactor in the permanently defueled state.

Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 4,11 Ventilation Filter System Surveillance Testing This subsection contains surveillance requirements necessary to demonstrate the operability of ventilation and filter systems including the containment hy1rogen purge system, the control room recirculation and breathing system, the spent fuel pool ventilation system and the containment ventilation / purge system. The LCO's for j

ATTACHMENT II Page 45 of 65 SIMIFICANT HAZARDS EVALUATION Ph2 POSED CHANGE NO. 207 these systems are specified in MYIS 3.13.0.3 and 3.25.A. B & C.

None of these LCO's were retained in the proposed PD 3 for reasons given under the above subsection.

l Therefore, the related surveillance requirements in this specification have not been l

retained in the croposed PDTS.

l The proposed change does nct:

1.

Involve a significant increase in the probability or consequence of an accident previously evaluated, The ventilation systems covered in these technical specification subsection were reviewed and evaluated as discussed above and found either to no longer be applicable to the Maine Yankee facility with its reactor in the permanently shutdown and defueled state, or not to meet the criteria established by the NRC for inclusion in technical specifications modeled after the improved Standard Technical Specifications contained in NUREG-1432. The function of the spent fuel pool ventilation system is no longer required to be operable by the current Maine Yankee Technical Specifications. The effect of radioactive decay since the permanent shutdown of the reactor has reduced the consequences of this event to levels below those previously analyzed. Therefore, the proposed changes to this MYTS subsection do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

These changes will not result in c.1y modification to structures or equipment needed for the safe storage of irradiated fuel or affect the methods of handling or storing irradiated fuel. Therefore, the proposed changes to this MYTS subsection would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

These changes will not result in any modification to structures or equipment needed for the safe storage of irradiated fuel or affect the methods of handling or storing irradiated fuel. Therefore, the proposed changes to this MYTS subsection would not involve a reduction in any margin of safety.

MYTS Subsection 4.12 - Previously Deleted - No Evaluation Necessary MYTS Subsection 4.13 - Previously Deleted - No Evaluation Necessary

ATTACHMENT II Page 45 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CPANGE NO. 207 i

HYTS Section 5 Administrative Controls' Consistent with the format of NUREG 1432, the administrative controls section is located in Section 5.0 of the proposed PDTS. Where practicable, the individual specifications in the proposed PDTS have also been patterned after those contained in the NUREG 1432. Some deviations from the standard technical specifications have been included as appropriate to the unique status of the Maine Yankee facility. The scope of activities, and consequently the size of the staff, at the Maine Yankee facility are greatly reduced from those required for an operating power plant.

Also, as demonstrated in the discussions above, the potentici impact on the health and safety of the public due to postulated accidents is much lower than at an operating power plant. Therefore, some administrative controls have been reduced as appropriate. The specific provisions of the current MYTS are discussed separately below.

The content of subsection 5.1 has been augmented in the proposed PDTS to be consistent with the con +ent of improved Standard Technical Specification. The shift manager on-site has been designated with responsibility for the command function.

The improved Standard Technical Specifications require that the command function be maintained in the control room. This requirement is based on the centralized nature of the controls of an operating reactor and the rapid response necessary to command those controls in an abnormal or accident situation. With the Maine Yankee reactor permanently shutdown and defueled and the irradiated fuel safely stored in the spent fuel pool, the number of relevant controls located in the control room and the gradual nature of abnormal and accident situations do not warrant that this command function remain in the control room. Capability is provided to maintain ready communication between the control room and the shift manager at all times. This reddy communication capatility int.ludes: pagers, walkie-talkies and/or the plant paging system. The individual qualified to stand watch in the control room will be provided with the training necessary to take the appropriate initial responses as described in procedures.

A provision is added to utilize generic titles in the PDTS for members of the staff as provided in Regulatorv Guide 1.8 - 1975 and/or ANSI N18.1 - 1971, unless otherwise defined in the technical specifications. Plant-specific. Maine Yankee titles for the functions and responsibilities associated with these generic titles are identificd in the FSAR and/or QA program. This provision allows functions and responsibilities to be specified without constraining the nomenclature of the' plant-specific titles. Changes to the plant-specific titles may be handled in accordance with the controlling regulatory process such as 10CFR50.54(a) or 10CFR50.59 as appropriate.

The general organizational requirements for the Maine Yankee facility was reworded and retained in the proposed PDTS. These requirements are patterned after the format and wording of the improved Standard Technical Specifications. The provisions of Proposed Change No. 206 (Reference C) to the Technical Specifications to address the permanently defueled condition have been retained. These provisions include the minimum shift crew composition and the requirements related to certified fuel handlers. The requirement to maintain an individual qualified in radiation

ATTACHMENT II Page 47 of 65 D GNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 protection procedures onsite when fuel is in the reactor has been deleted since there is no longer any fuel in the reactor. Radiation protection requirements including tM presence on individuals qualified in radiation protection procedures will be described in the Radiation Protection Program. The assertion of MYTS stating that an operator holding a Senior Reactor Operator (SRO) license is qualified as a certified fuel handler has been deleted as the SR0 licenses at the Maine Yankee facility will no longer be maintained once Proposed Change No. 206 (Reference C) is approved and implemented. However, the 6ssertion continues to be correct. The minimum shift crew composition table has been retained as submitted in Proposed Change No. 206 (Reference c). The unexpected absuce allowance was augmented to be consistent with the wording in the improved Standard Technical Specifications and has been transferred to table described above. The unit staff working hour requirements have been revised to adopt the wording of the improved Standard Technical Specifications to the extent consistent with the permanently shutdown and defueled status of the reactor.

