ML20217Q624
| ML20217Q624 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 02/27/1998 |
| From: | Laipson A AFFILIATION NOT ASSIGNED |
| To: | Julian E NRC OFFICE OF THE GENERAL COUNSEL (OGC), NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20217Q445 | List: |
| References | |
| LA, NUDOCS 9803120316 | |
| Download: ML20217Q624 (15) | |
Text
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wav= =wer "av oieuwhio FRANKLIN REGIONAL Dnector of Finance + Caiolyn Olsen COUNCIL OF -
Direcmr a giamung and De eiopmer.. . reggy sioan Main Tel 413 774 3167 Finance Tel 413 774-4804 GOVERNMENTS u ain rax 413 224 3169 rianning rax 433 224 ii95 MM 425 Main St. Greenfield, MA 01301 Community Health and Education + Data Management + Engineering Municipal Assistance
- P1anning and Development + Purchasing February 27,1998 OfEce of the Secretary Attn.: Mr. E. Julian, Esq./Rulemakings and Adjudication Staff U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Delivered by Hand to:
l Public Document Room,2120 L Street, NW Washington, DC l Office of the General Counsel U.S. Nuclear Regulatory Commission l
Washington, D.C. 20555 0001 RE: NRC Notice, 63 Fed. Reg. 4308-4330 (January 28,1998) Objection to Use ofNo Significant Hazards Consideration to Approve Yankee Atomic Electric Company's !
License Termination Plan (LTP) for the Yankee Nuclear Power Station, Rowe, Massachusetts (Docket No. 50 29) md Request for a 10 CFR Part 2, Subpart G Hearing ;
on the LTP.
To Whom It May Concern:
This letter is to serve as our communication to the Nuclear Regulatory Commission
! (NRC) relative to our continuing concems as to several aspects of the License Termination Plan (LTP) filed by Yankee Atomic Electric Company (YAEC) and as a I
( request that the NRC conduct a 10 CFR Past 2, Subpart G hearing on the LTP.
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The Franklin RegionalPlanning Board (FRPB)is e broad-based coalition comprised of a !
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representative from the Selectboard and Planning Board of each of the twenty-six (26) towns of Franklin County, eighteen (18) at large members living within the County, and l
the members of the Franklin Regional Council of Governments Executive Committee.
l I FRPB members and staff of our Planning Department have been reviewing, within their l own capabilities and limitations, the LTP since May of 1997. Our Board sent a series of questions to YAEC in December of 1997. In response, YAEC provided some partial information in early January of 1998, but most issues remain open.
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l We are a relatively small county of approximately 70,000 residents with limited 1
l resources to conduct a proper review of the LTP. The LTP is a complex plan
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incorporating much~ specialized technology. We do not have a battery of experts at our disposal, nor can we afford the legal services of attomeys who can best represent us j i
through this process. Our goal is simple. We wish to have the LTP reviewed and studied l
by independent experts. We would have YAEC address any concerns identified, in a j fashion that would leave us satisfied that the Yankee Nuclear Pov.er Station in Rowe, l
Massachusetts will be closed, dismantied, and all its components disposed of or stored in a proper manner that assures the County's populace, whose lives and property are j directly at risk from decisions made in this process, will be completely safe from radiation and hazardous materials used in the operation of the facility. As we believe this !
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is the first LTP application for a commercial nuclear plant in America (and therefore a precedent-setting application), a full and complete public review process should be instituted. Therefore, FRPB respectfully requests that the NRC conduct a public hening.
A number ofissues have been raised by FRPB which were outlined and submitted at the public meeting held at Mohawk Regional High School in Buckland, Massachusetts on January 13,1998. Concerns have materialized since that meeting, and, we believe, others will follow from a careful, independent exammation of the data, protocols and practices of YAEC in their proposed LTP. These issues are of grave concern and merit closer study and analysis than the NRC and YAEC have conducted. We believe potentially serious hazards exist which involve a significant reduction in the margin of safety to the !
present and future populace of Franklin County and environs. These issues include but are notlimited to:
- Decommissioning activities employ methodologies and techniques that are experimental, untested, and/or unproven. For example, the segmentation techniques that were used for cutting the high activity components were apparently untested and proved to be somewhat unsatisfactory, resulting in recommendations for modification of the technique. Similarly, decommissioning of the spent fuel pool 1
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and ion exchange pit will require the use of methods and techniques that have not l
l previously been employed.
