ML20140E126

Proposed Tech Specs Re Certified Fuel Handler

ML20140E126
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/30/1997
From:	CONNECTICUT YANKEE ATOMIC POWER CO.
To:
Shared Package
ML20140E119	List: CY-97-024, Application for Amend to License DPR-61,reflecting Staff Limitations & Requirements Appropriate to Present Configuration of Plant ML20140E126 ML20140E139 ML20140E157
References
NUDOCS 9706110250
Download: ML20140E126 (21)

Text

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6.0 ADMINISTRATIVE CONTROLS I

l 6.1 RESPONSIBILITY 6.1.1 The Executive Vice President and Chief Nuclear Officer shall be l l I responsible for overall facility operation and shall delegate, in writing, the

! succession to this responsibility during his absence.

f 6.2 ORGANIZATION l

6.2.1 ONSITE AND OFFSITE ORGANIZATIONS Onsite and offsite organizations shall be established for unit operation and l, corporate management, respectively. The onsite and offsite organizations shall include the positions for' activities affecting the safety of the nuclear power plant. ,

a. Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through t intermediate levels to and including all operating organization  ;

. positions. These relationships shall be documented and up~ dated-as appropriate, in the form of organization charts, functional ,

descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the Quality Assurance Topical Report. ,

b. The Unit Director shall be responsible for overall unit safe l .

operation and shall have control over those onsite activities j l necessary for safe operation and maintenance of the plant. l

c. The Executive Vice President and Chief Nuclear Officer, shall have corporate responsibility for overall plant nuclear safety and shall l tste any measures needed to ensure acceptable performance of the stdf in operating, maintaining, and providing technical support to l fM plant to ensure nuclear safety.

d. The individuals who train the :;:r: tin;; :t:ff N.those -- who carry l

! out health physics and quality assurance functions may report to ,

n the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.  !

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ertified Fuel Handlers and thduipment Operators g5E6.2.2 FACILITY STAFF ~

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4n. Each on-duty shift shall be composed of at least the minimum shift Rg a.

oo crew composition shown in Table 6.2-1; .

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y, feel it in the r rt:r. I: dditt::, dil; th: f::ility i: in g

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• ( -NQDE.1, 2, 3 Or 1, :t 1:::t ::: li;;r.;:1 0;r,1;r Operater :h:11 L:

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At least one person qualified to stand watch in the control room (a Certified Fuel -

Handler or an Equipment Operator) shall be present in the control room when irradiated fuelis in the spent fuell poo/;

HADOAM NECK .

6-1 Amendment No. JJJ, JJJ Jpp. 191 0410

-T - ---- _ _ . - _ _ _ _ _ _ . - . - - +--- e ,.-,-r+ - -. r

during fuel hindiing op5 rations / 3 FEBRUARY 1, 1995 ADMINISTRATIVE CONTROLS ,

c. An individual qualified in radiation protection procedures

• shall N

(1 j be on site 2 .n f=1 i: in the re::ter; N

d. All CGRE Ai.TERATICNS shall be observed and directly supervised by c licen::d I:ni;r Op;r:t:r ;r licen::d 5:nier Oper:t:r s (g.R either :

Uc.ited t: Nel ll:rdling who has no other concurrent T /

P responsibilities during this operation; )

e. DELETED httifiebHand k'g f.

Administrative procedures shall be developed and implemented to f .c limit the working hours of facility staff who perform 3  ::fet; rel:t:d f=tica:. These procedures should follow the W general guidance of the NRC Policy Statement on working hours (Generic Letter No. 82-12).

• The individual qualified in radiation protection procedures may be less ]

than the minimum requirements 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, provided immediate1 action is taken to fill the required position.

functions important to the safe stora e and handlin of irradiated fuel.

