ML20247B681

Corp:Consideration of Issuance of Amend to Facility OL & Opportunity for Prior Hearing, Petition of State of VT for Leave to Intervene & Request for Evidentiary Hearing.* Certificate of Svc Encl

ML20247B681
Person / Time
Site:	Vermont Yankee
Issue date:	08/22/1989
From:	Volz J VERMONT, STATE OF
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20247B535	List: ML20247B530 ML20247B643 ML20247B681
References
OLA-4, NUDOCS 8909130107
Download: ML20247B681 (14)

Text

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BEFORE THE UNITED STATES NUCLEAR 0QPj'i;.I;:0 '

REGULATORY CONNISSION "

ATOMIC SAFETY AND LICENSING BOARD No. 50-271 'c9 AUG 23 A8 27 Vermont Yankee Nuolear Power Corps )

consideration of Issuanca )

i of Amendment to Facility Operating )*

License and Opportunity for Prior Hearing re j Proposed Amendment )

)

Noticed at 54 FR 31120 (July 26, 1989) )

VERM&MT YANFFF NUM FAR PG^uiru OORD r CONSIDERATION OF THEUl^40r; OF AMFMDMENT "O FADILTTY OPERATING LICENRE AND OPPORTUNT"Y FOR PRYOR MFARING FETITTON DE TME STATE OF VERMhWT FOR LFAVE TO TivrrxWW AND REOUEST POR AN EVIDENTIARY MF1 RING NOW COMES the State of Vermont, by and through the undersigned counsel, and petitions for leave to intervene and for an evidentiary hearing in the above-styled cause pursuant to 10 CFR 2.714 and the notice published at 54 FR 31120 (July 26, 1989),

concerning extension of the expiration date of the Operating License. In support of said petition it is stated:

I.

RIGHT OF PETITIONER TO BE A PARTY, The proposed license amendment involves the Vermont Yankee Power Station located in Vernon, Vermont.

The amendment seeks to extend the expiration date of the Operating License frem December 11, 2007 to March 21, 2012.

The extension of the Operating Licenee ha's a petsntially.a v..ttecant affect on the environment of Page 1 890913010,' 090901 5" ^"" " N'

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the state of. Vermont, and on the health, welfare and safety of its people, and the State of Vermont has a clear right to participate in the proceedings.

II.

EIikwr OF PETITIONER'E PROPERTY, PTNAMETIT., OR 0;rnra ThrrkEST TN TMF PROGFiEnfiid.

The State of vermont. has a responsibility to ensure that the environments'of the State of Vermont, and the health, welfare and safety of its people are not compromised or adversely'affected by '

an improvident granting of the requested license amendment.

Issuance of the license amendment under the circumstances proposed could, if State health, safety and environmental concerns are not-adeguately addressed, result in a significant ineresse in risk to Vermont and its citizens from the Vermont Yankee plant. .

TTT, POERTET.? EFFECT OF ANY OehER WMTEM MAY BE Ei rrRED IN THE PRoerEBTMf2 ON TW PETITIG=1R ' S TihrRFET As noted, the requested amendment involves a plant which is physically located in vermont.

Any order permitting the requested amendment would have both direct and indirect effect on vermont and its citizenry.

TV, SPEETPIE AEPECTE OF THE Eifn.TECT Mirrzu As TO WHTCH FETITIOw n wfEurs TO ThrzavFNE.

The specific aspects of the subject matter of this proceeding which the State of Vermont seeks to address include but are not limited to:

1.

Increased risks to public health and safety from aging of equipment beycnd its intanded design lifetime.

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., xA gg.*!9.15.ts Ge2-BEB-ES A l

1 Nuclear equipment which was installed and/or operated i

during the construction period would exceed a 40-year  !

lifa if the amendment request.were. granted, thus-increasing the risk to the public.

2.

Adverse affacts on the environment of the State of Vermont resulting from not considering alternatives which are more environmentally suitable. The proposed extension causes generation of additdonal high- and low-level radioactive waste, additional safety risks and other additional environmental impacts. All of l-these impacts, plus the production'of these. resources necessary for addressing and mitigating these Tets, result in an adverse affact on the environment.

