ML20217K210

Safety Evaluation Supporting Amend 192 to License DPR-61

ML20217K210
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/27/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20217K201	List: ML20217K195 ML20217K204 ML20217K210
References
NUDOCS 9804070154
Download: ML20217K210 (11)

Text

l pn.. .

p" t UNITED STATES g j NUCLEAR REGULATORY COMMISSION 1 o WASHINGTON, D.C. 2055!H201 l

- **... l l

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.192 TO FACILITY OPERATING LICENSE NO. DPR-61 CONNECTICUT YANKEE ATOMIC POWER COMPANY' HADDAM NECK PLANT DOCKET NO 50-213

1.0 INTRODUCTION

By two letters dated May 30,1997 and identified as CY-97-006 and CY-97-024, the Connecticut Yankee Atomic Power Company (CYAPCo) submitted proposed revisions to the Haddam Neck Plant Technical Specifications (TS). CY-97-006 would change the Section 6.0 TS - Administrative Controls, by replacing licensed operators with Certified Fuel Handlers (CFH). The licensee also submitted a CFH training program for NRC approval.

J CY-97-024 proposed revised TS that are appropriate to the current permanently shutdown j and defueled status of the Haddam Neck Plant (facility or plant). However, at this time, only those changes proposed in CY-97-024 involving Section 6.0 are being evaluated.

NRC is consolidating both of these requests in this single license amendment as some of the same pages in Section 6.0 are affected by both requests. Portions of Section 6.0 remain unchanged. In the near future the remainder of the proposed TS and license condition changes in CY-97-024 will be processed by the staff.

2.0

SUMMARY

OF PROPOSED CHANGES IN CY-97-006 In CY-97-006, the following sections of the TS are proposed for change: Section 6.2-Organization, Section 6.4-Training, and TS Table 6.2-1. The changes in Section 6.2 provide requirements for the new CFH and Equipment Operator (EO) positions that reflect criteria appropriate to the defueled configuration of the facility. This change eliminates the no longer required licensed operator positions. Section 6.4 adds the requirement that a retraining and replacement training program for the CFH be maintained under the direction of the Unit Director. The changes to Table 6.2-1, which are described in Safety Evaluation (SE) Section 4.0.b, below, incorporates the changes to TS Sections 6 2 and 6.4.

On September 19,1997, CYAPCo responded to an August 28,1997, NRC Request for Additional Information on training for the new positions. The response in part stated, "The 9804070154 DR 980327  ?

ADOCK 05000223 .

PDR k

l l

L 2

following steps reflect the systematic approach to training (SAT) that is being used to-determine the content of CYAPCo operator training programs." The operator training programs referenced are for the proposed.CFH and EO positions. The systematic approach to training used for the operator training programs contains the following five key elements and is intended to provide a training system that will ensure successful job performance by these trained individuals. The elements of the program are:

a. Analysis of job performance requirements and training needs.

b. Derivation of learning objectives based upon the preceding analysis,

c. Design and implementation of the training program based upon the learning objectives.

l

d. Trainee evaluation.

e. Program evaluation and revision.

3.0 EVALUATION AND CONCLUSIONS ON CY-97-006 The TS changes proposed in CY-97-006 are consistent with: (1) current NRC licensing requirements for a plant no longer authorized for reactor operation and (2) the definition of CFH in 10 CFR 50.2. The licensee is providing an appropriate SAT based training program to personnel that perform CFH duties and which ensures that the facility will be operated cnd maintained in a safe and stable condition. Based on the above, the staff concludes that the proposed changes to the Haddam Neck Plant TS Section 6.2, Section 6.4, and TS Table 6.2-1 in CY-97-006, are acceptable and that the training program submitted as Nuclear Training Manual (NTM) - 7.083 is also acceptable.