(gg iA9 Amendment No. JJE, J S , 179 6-2 HADDAM NECK 0153

'n9/25/92 TABLE 6.2-1 MINIMUM SHIFT CREW COMPOSITION 2

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.< _.4 POSITION NUMBER OF INDIVIDUALS RE0VIRED TO FILL POSITION MODE 1. 2. 3. or 4 MODE 5 or 6 '

. 4 evr mn ,a nvr . .

nur STA 1* None Certified Fuel Handler 1*

Equipment Operator 1 Abbreviations:

SOP - Licensed Senier "e:cter Oper;ter f naa n.. i.,.._.__.._2..n........n___....

AGP - Additi;n:1 0;;r ter ,

STA -

Shift Technica1 Advisor The shift crew 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 on-duty shift crew members provided ,

immediate action is taken to restore the shift crew composition te within  ;

the minimum requirements of Table 6.2-1. This provision does not permit any gx shift crew position to be unmanned upon shift change due to an oncoming (7434 shift crewman being late or absent.

0; ring :ny :b::::e-ef the Shift Sep:rvi:Or free the ::: trol r:er while th:

unit i; in M0001, 2, 3, er 4, : individ :1 ( ther th: th: Shift T::hni::1 Advi: r) with : v: lid Seri:r 0;;r:ter li::::: :h:115: d::ign:ted t: ::::::

the re-trel ree= cc-- -d fenttier. Durin; : y aberne ef the Shift

'Supervi cr fre.T. the ;ntr:1 r;;: whil; th: ; nit i; in MODE 5 or 5, :n j ir.divid;;l with : v: lid S::i:r 0;;r:ter li::::: Or 0;:r:t:r li::::: :h:11 50  ;

d::ign:t:d t: :::r-- the :::trel re:r ::::::d ft:: tion.

r-3>* The STA position can be filled by either of the two Senior Reactor Operators (a dual-role individual), if he meets the requirements of Specification 6.3.1.2.1.

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• Does not include the Certified Fuel handler Supervising fuel handling operations.

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6-3 Amendment No. JJE,155 HADDAM NECK - -

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ADMINISTRATIVE CONTROLS l

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f. Successful completion of the Thames Valley State Technical College associate's degree in Nuclear Engineering Technology program, provided that the individual was enrolled in the i

, program by October 1, 1987.

2. Dedicated STA: Must meet the STA training criteria of NUREG-0737, i Item I.A.I.1, and have received specific training in plant design, g '

! and response and analysis of the plant for transients and - .c

'* i accidents. g  !

l 6.4 TRAINING LJnit Director)

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hA retraining and replacement training program for the facility staff shall be I l

maintained under the direction of the 1:1::r "r.it Cir;;tcr and shall meet or e exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 2 l and 10CFR55.59. The Dir::t:r "":1::r Tr:1-5;; has the overall responsibility J .

for the implementation of the* Training Program. sE  !

6.5 REVIEW AND AUDIT o m e

l 6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (POR Q E e I l oS FUNCTION E$  !

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, 6.5.1.1 The PORC shall function to advise the Unit Director on all. matters i l '

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related to nuclear safety. o.$

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COMPOSITION I

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6.5.1.2 The PORC shall be composed of at least eleven members. Members ~c shall collectively have experience and expertise in the following areas: gg E @- ,

Plant Operations 8 :i5 )

Engineering .s y Reactor Engineering @~ l Mechanical Maintenance Electrical Maintenance yg ec Instrumentation and Controls ",3 c

Health Physics .E 3 Work Planning and Control EE Quality Services $

Security L EEL '$

Chemistry y The minimum qualifications of PORC members shall be that all members have an  !

academic degree in an engineering or physical science field, or hold a sanagement position, and have a minimum of five years technical experience in I their respective field of expertise. The members of PORC shall be appuinted

! in writing by the Unit Director, who is the PORC Chairperson. The alternate l l Chairpersons of the PORC shall be drawn from the PORC members and be appointed in writing by the Unit Director.