Alternatives such as a natural gas fired plant,

• purchased power from canada, energy conservation, or better-load management may be more environmentally suitable. Making a decision at this time to approve 1

the proposed amendment before full consideration of alternative ways to meet future power needs, and before the likelihood of such future needs is clearly established, will tend to foreclose consideration of alternatives.

3.

Adverse burden of high and low level radioactive vastes upon the State of Vermont. Despite federal plans for high level waste disposal, no confidence exists that auch storage vill come into existence.

The license extansicn increases the amount of high o Page 3

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,- , cg,22 ee 15:49 ecz-Els-E342 P.6 level waste which will be stored in-state indefinitely. Federal law requires that states hold ultimate responsibility for disposal (and potentially ownership) of low-level radioactive waste. Vermont is unwilling to accept disposai and potential ownership of low-level waste beyond that produced under the present licensed period.

4.

Increased risks to public health and safety from reduction in the margins of safety for operation of the Vermont Yankee Power Station. The licenses has not established that there is an adequate margin of safety for operation of the plant for any period of time sfter that originally authorized in its operating license. .

The mere fact that it was authorized to operate until 2007 does not legally or technically mean it is safe to operate beyond that date, particularly since the plant was one of those that just met the ECCS criteria.

REQUEST TOR EVIDENTIARY HEARING In its proposed amendment application the licensee identifies the following iszues as directly relevant to the proposair Page 4

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,' .  ;,uc,12 591 sus ecz-eze-2342 P7-1.

Whether the operating life of the plant safety equipment will expire before the end of the proposed

. period of extension?

2.

Whether the ongoing maintenance and inspection programs have been functioning properly and will be able to assure the integrity of safety systems during the proposed extension period?

3.

Whether the margin of safety will be reduced by extending the operating life of the plant for the period of the extension request?

4. 'Whether the operating history of the pisnt and its equipment provides evidence that the plant can be operated safety for the additional time requested?

5. Whether the original design of the plant contIained sufficient excess conservatism that reliance on that conservatism to authorize operation of the plant after 2007 makes it unnecessary to adopt any modifications in the design or operation of the plant?

6. Whether the plant will increase radiation L

1 exposures to the worker and surrounding population as it gets older and more of its parts become irradiated?

7.

Whether there is safe and available capacity to store the nuclear wastes created by further operation of the plant?

p All of these matters are matters of safety significance for which the licensee n.ust present proof. In the initial operating -  ;

license prtceeding no findings of fact were made regarding the Page 5

• AUG 22 '89 15:50 802-E28-2~42

' P.8 saiety of the plant or any of its'systees beyond the date for which the license was sought.

There are no findings by any tribunal that operation of this plant beyond 2007 will provide I

adequate protection for the public health and safety. Whether the extension will'or will not result in the margins of safety falling below acceptable levels is the issue which the licenses must address with evidence in a hearing. It is their burden to prove what the margin of safety is in this plant, that the margin of safety exceeds the regulatory requirements and that extension of the operating life of the plant for an additional 10% will not bring the margin of safety below that level. Thus, at least for vermont Yankee, there is no basis to treat a proposti to extend the operating life of the plant as having already been reviewed.

V In addition, the Vermont Yankee plant was one of those

• plants.for which the calculation of its capacity to meet the ECCS criteria indicated that it just qualified. Thus, contrary to the assertions in the application for the amendment, there is not a significant excess margin of safety built into this plant which may be used to absorb the additional risk created by extending the life of the plant for four years.

The above discussion indicates that the proposed license amendment does involve significant hasards considerations. The licensee's application concedes as much by identifying numerous safety related issues whose resolution r.ust be made in order to determine whether the amendment should be issued.

It assumes the answer to the question to argue that prior approval of the plant to operate,until 2007 was the equivalent of approval of the plant Page 6,

f.UG 22 '99 15:51 SO2-E20-2342 P.9 1

to operate until 2012 because the licensee and the Commission made )

a technical' error in dating the license. The evidentiary findings- l only focussed on the year 2007. Thus the unreviewed safety.

l l question is 'whether there is reasonable assurance that the silant

)

1 can operate with adequate protection for the public health and safety after 2007.