The requirements for qualifications of the facility staff have been retained as worded in the current Maine Yankee Technical Specifications. The exception for the qualifications of Technicians has been removed. Maine Yankee proposes to relocate this exception to the Quality Assurance Program.

The requirements for training have been retained as submitted in Proposed Change No.

206 (Reference c).

f l

Maine Yankee proposes to replace the review and audit functions performed by the l

Plant Operating Review Comittee (PORC) and the Nuclear Safety Audit and Review I

Committee with tt'e review and audit requirement described in Attachment V and to relocate to these requirements to the Quality Assurance Program. With the termination of reactor operations at the Maine Yankee facility and the removal of operating authority pursuant to 10CFR50.82(a)(2), the scope and complexity of activities at the facility have been greatly reduced. Consequently, the permanent staff supporting the Maine Yankee facility will also be much smaller than those required to support an operating power plant. The reduced scope of activities and limited staff make operation of two review committees impracticable and unnecessary.

The responsibilities associated with the new review requirements will encompass the majority of the functions previously performed by the PORC and the NSARC. Selected functions have been modified consistent with the scope of activities at a permanently defueled facility.

The requirements for reportable events have not been retained in the proposed PDTS since these requirements are specified in the applicable regulations and additional detail is not necessary in the PDTS. This'is consistent with the improved Standard Technic <l Specifications. The requirements for safety limit violation reporting are unnecessary and have not been retained in the proposed PDTS since there are no safety limits that apply to the Maine Yankee facility with the reactor in the permanently shutdown and defueled condition.

The requirements for programs and procedures have been retained with appropriate l

ATTACl44ENT II-Page 48 of 65 SIGNIFICANT HAZARDS EVALUATIQN-PROPOSED CHANGE NO. 207

- modifications and divided into two separate specifications.

The requirements for. the Radioactive Effluent Controls Program have been retained.

= Maine Yankee proposes to. relocate the Radiological Environmental Monitoring Program requirements to the Offsite Dose Calculation Manual. consistent with the improved

>$tandard Technical Specifications.

- The-requirements. for the establishment,- implementation and maintenance _of procedures-l covering various activities has been-retained and modified to clarify that the specif_1 cation covers only such procedures applicable to the safe' storage of

-irradiated fuel. A reference to " refueling operations" has been deleted in the proposed PDTS since refueling operations will no longer be conducted at the Maine Yankee facility..A_ reference to procedures for surveillance and test activities of safety-related equipment has also been deleted since this provision is redundant.

Maine Yankee proposes to relocate the requirements for the Process Control-Program (PCP) to the FSAR, consistent with the improved Standard Technical Specifications.

00CM change requirements are included in the program specification. The requirements associated with permanent and temporary changes to procedures have not been retained in the proposed PDTS, consistent with the improved Standard-Technical Specifications.

Programs added to the proposed PDTS program subsection include: the radiat on protection program, off-site dose calculation manual (00CM), technical specification (TS) bases control program and inservice testing program. There are some programs specified _in the improved Standard Technical _ Specifications which do-not apply to a facility with a permanently shutdown and defueled reactor. These programs have not been included in_the proposed PDTS.

HThe improved Standard Technical Specifications require a program to ensure that any

-loss of safety function is detected and: appropriate action taken. The program consists of safety function evaluations, cross train checks and cvaluation to-determine the impact on supported system's operability and required action completion times. With the Maine Yankee reactor has been oermanently shutdown and defueled, the complexity 'of determining' safety functions normally associated with operating reactors is greatly reduced. As a result, the LC0 section of the proposed PDTS is_very straightforward making a Safety Functions Determination Program unnecessary.

- The reporting requirements subsection has been retained, with appropriate modifications. The wording is consistent with the improved STE to the extent consistent with the permanently shutdown and defueled status of the reactor.

.Several reports are no longer appropriate for a permanently defueled facility and have bef.n deleted, These include: Startup Reports Monthly Operating Reports, Special Reports and Core Operating Limits Report. The special report for excessive radioactive release and total dose have been deleted because they are redundant to

-the 00CM.

There are some reporting requirements specified in the improved Standard Technical Specifications which do not apply to a facility with a permanently shutdown and

ATTACHHENT II Page a of 55 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 defueled ieactor. These reporting requirements have not been included in the proposed PDTS. These reporting requirements are associated with systems, structures and components which either do not apply to Maine Yankee or are no longer required with the reactor in a permanently shutdown and defueled condition.

Maine Yankee proposes to relocate the requirements for the retention of various types of records to the Quality Assurance Program where they will be maintained pursuant to 10CFR50.54(a). This relocation is consistent with the improved STS.

