ML20237E357

Application for Amend to License DPR-3,removing Definition of Site Boundary Contained in Subsection 1.10 of Definitions & Modifying Subsection 5.1 of Design Features

ML20237E357
Person / Time
Site:	Yankee Rowe
Issue date:	08/20/1998
From:	Desiree Davis YANKEE ATOMIC ELECTRIC CO.
To:	Fairtile M NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20237E359	List: ML20237E357 ML20237E363
References
BYR-98-051, BYR-98-51, NUDOCS 9808310185
Download: ML20237E357 (5)

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TJephonetS08) 5684233

'YANKEEATOMIC ELECTRIC COMPANY  ;*E' L**iC'L9c- e av S80 Main Street, Bolton, Massachusetts 01740-1398

w. 1 DON K. DAVIS

.c,wn . August 20,1998 cw exccuws omcen P.C. No. 26i BYR 98-051 United States Nuclear Regulatory Conunission Document Control Desk Washington, DC 20555 i Attention: Mr. Morton B. Fairtile i Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation i

References:

(a) License No. DPR-3 (Docket No. 50-29) l (b) NUREG-1625, " Proposed Standard Technical Specifications for Permanently Defueled Westinghouse Plants" (c) USNRC Regulatory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants"

Subject:

Technical Specification Changes to Delete Definition of Site Boundary and -

Relocate Technical Specification Figure 5.1-1

Dear Mr. Fairtile:

Pursuant to 10 CFR Section 50.90 of the Commission's Rules and Regulations, Yankee Atomic Electric Company (YAEC) requests Nuclear Regulatory Commission (NRC) review and approval of the following modifications to Appendix A of the Yankee Nuclear Power Station (YNPS)

- License (Reference (a)).

PROPOSED CHANGES  !

I YAEC proposes to delete Subsection 1.10 of the DEFINITIONS Section of the YNPS Defueled L Technical Specifications to remove the definition of SITE BOUNDARY provided therein.

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l- .YAEC also proposes to modify Subsection 5.1 of the DESIGN FEATURES Section of the

YNPS Defueled Technical Specifications to read as follows

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l' i United States Nuclear Regulatory Commission . August 20,1998

' Attentio'n:

Mr. Morton Fairtile - Page 2 ~

5.1 SITE LOCATION - i

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The Yankee Nuclear Power Station is located in the town of Rowe, Massachusetts, three-quarters of a mile south of the Vermont-Massachusetts border. The site is at the bottom of a deep valley along the Deerfield River on the southeast bank of Sherman Reservoir. The geographical coordinates of the center of the site are as follows:

Latitude: N 42* 43'41" Longitude: W 72" 55' 42"

= YAEC also proposes to delete Figure 5.1-1 from the YNPS Defueled Technical Specifications I and to transfer the subject figure to the YNPS Final Safety Analysis Report. Annotated copies of _,

the present Technical Specification pages showing the proposed changes are provided in Attachment A to this letter. The proposed new pages of the Technical Specifications are

. provided in Attachment B.

L REASONS AND BASES FOR' CHANGES

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The inclusion of the definition of SITE BOUNDARY in the YNPS Defueled Technical i Specifications is unnecessary for the following reasons:

.1) The definition of this term already exists in 10 CFR Part 20;

12) The present YNPS Defueled Technical Specifications definition alludes to "any area within the SITE BOUNDARY used for residential quarters." Although the site map in i the YNPS Defueled Technical Specifications, Figure 5,1-1, shows a residence within - i the site boundary, this residence no longer exists; and

= 3) The NRC has not considered it to be necessary or useful to include the site boundary j

. definition in NUREG-1625, " Proposed Standard Technical Specifications for a Permanently Defueled Westinghouse Plants" (Reference (b)).