As noted on pages 1-2 above, even if the plant's safety equipment was designed to last forty years and there had been a finding to that effect, the date from which such forty years is to be counted is not the technically irrelevant date of when the plant got an operating lican'se, but when did the equipment begin to experience deterioration.

That date was far in advance of the issuance of legal permission to operate the plant and dependi;sg on the equipment involved could have been as early as the date the '

construction permit was issued. Thus, another unreviewed safety i question is when will the safety equipr.ent in the plant reach its forty year useful life?

While this discussion should indicate clearly that there are significant hazards considerations involved here and thus a hearing should be held, the Commission need not reach that issue to provide the result sought by the State of Vermont. Vermont i seeks an evidentiary hearing on the proposed amendment which will predate action on the proposal. Due to the wise decision of Vermont Yankee management to seek the proposed amendment well in advance of any possible need for it, there is ample time to provide the hearing requested by Vermont and still provide Vermont Yankee with a timely an:ver. By postponing any decision on the Page 7 l

f... c.o; II 's 15:52 802-9I5-2242 P 10

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amendment as a mattar of its discretionary power and because an early decision is unnecessary at this time, the Commission can avoid addressing the significant hasards question. Vermont does not care which route the Commission follows so long as the evidentiary hearing is held and the decision on the amendment application is based on the outcome of that hearing.

Finally, it is important to neta that the environmental concerns raised by Vermont involve the need to consider alternatives to the proposed action. Consideration of these alternatives should occur prior to any final decision in order to assure that the decision itself does not bias the consideration of the alternatives.

CONCLUSION The State of Vermont believes that an evidentiary hearing should be held on the preposal to extend the operating life of the Vermont Yankee Nuclear Power Station prior to any action being taken on the proposed amendment. The State has a strong and long-recognized interest in the operation of this nuclear power plant within its borders. Its request to intervene should be granted and the evidentiary hearing should be held. At the appropri- 2 time Vermont will identify with specificity all of its contentions and the bases for them.

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AUG 22 'S9 15:52 802-928-2342 P.11 m

The State of Vermont wishes.to participate in this-1 proceeding with respect to the issues set forth above as well as any other which may be raised by other parties hereto.

THE STATE OF VERMONT 4

By: '

h O/

James Volz -

(InterimDirectord for Public Advocacy Department of Public Service Special Assistant Attorney General All pleadings related to this matter should be served on:

James Vols Vermont Departner!t of Public Service ,

120 State Street Montpelier, VT 05602 LCONLIC.50P 4

ese Page 9,

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auG t2 Es 15:53 502-E25-2342 p.12 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD No. 50-271 Vermont Yankee Nuclear Power )

Corps Consideration of Issuance )

of Amendment to Facility operating )

License and Opportunity for Prior )

Hearing re Proposed Anandment )

Noticed at 54 FR 31120 tJuly 26, 1989) )

NOTTEE OF ADPriniver The undersigned counsel hereby files this notice of appearance in this proceeding.

Names James Volz .

Address: 120 State Street Montpelier, Vermont '05602 Telephone No.: 802-828-2811 Admissions: State of Vermont Party Represented: State of Vermont Respectfully submitted, By: h% [

7ames Volz I; Epocial Assistant Attorney General Special Counsel Vermont Department of Public Service 120 State Street Montpelier, Verment 05602 (802) 828-2811 cc Parties LAPPAJV.50P' -.

. . Lpus 22.'99 15:53.802-928-2342 P.13 E e, BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION-ATOMIC SAFETY AND LICENSING BOARD No. 50-271 Vcrmont Yankee-Nuclear Power )

Corps consideration of Issuance )

of Amendment to Facility Operating )

License and opportunity for Prior )

Hearing re Proposed Amendment )

Noticed at 54 FR 31120 (July 26, 1989) )

CERTIFICATE OF EERVICE I hereby certify that I served a copy of the foregoing-Petition to Intervene by causing a true copy hereof to be placed in the United States mail, postage prepaid, addressed as follows:-

Secretary'of the Commission U.S. Nuclear Regulatory Commission Washington,.D.C. 20555 office of the General Counsel-Bethesda U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

R.K. Cad, Esq.