Some record types will not been retained in the relocation to the Quality Assurance Program as they are no longer applicable as demonstrated by the discussions of specific MYTS sections. These include:

MYTS 5.10.2.f covering records of transient or operational cycles.

MYTS 5.10.2.i covering records of inservice inspections, and The requirements for the control of high radiation areas have been retained in the proposed PDTS. Additional provisions contained in the improved standard technical specifications have also been included. The scope and content of these requirements are consistent with the improved Standard Technical Specifications contained in i

NUREG-1432. The determination of radiation surveillance frequency specified in PDTS 5.8.1.c by Radiation Protection personnel or, when appropriate, by the Radiation Protection Manager.

Core Operating Limits Report subsection specifies core operating limit parameters to be established and implemented in the Core Operating Limits Report (COLR) by specified analytical methods which have been previously reviewed and approved by the NRC. With the Maine Yankee reactor permanently shutdown and defueled, these parameters and related analytical methods no longer apply. Therefore. this subsection has not been retained in the proposed PDTS.

The preposed change does not:

1.

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

This section of the MYTS provides for administrative controls over facility activities and does not directly affect the design of structures or equipment necessary for the safe storage of irradiated fuel or the methods used for handling and storage of such fuel in the spent fuel pool. The proposed changes to this section delete provisions that are no longer applicable due to the permanently defueled status of the facility and modifies other controls as appropriate for the reduced scope of activities at a permanently defueled facility. The safety significant aspects of the organization, facility staffing, qualification and training will continue to be maintained. Programs, piacedures and reports that are applicable to the safe storage of spent fuel are included in the technical specifications. The administrative controls to provide for reviews and audits of activities affecting the safe storage of irradiated fuel and the retention of records will be relocated to the Quality Assurance m..

ATTACMENT II Page 50 of 65 SIGNIFICANT HAZARDS EVALUAT10H PROPOSED CHANGE NO. 207 Program. The changes are administrative in nature and do not affect any-accidents applicable to the safe storage of irradiated fuel or the permanently shutdown and defueled condition of the reactor. Therefore, the proposed changes to this MYTS Section do not involve any increase

-in the probability or consequences of any accident previously evaluated.

2.

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

The revised administrative controls do not alter the design of L

structures or equipment needed for'the safe storage of irradiated fuel or the methods of fuel-handling and storage in the spent fuel pool.

The proposed technical specifications continue to provide for safety _

significant administrative controls and activities. Therefore, the proposed changes to this MYTS section would not create the possibility of a new or different kind of accident-from any accident previously evaluated, 3.

Involve a significant reduction in a margin of safety.

The proposed changes have no impact on the analyses of. postulated design basis accidents remaining applicable to the. Maine Yankee facility. Therefore, the proposed changes to this MYTS sbetion would not involve a reduction in any margin of safety.

Soecifications Included in the PDTS i

Specification-Included in the PDTS - Two LC0's and associated surveillance requirements are contained in the proposed PDTS. These specifications were

' determine to be necessary to meet 10CFR50.36(c)(2)(ii)(B) Criterion 2. in that they cover limits that are initial conditions for design bases accidents. These

= specifications are discussed separately below, PDTS 3.1.1 Spent Fuel Pool Water Level - This specification requires that the spent fuel pool water level be maintained within limits during fuel movement and requires verification of compliance at a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months frequency. The actions associated with this LC0 require immediate suspension of movement of irradiated fuel assemblies in the

-fuel: storage pool. The immediate actions minimize the potential for a fuel handling accident or a loss of shielding during fuel movement. Restrictions on crane operation with loads over the spent fuel pool are not included in the LCO, consistent with the improved Standard Technical Specification. These restrictions will be described in the FSAR.

The minimum water level in the fuel storage pool meets the assumptions of iodine

. decontamination factors following a fuel handling accident. Even though the spent fuel fission products have actually decayed at'least nine months, the proposed LC0 is based upon the existing analysis which assumes a one week and/or 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months decay period. The resulting doses which are calculated for the fuel handling accident are

ATTACHMENT II Page 51 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 below the values specified in 10CFR100. The specified water level also shields and minimizes the general area dose during fuel movement.

PDTS 3.1.2 Spent Fuel Boron Concentration - This specification places a limit on the minimum soluble boron concentration in the spent fuel pool. This limit applies whenever fuel assemblies are stored in the spent fuel pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the spent fuel pool. The design of the spent fuel pool is based on the use of unborated water, which maintains a subcritical condition (K,,, < 0.95) during normal operation with the spent fuel racks fully loaded.

However, the water in the spent fuel pool normally contains soluble boroi1. This results in large subcriticality margins under normal conditions. The presence of this soluble boron is credited in the analyses of abnormal conditions. Credit for soluble baron under abnormal or accident conditions is allowable since only a single accident need be considered at l

one time.

i PDTS 3.1.2 limits the boron concentration to no less than 1000 ppm to preserve, with operating margin, the initial conditions assumed in the accident analyses. An analysis value for boron concentration of 663 ppm, assumed in the analysis for the postulated misplacement of a fuel assembly, was determined to be required to maintain a 5% Ak/k safety margin to criticality. The LCO is applicable whenever fuel assemblies are stored in the spent fuel pool and a spent fuel pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool. When the concentration of boron in the spent fuel pool is less than required, the LC0 requires immediate action to minimize the potential for misplacement an fuel assembly, immediate actions are also required to either initiate action to restore fuel storage pool boron concentration to within limit or initiate action to perform a fuel storage pool verification.

