ML20217B605

Forwards Request for Removal of Confirmatory Orders Which Are Inappropriate in Permanently Defueled Plant Condition

ML20217B605
Person / Time
Site:	Maine Yankee
Issue date:	09/25/1997
From:	Hebert J Maine Yankee
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JRH-97-204, MN-97-108, NUDOCS 9709300085
Download: ML20217B605 (8)

Text

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329 BATH ROAD e BRUNSWICK, MAINE 04011 * (207) 798 4100 September 25,1997 MN 97108 JRil-97 204 i

UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, DC 20555

References:

(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 Change No.

206 - Facility Staffing and Training; MN 97-96, dated August 15,1997.

(d) Letter: J.R. liebert to USNRC; Regulatory Guide 1.97, l'rogram Commitments for Post Accident Monitoring (MN-97-102), dated September 4,1997

Subject:

Request for Re, ' oval of Cenain Confirmatory Orders Gentlemen:

In Reference (b), Maine Yankee informed the USNRC that the Board of Directors of Maine Yankee had decided to pemianently cease operations at the Maine Yankee Plant and that the fuel had been pemianently removed fmm the reactor. In accordance with 10CFR$0.82(a)(2), the certifications in the letter modified the Maine Yankee license to permanently withdraw Maine Yankee's authority to operate the reactor and to place fuel into the reactor vessel.

Maine Yankee has determined that many of the commitments made while the plant was operating are not appropriate in the permanently defueled plant condition. Several of the commitments were confinned by Commission order and thus require NRC concurrence to modify.

Attached is a request to remove confirmatory orders which are not appropriate in the peimanently defueled plant condition. Confimtatory orders dated July 10,1981, March 14,1983, and June 14, l

1984 confirmed Maine Yankee's commitments related to post TMl issues. The confirmatory order l

dated January 3,1996 confirmed Maine Yankee's commitments to limit power and containment i

pressure pending the completion of certain analyses. As indicated in the attached, these confinnatory orders are not warranted in the permanently defueled plant condition.

Very truly yours, A O~ D \\

l ames R. Hebert, Manager C{7gg7 Regulatory Affairs Department JRil/mwf 9709300085 970925 Enclosure hDR ADOCK 0500 9

{}kkkkkk c: Mr. Hubert Miller Mr. Richard A. Rasmussen Mr. Daniel H. Dorman Mr. Patrick J. Dostic Mr. Uldis Vanags

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J ATTACilMENT 1 REQUEST FOR ELIMINATION OF CONFIRMATORY ORDERS NOT APPLICABLE TO A PERMANENTLY DEFUELED REACTOR 1.

REQUEST FOR REMOVAL OF CONFIRMATORY ORDERS Maine Yankee hereby requests that the following confirmatory orders be removed.

1. Confinnatory Order dated July 10,1981. This order confirmed licensee commitments related to Post TMl related requirements. This order is not applicable to the permanently defueled plant condition and should be deleted.

2. Confimiatory Order dated March 14,1983. This order confimied licensee commitments related to post TMl related issues. This order is not applicable to the r.mianently defueled plant condition and should be deleted.

3. Confirmatory Order dated June 14,1984. This order confimled licensee commitments on Post-TMI related issues set forth in NUREG-0737 Supplement 1. This order is not applicable to or is not necessary in the permanently defueled plant condition and should be deleted.

4. Confirmatory Order dated January 3,1996. This order required, in part, the submittal of an integrated containment analysis. The requirement for this analysis should be deleted since the plant has permanently ceased operations and has defueled the reactor.

11. B A C K G R O U N D Many of the NRC's regulations and most of the provisions of the Maine Yankee Operating License and Technical Specifications were established to ensure the protection of public health and safety during plant operation. On August 7,1997, Maine Yankee ceitilled to the NRC that operation of the Maine Yankee plant had been permanently ceased and that the fuel had been pennanently removed from the reactor, in accordance with 10CFRS2(a)(2), these certifications modified the Maine Yankee license such that operation of the reactor and placement of fuel in the reactor vessel are no longer permitted. It is important that as Maine Yankee proceeds with the decommissioning of the plant that a clear regulatory framework be established. Those requirements which are not relevant to the permanently defueled plant condition should be eliminated to allow the stafTto focus on those provisions which are still appropriate. The NRC recognized this importance in their decommissioning regulations which became effective on August 26,1996, and eliminated many regulations which were not appropriate for plants in the permanently defueled condition. Maine Yankee is seeking exemption to other regulations which it believes are not appropriate for the current plant condition and in some cases involving plant equipment, must be eliminated to allow decommissioning to proceed.