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- The plan rests upon significant safety hazards that are not addressed Specifically, the questions of how and where the spent fuel will be stored, and questions of how the selected storage method will be implemented, monitored, and l
eventually decommissioned must be answered. YAEC has proposed elimination of the spent fuel pool in favor of a dry cask storage system, using technology that has not yet even been developed or reviewed. Decommissioning and elimination of the .
t spent fuel pool, and the associated activity including how the spent fuel will be !
moved into the dry cask system, then to be managed and monitored over many years, l surely raises many important safety issues that deserve to be discussed, planned, and !
scrutinized before the decommissioning and license termmation is granted s final L starnp of approval. Yet, this entire question has been set outside the. scope of the procedure before us. There is no assurance of any future opportunity to examine the l issue. A full discussion about the considerations, methods and procedures related to 1
l- . on site spent fuel storage and removal must be addressed within the scope of this 3
process. The on-site storage of high level and Greater Than Class C waste must be i
subject to public review and comment.
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. Methods that have been used to survey and monitor the site for contamination j l
! do not incorporate appropriate random sampling and data collection methods. j l i Instead, they rely on computer modeling and anecdotal evidence. This has resulted j l
in a decision not to sample or monitor a large area that is owned and controlled by l 1
YAEC but lies outside a small" impact area." Failure to randomly sample creates a ;
risk that contamination may exist in areas which have not been predicted by computer, perhaps due to vagaries in weather patterns, local hydrology, animal transport, or even illegal activity. Contamination from unpredictable sources will not i
be discovered using the current sampling strategy. Random sampling must also be ;
i used on the entire property to determine what, if any, mitigation is required, before any portion of the site is released.
l e Contamination of groundwater and methodologies for sampling remain an l
issue. The selection of monitoring welllocations appears to be based on the
! locations of known or suspected contamination sites and does not appear to factor in the possibility that local geology may include groundwater divides, impervious layers, or bedrock close to the surface. YAEC and the NRC need to conduct l
[ thorough investigations into possible groundwater contamination. They cannot assume a uniform substrate through which water moves predictably. Their analysis must also include discussion and investigation of the possible influences of surficial geology and bedrock features. In particular, the migration of radionuclides from 5
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acknowledged sub-floor contamination has not been sufficiently studied and considered in the context oflocal hydrology and surficial geology. ,
. Despite several rounds of questions and requests for specific data, neither l
YAEC nor the NRC has addressed the impacts of radionuclide releases on fish l
l due to emuent and accidental releases to the Deerfield River. No data has been provided to address the species, age, general health, or whether the fish was native or stocked -- all factors that must be correlated together in order to determine tme radionuclide levels in the sediment and food chain. There is insufficient information about the specific testing techniques which YAEC used. This is a critical issue.
Contaminated fish may be consumed by humans. They may introduce significant contamination into the entire food chain when other animals feed on contaminated fish. Further, the bicaccumulation of radionuclides in fish is indicative of the presence of these materials throughout the river system, at a level which may be more significant than revealed by the tests. Based on YAEC's and the NRC's insufficient investigation of the matter, it is premature to conclude that there is no safety hazard resulting from fish contamination.
- We question the adequacy of YAEC's sampling and testing of sediment in the Deerfield River,in the Sherman Pond Reservoir, and near the outfall pipes.
The sediment behind Number Five Dam in knroe Bridge was recently removed.
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Were these sediments adequately tested before they were removed, and how and where were they disposed of? The next impoundrnent downstream, the Fife Brook Dam, is a bottom release operation. How far downstream were sedunent tests conducted? The nature of the Fife Brook operation will allow the discharge of radionuclides. They could collect as far downstream as the Number Four Dam in Buckland. YAEC has not provided specific information about the depth or frequency of the sampling, sampling methodology, the random sampling methods used, and laboratory testing and handling ofmaterials.