The surveillance requirements verify that the concentration of baron in the spent fuel pool is within the required limit when the LC0 is applicable. As long as this condition is met, the analyzed accidents are fully addressed. The 7 day frequency is appropriate during the movement of fuel assemblies because no major replenishment of pool water that could result in a dilution of the boron concentration is expected to take place over such a short Deriod.

Spent Fuel Pool Temperature - The permanently defueled technical specifications (PDTS) for the Trojan plant contain a specification for maximum spent fuel pool temperature. The Trojan submittal indicates that this specification is based upon an initial maximum pool temperature assumed in the analyses of a prolonged loss of forced cooling to the spent fuel pool. This specification does not exist in the current MYTS or the improved Standard Technical Specifications (NUREG 1432 dated April 1995). The maximum spent fuel pool temperature at Maine Yankee is limited because its relation to the structural integrity of the spent fuel pool and the time to boil. Since the maximum spent fuel pool temperature is important to the structural integrity of the spent fuel pool and the time to boil, the Maine Yankee FSAR will include the value along with its basis. This is consistent with the improved Standard Technical Specificat1ons.

ATTACHMENT II Page 52 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 The proposed change does not:

1.

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

The proposed restrictions on the boron concentration and level in the spent fuel pool have no impact on the probability or consequences of the remaining applicable design basis accidents. These res M ctions are fulfilled by normal operating conditions, preserve initial conditions assumed in the analyses of postulated DBAs and ens de that the conditio1s of such DBAs are consistent with the analyses.

Therefore, the proposed changes to the MYTS do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The proposed restrictions on the boron concentration and level in the spent fuel pool are fulfilled by normal operating conditions and preserve initial conditions assumed in the analyses of postulated DBAS.

These additional restrictions do rat involve changes to any structure or equipment affecting the safe storage of irradiated fuel or the methods of handling or storing such fuel. Therefore, the proposed changes to the MYTS would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The proposed additional restrictions on the boron concentration and level in the spent fuel pool preserve initial conditions assumed in the analyses of postulated DBAs and ensure that margins of safety contained in the analyses are maintained. Therefore, the proposed changes to the MYTS would not involve a reduction in any margin of safety.

Summary of Sianificant Hazards Evaluation The following is a summary compilatior of the above significant hazards evaluations.

The proposed change does not:

1.

Involve o significant increase in the probability or consequences of an accide6L previously evaluated.

This proposed change is consistent with the improved Standard Technical Specifications. The relocation of requirements from the technical specifications to the licensee controlled documents is consistent with the criteria set forth in 10CFR50.36 for the content of technical specifications. The removal of definitions, generic LCO actions and

ATTACHMENT II Page 53 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 generic surveillance requirements has no impact on facility structures or equipment or the methods of operation of such structures or equipment. The deletion of design features and safety limits not applicable to the permanently shutdown and defueled status of the Maine Yankee reactor has no impact on the remaining applicable design basis accidents. The removal of LCO and Surveillance specifications which are related only to the operation of the nuclear reactor or only to the prevention, diagnosis or mitigation of transients or accidents primarily involving the reactor, do not affect the remaining applicable accidents previously evaluated. The critical safety functions involving core reactivit.y control, reactor heat removal, reactor coolant system inventory control and containment integrity are no longer necessary at the Maine Yankee facility. The postulated accidents involving damage to the reactor coolant system, main steam lines, main feed lines, steam generators or the reactor core and the subsequent release of radioactive mater 161 are no longer possible at the Maine Yankee facility. Spent fuel pool cooling and makeup related equipment and support equipment including electrical power systems are not required to be continuously available since there is time available to effect repairs or establish alternate sources of makeup flow in the event of a loss of cooling and makeup flow to the spent fuel pool. The effect of radioactive decay since the shutdown of the reactor has reduced the consequences of the fuel handling accident to levels below those previously analyzed. The relevant parameters associated with the spent fuel pool (level and boron concentration) that make up the initial conditions assumed in the applicable accident analysis are included in the technical specifications. The deletion and modification of provisions of administrative controls do not directly affect the design of structures or equipment necessary for the safe storage of irradiated fuel or the methods used for handling and storage of such fuel in the spent fuel pool. The changes to the administrative controls are, in fact, administrative in nature and do not affect any accidents applicable to the safe storage of irradiated fuel or the permanently shutdown and defueled condition of the reactor. Therefore, the proposed changes to the Maine Yankee Technical Specifications do not involve any increase in the probability or consequences of any accident previously evaluated.

2.

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

The proposed changes have no impact on facility structures or equipment affecting the safe storage of irradiated fuel or on the methods of operation of sucn structures or equipment or handling and storage of such fuel. These changes are consistent with the improved Standard Technical Specifications and add to the clarity and ease of use of the croposed PDTS. The removal of technical specifications which are related only to the operation of the nuclear reactor or only to the prevention, diagnosis or mitigation of transients or accidents

ATTACHMENT II Page 54 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 primarily involving the reactor, can not result in different or more adverse failure modes or accidents than previously evaluated because the reactor is permanently shutdown and defueled. The proposed deletion of provisions of the Maine Yankee Technical Specifications do not affect systems credited in the existing accident analyses for the remaining applicable postulated accidents at the Maine Yankee facility.

