ML20235Z261

Application for Amend to License DPR-61,revising Tech Spec 3/4.1, Reactivity Control Sys. Comparison Matrix to Existing Tech Specs & Westinghouse STS Encl

ML20235Z261
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/06/1989
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20235Z263	List: B13151, Proposed Tech Specs 3/4.1, Reactivity Control Sys ML20235Z261
References
B13151, TAC-48019, NUDOCS 8903150269
Download: ML20235Z261 (3)

Text

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s N UTILITIES o.nor.i Orvie.. . s.ioen sir..t. Boriin. Conn.cticut

', AFkTFORD CONNECTICUT 06141-0270 L L T J '""'00',"%'C"J,,, (203) 685-5000 L 1 March 6, 1989 Docket No. 50-213 B13151 Re: 10CFR50.90 i

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

References:

(1) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, Revised Technical Specifications, dated ,

October 26, 1988. l (2) F. M. Akstulewicz letter to E. J. Mroczka, Conversion of i Plant Specific Technical Specifications to the Standard Technical Specifications, dated September 12, 1987.

Gentlemen:

Haddam Neck Plant Amendment Request for Section 3/4.1 Revised Technical Specifications (TAC No. 48019) i Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPC0) l proposes to amend its Operating License, DPR-61, by including the proposed l changes identified in Attachment 1 of Reference (1) into the Technical Specifications of the Haddam Neck Plant as part of an improved set of Technical Specifications. This submittal re) resents the second in a series of submittals forwarding amendment requests w11ch will ultimately comprise an improved set of Technical Specifications for the Haddam Neck Plant. Along with the amendment request for Section 3/4.1, Reactivity Control System (the numbering and format is consistent with the Westinghouse Standard Technical Specifications (W STS, Rev. 5)), supporting documentation is provided as follows:

o Attachment 1 forwards the revised Technical Specification pages.

o Attachment 2 provides a description of the changes from the existing Technical Specifications. CYAPC0 has reviewed the proposed revised Technical Specification changes in accordance with 10CFR50.92 and has determined that they do not involve a significant hazards consideration.

The basis for this determination is discussed in Attachment 2.

o Attachment 3 provides a comparison matrix to the existing Technical l Specifications and the H STS as described in the preface to that I attachment

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U.S. Nuclear Regulatory Commission B13151/Page 2 March 6, 1989 Moreover, the Commission has provided guidance concerning the application of the standards in 10CFR50.92 by providing certain examples (March 6, 1986, FR7751) of amendments that are considered not likely to involve a significant hazards consideration. The changes proposed herein are enveloped by example (ii), a change that constitutes an additional limitation, restriction or control not previously included in the Technical Specifications. These proposed changes would add Limiting Conditions for Operation and Surveillance Requirements for the systems covered under the proposed revised Technical Specification sections and are consistent with the W STS. This will help ensure the operability and reliability of the systems covered under the proposed revised Technical Specification sections. Therefore, the proposed changes do not impact the consequences of any design basis accident.

Based upon the information in this submittal, there are no significant radiological or nonradiological impacts associated with the proposed changes, and the proposed license amendment will not have a significant effect on the quality of the human environment. The Haddam Neck Nuclear Review Board has reviewed and approved the proposed changes and has concurred with the above determination.

In accordance with 10CFR50.91(b), CYAPC0 is providing the State of Connecticut with a copy of this proposed amendment.

CYAPC0 acknowledges the receipt of your letter dated September 12, 1907 (Reference (2)). CYAPC0 believes that the process described in Reference (2) for converting the existing Technical Specifications for the Haddam Neck Plant to the H STS does not represent the optimum approach to amending our license.

Instead, we have provided a comparison matrix which compares the amendment request (i.e., the proposed changes) to the H STS, Rev. 5 as well as to our existing Technical Specifications.

In recent discussions with the NRC Staff, CYAPC0 was informed by the Staff that our process of converting the existing Technical Specifications to the W STS does not fulfill our earlier commitments for conversion of the Haddam Neck Plant Technical Specifications to the Standard Technical Specif~ cations.

Therefore, the Staff requested CYAPC0 to commit to implement the new Industry STS which are being developed by the Owners' Groups under the NUMARC STS improvement program. As you know, CYAPC0 is a member of the Westinghouse Owners' Group (WOG) - Technical Specification Subcommittee and is actively participating in the Industry Technical Specification Improvement Program. We agree with the concept and objectives of implementation of the new STS.

However, prior to making a firm decision on committing to implement the new STS for the Haddam Neck Plant, CYAPC0 believes it is necessary to know what

, the new STS will contain by observing the implementation process of the new l STS for the WOG lead plant. It is our understanding that the Staff's review I

of the lead plant submittal will be completed in the summer of 1990.

Therefore, at this time, we are not in a position to commit to implement the new STS. However, the implementation of the current proposed revised

U.S. Nuclear Regulatory Commission B13151/Page 3 March 6, 1989  ;

Technical Specifications for the Haddam Neck Plant is an appropriate and a worthwhile undertaking for both organizations for reasons discussed at length in our previous meetings on this issue. Completion of the current undertaking will close numerous open issues on the docket and provide a clear starting point for any future conversion to the new STS.

Should you have any questions on the attached amendment request and/or feel a meeting would help clarify the attached material, please contact our licensing representative directly.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY E. J./fVoczka //

Senior Vice President cc: Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, CT 06116 W. T. Russell, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant l J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant STATE OF CONNECTICUT)

I

) ss. Berlin COUNTY OF HARTFORD )

Then personally appeared before me, E. J. Mroczka, who being duly sworn, did i state that he is Senior Vice President of Connecticut Yankee Atomic Power  !

Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein, and that the statements contained in said information are true and correct to the i best of his knowledge and belief. '

L)2hdluL ~~

Notary P c MyCerken Exp!ma Varch H,1993

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