Roper and Gray 225 Franklin Street

• Boston, MA 02110 William Griffin Esq.

Attorney General's office State of Vermont Montpelier, VT 05602 New England Coalition on Nuclear Pollution, Inc.

P.O. Box 545 Brattlebero, VT 05301 eos

AUG' 22 *EF 15:54 802-E29-2242 . p,g4

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. i

' John Traficonte Department of the Attorney General l

One.Ashburton Place i Boston, MA 02108 t

Dated at Montpelier, Vermont this 22nd day of August, 1989. I 1

VERMONT DEPARTMENT OF PUBLIC SERVICE By: )  % (

r James Vols v y

- ( Interi.m for Public Advocacy Director /

LCSRJV.50P 1

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l em.

S- 131120

..o '.

. Federal Register / Vol. 54. No.142 / Wedarsdsy, July .26,1989 /

Nntices chinsTs incre:se th2 control room statiml reqmrements and, therefore, will . cvilsated. or (2) cre:te the possibility of not reduce the marge of safe . a new or different kind of accident from for the Vermont Yankee faciHty be The NRCstaff has the any accadant previonaly evaluated, or (3) with the data ofissuance of th licensee's proposed no sigmficant - involve a significantreductionin a construc6cn permit. Deosaber tt.1eer.

hazards determination and agrees with margm of safety. and ends on December 11.20Dr.

the licensee's analysis. De beensee has evaluated the Accounting for the four years and three .

Furthermore the Commission has . proposed amend = mat against the months required for plant constreason, provided guidance concernmg the standards in 10 CFR 50.92 and has this represents an effective operadng determined the following:

application of cnteria for determming whether a sigmficant hazards months. term of only 35 yeare and license 9, ne removalof the Reactor VesselHead '

consideration exists byi Wi.Ms Sprey Velves(RHR-82 and RHR4sn from Current NRC policyis toleone '

T ble 43.2.b of the Technical Specdcatione opmaung Hoense for a 401mrpubd.

certain examples of actions involving significant hasards consideration (61 ]yp yrenow raiuvement

,,,, ggg ,g 7751). As statedin example tvil). A m bdom es m w as-i=* M a ~ &e opersdag homem For Vasmet .

change to conform a license to changes valves are mamistned stooed and this Yank,dds hw wm Merd 21.ters.

in the regulation, whom the license Accordingly,it is proposed thatthe -.

ensadmen open the valmwedd reseove for these te w a. 'Veasant Yank opermeugbassehe %i ear,s.u.=

- change results in very minor changes to laci'.ity operations clearly in keepas father esmeenas to prended that the valm amandad to change the espbeden dak-witahe regulations."The proposed wtB remata ta rbeir teolated posioon. h to March 21,2012 consistemtwi&*- *

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changes associated with this .. removal d the cheek valve (so.aoleum the current - NRCpoli and the orWnall Table wd mee comung a the Techmos!

amendment are within the scope of this "P""'acadene ta roessadas that the Ro . M/w engineered dnignlife of, th.o. 'M m'yz '

example. sanar Accordingly, ea proposes Head sprayfuncesshas been.u Dus.ee proposed change does not tavolve

-i hasards consi me W w f Wondeformdesdent .

determine that the proposed changes a maressem to preddayw De t'a==iaala= bas provided mrer involve no signd ant hasartis consequenose of as sealdent previounty shahrds im'h hes==@dsts au consideration. evaluated. Opsessemas the RHR Syeessa h anynihanthasar%.ad ds a==

loco /PublicDocumentRoom - not reduced from existing requeenente and as statedin 10 CFR Mas (c). psopened locardon: University of Toledo Ubrary, is sts bounded by the - -- rai- meedin amendment to 88 operating, ~~

Documents Department. 2801 Bancroft the esfety amatyeis, thus the pmposed dange indm ao signsmme hasW6,,,,f,,,,,,

doesnotasamesposehtheof anoww A'

Atto Toledo for Ohio 43008.