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l HADDAM NECK 6-5 Amendment No. JJJ.JJJ,JJJ,JJJ.

e4n J/J. JJJ, 191

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ADMINISTRATIVE CONTROLS

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a. The applicable procedures recommended in Appendix A of Regulatory i Guide 1.33, Revision 2, February 1978; i

b. The requirements and recommendations of Sections 5.1 and 5.3 of ANSI N 18.7-1976.

c. Fire Protection Program implementation.

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d. Quality controls for effluent monitoring, using the guidance in Regult. tory Guide 1.21 Rev. 1, June 1974.

e. RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE CALCULATION MANUAL (REMODCM) implementation except for Section I.E, Radiological Environmental Monitoring. l

f. PROCESS CONTROL PROGRAM implementation. ,

l 6.8.2 Each procedure of Specification 6.8.1, and changes thereto, shall be reviewed by the PORC and shall be approved by the. Unit. Director prior to implementation and reviewed periodically as set forth in each document or in administrative procedures.

6.8.3 Temporary changes to procedures of Specification 6.8.1 may be made provided:

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a. The intent of the original procedure is not altered; l

b. The change is approved by te: ::dcr: ef the plant m: nag: rent i i

7-st #f, :t le::t =: Of th:: held: : S :icr Op;r:t:r if:=:: = the

=it :ffectedt and

c. j Thechangeisdocumented,reviewedbythePORCandapprovedbythe,l Unit Director within 14 days of implementation. l 6.8.4 Written procedures shall be established, implemented and maintained covering Section I.E., Radiological Environmental Monitoring, of the REMODCM.

6.8.5 All procedures and procedure changes required for the Radiological Environmental Monitoring Program of Specification 6.8.4 above shall be reviewed by an individual (other than the author) from the Radiological i Assessment Branch or the Production Operation Services Laboratory (POSL) and i i

approved by appropriate supervision.

Temporary changes may be made provided the intent of the original procedure ,

is not altered and the change is documented and reviewed by an individual (other l than the author) from the Radiological Assessment Branch or the POSL, within 14 days of implementation.

a member of the pla anagement staff and a Certified Fuel _

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HADDAM NECK 6-12 Amendment No. JJJ, JJJ JJJ.191 0411

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l Qocket No. 50-213-CY-97-024 1

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I Attachment 2 l

l Haddam Neck Plant l Proposed Revision To The Technical Specifications  !

l Certified Fuel Handler l .- Retyped Pages l

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l May 1997 ,

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i 6.0 ADMINISTRATIVE CONTR0LS i

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!' i d _ RESPONSIBILITY l

2 6.1.1 The designated CYAPC0 corporate officer shall be responsible for l

overall facility operation and shall delegate, in writing, the succession to j this responsibility during his absence.

6.2 ORGANIZATI_03 i

j 6.2.1 ONSITE AND OFFSITE ORGANIZATIONS j Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safety of the

nuclear power plant.

I a. Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization

.i positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the Connecticut Yankee Quality Assurance Program (CYQAP). l

b. An individual management position in the onsite organization shall l be responsible for overall unit safe operation and shall have control over those onsite activities and resources necessary for i safe operation and maintenance of the plant.

c. The. designated CYAPC0 corporate officer shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

d. The individuals who train the Certified Fuel Handlers and the Equipment Operators and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.

6.2.2 FACILITY STAFF

a. Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1;

b. At least one person qualified to stand watch in the control room (a Certified Fuel Handler or an Equipment Operator) shall be present in the control room when irradiated fuel is in the spent fuel pool; HADDAM NECK 6-1 Amendment No. JJ), JJJ, JJ), J7J.

0432

ADMINISTRATIVE CONTROLS 1 l

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c. An individual qualified in radiation protection procedures

• shall i be on site during fuel handling operations; l 1

d. All fuel handling operations shall be observed and directly supervised by a Certified fuel Handler who has no other concurrent responsibilities during this operation;

e. DELETED

f. Administrative procedures shall be developed and implemented to limit the working hours of facility staff who perform functions important to the safe storage and handling of irradiated fuel. l These procedures should follow the general guidance of.the NRC Policy Statement on working hours (Generic Letter No. 82-12). {

The individual qualified in radiation protection procedures may be less i than the minimum requirements for a period of time not to exceed J 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, provided immediate action is taken to fill the required position.