Many of the provisions of the Maine Yankee license are also not appropriate for the permanently defueled plant condition. In a letter dated August 15,1997, Maine Yankee submitted a request to modify the technical specifications related to staffmg and training. Maine Yankee will be submitting, under scparate cover, a request for other changes to the technical specifications to make them appropriate for the pennanently defueled condition. A request for a license modification would eliminate those license provisions, other than technical specifications, which are still active anJ are not appropriate for the pennanently defueled condition is also being submitted under separate cover.

This submittal would remove confirmatory orders which are not appropriate in the pennanently defueled plant condition.

111. JUSTIFICATION FOR GRANTING THE REQUEST This request would climinate those confinnatory orders which are not appropriate for the current plant condition. Elimination of these inappropriate provisions will allow the plant staff to focus on those requirements which are appropriate in the permanently defueled p ant condition.

1. Confirmatory Order dated July 10,1981. This order confimled licensee commitments related to Post-TMI related requirements. These requirements were primarily related to the prevention and mitigation of postulated accidents associated wit:i plant operation, and not the remaining Chapter 14 accidents to which the plant continues to be vulnerable in the current plant condition.

Therefore, this order is not appropriate in the pennanently defueled plant condition and should be removed. The requirements of this order are discussed separately below.

A) STA coverage and long term training program. Since the plant is in a permanently defueled condition, the type and complexity of potentiat accidents has been significantly reduced. Present technical specifications do not require a STA on shift when the plant is in a cohl shutdown mode. The need for a shift technical advisor has been eliminated.

Proposed Technical Specification changes to permanently climinate STA coverage have been submitted separately. A Certified Fuel Handler Training Program and related changes to technical specifications have also been submitted to allow the training program to focus on the safe storage and handling of spent fuel.

B) Upgraded operator training program. With the plant in a permanently defueled condition, the operator training program is no longer warranted except as related to the safe storage and handling of spent fuel. As indicated above, a Certified Fuel Handler Training Program and related changes to technical specifications have been submitted to allow the training program to focus on the safe storage and handling of spent fuel.

C) Accident procedures. With the plant in a permanently defueled condition, there are no longer any credible design basis accidents associated with an operating plant from startup through full power operation. The design basis accidents relative to a permanently defueled facility are a small subset of those considered for an operating facility. Those accident procedures which are in response to accidents associated with an operating plant are no longer necessary. This includes all the Emergency Operating Procedures (EOP's) and most of the Abnormal Operating Procedures (AOP's).-

1 D) Implementing procedures for feedback of operating experience With the plant in a peminnently defueled condition, procedures for the feedback ofoperating experience are not warranted. Nonetheless, Maine Yankee intends to retain an operating experience program related to decommissioning and the safe handling and storage of spent fuel.

E) Vital area shielding. With the plant in a permanently defueled condition, design basis accidents which could result in the necessity to shield remaining vital areas are not possible.

F) post accident sampling. With the plant in a pemaanently defueled condition, accidents which could result in the need for post accident sampling are not possible.

G) Training to mitigate core damage. With the plant in a permanently defueled condition, core damage is not possible.

H) Performance testing of relief valves and safety relief valves. With the plant in a permanently defueled condition, this testing is no longer warranted.

1) Aux feed water initiation and flow. With the plant in a permanently defueled I

condition, aux feed water is no longer required.

J) Containment isolation pressure set point. With the plant in a permanently defueled condition, containment isolation is no longer required.

K) Post accident noble gas monitor and iodine / particulate sampling. With the plant in a pemianently defueled condition, postulated accidents which would warrant sampling of the RCS are not possible.