The proposed technical specifications continue to require proper control and monitoring of safety significant parameters and activities.

The proposed restrictions on the boron concentration and level in the spent fuel pool are fulfilled by normal operating conditions and preserve initial conditions assumed in the analyses of postulated DBA's. Therefore, the proposed changes to the MYTS would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The deletion of provision of the technical specifications which are not l

related to the storage of irradiated fuel or which are-inconsistent with the scope of the improved Standard Technical Specifications will not affect the analyses of the design basis accidents remaining applicable to the Maine Yankee facility. The postulated design basis accidents involving the reactor are no longer possible due to the permanently defueled status of the Maine Yankee reactor. The requirements for systems, structures and components which have been deleted from the Maine Yankee Technical Specifications are not credited in the existing accident analysis for the remaining applicable postulated accidents and therefore do not contribute to the margin of safety associated with the accident analysis. Therefore, the proposed changes to the Maine Yankee Technical Specifications would not involve a significant reduction in a margin of safety.

Conclusion Maine Yankee has concluded that the proposed change to the Technical Specifications does not involve a signifi. cant hazards consideration as defined by 10 CFR 50.92.

ATTAClitENT II Page 55 of.65 SIGNIFICANT HAZARDS EVALtlATION

PROPOSED CHANGE NO. 207 ENVIRONMENTAls1MPACT DETERMINATION-This amendment' request meets the criteria specified in 10 CFR 51.22 (c)(9) for categorical exclusion or otherwise not requiring environmental review. Specific

-criteria contained in this section are discussed below:

1.

The amendment involves no significant hazards consideration. As demonstrated above, this requested amendment does not involve any significant hazards considerations.

2.

There is no significant change in_ the types or significant increase in a

the amounts of any effluents that may be released offsite. The requested license anendment proposes to modify the Maine Yankee Facility Operating License to reflect the permanently defueled and shutdown condition of the reactor. Administrative controls.on plant effluents remain in place to ensure applicable regulatory guidelines on plant effluents that may be released offsite are met. Thus, no L

anticipated plant activities as a result of 1ssuance of this requested amendment should result in a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite.

3.

There is no significant increase in individual or cumulative i.

occupational radiation worker exposure. The proposed amendment will provide relief from certain operational requirements that are inappropriate for a permanently shutdown and defueled reactor. These operational requirements (surveillance testing. inspections, etc.), in some cases, result in -the accrual of__ occupational radiation exposure for Maine Yankee workers. As the' requirements for conducting these activities are reduced, many of these activities may be eliminated.

The elimination of these unnecessary activities is expectad to result -

in a decrease in the cumulative radiation exposure. In addition,.

administrative controls shall remain in place to ensure that individual occupational radiation exposure is_ maintained below applicable

egulatory requirements.

On the basis of the preceding discussion, it has been concluded that the proposed amendment is acceptable and meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c)(9), and thus no environmental impact statement or

environmental assessment need to be prepared in connection with the issuance of this amendment.

' SCHEDULE CONSIDERATION-

-We request-that the NRC approval of this proposed change include a provision that allows Maine Yankee to determine the date that the PDTS will be-implemented. This flexibility in scheduling is being requested due to the numt r of proposed changes and the additional administrative controls which are to be ~,.aplemented concurrently with'the PDTS. Maine Yankee will notify the NRC of the proposed implementation date

ATTACHMENT II Page 56 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 for the PDTS.

Sumary Table The following table presents a comparison of current Maine Yankee technical specifications to the NUREG-1432 improved standard technical specifications and the proposed Maine Yankee PDTc Comparison of Current Maine Yankee Technical Specifications to Proposed Permanently Defueled Technical Specifications Current MYTS Improved STS Proposed PDTS REACTOR OPERATING CONDITIONS Refueling Shutdown Table 1.1-1 Definitions Not Applicable Condition (Condition 1)

Refueling Operations Table 1.1-1 Definitions Not Applicable Condition (Conditicn 2)

Cold Shutdown Condition Table 1.1-1 Definitions Not Applicable (Condition 3)

Transthermal Condition Table 1.1-1 Definitions Not Applicable (Condition 4)

Hot Shutdown Condition Table 1.1-1 Definitions Not Applicable (Condition 5)

Hot Standby Condition Table 1.1-1 Definitions Not Applicable (Condition 6)

Power Operation Condition Table 1.1-1 Definitions Not Applicable (Condition 7)

Higher Operating Condition Addressed in t.TS 3.0.4 Not Applicable REACTOR STATUS Refueling Boron Not included Specified in Scction 3.1.2 Concentration Cold Shutdown Boron Not Included Not Included Concentration Reactor Critical Not included Not Included Shutdown Margin 1.1 Definitions Described in the basis for Section 3.1.2 Low Power Physics Testing 1.1 Definitions Not Applicable