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HADDAM NECK 6-2 Amendment No. JJJ, JJJ, J/J, 0432

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l TABLE 6.2-1 MINIMUM SHIFT CREW COMPOSITION l

l POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION Certified Fuel Handler 1*

Equipment Operator 1 The shift crew composition may be or,e 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 on-duty shift crew members provided immediate action is taken to restore the shift crew 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.

Does not include the Certified Fuel Handler supervising fuel handling operations.

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HADDAN NECK 6-3 Amendment No. J7J. JJJ.

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I ADMINISTRATIVE CONTROLS  ;

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t 6.4 TRAINING A retraining and replacement training program for the Certified Fuel Handlers l shall be maintained under the direction of the Unit Director. A retraining 3 and replacement training program for the facility staff shall be maintained '

under the direction of the Unit Director and shall meet or exceed the l l requirements and recommendations of Section 5.5 of ANSI N18.1-1971. The Unit  :

i Director has the overall responsibility for the implementation of the Training  ;

Program. l l 6.5 REVIEW AND AUDIT 6.5.1 PLANT OPERATIONS REVIEW COMITTEE (PORC) l FUNCTION 6.5.1.1 The PORC shall function to advise the Unit Director on all matters related to nuclear safety.

COPIPOSITION i

I 6.5.1.2 The PORC shall be composed of at least seven members. Members shall l l collectively have experience and expertise in the following areas:

Plant Operations, l Decommissioning,*

Engineering, Maintenance, Health Physics, Chemistry / Radiochemistry, Quality Assurance, and Security.*

The minimum qualifications of PORC members shall be that all members have an academic degree in an engineering or physical science field, or hold a 1

management position, and have a minimum of five years technical experience in their respective field of expertise. The members of PORC shall be appointed in writing by the Unit Director, who is the PORC Chairperson. The alternate Chairpersons of the PORC shall be drawn from the PORC members and be appointed in writing by the Unit Director.  ;

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• These areas are exempt from the 5-year experience yequirement.

HADDAN NECK 6-5 Amendment No. JJJ,JJJ JJJ.JJJ.

un II),179,171,

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l ADNINISTRATIVE CONTROLS l l

l a. The applicable procedures recommended in Appendix A of Regulatory ,

l Guide 1.33, Revision 2, February 1978;

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b. The requirements and recommendations of Sections 5.1 and 5.3 of ANSI N 18.7-1976.

c. Fire Protection Program implementation.

, d. Quality controls for effluent monitoring, using the guidance in

! Regulatory Guide 1.21 Rev.1, June 1974.

e. RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE CALCULATION l MANUAL (REMODCM) implementation except for Section I.E, i Radiological Environmental Monitoring.

f. Process Control Program implementation, j 6.8.2 Each procedure of Specification 6.8.1, and changes thereto, shall be reviewed by the PORC and shall be approved by the Unit Director prior to

, implementation and reviewed periodically as set forth in each document or in administrative procedures.

6.8.3 Temporary changes to procedures of Specification 6.8.1 may be made .

provided:

a. The intent of the original procedure is not altered; .

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b. The change is approved by a member of the plant management staff and a Certified Fuel Handler; and  ;

c. The change is documented, reviewed by the PORC and approved by the I Unit Director within 14 days of implementation. )

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! 6.8.4 Written procedures shall be established, implemented and maintained i covering Section I.E., Radiological Environmental Monitoring, of the REMODCM.

l 6.8.5 All procedures and procedure changes required for the Radiological l Environmental Monitoring Program of Specification 6.8.4 above shall be 1 reviewed by an individual (other than the author) from the Radiological )

Assessment Branch or the Production Operation Services Laboratory (POSL) and l approved by appropriate supervision.

