ML20217K330

Safety Evaluation Supporting Amend 195 to License DPR-61

ML20217K330
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	10/19/1999
From:	NRC (Affiliation Not Assigned)
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ML20217K319	List: ML20217K316 ML20217K322 ML20217K330
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NUDOCS 9910260102
Download: ML20217K330 (51)

Text

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ftWE% l g 4 ' UNITED STATES.

s j ~. NUCLEAR REGULATORY COMMISSION )

? .2 WASHINGTON, D.C. 20066-0001 _I f

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.195 j CONNECTICUT YANKEE ATOMIC POWER COMPANY t

HADDAM NECK PLANT DOCKET NO. 50-213

1.0 INTRODUCTION

By letter dated June 3,1999, as supplemented by letter dated August 24,1999, the Connecticut Yankee Atomic Power Company (the licensee) submitted a proposed revision to the Haddam Neck Plant (HNP) Technical Specifications (TSs) and Operating License. The original letter proposed to relocate certain TS requirements to licensee-controlled documents, consistent with the guidance contained in NRC issued letters, NUREGs, and TS policy. In order to implement  ;

the relocation of limiting conditions for operation (LCOs) related to radioactive effluent controls,  !

administrative controls have been added for the control of radioactive effluents. The l administrative controls section of the TSs has been revised to more closely conform to l standardized TSs. A TS Bases Control Program has been added. The weight limit for loads carried over the spent fuel pool (SFP) has been increased. The proposed amendment deletes certain TSs that are either (1) no longer applicable to the permanently shutdown and defueled j state of the reactor, or (2) duplicate regulatory requirements, or (3) duplicate information i located in the Updated Final Safety Analysis Report. A number of editorial changes were made

' to clarify the language used, to correct typographical errors, to renumber the listings, to remove section numbers that no longer contain requirements,' and to renumber the pages in the TSs.

The licensee's June 3,1999, letter committed to implementing the relocation of certain TS  ;

requirements concurrent with implementation of the license amendment. The August 24,1999, supplement corrected typographical errors in and provided additional clarification of the original amendment request. It did not change the staff's initial proposed no significant hazards consideration determination or extend the scope of the original notice.

2.0 BACKGROUND

~ Section 182a of the Atdmic Energy Act of 1954, as amended (the Act), requires applicants for nuclear power plant operating licenses to state the TSs to be included as part of the license.

The Commission's regulatory requirements related to the content of the TSs are set forth in '

Section 50.36 of Title 10 of the Code of FederalRegulations (10 CFR). That regulation requires the TSs to include items in five specific categories: (1) safety limits, limiting system

. settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TSs.

The four criteria defined in 10 CFR 50.36 to be used in determining whether a particular matter is required to be included in the TSs as an LCO are as follows:

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- (1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a

< challenge to the integrity of a fission product barrier;  ;

l (3) a structure, system,'or component that is part of the primary success path and which .

functions or actuates to mitigate a design-basis accident or transient that either assumes I the failure of or presents a challenge to the integrity of a fission product barrier; and 1 (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

As a result, existing LCOs that fall within or satisfy any of the criteria in the regulation must be retained in the TSs, while those LCOs that do not fall within or satisfy these criteria may be i relocated to other licensee-controlled documents, such as the Technical Requirements Manual

. (TRM) and Radioactive Effluent Monitoring and.Offsite Dose Calculation Manual (REMODCM).

Addressing administrative controls corresponding to Section 6 of the licensee's TSs, l

10 CFR 50;N states that they."are the provisions relating to organization and management,  ;

procedures, reed keeping, review and audit, and reporting necessary to assure operation of l the facility in a safe manner." The specific content of the administrative controls section of the j TSs is therefore that information that the Commission deems essential for the safe operation of i l the facility that is not already adequately covered by other regulations. Accordingly, the staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(5) 1 and that are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety can be removed from ,

administrative controls. Existing TS requirements, therefore, may be relocated to more i

. appropriate documents (e.g. Security Plan, Quality Assurance (QA) Plan, and Emergency Plan) and controlled by the applicable regulatory requirement. Similarly, while the required content of -

"TS administrative controls is specified in 10 CFR 50.36(c)(5), particular details of administrative ,

controls may be relocated to licensee-controlled documents where 10 CFR 50.54,

'10 CFR 50.59, or other regulations provide adequate regu!atory control.

The staff relied on the standard TSs (STS) coatained in NUREG-1431, " Standard Technical Specifications _ Westinghouse Plants," and NUREG-1625, " Proposed Standard Technical i Specifications for Permanently Defueled Westinghouse Plants," for portions of its review. The l

NUREGs were primarily used to assess the acceptability of changes proposed to conform to

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STS.

-3.0 ORGANIZATION OF THE SAFETY EVALUATION (SE)

The licensee proposed additions to and deletions from its TSs, as well as certain changes in its existing TSs. In order to distinguish between the TSs as they exist before and after the

. amendment, the current TSs will be referred to as " CTS" and the amended TSs will be referred to as "ATS."'

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i Section 4.0 of the SE summarizes the proposed changes and sorts them into the following

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1. Relocation of TS Requirements to the TRM

2. Relocation of TS Requirements to the 'REMODCM

3. Relocation of TS Requirements to the Quality Assurance Program (QAP)

4. Changes for Consistency with Standardized TS

5. SFP Load Limit

6. Changes to License Conditions ,

7. TS Deleted Due to Permanent Shutdown and Defueling

8. TS that Duplicate Regulatory Requirements

9. TS that Duplicate Information in the Updated Final Safety Analysis Report  !

(UFSAR)

10. Editorial Changes and Corrections Section 5.0 of the SE is divided into subsections corresponding to the categories listed above in order to discuss and evaluate the proposed changes. To the extent possible, TS changcs are listed in order by TS number within each category. Specific changes are identified in Section 5.0. Each TS is listed in only one category, even though a TS may contain multiple changes that logically fit into more than one category. This primarily affects editorial changes and corrections. As a result, only those editorial changes and corrections that are not ,

discussed in conjunction viith a more substantial change category are discussed in the editorial l changes and corrections category. In general, each TS change listed in a subsection of the SE is acceptable for the sarae reasons; therefore, formal acceptance of the changes is listed at the i end of each subsectic.1. In some cases, where the reason (s) for a TS change does not fit the general category under which it is discussed, additional justification for the changes is made under the relevant TS listing.

Section 6.0 documents the consultation with the State of Connecticut.

Section 7.0 discusses environmental considerations.

Section 8.0 identifies the conclusion of the SE.

Attachment 1 contains a cross listing of CTS and ATS section numbers arranged in CTS order.

Each CTS is briefly described (by title or with the beginning few words of the requirement) and the ATS section, which corresponds to the CTS, is identified. In many cases, there is no corresponding ATS section. In some cases, an ATS section is added that has no corresponding CTS precursor. Where applicable, licensee commitments to relocate TS requirements to a licensee-controlled document are noted. The SE section that discusses each change is noted. In order to more clearly illustrate the changes from the CTS to ATS, the cross listing includes CTS section numbers that contain no requirements due to deletion in a previous license amendment, but were retained in the CTS as place holders. The ATS remove the place holders from the body of the requirements; however, the Index continues to list deleted section numbers for ATS Section 3/4.

Attachment 2 contains a listing of the ATS in ATS order and the CTS, if any, that were their precursors.

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Due to the combination and splitting of some CTS requirements in the ATS, some TS requirement sections may appear more than once in the listings.

4.0

SUMMARY

OF PROPOSED CHANGES j Relocation of TS Reauirements to the TRM 1

This request applies to meteorologicalinstrumentation and sealed source contamination. The l licensee proposes to. relocate these requirements verbatim to its TRM. The licensee proposes I deleting the requirements for charcoal filters in the fuel storage building air cleanup system l (FSBACS). The requirements for FSBACS operability and high-efficiency particulate air filter surveillance will be relocated to the TRM.

Relocation of TS Reauirements to the REMODCM j This request applies to radioactive effluent monitoring instrumentation and radioactive effluents.

The licensee proposes to relocate these requirements to its REMODCM. In order to provide

, programmatic control of effluent releases in the TSs, the licensee proposes to add a new ATS 6.6.4. 1 Relocation of TS Reauirements to the OAP This request applies to administrative controls for review, audit, and record retention requirements. The licensee proposes to relocate these requirements to its OAP. i Chances to Administrative Controls for Consistency with Standardized TS This request applies to administrative controls that describe responsibility, organization, staff qualifications, training, procedures and programs, radiation protection, and the REMODCM.

The licensee proposes a revision of these requirements to be consistent with standard TS and its organizational structure. The ATS are renumbered to eliminate section numbers that do not contain any requirements. A new TS bases control program is added.

SFP Load Limit j This request applies to TS 3/4.9.7. The licensee proposes an increase in the load limit from i 1650 to 1800 pounds for loads carried over the spent fuel racks.