[ieansar Gerald he kind dsealdet han any mm hhbpmadm@M Charnoff,Es uire Shaw.Pittman.Potts pmytonely evaluated. Mindnation of emblect

'"'"d3*"*" "U '**** ** '*

inammene m toMwr andTrowbri amendment would not: (1)isselse a c.a 2300 N Street.NW 83Ma ee 20hMpsmed vdm.4""""", whid wE "i fmA==* taaseene Anthogesbehaper Was . DC200BL emeure that deineserterof ede esato nna.=In="an of an scoldest

. snTc /ectDirocsar: John N.Hannon mie='=d at a5 emes.'Ites; esassinvdm no deamase tu any sh(2)mostes a new ditfuent of vessent Yankee NuclearPower D8088 M**88873 ,

Thp,'Khas reviewed te Stelles'r '

Vasiment Yankas Numinar Powe'r lisenseestenalgelacanthasards .v. m involve a mig =6h==* sedmodesi$$ML Vermen.Vermeest - aa==ad==edes detersminauen and agrom marginofsafety. eFatTnTalisein' emf i De linannee's analysessamtalmedin Date of applicationforamendmentt. wt& es homma's analysis. Band on the April 27,1980 letter statae the en .

February 2.1989 tids review, the sta5 therefore - w "; foll* Win 5:

aiUN W'r' aibus Description ofAmendmentivguese determines that the propond

%e proposed amendment deletes N posedamendmenttotheVenuset P

umandment does notinvolve a . Yankaa opmaung home does metimho valves RHR.32, RHR.33 and Reactor asynian.., hasards considerados. ? - anydangesin to desistwopgedenaf to Head Spray Check Valve 1029 from LocalpublicDocumentAcoar I" Table 4.7.2.b of the Technical locadore Brooks hiamorial Ubrary. 224 'mY I g"onda em ser Specifications. This table pertains to Main Street. B sttleboro. Vermont 05301. para u m % h e W eb esresse primary containment isolation valves AttorneyforLicensetJohn A.Riteher. .p des 6ble by se t'a=-i-a=='s regulamens.

not subject to Type Cleakage tests. Ropes and Grey.225 Franklin Street, a a nytocyR.seensasast.leadessa, a ndia, of no e6eniaa== basente RHR 32 and.33 are in a line that is Boston. Massachusetts 02110. - t's.4 closed oft by a blank flange, thus,no NRCProjectDirector Richard H. - oossidosamen to constement wie resent letC?

to uire surveillance testing. Wessman '. .

annone se appliconene of this type.h i pmposedertmoton wWhow to eigad0 mat Ch alve 10 29is in a disconnected 7 Vermont Yankee Nuclear Power impact on the safe operation of the planter line that no longer earves any funcean. Corporaties Decket No. SS 371 Veament of to Febhc.present ' an undue risk to the henkh Basisforproposedso sgruficant .a hazards constderntwn determination: Yankee Nacieer Power Station. Vernen.

y,,,,,,g De proposed license amendment to permit The Comunesion has provided . the 40.yw operating his does not oossatute standards fordetermining whethera Date ofapplicationforamendment: , ggagogy gy,,q, ,,,,gg,,,q,, ,, ,

significanthasards deterunnation exists April 27.19e9 and June 23.1989. d=haad in to CFR.Soeden' som for the ,

fouowing nessoner '

as stated in 10 Cf'R 50.92(c). A proposed Description ofamendmentrequest-The proposed amendment would extend a.%e proposed amendment does not amendment to an opMatmg k.ene b MMon dak d b @M@g involve a significantincreme m the involves no significant harards Ucense from December 11,2007 to coneideratione if operation of the facility March 21. 2012.