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. Final site clean-up questions remain. Issues regarding YAEC's formulations of effective yearly exposure dose equivalents need to be resolved. Spec 4fically, YAEC's use of plot averages and assumptions about lifestyle and future land use introduce confusion about the actual levels of radiation proposed to remain on the site, which apparently may meet the required levels as an area-wide average, but may in fact remain quite high in certain spots. Methodology for calculating and proving the final exposure rate of 15 mr/ year is very confusing. The assumptions related to unit conversions of picoeuries to millirems, the daily time of exposure (is it 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or only 87), and simdar issues must be satisfactorily explained. The final site survey criteria and plan, including the methodology and calculations, must be reviewed and affirmed by a competent, truly independent third party. Finally, in addition to 7
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l l laboratory testing work provided by the licensee and the NRC, the final site survey I l
testing work must also be independently verified by a third party. ;
l There is a fundamental problem with a number of YAEC's assertions, conclusions and the data used to substantiate the LTP. Much of the material is a product of earlier testing ;
i and documentation for previous filings. Therefore, YAEC did not specifically produce it for decommissioning. Furthermore, the GEIS on decommissioning is nearly ten years 1
old. Many facets of the GEIS are now incorrect. The NRC and YAEC should rely on fresh data for the entire LTP process. Independent analysis of the materials filed by i YAEC should be conducted. YAEC's in-house produced data, and conclusions of I YAEC's hired expens, are self-serving, and require thorough independent third party review.
Another area of concern relative to the review of the LTP process is what may be viewed as the lack of a strong response by the NRC. People believe that the NRC is engaged in regulatory activity to assure our safety, health, and welfare. Additionally, a l
l number of procedural aspects of the LTP review have been lacking. The operations of the Public Documents Room have been insufficient at best. For example, YAEC's l
! revisions of the LTP, used as one basis of the public meeting of January 13 in Buckland, Massachusetts, were not filed for public review prior to the meeting. There were a 8
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1 number of formal questions asked of YAEC by the NRC, but these questions and YAEC's responses were not made public until a later date. The official legal notice of the ,
J meeting was published in the Federal Register on January 5,1998, eight days before the public meeting. Mone of this is adequate to guarantee respect for and confidence in this
, licensing process.
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1 l Most public meeting notices run for thirty days, where d documents are available for l
public review for that entire period of time. Although the NRC was asked in advance to provide sufficient time for all public comments (the FRPB originally asked for two i
nights), the comment period itself only lasted one and one-half hours. Shortly after this public meeting, the NRC posted in the Federal Register a notice to amend YAEC's license to approve the LTP without a hearing, based on a finding ofNo Significant Hazards. This seems incongruous with so many outstanding questions and a lack of l
l complete data and impartial review. The sum total of this public review and input process falls far short of normal due process expectations.
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Therefore, the members of the FRPB and the citizens it represents, whose lives and property are at risk by approving the LTP as presently filed, requests the following relief:
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- 1) That the NRC initially provide the FRPB with a sum of one hundred thousand dollars
($100,000.00) forthwith in order for the FRPB to; a) hire experts to review YAEC's LTP, to make appropriate recommendations regarding final content and implementation; l b) retain legal assistance to represent properly the citizenry of Frankhn County and to l
l assure that the Yankee Nuclear Power Station decommissioning will be conducted in a l
j manner to protect their health, safety and welfare; and c) hire expert witnesses, as needed, for the adjudicatory process; 1
- 2) Grant a full, formal adjudicatory hearing under 10 CFR Part 2, Subpart G, to be held in Franklin County. Further, the NRC should not approve the LTP as presently filed l
without such a hearing process. The NRC should reject YAEC's application under its l No Significant Hazards Consideration determination. YAEC should not conduct any LTP activity until every aspect of the Plan is formally approved and findings are issued, subsequent to the bearing. FRPB reserves the right to amer,d its filings in response to l the LTP and a right to address new issues uncovered in the independent review process l within the adjudicatory hearing; and L
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- 3) From this point forward, to overcome even the appearance of the lack of due process, all materials and documents relative to the LTP shall be available for a period of thirty days before any meeting or hearing, and notice of any meeting or hearing shall be i advertised for a minimum of thirty days in the Federal Register and local media. ,
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I certify, under the penalty of perjury, that on this day, service of the above document was made by US Postal Service First Class Mail to Office of General Counsel and Thomas G. Dignan, Jr., Esq. ;
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IfI can be of further assistance, please feel free to contact me directly. My home telephone number is 978-544-2643. Thank you very much for your serious consideration of our filing.