4.0

SUMMARY

OF PROPOSED CHANGES IN CY-97-024 The propose; changes in CY-97-024 are to the following TS Sections: 6.1, 6.2, 6.3, 6.4, 6.5, 6.6, 6.7-deleted, 6.8, 6.9, 6.10, 6.11-no change, 6.12, 6.13, 6.14, 6.15-deleted and 6.16-deleted. The change requests are described below;

a. Section 6.1. RESPONSIBILITY Change " Executive Vice President and Chief Nuclear Officer" to "Vice President -

Operations and Decommissioning"

b. Sec ion 6.2 ORGANIZATION in Subsection 6.2.1.a, last line, change "the Quality Assurance Topical Report." to "the Connecticut Yankee Quality Assurance Program (CYQAP)."

F-

I I

f 3

in Subsection 6.2.1.b, replace the entire subsection with, *The Unit Director shall be responsible for overa!! unit safe operation and shall have control over those onsite activities

)

and resources necessary for safe operation and maintenance of the plant."

l in Subsection 6.2.1.c, change the phrase " Executive Vice President and Chief Nuclear

{

Officer," to "Vice President - Operations and Decommissioning."  !

l In Subsection 6.2.1,d, change the phrase " operating staff" to " Certified Fuel Handlers and the Equipment Operators."

TABLE 6.21 MINIMUM SHIFT CREW COMPOSITION 1

Delete the entire " MODE 1,2,3, or 4" column (including the column header). Delete the li column header " MODE 5 or 6." Delete the STA row (i.e., "STA 1' None"). Under l

" Abbreviations" delete "STA - Shift Technical Advisor." Replace with two column headers: POSITION and NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION. Under POSITION iist "CFH" and "EO." Under NUMBER OF... POSITION list "1"" for the CFH and "1" for the EO. A footnote added to the page reads: "' Does not include the Certified Fuel Handler supervising fuel handling operations." Delete the entire text in the two paragraphs forming part of the table and replace with the following paragraph: "The shift crews' composition may be one less than the minimum requirements of Table 6.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of an l on-duty shift crew member provided immediate action is taken to restore the shift crews' composition to within the minimum requirements of Table 6.2-1. This provision does not permit any shift crew position to be unmanned upon shift change due to an oncoming shift crewman being late or absent."

In Subsection 6.2.2.b, replace the entire subsection with, "At least one person qualified to stand watch in the control room (a Certified Fuel Handler or ao Equipment Operator) shall be present in the control room when irradiated fuel is in the spent fuel pool";

in Subsection 6.2.2.c, change "when fuel is in the reactor"; to "during fuel handling operations";

in Subsection 6.2.2.d, change " CORE ALTERATIONS" to " fuel handling operations" and replace "either... Fuel Handling" with "a Certified Fuel Handler."

in Subsection 6.2.2.f replace " safety-related functions" with " functions important to the safe storage and handling of irradiated fuel."

c. Section 6.3 FACILITY STAFF QUAllFICATIONS Delete Subsection 6.3.1.2.

1 I

t i

4

d. Section 6.4 TRAINING Insert the following new sentence at the beginning of the paragraph: "A retraining and replacement training program for the CFH shall be maintained under the direction of the Unit Director." Change " Nuclear Unit Director" to " Unit Director." Delete "and 10CFR50.59." Change " Director-Nuclear Training" to " Unit Director."

e. Section 6.5 REVIEW AND AUDIT in Subsection 6.5.1.2, in the 1st sentence, change " eleven" to "seven." In the 2nd sentence, delete the existing listing and replace with:

Plant Operations Decommissioning" Engineering Maintenance Health Physics Chemistry / Radiochemistry Quality Assurance Security

• In Subsection 6.5.1.2, add footnote, "'These areas are exempt from the 5 year experience requirment."