Chances to License Conditions This request applies to current license conditions C(6)(a) and (b), which pertain to the Integrated implementation Schedule Program for plant modifications. The licensee proposes

deleting these conditions. The request also applies to license condition D, which lists the license expiration date. The licensee proposes revising this requirement to be consistent with 10 CFR 50.51(b). -The licensee proposes to renumber license condition C(7) to C(6).

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-5 TSs Deleted Due to Permanent Shutdown and Defuelina This request applies to requirements for refueling operations. The licensee proposes deleting these requirements.

TSs Which Duplicate Reaulatory Reauirements j This request applies to certain reports specified by the CTS. The licensee proposes deleting the requirements.

TSs Which Duplicate information in the UFSAR I l

This request applies to CTS that describe and illustrate the site boundary, exclusion area, and j meteorological tower location. The licensee proposes deleting the majority of this information j from TSs. I Editorial Chances and Corrections i I

The CTS contain a number of place holder sections that do not contain any requirements. The l licensee proposes to eliminate them. However, the Index listing of TS Section 3/4 will retain the listing of deleted requirements. A number of editorial wording changes are proposed, as well as correction of typographical errors. The licensee proposes extensive renumbering and .

repagination of the remaining ATS.

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5.0 DISCUSSION AND EVALUATION 5.1 RELOCATION OF TS REQUIREMENTS TO THE TRM CTS 1.4. Channel Calibration CTS 1.5. Channel Check These CTS are definitions. Due to the relocation of requirements to licensee-controlled documents, the terms are no longer used in the TSs. They will be relocated to the TRM and the REMODCM.

CTS 3/4.3.3.4. Meteoroloaical Instrumentation (and associated tables)

The licensee proposes to relocate the following requirements to its TRM and delete them from the CTS:

CTS 3/4.3.3.4 Meteorological Instrumentation CTS Table 3.3-6 Meteorological Monitoring Instrumentation CTS Table 4.3-5 Meteorological Monitoring Instrumentation Surveillance Requirements These CTS require meteorological instrumentation to be operable, specify that a Special Report

! be submitted to the Commission if the number of operable channels does not meet the j minimum requirement, specify the required number of operable channels for meteorological 1 instrumentation, and specify the channel check and channel calibration frequencies for

! meteorological instrumentation.

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t CTS 3/4.7.5. Sealed Source Contamination Specifications for sealed source contamination are relocated to the TRM and deleted from the CTS. Each sealed source containing radioactive materialin excess of 100 microcuries of beta and/or gamma emitting material or 5 microcuries of alpha emitting materialis required to be 1 free of removable contamination greater than or equal to 0.005 microcuries. l l

CTS 3/4.9.12. Fuel Storaae Buildino Air Cleanuo System A. The licensee proposes deleting the following requirements pertaining to the charcoal filters in the fuel storage building from its TS: ,

1 CTS 4.9.12.a.2 Verifying.... carbon sample...

CTS 4.9.12.b After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation...

CTS 4.9.12.e After each complete... replacement of a charcoal..

This LCO required the fuel storage building air cleanup system (FSBACS) to be operating during movement of fuel within the storage pool or crane operation with loads over the SFP.

The basis for the restriction was to ensure that the iodine removal capability of the system, which was provided by the charcoal filters, was consistent with the assumptions of the safety analysis for a dropped fuel assembly.

The decay time since the fuel was last irradiated now exceeds 30 months. As a result, the remaining iodine inventory available for release has decreased to negligible levels. The analysis of the fuel handling accident in the defueled condition is presented in UFSAR Section 15.5.2.2 and Table 15.5-7. The analysis assumes no iodine filtration in the SFP water and none from the FSBACS. The offsite dose consequences of an unfiltered release are a small fraction of the reference values in 10 CFR Part 100, and less than the Environmental Protection Agency Protective Action Guides. Therefore, the FSBACS requirements to maintain the charcoal filters are no longer necessary.

B. The licensee proposes deleting the following requirements since they are no longer applicable:

CTS 3.9.12.b The provisions of Specification 3.0.3..

CTS 3.9.12 Footnote The above...does not apply... movement of fuel storage racks...

Specification 3.0.3 is a place holder only and contains no requirements. Therefore, CTS 3.9.12.b is no longer required.

The footnote to CTS 3.9.12 was created to allow installation of new spent fuel storage racks, l and was limited to work performed in preparation for the Cycle 19 rerack. Cycle 19 ended i July 22,1996. The footnote is no longer applicable.

C. The licensee proposes relocating the following requirements to its TRM and deleting them from its TSs:

3.9.12 The Fuel Storage Building Air Cleanup System shall be operable 3.9.12.a With the Fuel Storage Building Air Cleanup System inoperable i

I 4.9.12 The Fuel Storage Building Air Cleanup System shall be demonstrated 4.9.12.a At least once per 18 months l

j 4.9.12.a.1 Verifying that the cleanup (except that the phrase 'or charcoal absorber housings" will be deleted without relocation to the TRM) 4.9.12.a.3 Verifying a system flow 4.9.12.c At least once per 18 months 4.9.12.c.1 Verifying that the pressure drop (except that the phrase " charcoal absorber banks" will be deleted without relocation to the TRM) 4.9.12.c.2 Verifying that the system 4.9.12.d After each... replacement of a HEPA filter .

l These requirements assure that radioactive material in particulate form are filtered from the fuel l building gaseous effluent during operations involving fuel movement or crane movement with loads over the spent fuel pool. However, as noted above, the offsite dose consequences of an unfiltered release from a design-basis accident inside the spent fuel storage building are within ,

acceptable limits. l l

As noted in paragraph A above, charcoal filters are no longer necessary in the FSBACS. l Therefore, no surveillance requirements are required for charcoal filters.  !

Conclusion I

The CTS proposed for relocation to the iicensee's TRM do not meet any of the requirements of j 10 CFR 50.36 for inclusion as an LCO. Due to the permanently shutdown and defueled ,

condition of the plant, degradation of the reactor coolant system (RCS) pressure boundary can l' no longer L w ;n a significant fission product release, and the ' 3S boundary no longer serves as a fission product barrier. The spent fuel cladding continues a provide a fission product ,

barrier; however, none of the process variables, design features, and operating restrictions j referenced in the requirements proposed for relocation are an initial condition of a design-basis ,

accident or transient analysis that either assumes the failure of or presents a challenge to the  ;

integrity of a fission product barrier. None of the structures, systems, and components l referenced in the requirements proposed for relocation are part of a primary success path that functions or actuates to mitigate a design-basis accident or transient that either assumes or presents a challenge to the integrity of a fission product barrier. Finally, none of the structures, systemc. and components referenced in the requirements proposed for relocation have been determined to be significant to public health and safety from operating experience or a probabilistic safety assessment.

The licensee proposes to relocate certain requirements, as listed in Section 5.1 above, to Section 11 of its TRM, which is a document incorporated by reference into the UFSAR and controlled under the provisions of 10 CFR 50.59. These provisions will continue to be implemented by appropriate plant procedures; i.e., operating procedures, maintenance procedures, sunteillance and testing procedures, and work control procedures. Thus, sufficient regulatory controls exist to assure adequate protection of the public health and safety and the environment.

i-Therefore, relocating certain requirements to Section ll of the TRM, and deleting and revising other requirements, as listed in Section 5.1 above, is acceptable.

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8-5.2 RELOCATION OF TS REQUIREMENTS TO THE REMODCM CTS 1.2. Analoo Channel Operational Test CTS 1.4. Channel Calibration CTS 1.5. Channel Check CTS 1.12. FrecLuency Notation CTS 1.30. Source Check CTS Table 1.1. Frecuency Notation These CTS are definitions. Due to the relocation of requirements to licensee-controlled documents, the terrns are no longer used in the TS. They will be relocated to the REMODCM.

CTS 3/4 3.3.7 and 3/4.3.3.8 Radioactive Effluent Monitorina Instrumentation (and associated  !

tables)

The licensee proposed relocating the following CTS to its REMODCM:

CTS 3/4.3.3.7 . Radioactive Liquid Effluent Monitoring Instrumentation I CTS Table 3.3-9 Radioactive Liquid Effluent Monitoring Instrumentation l CTS Table 4.3-7 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance j Requirements  !

CTS 3/4.3.3.8 Radioactive Gaseous Effluent Monitoring Instrumentation CTS Table 3.310 Radioactive Gaseous Effluent Monitoring Instrumentation CTS Table 4.3-8 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements The primary function of radioactive effluent monitoring instrumentation is to show conformance to the discharge limits of 10 CFR Part 20. The radioactive effluent monitors are used routinely to provide continuous check on the releases of radioactive effluents from the normal plant effluent flow paths. The CTS require the licensee to maintain operability of various effluent monitors and establish setpoints in accordance with the REMODCM. The alarm / trip setpoints are established to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20.