ATTACHMENT II Page 57 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 Comparison of Current Maine Yankee Technical Specifications to Proposed Permanently Defueled Technical Specifications Current MYTS Improved STS Proposed PDTS Power Range Physics 1.1 Definitions Not Applicable Testing Rated Power 1.1 Definitions Not Applicable Quadrant Power Tilt 1.1 Definitions Not Applicable Adjusted Reference Not Included Not Included Temperature (ART)

Lowest Service Temperature Not Included Not Included Minimum Boltep Temperature Not included Not Included REACTOR PROTECTIVE SYSTEM Instrument Channels Not Included Not Included l

Reactor Trip Not Included Not Included Trip Module Not Included Not Included ENGINEERED SAFEGUARDS SYSTEMS l

Subsystem Not Included Not Included Degree of Redundancy Not Included Not Included MISCELLANE0US DEFINITIONS Operable 1.1 Definitions Not Applicable Operating Not Included Not Included Control Element Assemblies Not Included Not Included Partial-Length Control Not Included Not Included Element Assemblies Fire Suppression Water Not Included Relocate to the FSAR System Core Operating Limits 1.1 Ocfinitions Not Applicable Report Radio Isotope Release Not Included Not Included Limits E - Average 1.1 Definitions Not Applicable Disintegration Energy 1

ATTACHMENT II Page 58 o: 65 i

SIGNIFICANT HAZERDS EVALUATION PROPCSED CHANGE NO. 207 Comparison of Current Maine Yankee Technical Specifications to Proposed Permanently Defueled Technical Specifications Current MYTS Improved STS Proposed PDTS Dose Equivalent 1-131 1.1 Definitions Not Applicable Reportable Event Not Included Not Included Remedial Action 1.1 Definitions 1.1 Definitions Noncompliance Not Included Not Included Nonconformance Not Included Not Included Frequency Notation 1.4 Frequency 1.4 Frequency Table 0.1 Minimum Pressurization Not Included Not Included Temperature Off-Site Dose Calculation Program Included in Program Included in Manual (0DCM)

Section 5.5.1 Section 5.6.3 Member (s) of the Public Not included Not Included Site Boundary 4.1 Site Location Described in Section 4.1.1 Gaseous Radwaste Treatment Not Included

' ot Included System Process Control Program Not Included Relocate to the FSAR (PCP)

Ventilation Exhaust Not Included Relocate to the FSAR Treatment System Unrestricted Area Not Inc hded Not Included 1.1 Fuel Storage 4.3 Fuel Storage 4.2 Fuel Storage 1.2 Site Description 4.1 Site Location 4.1 Site 1.3 Reactor 4.2 Reactor Core Not Applicable 1.4 Containment Not Included Not Applicable 2.0 Safety Limit 2.2 Safety Limit Not Applicable Violations Violations 2.1 Limiting Safety System 3.3.1 Reactor Protective Not Applicable Setting - Reactor System (RPS)

Protection System Instr amentation

ATTACHMENT II Page 59 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 Comparison of Current Maine Yankee Technical Specifications to Proposed Permanently Defueled Technical Specifications Current MYTS Improved STS Proposed PDIS 2.2 Safety Limit - Reactor 2.1.1 Reactor Core Safety Not Applicable Core Limit 3.2 Power Distribution Limits 2.3 Safety Limit - Reactor 2.1.2 Reactor Coolant Not Applicable Coolant System Pressure System (RCS) Pressure Safety Limit 3.0 Limiting Condition for 3.0 Limiting Condition for 3.0 Limiting Condition for Operation Operation (LCO)

Operation (LCO)

Applicability Applicability A. Nonconformances with 3.0.3 Exceeding LC0 Mostly Not Applicable LCO's Actions or None Provided 3.0.2 Implementation of.

LCO Actions B. Entry into a Higher 3.0.4 Changes in Modes or Not Applicable Operating Condition Conditiors C. Operability of Safety-3.0.6 Support Systems Not Applicable Related Components with 3.8 Electrical Power Emergency Power Sources 3.1 Reactor Core 3.2 Power Distribution Not Applicable Instrumentation Limits 3.2 Reactor Coolant System 3.4.16 RCS Specific Not Applicable Activity Activity 3.3 Reactor Coolant System 3.4 Reactor Coolant System Not Applicable Operational Components (RCS) 3.4 Combined Heatup.

3.4 Reactor Coolant System Not Applicable Cooldown and Pressure Temperature Limitations 3.5 Chem 1 cal and Volume Not Included Not Applicable Control System 3.6 Emergency Core Cooling 3.5 Emer'.ency Core Cooling Not Applicable and Containment Spray System (ECCS)

Systems 3.7 Boron and Sodium 3.5 Emergency Core Cooling Not Applicable Hydroxide Available for System (ECCS)

Containment Spray System

ATTACHMENT II Page 60 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 2QZ Comparison of Current Maine Yankee Technical Specifications to Proposed Permanently Defueled Technical Specifications Current MYTS Improved STS Proposed PDTS 3.8 Reactor Core Energy 3.4 Reactor Coolant System Not Applicable Removal (RCS) 3.7 Plant Systems 3.9 Operational Safety 3.3 Instrumentation Not Applicable Instrumentation Control System and Accident Monitoring Instrumentation A. Reactor Protection 3.3.1 Reactor Protective Not Applicable System System (RPS)