L) Inadequate core cooling instrumentation. With the plant in a permanently shutdown condition, design basis accidents which could result in inadequate core cooling are not possible.

M) Report on SBLOCA and probability of failure of PORV/SV/RV. This report has l

been completed.

i N) Submit report of safety relief valve and relief valve failures and challenges. This report has been completed.

O) ECCS system outages report. This report has been completed.

P) Submit program for SBLOCA methods. This program has been submitted. Small break loss of coolant accidents are not possible in the defueled condition.

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Q) In plant iodine monitoring post accident. In the pemianently defueled plant condition, the only design basis accident which could result in the release of radioactive iodine is a fuel handling accident, and therefore the likelihood of a large release of radioactive iodine is significantly reduced. With a minimum decay time of the spent fuel of over eight months, the potential source term associated with a fuel handling accident has been reduced. The continued ability to monitor in plant radioactive iodine from a postulated fuel handling accident will be retained as long as the potential source term warrants such monitoring ability.

R) Control room habitability. With the plant in a permanently defueled condition, the design basis accidents which require the control room to be staffed and which would threaten the habitability of the control room are not possible. With the plant having been shut down for over eight months, the potential source term associated with a design basis fuel handling accident does not challenge the habitability of the comrol room. Continued protection against other postulated incidents which could threaten the habitability of the control room (i.e. hazardous gas release) are not warranted in the defueled plant condition. In the defueled plant condition, continuous occupation of the control room is not necessary to ensure the safe handling and storage of spent fuel, and the control room could be evacuated, if necessary, in the event of a release of hazardous chemicals requiring such evacuation, without affecting the stored fuel.

2. Confirmatory Order dated March 14,1983. This order confirmed licensee commitments related to post-TMl related issues. These requirements were primarily related to the prevention and mitigation ofpostulated accidents associated with plant operation, and not the remaining Chapter 14 accidents to which the plant continues to be vulnerable in the current plant condition.

Therefore, this order is not appropriate to the pennanently defueled plant condition and should be removed. Each of the requirements of the order are discussed separately below.

A) include simulator exams in operator license exams. In the permanently defueled plant condition, continued use of the plant simulator is not wanranted.

B) Plant shielding for access to vital areas. In the permanently defueled plant condition, postulated design basis accidents which warrant shielding to remaining vital areas are not possible.

C) Install upgraded post-accident sampling equipment. In the permanently defueled plant condition, design basis accidents which would warrant sampling of the RCS are not possible.

D) Training for mitigating core damage in the permanently defueled plant condition, core damage is not possible.

E) Aux feed water flow instrumentation to steam generator, in the permanently defueled plant condition, aux feed water flow is not required.

F) Lower contairunent pressure set point. In the permanently defueled plant condition, containment isolation is not required.

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4 G) Isolate purge and vent valves on radiation signal, in the pennanently defueled plant condition, the purge and vent valves are not required to function automatically.

II) Install noble gas effluent monitors. With the plant in a permanently defueled E.

condition, most design basis accidents are no longer possible. The potential source tenn associated with the remaining design basis accidents to which the plant continues to be vulnerable has been significantly reduced by over eight months of decay since the plant was last operated. The cor.tinued ability to monitor nobel gas from a postulated fuel handling accident will be retained as long as the potential source tenn warrants such monitoring ability.

1) Provide for effluent monitoring ofiodine. With the plar.t in a pennanently defueled condition, most design basis accidents am no longer possible. The potential source tenn associated with the remaining design basis accidents to which the plant continues to be vulnerabh has been significantly reduced by over eight months of decay since the plant was last operated. The continued ability to monitor iodine from a postulated fuel handling accident will be retained as long as the potential source tenn warrants such monitoring ability.

J) Insiali in-containment radiation monitor. With the plant in a permanently defueled condition, most design basis accidents are no longer possible. The potential source tenn associated with the remaining design basis accidents to which the plant continues to oc vulnerable has been significantly reduced by over eight months of decay since the plant was last operated. Therefore, the continued requirement for an in-containment radiation monitor is not warranted.

K) Provide containment pressure indication. Containment isolation is not required in the defueled plant condition.