In Subsections 6.5.1.6.e, 6.5.1.6.h, and 6.5.1.8, delete " Chairperson of the" In Subsection 6.5.1.6.e, change " Executive Vice President and Chief Nuclear Officer" to "Vice President - Operations and Decornmissioning."

in Subsection 6.5.1.7.c, change " Executive Vice President and Chief Nuclear Officer" to "Vice President - Operations and Decommissioning," in two places. In Subsection 6.5.2.1.b, delete the existing listing and replace with:

Plant Operations Decommissioning Engineering Radiological Safety Chemistry / Radiochemistry Quality Assurance Environmental Protection in Subsection 6.5.2.1, last paragraph, change " Executive Vice President and Chief Nuclear Officer" to "Vice President - Operations and Decommissioning" in two places.

In Subsection 6.5.2.2, change " Executive Vice President and Chief Nuclear Officer" to "Vice President - Operations and Decommissioning" and change "seven members" to "five members."

5 j i

1 in Subsection 6.5.2.3, change " Executive Vice President and Chief Nuclear Officer" to I "Vice President - Operations and Decommissioning."

in Subsection 6.5.2.5, change " Northeast Utilities' nuclear unit." to "Haddam Neck Plant."

In Subsection 6.5.2.6.k, change " Audits and audit plans." to " Audits and the Annual Audit Plan."

I in paragraph following Subsection 6.5.2.6.k, change " Executive Vice President and Chief Nuclear Officer" to "Vice President - Operations and Decommissioning."

)

l in Subsection 6.5.2.7, change " Nuclear Group Procedures" to " appropriate administrative procedures." In Eubsection 6.5.2.7.c, delete "all." In Subsection 6.5.2.7.g, change ,

" Executive Vice Pasident and Chief Nuclear Officer." to "Vice President - Operations and Decommissioning."

In Subsection 6.5.2.8 items b and c are deleted. This subsection should now read:

" Written records of reviews and audits shall be maintained. As a minimum these records shallinclude results of the activities conducted under the provisions of Section 6.5.2."

f. 6.6 REPORTABLE EVENT ACTION in Subsection 6.6.1.b, delete " Chairperson of the" and change " Executive Vice President and Chief Nuclear Officer." to "Vice President - Operations and Decommissioning."

g. 6.7 SAFETY LIMIT - DELETED

h. 6.8 PROCEDURES AND PROGRAMS in Subsection 6.8.1.f, change " PROCESS CONTROL PROGRAM" to " Process Control Program."

In Subsection 6.8.3.b, change "two members of the plant management ctaff, at least one of whom holds a Senior Reactor Operator license on the unit affected"; to "a member of the plant management staff and a Certified Fuel Handler";

i. 6.9 REPORTING REQUIREMENTS In the footnote associated with Subsection 6.9.1.5.a change "Section 20.407" to "Section 20.2206". Delete Subsections 6.9.1.1, 6.9.1.2, 6.9.1.3, 6.9.1.5.b, 6.9.1.5.c, 6.9.1.8, and 6.9.1.9.

s

6

j. 6.10 RECORD RETENTION in Subsection 6.10.2.a, delete " covering a time interval at each power level." In Subsection 6.10.2.e, delete " reactor." in Subsection 6.10.3.d, change "expsure" to

" exposure." In Subsection 6.10.3.f, change the statement to read " Records of transient or operational cycles of the reactor vessel." In Subsection 6.10.3.h, change the statement to read " Records of inservice insper tions performed under previous amendments to these TS." In Subsection 6.10.3.m, change " Radiological Effluent Monitoring and Offsite Dose ,

Calculation Manual" to " RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE

{

CALCULATION MANUAL." '

k. 6.11 RADIATION PROTECTION PROGRAM - NO CHANGE l l

1.6.12 HIGH RADIATION AREA I i

In Subsection 6.12.1,1st paragraph,1st sentence, change "but less than 1000 mR/h at 45 cm (18 in.)" to "but equal to or less than 1000 mR/h at 30 cm (12 in.),"; change "20.203(c)(5)" to "20.1601(c)"; change "20.203(c)," to "20.1601"; and change "45 cm 4 (18 in.)" to "30 cm (12 in.)."