Very truly yours, lA 'pson, Chair Franklin Regional Planning Board l
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4308 Federal Register /Vol. 63, No.18/ Wednesday, January 28,1998 / Notices the working papers at the Website. m NUCLEAR REGULATORY select " Final Rule on Radiological COMMISSION However, should circumstances change i
Criteria for License Termination," then during the notice period such that I'
select "Lic Term Document Library," Biweekly Notice; Applications and failure to act in a timely way would -
then select " Regulatory Guide " and result, for example, in derating or Amendments tc Facility Operating shutdown of the facility, the then select'" Module C.2: Regulatory Licenses involving No Significant Commission may issue the license Position-Final Status Survey," or Hazards Considerations amendment before the expiration of the
" Module C.1: Regulatory Position-Dose L Background 0 Modeling. P Pursuant to Public IAw 97-415, the daQ9 i : th ) hatits Meeiing Agenda U.S. Nuclear Regulatory Commission amendment involves no significant hazards consideration. The final i
9 00 Welcome and introduction (the Commission or NRC staff)is publishing this regular biweekly notice. determination will consider all public 9:05 Presentation describing issues and State comments mceived befom I Public Law 97-415 revised section 189
' considered in developin8 the draft of the Atomic Energy Act of1954, as action is taken. Should the Commission working paper amended (the Act), to require the take this action, it will publish in the Federal Register a notice ofissuance 10:30 Break Commission to publish notice of any and provide for opportunity for a amendments issued, or proposed to be 10:45 Public comments on the draft issued, under a new provision of section hearing aller issuance. The Commission working paper. Attendees will be 189 of the Act. This provision grants the expects that the need to take this action asked for questions and cc iments Commission the authority to issue and will occur very infrequently.
Written comments may be submitted on each section of the draft working rnake immediately effective any by mail to the Chief, Rules and paper, amendment to an operating license Directives Branch, Division of 12:00 1.unch upon a determination by the Administration Services, Office of 1:30 Continuation of public comments- Commission that such amendment Administration, U.S. Nuclear Regulatory involves no significant hazards 5:00 Adjourn Commission, Washington, DC 20555-consideration, notwithstanding the 0001, and should cite the publication Submitting Written Comments pendency before the Commission of a date and page number of this Federal request for a hearing from any person.
Comments may be posted This biweekly notice includes all Register notice. Written comments may electronically on the NRC Technical notices of amendments issued, or also be delivered to Room BD22. Two White Flint North,11545 Rockville Conference Forum Website mentioned proposed to be issued from January 5 Pike Rockville,M land from 7:30 above. Comments submitted 1998, through January 15,1998. The last a.m. to 4:15 p.m. F eral workdays, electronically can also be viewed at that biweekly notice was published on Copies of written comments received Website. Comments may also be mailed January 14,1998 (63 FR 2271). may be examined at the NRC Public to the Chief, Rules and Directives .
Nots.ce ofConsideration ofIssuance of Document Room, the Gelman Building, Branch, U.S. Nuclear Regulatory Amendments to Facility Operating 2120 L Street, NW., Washin8 ton, DC.
Commission, Washington, DC 20555. Licenses, Proposed No Significant The filing of requests for a hearing and FOR FURTHER #FOmsADON: For Hazards Consideration Determination,- petitions for leave to intervene is and Opportunity for a Hearing dM information or questions on meeting dYyybruary ,1998, the licensee arrangements, contact Nina Barnett, The Commission has made a proposed determination that the may file a request for a hearing with Office of Nuclear Regulatory Research, respect to issuance of the amendment to U.S. Nuclear Regulatory Commission, following amendment requests involve the subject iv:ility operating licanse and Washington, DC 20555, telephone 301- no significant hazards consideration. any person whose interest may be 415-6187, fax 301-415-5385. E-mail: Under the Commission's regulations in affected by this proceeding and who NMB4NRC. GOV. For technical 10the of CFR 50.92, facility in this means accordance that with the operation wishes to participate as a party in the information or questions, contact proceeding must file a written request Stephen A. McGuire, Office of Nuclear proposed amendment would not (1) for a hearing and a petition for leave to Regulatory Research, U.S. Nuclear involve a significant increase in the intervene. Requests for a hearing and a probability or consequences of an petition for leave to intervene shall be Regulatory Commission, Washington, accident previously evaluated l or (2)
DC 20555, telephone 301-415-6204: filed in accordance with the create the possibility of a new or fax: 301-415-5385:E-mail: Commission's " Rules of Practice for different kind of accident from any Domestic Licensing Proceedings"in 10 SAM 20NRC.COV.