MOD M NW NMM previously evaluated, in accordat/ce with the proposed ^8'I*d d'8'*d**" *** 'd**'8'd "

amendment would not:(1)lavolve a Section103.cof the AtomicEnergy the only mechamem heving potannalimpact significant in*.rease in the probability or Act of1954 authorizes the issuance of on the probability of oocarrence of an

- consequences of an accident previously facility operating licenses for a period of accident previonely evaluated. Chansse In' up to 40 years. The current license term the population size and distribution were idennfied as the onlyparameterhevmg

x ..

4-x Fad ===I Regist:r '/ Vet M. No.142 / Wtdaesday. July 26. 1989 / Nottaes 31321 i - potentialinspect enpmeeus aamcluenons . ' Conserwahame hewe been acerposeted in staff proposes to snake a no sigmficant

~ concorsues the eenseousmoso af an accident the deessa. construcuan. and operations of previously evaluated. hazards consideration determmation.

Vermont Yankee. Fr rthermore, programa

~ . Conservatism heve beenincorporated. In have been developed and continue to be Loca/PublicDocumentRoom

the design, cometraction, and operations of implemented se amoure shot she isoliity is locatlom Brooks Memorial Library, 224 the Vennent Tenhoe feallHy.Forthennore, opasted se ent==d d try design andin Main Street Brstiloboro. Vermont 05301.

propens have beendeveloped and . accordanos with the Tashmes! Attameyforlscensee:R.K. Gad.III.

. 'est(11eastemte and mamtein Specifications. In partaceler, the in-Smios Esq Ropes and Grey,225 Franklin the service Ide of structores, syntems and Inspection /Teoting.Envuonmental ' Street. Boston. Massachusetts 02110.

comiponents; tz) ooedne tenha sal analyase Qualthention. and Mahnenance heerene NRCPmfeciDirector: Richard H.

for vectfying the adequacy of structures, assure that facility structurse. systems.and systems and components;and/or(3) allow Weseman ra=p===*= wm he ridustashed er replaced.

survonense wasamassee,andsnopectionof as appupdate. That is, sessedimos of the age NOTICE OFISSUANCE OF l the fasihty. Sodi programe essere that the -  : of the facihty, these proyams answe that Vermeest Yankee inesty wGl be operated me AMENDMENTTO FACILITY structuren, systems and omeponents are OPERA'I1NG IJCENSE latended by te design and the Technical refurbished and/orsoplaced to maintain -

Spectanations.Thatis,regardless of the age component functional capability and the During the panod since publication of of the overall facihty, these pmgreme mure merglas of safety required by the Technical the last aiweekly notsas, the that the stuustsee, ebensues. or semponents Specifications. No changes to these programs will b3 minddehed and/orreplaced to Comuniesien has issued the followmg -

are necessary for amourug that Vennost ' amendments. h em==ia=i= bas maintels amusensus desanomal espebmay Yankee wE ==et=== to perdenn as designed end the masses of amisty regelred by the determinedfor eachof these and in accordance with the T=rA=imi amentimanie that the application

- Technicat ap=camtions -

alesehmessets the ahese posgens am Specdications duung an =dda===l iour yurs complies with the standards and andabrussenesefepassesa Dendure.

nessesary for assuring that dense the there to ao passibusty that e shserent type of requiramanta af the AtomicEnergy Act ~

peepeesd esmondment ease. Wassent Yankee . accident is created, of 1954, as amended {the Act), and the -

. constuese as perimesasantanded by ate c. no propsued ====d===# dose not Commiasion's rules and regulations. The

^

design and Technical ^

~

lavolve a atenifasant seduction in a margin of Ca'n=imalm has made appropnale nerefore, the proposee amendment will aa'i ety. fmdings as requiredby the Act and the

. have no signe' cant tapaat on plant ser'ety. De natstas of enfetyidentified a the In 1933,voneset Ysides Neelear Power Commission's rules ard! regulations in 10 TechnicalspoetP. etions have been CFR Chapter 1 which are set forth in the Corporation conducted e study to update the incorparatedinto the faceity's desi8'.

populationagmes tendh the license amendment.

conemotion, and operaticos. With suspect to

' Envira===nens gepet and Final Safeb . opeastsame.suek mespne ase the beme for the Notice of Canaderation of issuance of -