in Subsection 6.12.2, change "45 cm (18 in.)" to "30 cm (12 in.)"

m. 6.13 RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE CALCULATION 3 i

MANUAL (REMODCM)

Change " Radiological Effluents Monitoring Manual" to " RADIOLOGICAL EFFLUENT MON:TORING MANUAL (REMM)." Change "Offsite Dose Calculation Manual" to "OFFSITE DOSE CALCULATION MANUAL (ODCM)."

n. 6.14 RADIOACTIVE WASTE TREATMENT ,

Change " PROCESS CONTROL PROGRAM" to " Process Control Program."

o. 6.15 SYSTEMS INTEGRITY - DELETED

p. 6.16 PASS / SAMPLING AND ANALYSIS OF PLANT EFFLUENTS - DELETED 5.0 EVALUATION AND CONCLUSIONS ON CY-97-024 l

a. 6.1 RESPONSIBILITY The change from " Executive Vice-President and Chief Nuclear Officer" to "Vice President -

Operations and Decommissioning," as described in SE Section 4.0.a, above, reflects the

7 revised CYAPCO organization implemented after a permanent shutdown of the facility.

Past and future management changes were or will be documented in the CYOAP, as required by TS 6.2.1.b. The CYQAP is inspectable and fully enforceable. Based on these considerations, the staff concludes that the title change is acceptable,

b. 6.2 ORGANIZATION The change to Subsection 6.2.1.a constitutes a minor title change for the Quality Assurance Program and is, therefore, acceptable. In Subsection 6.2.1.b, unit safe operation is assigned to the Unit Director rather than the Executive Vice President -

Haddam Neck, a position that no longer exists. The Unit Director position is comparable to that'of " Plant Manager," and, therefore, is the proper level of management needed to '

ensure safe operation of the plant. The change to subsection 6.2.1.c, reflects the new CYAPCO organization. The justification is identical to that of Subsection 6.1, above, and is, therefore, acceptable.

c. 6.3 FACILITY STAFF QUALIFICATIONS Subsection 6.3.1.2 was deleted as it provided qualifications for the Shift Technical Advisor (STA) poaition. The STA was only required during reactor operation. Because the plant ,

has permenently ceased operations and the reactor has been permanently defueled, the '

STA position is no longer necessary. Based on the above, the staff concludes that the ,

change is acceptable,

d. 6.4 TRAINING The changes described in SE Section 4.0.d, above are acceptable as they serve to implement a training program for the CFH position. The change in the title of the Unit Director from Nuclear Unit Director is proper. Based on these considerations, the staff concludes that the changes to TS Section 6.4 are acceptable.

e. 6.5 REVIEW AND AUDIT in Subsection 6.5.1.2, the reduced size and new composition of the Plant Operations and Review Committee, as described in SE Section 4.0.e, above, properly reflects the needs of a permanently shutdown plant and provides the proper skills and experience for this committee in its role of overseeing safe plant operations on a day-to-day basis. Based on these considerations the staff finds the changes to this committee appropriate and therefore acceptable.

In Subsections 6.5.1.6.e, 6.5.1.6.h, and 6.5.1.8, there are minor administrative changes to reflect a title change and document distribution. Based on staff review these minor changes are acceptable.

{ ]

l 1

8 l l

- I n Subsections 6.5.'1.6.e and 6.5.1.7.c, the change to "Vice President - Operations and Decommissioning," is the same as in TS Section 6.1, above. Therefore, on the same basis, the~ staff con'cludes the change is acceptable. ,

l In Subsection 6.5.2.1.b, the changes in the Nuclear Safety Assessment Board (NSAB) composition results from the plant being permanently shutdown thus requiring the addition of members skilled in decommissioning and environmental protection, and removal of those skills required for reactor operations. Based on staff review of the new NSAB composition, the staff finds the revised NSAB composition acceptable.