accident previously evaluated; or (3) CFR Part 2. Interested persons should Dated at Rockville, Maryland this 22nd day involve a significant reduction in a consult a current copy of 10 CFR 2.714 Manuary, ma. margin of safety. The basis for this proposed determination for each which is available at the Commission's For the Nuclear Regulatory Commission. Public Document Room, the Gelman Cheryl Trottier, amendment request is shcwn below. Building,2120 L Street, NW.,
The Commission is seeking public Washington, DC and at the local public Chief, Radiation Pmtection and Heohh Effects comments on this proposed Smach, Division ofRegulatory Applications, determination. Any comments received document room for the particular '
RES. facility involved. If a request for a within 30 days after the date of hearing or petition for leave to intervene (FR Doc. 98-2017 Filed 1-27-98; 8:45 ami publication of this notice will be nup.o goog yo c., is filed by the above date, the i considered in making any final Commission or an Atomic Safety and determination.
Normally, the Commission will not Licensing Board, designated by the Conunission or by the Chainnan of the issue the amendment until the Atomic Safety and Licensing Board expiration of the 30-day notice period. Panel, will rule on the request and/or
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Feder:1 Register /Vol. 63, No.18/ Wednesday, January 28,1998 / Notices 4309 x
petition; and the Secretary or the Those permitted to intervene become Description of amendment request:
designated Atomic Safety and Licensing parties to the proceeding, subject to any The requested amendment revises Board will issue a notice of a hearing or limitations in the order granting leave to Technical Specification Section 5.6.5, an appropriate order. Intervene, and have the opportunity to " Core Operating Limits Report (COLR)."
As required by 10 CFR 2.714, a participate fully in the conduct of the The mvisions add reference to an petition for leave to intervene shall set hearing, including the opportunity to additional approved methodology for forth with particularity the interest of present evidence and cross-examine correlating departure from nucleate the petitioner in the proceeding, and witnesses. boiling (DNB) ratios. The added how that interest may be effected by the If a hearing is requested, the methodology is the Siemens Power results of the proceeding. The petition Commission will make a final Corporation Topical Report, EMF should specifically explain the reasons determination on the issue of no 153(P)(A), IfTP: Departure from why intervention should be permitted significant hazards consideration. The Nucleate Boiling Correlation for liigh with particular reference to the final determination will serve to decide Thermal Performance Fuel."
following factors: (1) the nature of the when the hearing is held. Basisforproposed no significant petitioner's right under the Act to be If the final determination is that the hazards considemtion determination:
made a party to the proceeding:(2) the amendment request involves no As required by 10 CFR 50.91(a), the nature and extent of the petitioner's significant hazards consideration, the licensee has provided its analysis of the property, financial, or other interest in Commission may issue the amendment issue of no significant hazards the proceeding; and (3) the possible and make it immediately effective, considerati m, which is presented cffect of any order which may be notwithstanding the request for a below:
cntered in the proceeding on the hearing. Any hearing held would take 1. Does the chan8e involve a petitioner's interest. The petition should place after issuance of the amendment. significant increase in the probability or also identify the specific aspect (s) of the if the final determination is that the consequences of an accident previously subject matter of the proceeding as to amendment request involves a evaluated?
which petitioner wishes to intervene. significant hazards consideration, any The proposed change adds a Any person who has filed a petition for hearing held would take place before methodology that has been previously leave to intervene or who has been the issuance of any amendment. reviewed and approved by the NRC for admitted as a party may amend the A request for a liearing or a petition determining the DNB safety limit. The petition without requesting leave of the for leave to ir.tervene must be filed with new methodology utilizes the Ifigh Board up to 15 days prior to the first the Secretary of the Commission, U.S. Thermal Performance (IITP) correlation prehearing conference scheduled in the Nuclear Regulatory Commission, deseloped by the fuel manufacturer, ,
proceeding, but such an amended Washington, DC 205554001, Attention: Siemens Power Corporation.The liTP petition must satisfy the specificity Rulemakings and Adjudications Staff, or correlation is empirically based and requirements described above, may be dehvered to the Commission's results in a DNB safety limit that .