CTS 3.4.11. Radioactive Effluents (includina all subsections)

A. The licensee proposes to delete the following CTS:

CTS 3/4.11 - Radioactive Effluents CTS 3/4.11.1 Liquid Effluents CTS 3/4.11.2 Gaseous Effluents The TSs listed above are section headings only and contain no requirements. They are no longer necessary since all subsections containing requirements will be relocated to thn l REMODCM.

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B. The licensee proposes relocating the following requirements to its REMODCM: l l

CTS 3/4.11.1.1 Liquid Effluents - Concentration CTS 3/4.11.1.2 Dose, Liquids CTS 3/4.11.2.1 Dose Rate _

CTS 3/4.11.2.2 Dose, Noble Gases CTS 0/4.11.2.3 - Dose, Radioactive Materialin Particulate Form )

CTS 3/4.11.3 Total Dose The CTS listed above provide limitations on (1) the ave age annual concentrations of radioactive materials released in liquid and gaseous effluents at the boundary of the unrestricted area, (2) the quarterly and annual projected doses to members of the public from radionuclides released in liquid and gaseous effluents, and (3) the annual doses to individual members of the public from all plant sources. The limitations of the radioactive effluent CTS provide assurance that the radiation doses to the public and the environment will not exceed the requirements of 10 CFR Part 20 and 40 CFR Part 190 during normal operation of the facility.

ATS 6.6.4. Radioactive Effluents Controls Proc am ATS 6.6.4.a ATS 6.6.4.b ATS 6.6.4.c ATS 6.6.4.d ATS 6.6.4.e l

. ATS 6.6.4.f l ATS 6.6.4.a ATS 6.6.4.a.1 ATS 6.6.4.a.2 AT_S. 6.6.4.h ATS 6.6.4.1 ATS 6.6.4.1 The licensee proposed the addition of programmatic controls of radioactive effluents that closely follow the controls included in standard TS. These controls provide for the monitoring,

- sampling, and analysis of liquid and gaseous effluents; limitations on the concentrations of radioactive material in liquid effluents; limitations on the dose rate at the site boundary resulting from radioactive materials in gaseous effluents; limitations on the quarterly and annual doses or dose commitments to a member of the public from radioactive materials in liquid and gaseous effluents; and limitations on the dose or dose commitment to members of the public at any point beyond the site boundary conforming to 40 CFR Past 190.

The licensee proposed retaining the concentration limits for liquid effluents as listed in Table 11, Column 2 of Appendix B to 10 CFR Part 20, which contains the limits as they existed before the 1994 revision to 10 CFR Part 20. These limits are contained in CTS 3/4.11.1.1, which will be relocated to the REMODCM. Retaining the existing limits in the programmatic controls of ATS 6.6.4 will not decrease the level of safety provided to the public and environment.

I Conclusion The CTS proposed for relocation to the licensee's REMODCM do not meet any of the requirements of 10 CFR 50.36 for inclusion as a limiting condition of operation. Due to the permanently shutdown and defueled condition of the plant, degradation of the RCS pressure boundary can no longer result in a significant fission product release, and the RCS boundary no longer serve as a fission product barrier. The spent fuel cladding continues to provide a fission product barrier; however, none of the process variables, design features, and operating restrictions referenced in the requirements proposed for relocation are an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challonge to the integrity of a fission product barrier. None of the structures, systems, and components referenced in the requirements proposed for relocation are part of a primary success path which functions or actuates to mitigate a design-basis accident or transient that either assumes or presents a challenge to the integrity of a fission product barrier. Finally, none of the structures, systems, and components referenced in the requirements proposed for relocation have been determined to be significant to public health and safety from operating experience or a probabilistic safety assessment.

However, the provisions of 10 CFR 50.36a require each reactor licensee to include TS requirements in its license to keep releases of radioactive materials to unrestricted areas as low as is reasonably achievable. The staff determined, in Generic Letter 89-01, dated January 31, 1989, that the requirements of 10 CFR 50.36a could be satisfied by adding programmatic controls consistent with the regulatory requirements to the Administrative Controls section of the licensee's TSs. A licensee that adopted appropriate controls could then relocate procedural details contained in radiological effluent technical specifications to its ODCM, which, in HNP's case, is equivalent to its REMODCM. The licensee has proposed adding programmatic controls for radioactive effluents consistent with the requirements of 10 CFR 50.36a as ATS 6.6.4, Radioactive Effluents Controls Program.

After relocation to the REMODCM, any changes to these requirements regarding radioactive effluent monitoring instrumentation will require a safety evaluation pursuant to 10 CFR 50.59.

Changes must also conform to 10 CFR Part 20, Appendix l to 10 CFR Part 50, ATS 6.6.3, Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM), and the programmatic controls of ATS 6.6.4. Thus, sufficient regulatory controls exist to. ensure continued adequate protection of public health and safety.

Therefore, deletion and relocation of certain requirements to the REMODCM, with concurrent implementation of the programmatic controls of ATS 6.6.4, as listed in Section 5.2 above, is acceptable.

5.3 RELOCATION OF TS REQUIREMENTS TO THE OAP The proposed TS amendment would revise the administrative controls section of the HNP TSs, and other affected TS sections, to generally conform to NUREG-1431, Revision 1, and draf t NUREG 1625 and would relocate certain OA-related requirements from the TSs to the Connecticut Yankee OAP (CYOAP) in accordance with NRC Administrative Letter (AL) 95-06,

" Relocation of Technical Specifications Administrative Controls Related to Quality Assurance,"

dated December 12,1995.

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l CTS 6.5. Review and Audit (includina all subsections)

These CTS list tiio function, composition, authority, and responsibsties of the Plant Operations Review Committee (PORC) and Nuclear Safety Assessment Board (NSAB).

The licensee proposed that the review and audit func; ions specified in existing TS 6.5 and its subsections be relocated from the TSs to the CYOAP. such that future changes could be made pursuant to 10 CFR 50.54(a). Section 13.4, " Operational Review," of NUREG-0800, the

" Standard Review Plan," provides the acceptance criteria used by the staff to evaluate TS provisions related to the plant staff review of operational activities performed by licensee 7ganizational units fulfilling the review and audit function. These acceptance criteria are based on meeting the relevant requirements of 10 CFR 50.40(b) as it relatas to the licensee being technically qualified to engage in licensed activities, and of Appendix B to 10 CFR Part 50 as it relates to the review and audit functions required by the licensee's OAP. Therefore, TS provisions associated with the review and audit function satisfy the criteria in both 10 CFR 50.36(c)(5), and Appendix B to 10 CFR Part 50. However, the review and audit provisions that are essential for the safe operation of the facility are adequately covered by existing regulations and can be relocated to the licensee's OAP description. Additionally, the following considerations support relocating these items from the TSs:

a. The licensee has proposed that the PORC function, membership, qualifications, meeting frequency, quorum, responsibilities, authority, and records provisions be relocated, verbatim, to Appendix F," Administrative Controls," of Revision 2 to the CYOAP.

Subsequent changes associated with PORC requirements will be controlled effectively under 10 CFR 50.54(a).

b. The licensee has proposed that the NSAB qualifications, composition, meeting frequency, 1

quorum, responsibilities, audit program, and records provisions be relocated, verbatim, to Appendix F," Administrative Controls," of Revision 2 to the CYOAP. Subsequent changes associated with CYOAP requirements will be controlled effectively under 10 CFR 50.54(a).

This approach is consistert with NRC AL 95-06, " Relocation of Technical Specification Admir,istrative Controls Related to Quality Assurance," dated December 12,1995, which provides guidance for relocating TS administrative requirements. This approach results in an

- equivalent level of regulatory authority while providing for a more appropriate change control process.

QTS 6.10. Record Retention (includina all subsections)

These CTS identify the records that must be retained and the applicable retention periods.

The licensee proposed to relocate, verbatim, the record retention requirements in TS 6.10,

" Record Retention," to CYOAP Appendix F," Administrative Controls." Once relocated to the #

CYOAP, these record retention requirements are adequately addressed by 10 CFR 50.54(a).

In addition to specific record retention commitments in the CYOAP, the licensee relies upon its

. commitments to ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," and ANSI N45.2.9-1974, " Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants,"

(as endorsed by Regulatory Guide 1.88, " Collection, Storage, and Maintenance of Nuclear

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'. 12-Power Plant Quality Assurance Records," Revison 2) to satisfy the regulatory requirements of

~ 10 CFR Part 50, Appendix B, Cmeria XVll, " Quality Assurance Records."

Changes to the record retention provisions in the CYOAP are made pursuant to 10 CFR 50.54(a). .In addition, other regulations such as 10 CFR r art 20, Subpart L, and 10 CFR 50.71 require the retention of certain records related to operation of the nuclear plant.