L) Provide < stinment water level indication. Containment isolation is not required in the defueled plant condition.

M) Provide containment hydrogen concentration. Hydrogen generation from metal-water reaction is no longer possible since all fuel has been removed from the reactor vessel and transferred to the fuel pool.

N) Overtime limit policy. In the defueled plant condition, the need to have a limit on overtime related to safety related activities has been sharply reduced. Overtime limit policy is also addressed in the technical specifications. A proposed chang: to these technical specifications to better reflect the defueled plant condition has been submitted under separate cover. (Reference c)

O) Submit report on the relief & safety valve program. This report has been submitted.

P) Submit report on the block valve test program. This report ha 'een submitted.

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u Q) Control room habitability modifications. With the plant in a permanently defueled condition, and with the plant having been shut for over eight months, the design basis accidents which require the control room to be staffed and which would threaten the habitability of the control room are not possible. Continued protection against other postulated incidents which could threaten the habitability of the control room are not warranted in the defueled plant condition, since the control room could be safely evacuated if required.

3. Confirmatory Order dated June 14,1984. This order confirmed licensee commitments on Post-TMI related issues set fonh in NUREG-0737 Supplement 1. These requirements were primarily related to the prevention and mitigation of postulated accidents and emergency preparedness associated with plant operation, and not the remaining Chapter 14 accidents to which the plant continues to be vulnerable in the current plant condition. Other requirements related to emergency preparedness are found in 10CFR50.47 and Appendix E to 10 CFR50. Any exemptions to these requirements will be submitted under separate co ;cr. Therefore, this order is not appropriate to the permanently defueled plant condition and should be removed. The specific requirements of this order are discussed below.

E A) Safety parameter display system. The safety parameter display system is not required in the defueled plant condition. Postulated design basis accidents which would warrant its use are no longer possible, l

B) Detailed control room design review. This design review has been completed. Most of the plant's design basis accidents are not possible in the defueled plant condition. The l

few remaining design basis accidents are not complex and do not warrant the continued I

application of control room design criteria.

C) Regulatory Guide 1.97 installation requirements. These instruments have been installed. With the plant in a permanently defueled condition, most of the postulated design basis accidents for which the Regulatory Guide 1.97 instrumentation was intended are no longer possible. Additionally, the potential source term associated with the remaining accidents have been significantly reduced by over eight months of decay time since the plant last operated. Therefore, Regulatory Guide 1.97 instrumentation is no longer warranted. As indicated in Reference (d) Maine Yankee intends to deactivate these instruments on a schedule cansistent with regulatory approval and operational considerations.

D) Upgrade emergency operating procedures. The emergency operating procedures have been upgraded. With the plant in the permanently defueled condition, the postulated design basis accidents which the emergency operating procedures were based on are no I

longer possible.

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O E) Emergency response facilities. With the plant in a permanently defueled condition, most of the plant's postulated design basis accidents are no longer possible. The potential source term associated with the remaining design basis accidents has been significantly reduced by over eight months of radioactive decay since the plant last operated. Requirements associated with emergency response facilities are also contained in 10 CFR 50.47 and Appendix E to 10 CFR 50. Any exemptions to these requirements will be submitted under separate cover.

3. Confirmatory Order dated January 3,1996. This order required, in part, the submittal of an integrated containment analysis. The containment building is not required to be operable in the permanently defueled plant condition. Therefore, the requirement for this analysis should be removed since the plant has permanently ceased operations and has defueled the reactor.

IV. CONCLUSION The purpose of this request is to eliminate requirements which are not appropriate in the permanently defueled plant condition. Since the plant has pemianently ecased operation and will be maintained in a defueled condition, many commitments related to the operation of the plant are no longer appropriate. Elimination of these unnecessary requirements allows the plant staff to focus on those requirements which continue to be appropriate to the existing plant conditions. The request does not afTect those Chapter 14 accidents which are appropriate to the current plant condition: fuel handling accident, spent fuel cask drop, and radioactive liquid waste system leaks and failures.

Maine Yankee has concluded that this request to remove confirmatory orders will climinate requirements which are not appropriate in the permanently defueleo plant condition.

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