Aslnoted above, the definition of the, term SITE BOUNDARY, including the context in which this term is to be interpreted and applied, is provided in 10 CFR Part 20; therefore, the present

' inclusion of the SITE BOUNDARY definition in Section 1.0 of the YNPS Defueled Technical

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. Specifications is an unn6cessary redundancy. Consistent with this assertion, the present YNPS Defueled Technical Specifications includes the term UNRESTRICTED AREAS, which like the p term SITE BOUNDARY, is defined in 10 CFR Part 20 and cited in Section 6.7.5 of the  ;

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,' i l ' United States Nuclear Regulatory Comnussion August 20,1998 L ?Attentidn

. Mr.- Morton Fairtile . Page 3

i YNPS Defueled Technical Specifications; however, the definition of UNRESTRICTED AREAS was never incorporated in Section 1.0. The judgment that it is unnecessary to duplicate definitions of terms already defined in the regulations in the individual Technical Specifications of units appears to be endorsed by the fonnat and recommended content of the Standard Technical Specifications for both operating and permanently defueled plants. l Concerning the proposed textual description of the YNPS site location and the removal of Figure 5.1 1 from the YNPS Defueled Technical Specifications and its relocation in the YNPS Final Safety Analysis Report, the applicable section of the NRC's regulations dealing with the required content of Technical Specifications, Section 10 CFR 50.36 (c)(4), states

" Design features to be included are those features of the facility such as material of construction, and geometric arrangements, which, if altered or modified, would have a j significant effect on safety and are not covered in categories described in paragraphs (c) (1), (2), and (3) of this section."

i-The referenced paragraph (c) (1) deals with safety limits, limiting safety system settings, and limiting control settings; paragraph (c) (2) deals with limiting conditions for operation; and l paragraph (c) (3) deals wi_th surveillance requirements. None of the above cited criteria for L content of Technical Specifications applies to the site map, Figure 5.1-1, in the current YNPS Defueled Technical Specification.

L In addition, two NRC guidance documents support the proposed change. NUREG-1625 l 1(Reference (b)) calls for a " Text description of site location" in the DESIGN FEATURES section -

L '(page 4.0-1) of these Standard Technical Specifications. Also, Regulatory Guide 1.70

-(Reference (c)) directs applicants and licensees to provide the site map for their facility in Section

' 2.1.1.2 of their Safety Analysis Report.

Therefore, in the spirit of the NRC's Technical Specification improvement initiatives which encourage licensees to request removal ofinappropriate and/or unnecessary information from I their Technical Specifications, YAEC proposes to remove Figure 5.1-1 from the YNPS Defueled l Technical Specification, relocate the subject figure in the YNPS FSAR, and to provide a textual f

. description of the site location in the YNPS Defueled Technical Specification.

SAFETY CONSIDERATIONS The proposed changes are administrative in nature and in no way affect the safety of YNPS. The proposed deletion of the definition for SITE BOUNDARY in no way reduces or eliminates any regulatory requirement which YAEC must currently satisfy. Likewise, the relocation of the j YNPS site inap from the YNPS Technical Specification to the YNPS FSAR is devoid of any safety implications. Therefore, the changes will not:

i United States Nuclear Regulatory Commission August 20,1998 Attentio'n: Mr. Morton B. Fairtile Page 4 j

1. Involve a significant inc: case in the probability or consequences of an accident previously evaluated. The administrative nature of the changes will not affect

. safety-related systems or components and, therefore, involve no significant I increase in the probability or consequences of an accident previously evaluated.

2. Create the possibility of a new or different accident from any previously evaluated. The proposed changes do not modify any plant systems or components and, therefore, do not create the possibility of a new or different accident from any previously evaluated.

3. Involve a significant reduction in the margin of safety. The proposed changes do not involve any physical changes to the plant nor any change in plant procedures.-

Therefore, there will be no reduction in the margin of safety, i

Based on the considerations noted above, it is concluded that the proposed changes will not endanger the public health and safety.

The pro' posed changes have been reviewed by the Plant Operation Review Committee and the Nuclear Safety Audit and Review Committee.

SCHED1]LE OF CHANGE The proposed changes will be implemented upon approval by the Commission.

I Very truly yours, YANKEE ATOM ECTRIC COMPANY j ,

Don K. Davis, Chairman l President and CEO l

h ' Attachments cc: USNRC, Region I' L

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United States Nuclear Regulatory Commission August 20,1998 Attentio'n: Mr. Morton Fairtile Page 5 COMMONWEALTH OF MASSACHUSETTS WORCESTER COUNTY Then personally appeared before me, Don K. Davis, who, being duly sworn, did state that he is Chairman, President, and Chief Executive Officer of Yankee Atomic Electric Company, that he is duly authorized to execute and file the foregoing document in the name and on the behalf of Yankee Atomic Electric Company and that the statements therein are true to the best of his knowledge and belief.

M Kathryn Gates # / Notary Public My Commission Expires January 1,2004 l

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