Temporary changes may be made provided the intent of the original procedure is not altered and the change is documented and reviewed by an individual (other than the author) from the Radiological Assessment Branch'or the POSL, j within 14 days of implementation.

HADDAN NECK 6-12 Amendment No. JJ), JJJ, JJJ. JJJ.

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Docket No. 50-213 CY-97-024 l

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l Attachment 3 Haddam Neck Plant Proposed Revision To The Technical Specifications l

Certified Fuel Handler Description Of Changes l

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I~ May 1997

U. S. Nucl::ar R:gulatory Commission CY-97-024/ Attachment 3/Page 1 GENERAL The change descriptions describe herein reflect changes to the Technical Specification presently in effect and not to any other proposed Technical Specification revisions presently under review by the NRC Stati.

6.0 ADMINISTRATIVE CONTROLS Changes 6.2. ORGANIZATION in Subsection 6.2.1.d, change " operating staff" to " Certified Fuel Handlers and the Equipment Operators" In Subsection 6.2.2.b, replace "At least . . control room;" with "At least one person qualified to stand watch in the control room (a Certified Fuel Handler or an 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."

TABLE 6.2-1 MINIMUM SHIFT CREW COMPOSITION Below the " POSITION" and " NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION" headers and above the " MODE 1,2,3, or 4" and the " MODE 5 or 6" headers, insert two rows, the first row stating:

" Certified Fuel Handler 1*" and the second row stating: " Equipment Operator 1" Under the " MODE 1,2,3, or 4" and the " MODE 5 or 6" headers, delete the SOP, ROP, and AOP rows. In the STA row change "1*" to "1**" Under the " Abbreviations" grouping, delete the SOP, ROP, and AOP rows. Delete the 2nd paragraph" The existing footnote, "* The STA . Specification 6.3.1.2.1." becomes the second footnote by addition of an additional asterisk ("*"). The new first footnote states: "* Does not include the Certified Fuel Handler supervising fuel handling operations."

U. S. Nuclear Regulatory Commission CY-97-024/ Attachment 3/Page 2 l

6.4 TRAINING l

l. Insert the following new sentence at the beginning of the paragraph:

"A retraining and replacament training program for the Certified Fuel l

Handlers shall be maintained under.the direction of the Unit Director."

Change " Nuclear Unit Director" to " Unit Director". Delete "and i 10CFR55.59". Change " Director-Nuclear Training" to " Unit Director". I 6.8 PROCEDURES AND PROGRAMS

, in Subsection 6.8.3 b, change "two members of the plant rnanagement

( staff, 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 Handier "

l Reasons and Basis l

l The changes reflect the limitations and requirements appropriate to the present configuration of the plant. The primary reason for this change is to include in the Technical Specifications the requirements pertaining to the Certified Fuel Handler position and the requirements pertaining to the revised crew staffing.

The change of title from " Nuclear Unit Director" to " Unit Director" reflects the new organization titles. In addition, the Unit Director will now have the overall l l

responsibility for the Training Program since the emphasis is on a defueled facility rather than an operating plant.

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Rocket Nos._50-213 CY-97-024 L

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l-Attachment 4 Haddam Neck Plant Proposed Revision To The Technical Specifications Certified Fuel Handler l

Safety Assessment And No Significant Hazards Consideration j I

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l U. S. Nuclear R@gulatory Commission i CY-97-024/ Attachment 4/Page 1  !

l Haddam Neck Plant Proposed Revision To The Technical Specifications Certified Fuel Handler Safety Assessment And No Significant Hazards Consideration I 1

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l Safety Aanessment I l

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t. The Haddam Neck Plant (HNP) has permanently ceased operations, the reactor has

( been permanently defueled, and the spent fuel stored in the spent fuel pool.