Not later than 15 days prior to the first Public Document Room, the Gelman corresponds to a 95% probability at a j prehearing conference scheduled in the Building,2120 L Street, NW., 95% confidence level that DNB will not +
proceeding, a petitioner shall file a Washington, DC, by the above date. A occur. The DNB ratio safety limit is a >
supplement to the petition to intervene copy of the petition should also be sent conservative design value which is used which must include a list of the to the Office of the General Counsel, as a basis for setting core safety limits.
contentions which are sought to be U.S. Nuclear Regulatory Commission, The DNB correlation is not assumed to litigated in the matter. Each contention Washington, DC 205554001, and to the be an initiator of analyzed events oi-must consist of a specific statement of attorney for the licensee, transients, and use of the new DNB thiissue oflaw or fact to be raised or Nontimely filings of petitions for correlation will not alter assumptions controverted. In addition, the petitioner leave to intervene, amended petitions, relative to mitigation of accident or shall provide a brief explanation of the supplemental petitions and/or requests transient events. The proposed change br_ses of the contention and a concise for a hearing will not be entertained has been confirmed to ensure that no statement of the alleged facts or expert absent a determination by the previously evaluated accident or opi;ilon which support the contention Commission, the presiding officer or the transient results in a DNB less than the and on which the petitioner it.tends to Atomic Safety and Licensing Board that ' DNB correlation safety limit. The !!TP rely in proving the contention at the the petition and/or request should be DNB correlation assures with high hearing. The petitioner must also granted based upon a balancing of confidence that, for accidents and provide references to those specific factors specified in to CFR 2.714(a)(1) transients that do not result in a DNBR sources and documents of which the (i)-(v) and 2.714(d). less than the HTP DNBR safety limit, petitioner is aware and on which the For further details with respect to this departure from nucleate boiling and petitioner intends to rely to establish action, see the application for subsequent fuel overheat will not occur those facts or expert opinion. Petitioner amendment which is available for in HTP fuel.
must provide sufficient information to public inspection at the Commission's Therefore, the proposed change does show that a genuine dispute exists with Public Document R >om, the Gelman not involve any increase in the the applicant on a material issue of law Building,2120 L Stfeet, NW., probability or consequences of an or fact. Contentions shall be limited to Washington, DC, at d at the local public accident previously evaluated.
matters within the scope of the document room for che particular 2. Does the change create the amendment under consideration. The facility involved. possibility of a new or different kind of contention must be one which,if accident from any accident previously proven, would entitle the petitioner to Caroh,na Pover & Light Company, evaluated?
relief. A petitioner who fails to file such Docket No.30-261, it.B. Robinson The proposed change does not a supplement which satisfies these Steam Electric Plant, Unit No. 2 nvolve any physical alteration of plant requirements with respect to at least one Darlington County, South Carolina systems, structures, or components or contention will not be permitted to Date of omendment mquest: changes in parameters governing normal participate as a party. Decembe* 17,1997, plant operation. The proposed change
R' 28,1998 / Notices Federal Register /Vol. 63, No.18/ Wednesday, January 4328 decommissioning and fuel storage review, it appears that the three consideration, which is presented activities described in the License standards of to CFR 50.92(c) are Termination Plan are consistent with below: satisfied. Therefore, the NRC staff The Davis-Besse Nuclear Power those in the approved Decommissioning proposes to determine that the Plan.The proposed change does not St: tion (DBNPS) has reviewed the amendment request involves no proposed changes and determined that affect plant systems, structures, or a Mgnificant hazards consideration does significant hazards consideration.components in any way not previously Local Public Document Room not exist because operation of the Davis- locotion: Universi:y of Toledo, William evaluated in the approved Decommissioning Plan, and no new or Besse Nuclear Power Station, Unit
- Number 1,in accordance with these Carlson Library, Government Documents Collection,2801 West different failure modes will be created.
changes would: Therefore, the proposed change is t a. Not involve a significant increase Bancroft Avenue. Toledo,OH.