Concl>:iion 1

These requirements are administrative controls that are not essential for the safe operation of the facility and are adequately covered by existing regulations. Therefore, removing these requirements from the CTS and relocating them to the licensee's OAP is acceptable.

5.4 CHANGES FOR CONSISTENCY WITH STANDARD TSs s

ATS 1.2. Certified Fuel Handler A new definition is added for the position of certified fuel handler.

CTS 5.1. Site ,

This TS is a title heading only. The licensee proposes adding a textual description of the site.

ATS 6.1.2. Unit Director Addition of this section formalizes the function of the Unit Director. This position has direct line i of command responsibility for the safe storage of spent fuel. The change reflects the licensee's )

' organization. <

ATS 6.1.3. Shift Manaaer

Addition of this section formalizes the function of the Shift Manager, This position has direct l line of command responsibility for the safe storage of spent fuel. The change reflects the )

licensee's organization.-

CTS 6.2.1. Onsite and Offsite Oraanization The title of the section is changed to " Gen'eral Organizational Requirements."

in the first paragraph of the requirement, the words "Onsite and offsite" are changed to " Unit,"

the words "The onsite and offsite" are' changed to "These," and the words " safety of the nuclear power plant" are changed to " safe storage of irradiated fuel." Deleting the reference to offsite organization reflects the reduced reliance on offsite support during decommissioning. The changes reflect the licensee's organization, l

CTS 6.2.1.b f The requirement is changed from "The Unit Director shall be responsible for overall unit safe l operation and shall have control over those activities and resources necessary for safe

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l-L  ; operation and maintenance of the plant." to "The Unit Director shall have overall responsibility L for the unit. operation and'shall have control over those activities necessary for maintenance and storage of irradiated fuel in a safe condition." The changes reflect the licensee's

' organization due to permanent cessation of operations.

CTS 6.2.1.d '

The requirement changes the words " independence from operating pressures" to " ability to perform their assigned fonctions."

CTS 6.2.24 The requirement was revised to make it applicable during movement of loads over f uel storage racks containing fuel.

CTS 6.2.2.e This CTS is a place holder only; it contains no requirements. The requirements of CTS 6.2.2.f have been moved into this place.

CTS 6.2.2.f The section is renumbered to' ATS 6.2.2.e. The requirement to follow the guidance of Generic Letter 82-12. " Nuclear Power Plant Staff Working Hours," was removed. The licensee stated l that staff working hours continue to be controlled by a procedure that requires management

~ approval to exceed normal working hours.

ATS 6.2.2.f '

A requirement that the Shift Manager shall be a qualified Gertified Fuel Handler was added.

Table 6.2-1. Minimum Shift Crew Comoosition i The position of Certified Fuel Handler is changed to Shift Manager. The words " crew composition" are changed to " crew's composition"in two places. The notation "(page 1 of 1)"is added.

t ' CTS 6.4. Trainino l

The title is chan'ged from capitals to initial capitals with lowercase letters following. The training

!i requirements are moved to ATS 6.4.1. ,

ATS 6.4.1 l The requirements _of CTS 6.4 have been revised and moved to ATS 6.4.1. The requirement  !

I that the training and replacement training program for Certified Fuel Handlers be NRC l approved is added.. The requirement to meet the standards of Section 5.5 of ANSI N18.1-1971 I is removed. The r'eferenced ANSI section is no longer applicable since the HNP no longer l

rnaintains or needs to maintain Licensed Reactor Operators due to the permanent shutdown L

u

i 14 and defueling of th_a reactor. The NRC previously evaluated the Certified Fuel Handler training ,

program and found it acceptable (Issuance of License Amendment No.192, dated March 27, l 1998).

' ATS 6.5.1.b Portions of CTS 6.8.1.e, CTS 6.8.1.f, and CTS 6.8.4, pertaining to procedures for the Process

. Control Program and REMODCM have been included in new ATS 6.5.1.b.

- In addition, a new requirement to establish, implement, and maintain written procedures for programs specified in new ATS Section 6.6 and its subsections was added.

ATS 6.6.2. Process Control Prooram (PCP)

ATS 6.6.2.a ATS 6.6.2.a.1 ATS 6.6.2.a.2 ATS 6.6.2.b ,

New TS requirements are added to specify the contents of the PCP. The new requirements specify how changes to the PCP shall be documented, recorded, and implemented.

ATS 6.6.5. Radiolcaical Environmental Monitorina Proaram ATS 6.6.5.a ATS 6.6.5.b New' TS requirements are added to specify the contents of the radiological effluent monitoring program (REMP) and require that it shall be included in the licensee's REMODCM.

ATS 6.6.7. Technical Soecifications Bases Control Proaram ATS 6.6.7.a ATS 6.6.7_b ATS 6.6.7.b.1 ATS 6.6.7.b.2 ATS 6.6.7.c ATS 6.6.7.d The licensee added a new TS Bases Control Program to 'he ATS. It provides a means for processing changes to the Bases of the ATS.

-CTS 6.8.1' This section requires that written procedures and/or administrative policies shall be established, implemented, and maintained to cover activities listed in the succeeding subsections. The requirement for administrative polices in addition to or as a substitute for procedures is r' emoved.- The section is renur bered as ATS 6.5.1.

! CTS 6.8.1.a The requirement is changed to clarify that the applicability of Regulatory Guide 1.33 is restricted to those portions that are applicable to the permanently shutdown and defueled condition of the plant. The subsection is renumbered as ATS 6.5.1.a.

CTS 6.8.1.b -

This CTS requires that the licensee shall establish and maintain written procedures to implement the requirements and recommendations of Section 5.1," Program Description"(for programs, policies, and procedures), and Sectio . 5.3, " Preparation of Instructions and Procedures," of ANSI N18.7-1976. The licensee proposes to delete this requirement.

i in Appendix C of its OAP, Revision 2, the licensee lists its commitn.ent to use the guidance of Regulatory Guide 1.33 - 2/78, which endorsas ANSI N 18.7-1976. Therefore, the licensee's OAP retains the requirement specified in CTS 6.8.1.b. The CYOAP is subject to the controls of 10 CFR 50.54(a). Therefore, sufficient regulatory controls exist to assure the protection of the public health e.nd safety and the deletion of this subsection is acceptable.

CTS 6.8.1.e The requirement to establish, implement, and maintain procedures for the REMODCM is provided by ATS 6.5.1.b and ATS 6.6.3. Therefore, deletion of this subsection is acceptable.

CTS 6.8.1.f. Process Control Proaram This section requires that written procedures to be established, implemented, and maintained for the PCP. This requirement was moved to ATS 6.5.1.b. Therefore, deletion of this subsection is acceptable. l CTS 6.8.1.a. Spent Fuel Coolina and Makeuo Monitorina The scope of this program was extended to included SFP water chemistry. The requirement is ,

renumbered as ATS 6.6.6. I CTS 6.8.2 This CTS specifies review by the PORC and approval by the Unit Director prior to implementation for each activity listed in CTS 6.8.1, which was renumbered tt ATS 6.5.1. The new requirement also applies to programs listed in ATS 6.6 and its subsections. The review by PORC is deleted and replaced with the requirement, " independently reviewed in accordance with administrative procedures." The requirement to periodically review procedures is deleted.

CTS 6.8.2 is renumbered as ATS 6.5.2.

With the permanent shutdown and defueling of the reactor, the scope and complexity of activities at the facility have been reduced. The changes to the procedure review requirements of this section are consistent with draft NUREG-1625 for standard TS. In addition, the licensee is committed to ANSI 18.7, as clarified in the CYOAP Exception No. 8, which requires periodic review of procedures. The licensee stated that administrative procedures will be implemented

L, {

o 16- 3 l

to ensure that independent technical reviews are performed by individuals who are qualified.

The licensee stated further that administrative controls will be implemented to ensure that the a designee acting for the Unit Director will meet appropriate qualifications.

]

. CTS 6.8.3. Temocrary Chanaes CTS 6.8.3.a -

CTS 6.8.3.b : 1 CTS 6.8.3.c - l This CTS and its subsections specify requirements for making temporary changes to 1 o ,

' procedures for activities listed in C_TS 6.8.1. l LThe applic. ability statement is changed from CTS 6.8.1 to ATS 6.5.1, which is consistent with the renumbering of the ATS. The section is renumbered as ATS 6.5.3.

]

' CTS 6.8.3.a, changes " original procedure" to " existing procedure" and is' renumbered as ATS 6.5.3.a.

CTS 6.8.1.b, changes _" Certified Fuel Mandler" to all capital letters to signify it (s a term defined in the TS and is renumbered as ATS 6.5.3.b.