With the irradiated fuel and other radioactive components now stored in the spent fuel pool, qualified personnel will still be needed to safely monitor and maintain the spent l fuel pool and its associated support structures, systems, and components (SSCs).

! These SSCs include: pool temperature and water level instrumentation, equipment, and controls; HVAC; power sources; make-up water sources; radiation monitoring sensors and readouts; and fuel handling equipment in the spent fuel building. There also l remains a need for future handling of the irradiated fuel and other radioactive components now stored in the spent fuel pool.

The duties of the shift staff are greatly reduced due to the permanent shutdown of all l the power producing and other safety-related SSCs directly pertinent to reactor l operations. In the defueled condition, only the SSCs related to the spent fuel pool

! would be of concern to the shift staff. The reaction time required of the operating staff 1 to restore decay heat removal to the spent fuel pool is on the order of days. Therefore, the minimum shift staff of two is adequate.

I The proposed changes to Technical Specification Sections 1.3,6.2.1.d,6.2.2 and 6.4 1 and Technical Specification Table 6.2-1 deal w;th the requirements of the Certified Fuel Handler and the Equipment Operator positions. J The Certified Fuel Handler position replaces the licensed Senior Reactor Operator and licensed Reactor Operator positions. The qualification, staffing and training requirements of the Certified Fuel Handler position are appropriate to the present configuration of the HNP. Presently, personnel who will assume the position of Certified Fuel Handler are either previously licensed Senior Reactor Operators or previously licensed Reactor Operators at the HNP. Future candidates for the Certified Fuel Handler position who do not have this experience, will undergo the formal training program described in Attachment 5.

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l U. S. Nucl ar Regulatory Commission CY-97-024/ Attachment 4/Page 2 The Equipment Operator position combines elements of the licensed Reactor Operation position and the non-licensed Nuclear Systems Operator position. Presently, personnel who will assume the position of Equipment Operator are either previously licensed Senior Reactor Operators, previously licensed Reactor Operators or Nuclear Systems Operators at the HNP. Future candidates for the Equipment Operator position who do .

not have this experience, will undergo a formal training program which has its origins in the current NRC Licensed Operator and the current Nuclear Systems Operator training programs.

Future changes to either the Certified Fuel Handler Program or the Equipment Operator l Program will be made, as appropriate, to reflect the plant condition during the 1 l

decommissioning process. Therefore, based on the above discussions, the present plant condition and the necessary qualifications and training for Certified Fuel Handlers i and Equipment Operators, these proposed changes to Technical Specifications do not diminish the level of protection of the public health and safety.

Sjgnificant Hazards Consideration l

CYAPCO has reviewed the proposed changes to the Technical Specifications in accordance with 10CFR50.92 and concluded that the changes do not involve a significant hazards consideration (SHC). The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed changes do not involve an SHC because the changes would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed qualification, staffing and training requirements are appropriate for l

the present plant conditions.

The plant has permanently ceased operations, the reactor has been permanently defueled, and the spent fuel stored in the spent fuel pool.

Because the present plant conditions, many of the postuisted accidents previously evaluated (i.e., LOCA, MSLB, etc.) are no longer possible. The accidents previously evaluated that are still applicable to the plant are fuel handling accidents and gaseous and liquid radioactive releases.

These is no significant increase in the probability of a fuel handling accident since

[ refueling operations have ceased. In fact, there ~is more likely a decrease in

probability of a fuel handling accident since the need to move / rearrange fuel assemblies is minimal until they are removed from the spent fuel pool (i.e., for

dry cask storage or for transferring to USDOE possession).