In the last paragraph of Subsection 6.5.2.1, the changes to "Vice President - Operations

. and Decommissioning," are the same as in TS Section 6.1, above. Therefore, on the same ,

basis, the staff concludes the changes are acceptable. I in Subsection 6.5.2.2, the change to "Vice President - Operations and Decommissioning,"

is the same as in TS Section 6.1, above. Therefore, on the same basis, the staff concludes the change is acceptable. The change in the composition of the NSAB is discussed and justified under Subsection 6.5.2.1.b, above, and is therefore also acceptable.

In Subsection 0.5.2.3, the change to "Vice President - Operations and Decommissioning,"

is the same as in TS Section 6.1, above. Therefore, on the same basis, the staff concludes the change is acceptable, in Subsection 6.5.2.5, there is an administrative change that reassigns responsibility to an individual NSAB for the plant rather than jointly with the Millstone units. This change reflects the reorganization described in a CYAPCo letter of December 3,1997 (CY-97-129) and is acceptable.

In Subsection 6.5.2.6.k, NSAB is assigned the responsibility of reviewing all audits and the Annual Audit Plan. Formerly the NSAB reviewed all audits and audit plans. The staff concludes that annual review of audit plans is sufficient for a permanently shutdown facility and, therefore, the change is acceptable. I In the last paragraph of Subsection 6.5.2.6, the change to "Vice President - Operations and Decommissioning," is the same as in TS Section 6.1, above. Therefore, on the same basis, the staff concludes the change is acceptable.

in Subsection 6.5.2.7, a minor editorial change states that the NSAB audits are now controlled by the administrative procedures, not the Nuclear Group Procedures, in i Subsection 6.5.2.7.c, the word "all" is unnecessary. The staff concludes that these editorial changes are acceptable, in Subsection 6.5.2.7.g, the change to "Vice President -

Operations and Decommissioning," is the same as in TS Section 6.1, above. Therefore, on ]

the same basis, the staff concludes the change is acceptable, i

l l

9 l In SuMeetion 6.5.2.8, some redundant material regarding written records is deleted. The licensee properly cross-referenced TS Subsection 6.5.2 for the better source of these requirements; therefore, the change is acceptable.

f. 6.6 REPORTABLE EVENT ACTION In Subsection 6.6.1.b, firstly, an administrative change requires that the results of reportable event reviews be submitted to the whole NSAB rather than to the chairman of the NSAB. This is a minor but sensible change and is, therefore, acceptable. A second change, which is the change to "Vice President - Operations and Decommissioning," is the same as in TS Section 6.1, above. Theref:,re, on the same basis, the staff concludes the change is acceptable,

g. 6.7 SAFETY LIMIT VIOLATION This section is properly deleted as safety limits, which refer only to reactor operation, are no longer pertinent due to a permanent shutdown of the plant,

h. 6.8 PROCEDURES AND PROGRAMS In Subsection 6.8.1.f, a change in the phrase " Process Control Program" from all uppercase to initial capitalletters followed by lowercase was mao 3; however, the content of the subsection remains unchanged Therefore, this editorial change is acceptable.

In Subsection 6.8.3.b, temporary changes to procedures of Specification 6.8.1 may be made by one me.nber of the plant management staff and a Certified Fuel Handler. This change is consistent with staffing changes approved in this safety evaluation and properly reflects the needs of a permanently shutdown and defueled plant. The staff concludes the change is acceptable.

i. 6.9 REPORTING REQUIREMENTS Subsections 6.9.1.1, 6.9.1.2, 6.9.1.3, 6.9.1.5.b, 6.9.1.5.c, 6.9.1.8 and 6.9.1.9 were deleted as they covered reports associated with startup or reactor operation. As the plant has permanently ceased operations and the reactor has been permanently defueled, the staff concludes that these reports are no longer necessary. The footnote referenced by the asterisk in Subsection 6.9.1.5.a was properl/ changed from former 10 CFR 20.407 to the current 10 CFR 20.2206 and is therefore acceptable.