CTS 6.8.3.c removes the requirem_ent that the PORC review temporary changes and allows the Unit Director to delegate authority to approve temperary procedure changes and is renumbered

'as ATS.6.8.3.c. The removal of PORC approval for temporary procedure changes !s replaced

- by review and approval of three knowledgeable individuals: a member of plant management, a certified fuel handler, and the Unit Director or designee. This is acceptable due to the reduced I

. scope and complexity of procedures applicable to the permanently shutdown and defueled j condition of the ptant.' The licensee stated that administrative controls will be implemented to ensure that the a designee acting for the Unit Director will meet appropriate qualifications. The

subsection is renumbered as ATS 6.8.3.c.

CTS 6.8.4 :

'This CTS specified requirements for procedures covering Section I.E of the REMODCM. This j requirement will be contained in ATS 6.5.1.b. Therefore, deleting CTS 6.8.4 is acceptable.

CTS 6.8.5 This CTS specifies review and approval of changes to procedures in the REMP. CTS 6.8.5 wil!

be deleted.1However, the REMP requirements will be separately specified in ATS 6.6.5.

Review and approval of REMP changes will be adequately controlled by ATS 6.5.1.b, ATS 6.5.2, and ATS 6.5.3 (and subsections), which specify requirements for establishing, implementing, maintaining, changing,' reviewing and approving procedures, in addition, because the REMP is part of the REMODCM, the requirements of ATS.6.6.3 also apply to 1

changes in the REMP. Therefore, sufficient controls exist to assure that REMP procedures are adequately controlled. Deleting CTS 6.8.5 is acceptable.

i

1 l

i 17 CTS 6.9.1.4. Annual Reports This CTS specifies March 1 as the submittal date for annual reports. This section is deleted and the annual submittal date is specified separately for each report in the applicable subsection of the ATS.

CTS 6.9.1.5 CTS 6.9.1.5.a These TSs specify the content of the Occupational Radiation Exposure Report. The content is I revised to change the annual submittal date from March 1 to May 1. The words " greater than" are changed to ">"; " man-rem" changed to " person-rem"; " reactor operations and surveillance, inservice inspection" changed to " decontamination and decommissioning, surveillance"; and

" refueling" changed to " spent fuel movement." The footnote stating "This tabulation i supplements the requirements of Section 20.2206 of 10 CFR Part 20"is changed to "This (

tabulation supplements the requirements of 10 CFR 20.2206," and is moved into the text of the specification. The requirements are renumbered as ATS 6.7.1. j CTS 6.9.1.6. Annual Radioloaical Environmental Operatina Report This section is completely revised to be consistent with the STS. A new annual submittal date of May 1 is specified. The section was renumbered as ATS 6.7.2.

CTS 6 9.1.7. Semiannual Effluent Release Report The wording of this CTS was revised to reflect the STS. In addition, the ATS specifies a new annual submittal date of May 1 and allows changes to the REMODCM to be submitted as part of or concurrently with the annual effluent release report.

The requirement for the effluent release report was revised to allow an annual submittal frequency as part of License Amendment No.170, issued November 23,1993. The 1993 TS revision was in accordance with a change to 10 CFR 50.36a that became effective in 1992.

However, the title of CTS 6.9.1.7 was not changed in the 1993 amendment. This CTS was renumbered and its title revised to ATS 6.7.3, Annual Effluent Release Report.

CTS 6.13. Radioloaical Effluent Monitorina and Offsite Dose Calculation Manual The CTS describes the content of the REMODCM and specifies that it shall have two sections.

These requirements are replaced with a description that does not specify the number of sections. The revised TS adds the requirement that the REMODCM shall contain the Radioactive Effluent Controls and Radiological Environmental Monitoring Program, and descriptions of the information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release Reports.

The revised TS removes the requirement that the REMODCM shall specify operating guidelines for radioactive waste treatment systems. The requirement to operate radioactive waste treatment systems in accordance with REMODCM guidelines was moved to ATS G.S.1.e. The section is renumbered as ATS 6.6.3.

1 CTS 6.13.a This CTS specifies that changt i o the REMODCM shall be documented and retained. The phrase,"as required by Specification 6.10.3.m"is deleted. The requirements of CTS 6.10.3.m will be relocated to the CYOAP. As noted in Section 5.3 of this SE, the CYOAP is subject to the controls of 10 CFR 50.54(a). The section is renumbered as ATS 6.6.3.a.

CTS 6.13.a.1 The requirement is given a slight format change and renumbered as ATS 6.6.3.a.1. j CTS 6.13.a.2 I The requirement is given a slight format change and renumbered as ATS 6.6.3.a.2.

CTS 6.13.b The revision changes the requirement for the PORC to review and accept revisions to the REMODCM to an independent review. The revision allows the Unit Director to delegate the authority to approve REMODCM changes. The requirement is renumbered as ATS 6.6.3.b.

CTS CTS 6.13.c l

The reference to the two sections of the REMODCM is deleted, and " Annual Radioactive Effluent Report"is changed to " Radioactive Effluent Release Report." The abbreviation "e.g."

is changed to "i.e."

CTS 6.14. Radioactive Waste Treatment This CTS requires procedures for making effluent discharges and for operating radioactive waste systems. It specifies that the radioactive waste system be operated in accordance with the REMODCM and PCP. These requirements are relocated to various sections of the ATS.

The requirement for procedures for liquid and gaseous effluent discharges is contained in ATS 3.5.1.b. The requirement for procedures to process, package, and dispose of solid radioactive waste in accordance with the process control program is contained i '6.5.1.b.

The requiremer:t for procedures to specify use of the radioactive waste sys .

v ndance with the REMODCM is contained in ATS 6.5.1.e. The PCP is contained in . . " . and its subsections. Therefore, because the requirements of CTS 6.14 are retained . . ..ier TSs, deletion of CTS 6.14 is acceptable.

Conclusion The changes listed in Section 5.4 above are consistent with the STS and are acceptable.

,+

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.l 5.5 SFP LOAD LIMIT 4

CTS 3/4.9.7. Crane Travel - Soent Fuel BeMna The licensee proposed an increase in the limit for handling loads over the'SFP from 1650 to - I 31800 pounds. In a_ letter to the NRC dated February 19,1997, the licensee determined that the

total weight of some fuel assemblies plus the associated rod control cluster assembly (RCCA)

. , - and the fuel handling tool would exceed 1650 pounds. The licensee determined that the

heaviest combination of fuel assembly, RCCA, and tool would not exceed 1800 pounds.

- The basis for the weight limit is to ensure that in the event that the load was dropped that

' 3 (1) the activity released will be_ limited to that contained in a single fuel assembly and (2) any l

. possible distortion of fuel in the SFP racks will not result in a critical assembly.

The first basis for the weight limit is to ensure that consequences of a load drop remain within

' the bounds of the design-basis accident analysis for a dropped fuel assembly. That analysis is contained in UFSAR Section 15.5.2, which assumes all fuel rods (a total of 204 for HNP) in a )

fuel assembly will rupture and release the gap activity. )

L . The UFSAR drop analysis is conservative since the forces generated in an actual fuel assembly

' drop would likely not cause damage sufficient to rupture all the fuel rods. For example, in 1986,

7the licensee' dropped a fuel assembly into the reactor vessel during a refueling outage. The event is documented in LER 50-213-86-012, dated March 27,1986. The assembly dropped.

between 2 and 4 feet. That distance is approximately the same height that a fuel assembly -

. 'would fall duing fuel movement in the SFP. The fuel assembly suffered denting and twisting, l

' but no fuel rods were ruptured and no gap activity was released.' The weight of the dropped i

assembly was approximately 1200 pounds, since it did not include an RCCA or the fuel handling tool. However, considering the lack of any fuel rod rupture in the actual event, it can J be concluded that an 1800-pound weight would not result in the rupture of more than 204 fuel

. rods.

I' . The second basis for the weight limit is to ensure that distortion of the fuel racks will not result

~

i l in a critical assembly. By letter dated March 31,1995, the licensee presented the results of an analysis of dropping a 2300-pound fuel assembly unit with the fuel handling tool onto the SFP racks. Two drop cases were presented. The first considered the effects of a heavy fuel

, assembly dropping through an empty storage cell and impactino the babe of the cell. The L l second considered a drop onto the SFP racks from a height # 36 inches. In both cases, the ,

stored fuel would remain subcritical.

' Therefore, an increase to 1800 pounds in the weight limit for loads canied over the SFP is L acceptable.  :

5.6 ' CHANGES TO LICENSE CONDITIONS

' Current License Condition C.(6Ma) and (b)

. The condition was originally issued to HNP n License Amendment No.150, dated February 26, 1992. It required the licensee to implement and , maintain in effect the Integrated

. implementation Schedule (llS) Program Plan. The llS was a method used to schedule plant l

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modifications and engineering studies found to be justified under the HNP Integrated Safety Assessment Program (ISAP). The ISAP was a method used to make balanced decisions on backfitting certain safety improvements to older operating ~ plants, such as HNP. License

= Amendment No.183, dated February 23,1995, extended the effective date for continuing the

. program to February 23,1998.