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1 U. S. Nucl:ar R:gulatory Commission CY-97-024/ Attachment 4/Page 3 l There is no significant increase in the consequences of a fuel handling accident since the accident scenarios assume an assembly with significant amounts of I

radioactive iodine or noble gas. The plant was shutdown on July 22,1996.

l Except for 1-125 (half-life ~59.5 days),1-129 (half-life ~1.6E7 years), and Kr-85 l l (half-l;fe ~10.8 years), the spent fuel inventory of the dose-contributing l radioactive iodine and noble gas isotopes has decayed more than 20 half-lives l since shutdown (i.e., less than 0.0001% of the original amount remains). In

addition, the definition for " Dose Equivalent 1-131" (" Standard Technical  ;

l Specifications, Westinghouse Plan!t.' NUREG-1431) does not include I-125 and l l l-129 in the dose assessment due to their negligible spent fuelinventory. Except l l for Kr-85, the other noble gas nuclides that contribute to a whole body dose have <

l also decayed to a negligible amount. CYAPCO has performed fuel handling and I cask drop accident dose calculations which conclude that doses (i.e., whole body and thysoid) at the Exclusion Area Boundary and the Low Population Zone are a small fraction of the 10CFR100 dose limits. In fact, due to this decreased radioactive inventory, there is a significant decrease in the consequences of a fuel handling accident.

The radiological consequences of a gaseous or liquid radioactive release are bounded by the fuel handling accident. With the plant defueled and permanently shutdown, the demands on the radwaste systems are lessened since no new radioisotopes are being generated by irradiation. Therefore, there is no increase in the consequences of a gaseous or liquid radioactive release.

Based on the above, the proposed changes to the Technical Specifications do not involve a significant increase in the probability or concequences of an accident previously evaluated.

2. Cmate the possibility of a new or different kind of accident from any accident previous!y evaluated.

There is no change in how spent fuel is stored or moved in the spent fuel pool.

Therefore, the postulated fuel handling accidents are still bounding and are still considered as credible posiulated accidents.

Based on the above, the proposed changes to the Technical Specifications do

! not create the possibility of a new or different kind of accident from any accident previously evaluated.

U. S. Nucl ar R:gulatory Commission

! CY-97-024/ Attachment 4/Page 4 l

3. Involve a significant reduction in a margin of safety.

There is no change in how spent fuel is stored or moved in the spent fuel pool l The plant was shutdown on July 22,1996. Exept for 1-125 (half-life

~59.5 days),1-129 (half-life ~1.6E7 years), and Kr-85 (half-life ~10.8 years), the spent fuel inventory of the dose-contributing radioactive iodine and noble gas  :

. isotopes has decayed more than 20 half-lives since shutdown (i.e., less than I 0.0001% of the original amnunt remains). In addition, the definition for " Dose Equivalent 1-131" (" Standard Technical Specifications, Westinghouse Plants," l l

NUREG-1431) does not include I-125 and 1-129 in the dose assessment due to their negligible spent fuel inventory. Except for Kr-85, the other noble gas nuclides that contribute to a whole body dose have also decayed to a negligible amount. CYAPCO has performed fuel handling and cask drop accident dose l calculations which conclude that doses (i.e., whole body and thyroid) at the i Exclusion Area Boundary and the Low Population Zone are a small fraction of the 10CFR100 dose limits.

Therefore, there is no significant reduction the margin vf safety. In fact, due to this decreased radioactive iodine inventory, there is more likely an increase in I the margin of safety.

Based on the above, the proposed changes to the Technical Specificsions do i not involve a significant reduction in a margin of safety, i

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Docket Nos. 50-213 l CY-97-024 i

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! Attachment 5 Haddam Neck Plant l Proposed Revision To The Technical Specifications I

Certified Fuel Handler

Proposed Certified Fuel Handler Training Program i

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i l May 1997 l

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i l U. S. Nucl:ar Regulatory Commission CY-97-024/ Attachment 5/Page 1 LIST OF ENCLOSURES

1. Connecticut Yankee Certified Fuel Handler Initial Certification Training Program implementing Procedure

2. Connecticut Yankee Certified Fuel Handler Initial Certification Training Program i Description '

3. Connecticut Yankee Certified Fuel Handler Recertification Training Program l Implementing Procedure i

4. Connecticut Yankee Certified Fuel Handler Recertification Training Program Description l

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