Instrumentation-Operating 3.3.2 Reactor Protective System (RPS)

Instrumencation-Shutdown 3.3.3 Reactor Protective System (RPS) Logic and Trip Initiation B. Engineered Safeguards 3.3,4 Engineered Safety Not Applicable Features Actuation System Features Actuation System (ESFAS) Instrumentation 3.3.5 Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip C. Accident Monitoring 3.3.11 Post Accident Not Applicable System Monitoring (PAM)

Instrumentation 3.10 CEA Group. Power 3.2 Power Distribution Not Applicable Distribution, Moderator Limits Temperature Coefficient Limits and Coolant Conditions 3.11 Containment 3.6 Containment System:

Not Applicable 3.12 Station Service Power 3.8 Electrical Power Not Applicable Systems 3.13 Refueling and Fuel 3.9 Refueling Operations Mostly not applicable Consolidation Operations 3.1 Defueled Systems A. Fuel Handling Crane -

Not included Relocate to the FSAR Loao Test l

l

ATTACHMENT II Page 61 of 65 SIGNIFICANT HAZARDS EVALUATI0fl PROPOSED CHANGE NO. 207 Comparison of Current Maine Yankee Technical Specifications to Proposed Permanently Defueled Technical Specifications Current MYTS Improved STS Proposed PDTS B. Decay Time - Irradiated Not included Not Included Fuel C. Refueling Boron 3.9.1 Boron Concentration 3.1.2 Spent Fuel Pool Concentration Boron Concentration D. Core Alterations or Movement of Irradiated Fuel within Containment D 1 Decay Time -

3.9.3 Containment Not Applicable Containment Equipment Penetrations Hatch D.2 Decay Time - Personnel 3.9.3 Containment Not Applicable Airlock doors Penetration D.3 Containmerit Venting 3.9.3 Containment Not Applicable and Purging Penetrations 3.3.7 Containment Purge Isolation Signal D.4 Radiation 3.9.3 Containment Not Applicable Instrumentation for Penetrations Containment Ventilation 3.3.7 Containment Purge Isolation Isolation Signal D.5 Containment Purge Trip 3.9.3 Containment Not Applicable Valve Testing Penetrations 3.3.7 Containment Purge Isolation Signal D.6 Radiation Monitoring Not Included Relocate to the FSAR D.7 Neutron Flux 3.9.2 Nuclear Not Applicable Instrumentation Instrumentation D.8 Residual Heat Removal 3.9.4 Shutdown Cooling and Not Applicable Coolant Circulation - High Water Level D.9 Residual Heat Removal 3.9.5 Shutdown Cooling and Not Applicable

- Low Water Level Coolant Circulation - Low Water Level D.10 Minimum Water Level 3.9.6 Refueling Water 3.1.1 Spent Fuel Pool Level Water Level i

ATTACHMENT II Page 62 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 Comparison of Current Maine Yankee Technical Specifications to Proposed Permanently Defueled Technical Specifications Current MYTS Improved STS Proposed PDTS C.11 Communication Not included Not Applicable E. Spent Fuel Storage Rack Not included Relocate to the FSAR Movement F. Decay Time - Fuel Not included Relocate to the FSAR Consolidation 3.14 Primary System 3.4 Reactor Coolant System Not Applicable Leakage (RCS) 3.15 Reactivity Anomalies 3.1 Reactivity Control Not Applicable Systems 3.16 Deleted N/A Not Applicable 3.17 Gaseous Radioactive Program Required by 5.5 Not Applicable Waste Storage 3.18 Reactor Coolant Not included Not Applicable System Oxygen and Chlorine / Fluoride Concentration 3.19 Safety injection 3.4 Reactor Coolant System Not Applicable System (RCS) 3.20 Shock Suppressors Not included Not included (Snubbers) 3.21 Deleted Not Applicable Not Applicable 3.22 Feedwater Trip System 3.3 Instrumentation Not Applicable 3.7 Plant Systems 3.23 Deleted Not Applicable Not Applicable 3.24 Secondary Coolant 3.7 Plant Systems Not Applicable Activity 3.25 Installed Ventilation Program Required by 5.5 Not Applicable and Filter Systems A. Containment Hydrogen 3.6.8 Hydrogen Recombiners Not Applicable Purge 3.6.9 Hydrogen Mixing Systems

ATTACHMENT 11 Page 63 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 Comparison of Current Maine Yankee Technical Specifications to Proposed Permanently Defueled Technical Specifications Current MYTS Improved STS Proposed PDTS B. Control Room 3.7.11 Control Room Not Applicable Ventilation System Emergency Air Cleanup System 3.7.12 Controi Room Air Temperature Control System C. Spent Fuel Pool 3.7.14 Fuel Building Air Relocate to the FSAR Ventilation System Cleanup System 3.26 Reserved Not Applic6ble Not Applicable l

3.27 Reserved Not Applicable Not Applicablo 3.28 Deleted Not Applicable Not Applicable 4.0 Surveillance SR 3.0 Surveillance SR 3.0 Surveillance Requirements Requirement (SR)