HNP submit *ed certifications of permanent shutdown and defueling of the reactor on December 5,1996. As a result, modifications and studies intended to improve operating safety are no longer relevant to HNP,- Additionally, the expiration date for the program has passed.

~ Therefore, removal of these license conditions is acceptable.

Current License Condition C.i7)

This requirement is renumbered as C.(6). This requirement prohibits the movement of spe,iat nuclear material used as reactor fuel into containment. The only change is editorial and is acceptable.

~

Current License Condition D This condition states that the operating license shall expire at midnight, June 29,2007. Due to

. the permanent cessation of operations of the plant, the licensee proposes to revise the condition to comply with 10 CFR 50.51(b), which provides that the license of a facility that has permanently ceased operations will continue in effect beyond the expiration date to authorize ownership and possession of the facility until the Commission notifies the licensee in writing -

that the license in terminated. Therefore, this change is acceptable.

5.7: TS DELETED DUE TO PERMANENT SHUTDOWN AND DEFUELING i

' CTS 1.8. Core Alteration CTS 1.18. Ooerational Mode - Mode CTS 1.27; RHR IResidual Heat Removal 1 Looo CTS Table 1.2. Ooerational Modes

. The CTS listed above are definitions of terms relevant to reactor operation. Due to the

permanent ~ cessation of operations and defueling of the reactor, they are no longer applicable.

CTS 3/4.9. Refuelino Operation

- The heading on the pages remaining in Section 3/4.9 was changed from " Refueling Operations"

- ' to " Spent Fuel Building Operations."

-.D .

_ 1;

_ CTS 3/4.9.1. Boron Concentration -

The purpose of this LCO was to limit the reactivity of the reactor coolant system and refueling canal to less thari or equal to 0.94 Kg. It was applicable to the refueling mode.

Both the RCS and refueling canal are located in the containment. The licensee has removed all nuclear fuel from containment and License Condition C.(7), renumbered as C.(6), prohibits the licensee from moving reactor fuel back into the containment. The absence of nuclear fuei in  ;

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1 containment ensures that reactivity in containment areas will be zero. Therefore, the requirement is no longer applicable.

i CTS 3/4.9.2. Instrumentation l

}

This LCO required that source range neutron flux monitors would be operating during refueling. I The basis for requiring the neutron monitors was to detect reactivity chane,ea in the core. This requirement is unnecessary for a permanently defueled reactor. 4 l

CTS 3/4.9.3. Decay Time j Fiaure 3.9-1. Reauired Hold Time '

The LCO and associated table required the licensee to wait a specified amount of time before moving fuelin the reactor vessel. Cooling water temperature affected the required amount of decay and hold time. This requirement is unnecessary for a permanently defueled reactor.

CTS 3/4.9.4. Containment Buildina Penetrations This LCO required certain equipment to be in place or operable so that a release of radioactive materials inside containment wou'Id be restricted from leaking into the environment. The restrictions were based on a fuel element rupture. The licensee has removed all nuclear fuel from containment and License Condition C.(7) (renumbered as Condition C.(6)) prohibits the licensee from moving reactor fuel back into the containment. Therefore, the requirement is no longer applicaole.

CTS 3/4.9.5. Communications This LCO required communication between personnel in the control room and the refueling cavity during core alterations. The licensee has removed all nuclear fuel from the containment and License Condition C.(7), renumbered as C.(6), prohibits the licensee from moving reactor fuel back into the containment. Therefore, the requirement is no longer applicable.

CTS 3/4.9.6. Manioulator Crane This LCO specified the crane to be used to lift fuel assemblies out of the reactor vessel, and ensured that the core internals and reactor vessel would not be subjected to excessive lifting forces. The licensee has removed all nuclear fuel from containment and License Condition C.(7), renumbered as C.(6), prohibits the licensee from moving reactor fuel back into the containment. Therefore, the requirement is no longer applicable.

CTS 3/4.8. Residual Heat Removal (RHR)

This is a section title only. Because all subsections will be deleted, deleting the title is acceptable.

4 l

1 1

i CTS 3/4.9.8.1. Hiah Water Level CTS 3/4.9.8.2. Low Water Level These LCOs required at least one RHR loop to be operating during certain refueling conditions.

The bases for the LCOs were to remove decay heat generated by nuclear fuel in the reactor vessel. The licensee has removed all nuclear fuel from containment and License 1 Condition C.t 7), renumbered as C.(6), prohibits the licensee from moving reactor fuel back into  !

the containment. Therefore, these requirements are no longer applicable. l CTS 3/4.9.9. Containment Purae j This LCO required that certain containment ventilation valves be operable during movement of fuelin the containment. The licensee has removed all nuclear fuel from containment and License Condition C.(?), renumbered as C.(6), prohibits the licensee from moving reactor fuel back into the containment. Therefore, this requirement is no longer applicable. 4 CTS 3/4.9.10. Water Level - Reactor Vessel This LCO required at least 23 feet of water be maintained over the top of the reactor vessel flange during movement of fuel assemblies of control rods within the containment. The licensee has removed all nuclear fuel from containment and License Condition C.(7),

renumbered as C.(6), prohibits the licensee from moving reactor fuel back into the containment.

Therefore, this requirement is no longer applicable.

CTS 3/4.9.15. Soent Fuel Pool Coolina This LCO specified operability requirements for SFP cooling during refueling. Due to the permanent shutdown and defueling of the HNP reactor, it is no longer applicable and has been superseded by CTS 3/4.9.16, " Spent Fuel Pool Cooling - Defueled." Therefore, CTS 3/4.9.15 is no longer necessary. i Conclusion The requirements listed in Section 5.7 above are no longer applicable to the permanently shutdown and defuelod condition of the plant. Therefore, their deletion is acceptable.

5.8 TSs THAT DUPLICATE REGULATORY REQUIREMENTS I CTS 1.26. Reportable Event This definitioa states that a reportable event is any condition specified by 10 CFR 50.73 as a l reportable event.

CTS 6.6. Reportar;!e Event Action (and subsections)

This TS requires that the licensee will submit reports in accordance with 10 CFR 50.73.

Because this requirement is specified by regulation, it is not necessary to retain it in the CTS.

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.i L ,

The TS also requires that each event reportable' under 10 CFR 50.73 will be reviewed by the licensee's PORC and the results of the review be submitted to the licensee's NSAB and the VP - Operations and Decommissioning. This requirement is a duplicate of CTS 6.5.1.6.f, which I requires PORC review of reportable events, CTS 6.5.2.6.f, which requires NSAB review of l

reportable evente, and CTS 6.5.2.6, which requires repor1ing the results of the NSAB review to the VP - Operations and Decommissioning. These requirements will be relocated to the licensee's OAP, as discussed in Section 5.3 of this SE, Changes to 'he OAP are controlled by 10 CFR 50.54(a)

CTS 6.9.2. Soecial Reoorts This TS specifies the address to which special reports must be mailed. This requirement i duplicates the requirements of 10 CFR 50.4, which specifies the mailing requirements for 1 written communications with the NRC.

A second requirement of this TS is that special reports must be submitted within the time period

. required for' each report. Special reports are required by CTS 3/4.3.3.4, which will be relocated i to the TRM. Therefore, the second TS duplicates requirements that will be maintained in licensee documents that are controlled under 10 CFR 50.59.

Conclusion The requirements of the CTS listed in Section 5.8 above duplicate requirements found in the regulations and licensee-controlled documents subject to control by the regulations. Sufficient  ;

regulatory controls exist to assure the reporting requirements will be maintained, and deleting j CTS 1.26, CTS 6.6 and its subsections, end CTS 6.9.2 is acceptable.

'5.9 TSs THAT DUPLICATE UFSAR INFORMATION ,

j GTS 5.1.1; Exclusion Area l QTS Fiaure 5.1-1 These TSs duplicate information found in UFSAR Section 2.1.2.1 and Figure 2.1-3. I CTS 5.1'.2. Ilow Pooulation Zone CTS Fiaure 5.12 ^

. These TSs duplicate information fo ;nd in UFSAR Section 2.1.3.4. I i

. CTS 5.5 Meteorploalcal Towe-location j This'TS ' specifies that the "neteorological tower location shall be as indicated on Figure 5.1-1.

The TS figure is a durGate of UFSAR Figure 2.1-3. )!

Conclusio_0 _

l, The information contained in the CTS listed above duplicates information in the UFSAR.

L ,

inic ;ation contained in the UFSAR is controlled under 10 CFR 50.59; therefore, any changes will require an SE pursuant to _10 CFR 50.59. Any changes must also conform to the l

4

rc requirements of 10 CFR Part 50 and Part 100. Thusi sufficient regulatory controls exist to ensure continued protection of public health and safety. Deleting the information from the CTS -

l listed above is acceptable.

5.'10 EDITORIAL CHANGES AND CORRECTIONS N

The index was repaginated and the listing of sections revised to coincide with the changes made to the TSs. Terms defined in Section 1.0 of the TSs are changed to uppercase letters where they appear in the ATS.