Analysis Report and a paiset populations facility opmting and emagsmay peasden. Amendment to FacDity Operating enoughtheyearEng Asthereport a wellmthe WemmW Yamhee h4ervune License andPreposed Nonsignificant haanstes,ese praisenedpapelsten in the 30 W'1houng,h a Hazards Canalderation Dirtermination anGe eres ourner., ding 1beVermont Yenkee n iia =*'= and Assintemence programs. and OpporttmityforHearing in facihty is exposeed to summe anchanged De inspection, surveinance,and connection with these actions was daring thegesposed** tem.Dm snaintenanos requirements of these programe publishedtMbe FedeselRegisteres am asodenges toeleenholm mee assure ehet.segadieseaf es age of the beendentes,ahe homeno de population to the

• indicated.hio segmeet der a heenne er eenmalliascher ehe6-=*==alespebilitseeof pention for Asees to intereene was Aled saw i-u= T-Je pro 6estedas being structmee,ayatema and  : willbe anddieasemat population contar snaintained thmughout the liIs of the facmty fausewaiig Mistedes.-

is supected to remain mare than 11/3 times through refmhishment and/or replacement. Unless othemmise indmated.the the usersurt9veedle terw PoPalation Zone as appngehte.to musetthe 14chntual Commission has detenmned that these (IJ'Z) radius fuem thefeellley se segelmd bY . Specifloations.No ahmenos to enose piegrunns amendments satisfy the criteria for to CFR tetsglallII,assed en the reseite of are massesary as assure thatdanse the categorical exclusion in accordance this study,theaE.elseespeams tram naad==8Jemt peansand shme months of with 10 CFR 51.22. 'therefore, pursuant solosses duetoy==mdaa-d soonisate are operation. Vermont Yankee will continue to expected to samoin semil withh the heite set periens as latended by its design and the to 10 CPR 51.2s(b).no ermronmental impact statement or ermronmental forth in10 CFR. Pert 100. - TedhnicalSpecifications.

Sessume abase unlines be significest %erefore,the proposed amendment de assessment need be prepared for tbese idemges e to espelasian and me shetnbotion not veduas the seerpa of eefety se denned in amendments.If the Comminsion bas

,g,,,,gsg the plant.and Vennent Yankes the Technicalsp an==*== bases. Prepared an anytronmental ansessment Nuclear Power Corporation will continue to Comoisesen uderde specialtdrcumstances operate the plant in accordance with its Based onthe aboue esasehmenom we provisionin10 CFR 51.12(b)and has l

deelge and finnimmeal Speisheetame. she cemeund that the esammenen of Voimont made a determination based on that potentialradiologicoloenoegenmuse,of an Yankee's operating heemas in eenardance assessment. itis soinchcated.

assadent ;aseinseedremes with the proposed amend ===* willnot For furtherdetails with respect to the

- involve a signdicantincionesin the

%e propomodame=ame=t will not result ia probability or consequences of accidente action see(1) the applications for enincrossela thepsobability or the previouslycanaldered. nar treete the amendments.(2) the amendments, and consegmences of an socident previouslF poselhetydanearer Bfferent kind of (3) the Comunission's nineted letters' evelnated in the FSAR boosuse: (t) feeility ace 6drait, and wHI not teve6ee a signifuent S6ty BealmadonMor operations wE be meanneed in aconsdance reduction is a safety maryn.Therefore, we Envireamsental Anaessmenteas wtst die femmsere approved elesign and conclude that these is ao eqqmar==* hazards indicated. Allof these stems are

. TechnimelEr==d8'===== and(2)rh== pes to r .a ,=a associated with the proposed avallable for public inspection at the ihm ==r=1=e==amddstr6behen een==d=F amendment to the Vemment Yankee operating Commiaminn's Public Docenent . Room.

Vemment Yankesaosaspecsad to be license. the Gelman Beilding. 2120 L Street. NW.

negligible andwill actampact an the .g.he skib mviewed b homeee's Provacuely determined IJ'Z boundary. Washsngton. DC, and at the local public pr en t analysis and agrees with it. Therefore, document roorns fe: the particular b.

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