Requirement (SR)

Applicability Applicability A. Maximum Allowable SR 3.0.2 25% Extent of SR 3.0.2 25% Extension of Surveillance Interval Surveillance Frequencies Surveillance Frequencies Extension B. Applicability of SR 3.0.1 Applicability of SR 3.0.1 Applicability of Surveillance Requirements Surveillance Requirements Surveillance Requirements 4.1 Instrumentation and SR 3.3 Instrumentation Mostly Not Applicable Control Relocate certain radiation monitors to the FSAR 4.2 Equipment and Sampling SR 3.4 Reactor Coolant Mostly Not Applicable Tests System except for:

SR 3.5 Emergency Core SR 3.1.2 Spent Fuel Pool Cooling System Boron Concentration and SR 3.6 Containment Systems the following:

SR 3.7 Plant Systems 4.2 Table 4.2-1 Item 8 Not Included Relocate to the Liquid Radwaste Radioactivity Effluents Radioactivity Analysis Control Program 4.? Table 4.2-1 Item 11 Not included Relocate to the FSAR Sealed Source Leakage 4.2 Taole 4.2-1 Item 18 Not Included Relocate to the Incinerated Oil Principal Radioactivity Effluents Gamma Control Program I

ATTACHMENT II Page 64 of 65 SIGNIFICANT HAZARDS EVALUATION PROPOSED CHANGE NO. 207 Comparison of Current Maine Yankee Technical Specifications to Proposed Permanently Defueled Technical Specifications Current MYTS Improved STS Proposed PDTS 4.3 Reactor Coolant System Not included Not Applicable Leak Tests 4.4 Containment Testing 3.6 Containment System or Not Anplicable Program Required by 5.5 4.5 Emergency Power System 3.8 Electrical Power Not Applicable Periodic Testing Systems 4.6 Periodic Testing SR 3.5 Emergency Core Not Applicable Cooling System SR 3.6 Containment Systems SR 3.7 Plant Systems Programs Required by 5.5 4.7 Inservice Inspection Program Required by 5.5 5.6.5 Inservice Testing and Testing of Safety Program Class Components 4.8 Deleted Not Applicable Not Applicable 4.9 Shock Suppressors Not included Not Included (Snubber) Surveillance Testing 4.10 Steam Generator Tube Program Required by 5.5 Not Applicable Surveillance 4.11 Ventilation Filter Program Required by 5.5 Not Applicable System Surveillance Testing 4.12 Deleted Not Applicable Not Applicable 4.13 Deleted Not Applicable Not Applicable 5.1 Responsibility 5.1 Responsibility 5.1 Responsibility 5.2 Organization 5.2 Organization 5.2 Organization 5.3 Facility Staff 5.3 Unit Staff 5.3 Unit Staff Qualifications Qualifications Qualifications 5.4 Training Not Included 5.4 Training 5.5 Review and Audit Not included Relocate to the Quality Assurance Program

ATTACHMENT II Page 65 of 65 SIGNIFICANT HAZARDS EVALUATIDH PROPOSED CHANGE NO. 207 4

Comparison of Current Maine Yankee Technical Specifications to Proposed Permanently Defueled Technical Specifications Current MYTS Improved STS Proposed PDTS 5.6 Reportable Event Not Included Not Included Action 5.7 Safety Limit Violation Not included Not Applicable Report 5.8 Programs and 5.4 Procedures 5.5 Procedures Procedures 5.5 Programs and Manuals 5.6 Programs and Manuals 5.8.1.a Radioactive 5.5.4 Radioactive Effluent 5.6.3 Radioactive Effluent Effluent Controls Program Controls Program Controls Program 5.8.1.b Radiological Not Included but referred Relocate to the ODCM l

Environmental Monitoring to in 5.5.1 Offsite Dose Program Calculation Manual 5.8.2 Procedures 5.4 Procedures 5.5 Procedures 5.8.2.g Process Control Not Included Relocate to the FSAR Program Procedures 5.8.2.h Offsite Dose 5.5.1 Offsite Dose 5.6.2 Offsite Dose Calculation Manual Calculation Manual Calculation Manual 5.8.3 Procedure Review Not Included Relocate to the Quality Assurance Program 5.8.4 Temporary Procedure Not Included Relocate to the Quality Changes Assurance Program 5.8.4.d Process Control Kat Included Relocate to the FSAR Program Changes 5.8.4.e Offsite Dose 5.5.1 Offsite Dose 5.6.2 Offsite Dose Calculation Manual Changes Calculation Manual Calculation Manual 5.8.5 Working Hours 5.2.2.e Working Hours 5.2.2, Working Hours 5.9 Reporting Requirements 5.6 Reporting Requirements ' G.7 Reporting Requiremeats 5.10 Record Retention Not Included Relocate to the Quality Assurance Program 5.11 Radiation Protection 5.5 Programs and Manuals 5.6 Programs and Manuals Program 5.12 High Radiatior. Area 5.7 High Radiation Area 5.8 High Radiation Area

ATTACHMENT III PROPOSED CHANGE NO. 207 Maine Yankee Proposed Technical Specification f

_ _.

ML20212A602

Text

Reference:

Subject:

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