. The revised index retains listings of section numbers that no longer contain requirements as 9

. place holders in TS Section 3/4 (LCOs and Surveillance Requirements) and the Bases section.

CTS Section 1.0. Definitions The licensee proposed removing section numbers that no lof ger contain a definition,

renumbering remaining definitions, and repaginating Section 1.0. A list of the definitions removed is shown in' Attachment 1.

CTS 1.15. Member (s) of the Public

' Th'is definition is unchanged, but renumbered nTS 1.3.

' CTS 1.17. Operable - Ooerability

' This definition is unchanged, but renumbered as ATS 1.4.'

CTS 1.23: Radioa'ctive Waste Treatment Systems The licensee proposes to change "to meet the LCO's" to "to meet requirements" and change "in these specifications" to "in the REMODCM," and renumber as ATS 1.5.

CTS 1.2'4. Radiolocical Effluent Monitorina and Offsite Dose Calculation Manual (REMODCM)

The licensee proposes to change " Specification 6.13" to " Specification 6.3," and renumber as

. ATS 1.6.'

c CTS 1.29' Site Boundarv

' This definition is unchanged, but renumbered as ATS 1.7.

CTS Section 3/4. Limitina Conditions for Ooeration and Surveillance Reauirements -

,y 1

Section numbers that no longer contain requirements were removed. Pages that no longer contain requirements were removed.- The remaining pages were renumbered. The remaining LCOs retained their existing section numbers.-

l D

CTS 3/4 9.11. Water Level- Storaae Pool l _. The section title was changed from " Water Level- Storage Pool" to " Water Level - Spent Fuel l Pool."

The LCO was changed from "At least 20 feet of water shall be maintained over the top of irradiated fuel assemblies seated in the storage pool" to "2 20 feet of water shall be maintained over the top of fuel V semblies seated in the spent fuel pool."

The applicability statement was changed from "Whenever irrcdiated fuel ?ssemblies are in the storage pool" to "Whenever fuel assemblies are in the spent fuel poor The action statement was revised to delete reference to Specification 3.0.3 and split the first part into two parts. Specifically, the action statement was changed from

a. With the requirements of the above specification not satisfied, suspend all movements of fuel assemblies and crane operations with loads in the fuel storage areas and restore the water level to within its limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

b. The provisions of Specification 3.0.3 are not applicable.

to With the requirements of the above specification not satisfied,

a. suspend all movements of fuel assemblies and crane operations with loads over storage racks containing fuel, and

b. restore the water level to within its limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Specification 3.0.3 is a place holder only and has no requirements. Therefore, deleting the reference to it is acceptable.

The surveillance requirements were changed from "4.9.11 The water level in the storage pool shall be determined to be at least its minimum required depth at least once per 7 days when irradiated fuel assemblies are in the fuel storage pool" to "4.9.11 The water level in the spent fuel pool shall be determined to be at least its minimum required level at least once per 7 days when fuel assemblies are in the spent fuel pool."

CTS 3/4.9.13. Movement of Fuelin the Soant Fuel Pool The LCO requirement was changed from " greater than or equal to 800 ppm" to "2 800 ppm."

The : action statement was changed from "less than 800 ppm" to "< 800 ppm."

The surveillance requirement was changed from " greater than or equal to 800 ppm" to "a 800 ppm" and from "every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter" to "every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter during fuel movement." This editorial change is an acceptable clarification of the intent of the surveillance requirement.

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l CTS 3/4.9.14. Spent Fuel Pool -- Reactivity Condition  !

The hyphen in the title of the LCO is changed from " " to " ."

l

'he LCO requirement is changed from "The Reactivity Condition of the spent fuel pool shall be j

- r h that K , is less-than-or-equal-to 0.95 at all times" to "The reactivity condition of the spent fuel pool shall be such that K.,is s 0.95 at all times." l CTS Fioures 3.9-2. 3.9-3 and 3.9-4. Soent Fuel Pool Rack The figures remain the same; however, the heading, " Spent Fuel Building Operations"is added to each page. The pages are renumbered.

CTS 3/4.10. Deleted ,

I This CTS contains no requirements and was removed. '

CTS 3/4.9.16. Scent Fuel Coolina - Defueled The LCO requirement changes "less than or equal" to "s" and " degrees F" to "*F."

The action statement is changed from " irradiated fuel assemblies" to " fuel assemblies."

The surveillance requirements change "less than or equal" to "s" and " degrees F" to "*F."

CTS. Section 5.0 Pages that no longer contain requirements are removed and the remaining pages renumbered.

Section numbers that no longer contain requirements are removed.

CTS 5.6. Soent Fuel Storaae The section is renumbered as ATS 5.2.

CTS 5.6.1 and CTS 5.6.1(a). (b). (c). Criticality The section is renumbered as ATS 5.2.1 and ATS 5.6.1.(a), (b), (c). The words "less than or equal to" are changed to "s" in subsections a, b, and c.

CTS 5.6.2. Drainaae The section is renumbered as ATS 5.2.2.

CTS 5.6.3. Capacity l

! The section is renumbered as ATS 5.2.3.

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.e .27-CTS. Section 6.0 - i The sections and pages that no longer contain requirements are removed and the remaining sections and pages are renumbered. Section titles are changed from uppercase to lowercase with initial capitalletters.

CTS 6.1.- Responsibility -

.' The title is changed from capital letters to an initial capital letter with lowercase letters following.

CTS 6.2. Oraanization 1 . The title is changed from capital letters to an initial capital letter with lowercase letters following.

CTS 6.2.2. Facility Staff CTS 6.2.2.b

' The title is changed from capital letters to an initial capital letter with lowercase letters following.

' The words " Certified Fuel Handler" are changed to " CERTIFIED FUEL HANDLER" in CTS 6.2.2.b.

- CTS 6.3. Facility Staff Reauirements The title is changed from capital letters to an initial capital lett er with lowercase letters following.

CTS 6'.-3.1.2 :

--This TS contains no requirements and was removed.

i CTS 6.7

'This TS contains no requirements. The section number was reused for the ATS.

L CTS 6.8. Procedures and Proarams The' title is changed frora capital letters to an initial capital letter with lowercase letters following.

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l The section is renumbered as ATS 6.5.

CTS 6.8.1.c This section is renumbered as ATS 6.5.1.c

' CTS 6.8.1.d This TS is renumbered as ATS 6.5.1.d.

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- CTS 6.9. Reportina Reauirements This is a title heading, it is renumbered as ATS 6.7.

CTS 6.9.1. Routine Reports

- CTS 6.9.1.1

CTS 6.9.1.2 CTS 6.9.1.3

CTS 6.9.1 requires that the reports listed in CTS 6.9,1,1 through CTS 6.9.1.3 be submitted to the Commission and the resident inspector.L However, the reports listed in CTS 6.9.1.1 through CTS 6.9.1.3 were deleted in previous license amendments and, thus, contain no requirements.

These sections will be removed from the ATS.

CTS 6.9'.1.5.b

' CTS 6.9.1.5.c

. CTS 6.9.1.8_

. CTS 6.9.1.9  ;

Th'ese sections contain no requirements and are removed from the ATS.

6.11. Radiation Protection Prooram

- 6.11.1 -

The title is changed from capital letters to an initial capital letter with lowercase letters following.

The word " Procedures" was changed to "A program." No requirements were changed. The requirement for procedures for the radiation program is located in ATS 6.5.1.b. CTS Sections 6.11 and 6.11.1 were combined and renumbered as ATS 6.6.1.

6.12. Hiah Radiation' Area I i

l This is a title section only. The title was changed from capital letters to an initial capital letter j

, with lowercase letters following, it is renumbered as ATS 6.8.

J';TS 6.12.1.1.a.1.b. and 1.c

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The words " paragraph 20.1601(c)" is changed to "10 CFR 20.1601(c)" "of CFR Part 20" is deleted; " greater than" changed to ">"; "mR/hr" changed to " mrem /hr"; " equal to or less than" ..

changed to "s": "such high radiation areas" changed to "such areas";" that continuously" l

- changed to "" aich continuously"; "; or" replaced with "."; and ";" replaced with "and." The

. sections are renumbered as ATS 6.8.1,6.8.1.a,6.8.1.b, and 6.8.1.c, respectively.

' CTS 6.12.2 (first.paraarachi L 'LThe words " greater than" are changed to ">"; "mR/hr" is changed to " mrem /hr"; "shif t I _' supervisor" is changed to " shift manager"; and "that area" is changed to "those areas." The requirementt sre renumbered as ATS 6.8.2.

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I CTS 6.12.2 (second oaraaraoh)

There are no changes in requirements. The section is renumbered as ATS 6.8.3.

CTS 6.15 and CTS 6.16 These TSs contain no requirements and were removed. l j

Conclusion The corrections and editorial changes described above do not change the meaning or intent of the TSs and are acceptable.