Attorneyforlicensee: Jack Newman, administrative in nature and does not in the probability of an accident create the possibility of a new or Al Gutterman, Morgan. Lewis & different kind of accident from any pmvlously evaluated because the Brockius,1800 M Street.NW.,
probability of previously analyzed . Washington, DC 20036-5869. previously evaluated.
accidents is not affected by the criteria 3. Involve a significant reduction in a NRCActing Pmject Director: Richard In the core alteration definition margin of safety. Approvalof the
. (Technical Specification (TS) 1.12). Nor P. Savio. License Termination Plan by license ds these changes,the proposed Yankee Atomic Electric Company' amendment is administrative in nature relocation of the refueling Docket No.50-029, Yankee Nuclear since all decommissioning and fuel communicationsTS 3/4.9.5 and Bases to Power Station, Franklin County, storage activities described in the the DBNPS Updated Safety Analysis Massachuseus License Termination Plan are consistent Report (USAR) Technical Requirements with those in the approved Date of amendment mquest:
Manual (TRM), or the proposed addition Deccmber 18,1997. Decommissioning Plan. Therefore, the cf new TS 3.0.6 and Bases regarding Description of amendment request:By proposed change does not involve a return to service ofinoperable letter dated May 15,1997, the licensee significant reduction in a margin of equipment, affect any accident initiator, submitted a License Termination Plan. safety.
or assumption made in any safety The NRC previously published a notice The NRC staff has reviewed the analysis. he proposed changes are dated August 14,1997,in the Federal licensee's analysis and, based on this admin!strative in nature and am review,it appears that the three constatent with NUREG-1430. Revision Register (62 FR 43559) advising of standards of toCFR50.92(c)are receipt of the Plan.ne pmposed 1, " Standard Technical Specifications, satisfied. Therefore, the NRC staff request is for a license amendment Babcock and Wilcox Plants " dated approving the Plan for the Yankee proposes to determine that the April 1995, as modified by a pending amendment request involves no NUREG-1430 change approved by the Nuclear Power Station.
Basisforpmposed no significant significant hazards consideration.
NRC TechnicalSpecificationTask LocalPublic Document Room hasards considemtion determination: locofion:Greenfield Community Fouce (TSTF) Standard Technical As sequired by 10 CFR 50.91(a),the Specifics ; ion Change Traveler Number licensee has provided its analysis of the College,1 College Drive, Greenfield, 165. issue of no significant hazards Massachusetts 01301.
Ib. Not involve a significant increase consideration, which is presented Attorneyforlicensee: Thomas Dignan, In the consequences of an accident ~ Esquim, Ropes and Gray,One below: International Place, Boston,'
previously sealuated because the The proposed change willnot:
proposed changes do not affect accident 1. Involve a significant increase in the Massachusetts 02110-2624.
conditlosit or aseen ons used in NRCProject Director: Seymour H.
' Probability or consequences of an evakustingtheradio cal accident previousi evaluated. Accident Weiss.
consequences of an accident The PPmM Notice oflesuance of Amendiments to i g P en an Facility Operating Licenses
[ter s ros con incorporated into the PSAR. Alj isolation, or allowable radiological During the period since publication of decommissioning and fuel storage releases, the last biweekly notim, the 2.Not create the possibility of a new activities described in the License Commission has issued the following or different kind of accident from any Termination Plan are consistent with those in the approved Decommissioning amendments.The Commission has accident previously evaluated because Plan. No systems, structures, or determined for each of these amendments that the application the proposed changes do not change the components that could initiate or be way the plant is operated. No new or required to mitigate the consequences of complies with the standards and different types of failures or accident an accident are affected by the proposed requirements of the Atomic Energy Act initiaton are introduced by the of 1954, as amended (the Act), and the change in any way not previously Commission's rules and regulations.
proposed changes.
- 3. Not involve a significant reduction evaluated in the approved The Commistion has made appropriate Decommissioning Plan. Therefore, the In a margin of safety because no inputs findings as required by the Act and the into the calculation of any Technical proposed change is administrative in Commission's rules and regulations in Specification Safety Limit, Limiting nature and does not involve an increase to CFR Chapter 1, which are set forth in in the probability or consequences of an Safety System Settings. Technical accident previously evaluated. the license amendment.
Specification Limiting Condition for 2. Create the possibility of a new or Notice of Consideration ofIssuance of Operation, or other previously defined Amendment to Facility Operating different kind of accident from any margins for any structure, system, or accident previously evaluated. Accident License, Proposed No Significant Hazards Consideration Determination, component important to safety are being analyses are included in the approved affected by the proposed changes. Decommissioning Plan and are and Opportunity for a Hearing in
'Ibe NRC staff has aviewed the incorporated into the FSAR. All connection with these actions was llansee's analysis and, based on this L