j. 6.10 RECORD RETENTION The revised Section 6.10 retains the record retention requirements of Title 10 of the Code of Federal Regulations. Section 6.10.2.a and Subsection 6.10.2.e are revised to properly delete references to reactor operation. Because the plant has permanently ceased operations and the reactor has been permanently defueled, these references are no longer necessary. The Subsection 6.10.3.d change is editorial since it corrects a misspelling. Old

10 <

l Subsection 6.10.3.f required those records of transient or operational cycles be retained for components described in Table 5.7-1. Because the plant has permanently ceased i operations and the reactor has been permanently defueled, Table 5.7-1 has been deleted (i.e., reactor vessel design transients are no longer applicable). Therefore, the revised Subsection 6.10.3.f refers properly only to the reactor vessel historical records. In Subsection 6.10.3.h, the inservice inspection requirements have been deleted from the TS.

Therefore, Subsection 6.10.3.h now refers to previous TS amendments. In Subsection 6.10.3.m, the change is editorial. Based on the considerations discussed above, the staff finds that the changes to Section 6.10 conform to the permanently shut dowr; status of the plant and are, therefore, acceptable.

k. 6.11 RADIATION PROTECTION PROGRAM This ,section was unchanged,

l. 6.12 HIGH RADIATION AREA in revised Subsection 6.12.1, the addition of " equal to or" to the phrase less than 1000  ;

mR/h" eliminates the ambiguity of what the controls are at precisely 1000 mR/h and makes the phrase consistent with the rest of Section 6.12. The remainder of the changes are due  !

to the revisions made to 10 CFR Part 20. NUREG-1431 (" Standard TS Westinghouse Plants") provided the basis for the reference changes and the requirements of 10 CFR 20.1601(a)(1) provided the basis for the distance related changes. The licensee implemented the more stringent requirements of 10 CFR 20.1601 before requesting this TS change. Based on the above, the staff concludes that the changes to TS 6.12 are acceptable. l

m. 6.13 RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE CALCULATION MANUAL (REMODCM)

The changes described in SE Section 4.0.m, above, are purely editorial and, therefore, acceptable,

n. 6.14 RADIOACTIVE WASTE TREATMENT The change described in SE Section 4.0.n, above, is purely editorial and, therefore, acceptable.

o. 6.15 SYSTEMS INTEGR!TY Old TS Section 6.15 required a program to reduce the leakage from systems that could contain highly radioactive fluids during reactor, steam generator or main coolant system accidents or transients such as a loss-of-coolant accident. Because the plant has permanently ceased operations and the reactor has been permanently defueled, such

)

11 transients or accidents are no longer possible. Based on these considerations, deletion of Old Section 6.15 is acceptable.  !

- p. 6.16 PASS / SAMPLING AND ANALYSIS OF PLANT EFFLUENTS Old TS Section 6.16 required a program for post-accident sampling. Because the plant has 4 permanently ceased operations and the reactor has been permanently defueled, such I accidents are no longer possible. Based on these considerations deletion of Old Section 6.16 is acceptable, i

6.0 STATE CONSULTATION

.in accordance with the Commission's regulations, the Connecticut State official was notified of the proposed issuance of the amendment. The State official had no comments.

7.0 ENVIRONMENTAL CONSIDERATION

S l The amendment changes administration procedures and requirements of the license.

Accordingly, the amendment meets the eligibility criteris for categorical exclusion set forth l in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement j or environmental assessment need be prepared in connection with the issuance of the I amendment.

l 1

8.0 CONCLUSION

j The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the i public.

Principal Contributors: Richard Pelton (CFH Review)

- Morton Fairtile Date: March 27, 1998

_