6.0 STATE CONSULTATICN in accordance with its regulations, the State of Connecticut official was notified of the proposed issuance of the amendment. The State official had no comment.

7.0 ENVIRONMENTAL CONSIDERATION

S The amendment changes requirements with respect to installation or use of facility components located within the restricted area, as defined in 10 CFR Part 20, and changes surveillance requirements, in addition, the amendment changes recordkeeping, reporting, and administrative procedures or requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the prope sed amendment involves no significant hazards consideration, and there has been no public comment on such finding (64 FR 38024, July 14,1999).

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental assessment or environmental impact statement need be prepared in connection with the i.ssuance of the amendment.

8.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by j operatim in th? proposed manner, (2) such activities will be conducted in compliance with the J Commission's regulat;on+3, and (3) the issuance of the amendment will not be inimical to the I comrnor, defense and security.or to the health and safety of the public.  !

Attachments: 1. List of Changes ,

2. List of Amended Technical Specifications Principal Contributors: T. L. Fredrichs R. M. Latta i l

Date: October 19, 1999  !

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List of Changes June 3,1999 TS Change Request CTS Section Description ATS Section Commitment SER Section License Integrated implementation None 5.6 C(6)(a) & (b) Schedule License C(7) Fuel Movement License C(6) 5.10 License D Expiration Date License D 5.6 Index Index Index 5.10 Section 1 Definitions - Section 1 5.10 , {

1.1 Action 1.1 NA 1.2 Analog Channel Operational Test None REMODCM, 5.2 Note 1 l

Certified Fuel Handler 1.2 5.4  !

i 1.3 Deleted in previous amendment None 5.10 1.4 Channel Calibration None REMODCM, 5.2 l Note 1 TRM, Note 2 5.1 l

1.5 Channel Check None REMODCM, 5.2 Note 1 TRM, Note 2 5.1 1.6 Deleted in previous amendment None 5.10 1.7 Deleted in previous amendment None 5.10 1.8 Core Alteration None 5.7 1

i.9 Deleted in previou-s amendment None 5.10 l 1.10 Deleted in previous amendment None 5.10 1.11 Deleted in previous amendment None 5.10 j 1.12 Frequency Notation None REMODCM, 5.2 Note 1 1.13 Deleted in previous amendment None 5.10 1.14 Deleted in previous amendment None 5.10 l 1.15 Member (s) of the Public 1.3 5.10 1.16 Deleted in previous amendment None 5.10 1.17 Operab!e - Operability 1.4 5.10 )

1.18 Operational Mode - Mode None 5.7 l

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. HNP List df Changes Attachment 1 Page 2 l CTS Section . Description ATS Section Commitment SER Section 1.19 Deleted in previous amendment None 5.10 l l

1.20- Deleted in previous amendment None 5.10 1

1.21 Deleted in previous amendment None 5.10 1.22 Deleted in previous amendment None 5.10 1.23 Radioactive Waste Treatment 1.5 5.10 Systems 1.24 Radiological Effluent Monitoring 1.6 5.10 and Offsite Dose Calculation Manual (REMODCM) 1.25 Deleted in previous amendment None 5.10 1.26 Reportable Event None 5.8 l

1.27 RHR Loop - None 5.7  !

1.28 Deleted in previous amendment None 5.10 l 1.29 Site Boundary 1.7 5.10 l 1.30 Source Check None REMODCM, 5.2 Note 1 1.31- Deleted in previous amendment None 5.10 1.32 Deleted in previous amendment. None 5.10 1.33 Deleted in previous amendment None 5.10 1.34 Deleted in previous amendment None 5.10 1.35 Deleted in previous amendment None 5.10 1.36 Deleted in previous amendment None 5.10 1.37 Deleted in previous amendment None 5.10 Table 1.1 Frequency Notation None REMODCM, 5.2 Note 1 Table 1.2 Operational Modes None 5.7

[. Section 2 ' Deleted in previous amendment None NA 3/4.0 Applicability 3/4.0 NA 3.0.1 Compliance with LCO 3.0.1 NA 3.0.2 Noncompliance with specification 3.0.2 NA

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1 HNP List of Changes Attachment 1 Page 3 CTS Section Description ATS Section Commitment SER Section

! 3.0.3 Deleted . 3.0.3 NA 3.0.4 Entryinto ACTION requirement 3.0.4 NA 4.0.1 Surveillance requirements shall 4.0.1 NA be met 4.0.2 Surveillance requirements shall 4.0.2 NA l be performed 1 4.0.3 Failure to perform a surveillance 4.0.3 NA requirement 4.0.4 No entry into applicable condition 4.0.4 NA i unless surveillance has been i performed 4.0.5 Deleted None 5.10 l 4.0.6 Deleted None 5.10 I 3/4.1- Deleted in previous amendment None 5.10 j 3/4.2 Deleted in previous amendment None 5.10 3/4.3 Instrumentation None 5.10 l 3/4.3.1 Deleted in previous amendment None 5.10 3/4.3.2 Deleted in previous amendment None 5.10 3/4.3.3 Deleted in previous amendment None 5.10 3/4.3.3.1 Deleted in previous amendment None 5.10

3/4.3.3.2 Deleted in previous amendment None 5.10 3/4.3.3.3 Deleted in previous amendment None 5.10 Table 3.3-5 Deleted in previous amendment None 5.10 Table 4.3-4 Deleted in previous amendment None 5.10 I

3/4.3.3.4 Meteorological Instrumentation None TRM, Note 2 5.1 Table 3.3-6 Meteorological Instrumentation None TRM, Note 3 5.1 Table 4.3-5 Meteorological Instrumentation None TRM, Note 3 5.1 Surveillance Requirements 3/4.3.3.5 Deleted in previous amendment None 5.10

'3/4.3.3.6 Deleted in previous amendment None 5.10  ;

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, HNP List of Changes Attachment 1 Page 4 CTS Section . Description ATS Section Commitment SER Section j 3/4.3.3.7 Radioactive Liquid Effluent - None REMODCM, 5.2 Monitoring instrumentation Note 1 1 Table 3.3-9 Radioactive Liquid Effluent None REMODOM, 5.2 L Monitoring instrumentation Note 1 Table 4.3-7 Radioactive Liquid Effluent None REMODCM, 5.2 Monitoring Instrumentation Note 1 1 Surveillance Requirements 1 3/4.3.3.8 Radioactive Gaseous Effluent None REMODCM, 5.2 j Monitoring Instrumentation Note 1 Table 3.3-10 Radioactive Gaseous Effluent None REMODCM, 5.2 Monitoring Instrumentation Note 1 Table 4.3-8 Radioactive Gaseous Effluent None REMODOM, 5.2 l Monitoring Instrumentation Note 1 Surveillance Requirements 3/4.3.3.9 Deleted in previous amendment None 5.10 l

3/4.3.4 Deleted in previous amendment None 5.10 l 1

3/4.4 Deleted in previous amendment None 5.10 3/4.5 Deleted in previous amendment None 5.10 3/4.6 Deleted in previous amendment None 5.10 3/4.7 Plant Systems None 5.10 3/4.7.1 Deleted in previous amendment None 5.10 3/4.7.2 Deleted in previous amendment None 5.10 3/4.7.3 Deleted in previous amendment None 5.10 3/4.7.4 Deleted in previous amendment None 5.10 3/4.7.5 Sealed Source Contamination None TRM, Note 2 5.1 3/4.7.6 Deleted in previous amendment None 5.10 3/4.7.7' Deleted in previous amendment None 5.10 3/4.7.8 Deleted in previous amendment None 5.10 3/4.7.9 Deleted in previous amendment None 5.10 3/4.7.10 Deleted in previous amendment None 5.10 3/4.7.11 Deleted in previous amendment None 5.10 3/4.7.12 Deleted in previous amendment None 5.10 l

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! ' HNP List of Changes Attachment 1 Page 5 CTS Section Description ATS Section Commitment SER Section l

3/4.8 Deleted in~ previous amendment' None 5.10' i l

3/4.9 Refueling Operation 3/4.9 5.7 1 3/4.9.1 Boron Concentration Wone 5.7 3/4.9.2 Instrumentation None 5.7 3/4.9.3 Decay Time i None . 5.7 Figure 3.9-1 Required Reactor Hold Time for a None 5.7 I

Full Core Offload 3/4.9.4 Containment Building None 5.7 Penetrations i 3/4.9.5 Communications None 5.7 3/4.9.6 Manipulator Crane None 5.7 3/4.9.7 Crane Travel _- Spent Fuel 3/4.9.7 5.5 Building 3/4.9.8 Residual Heat Removal and None 5.7 Coolant Circulation 3/4.9.8.1 High Water Level. None 5.7 l 3/4.9.8.2 Low Water Level None 5.7 1

l 3/4.9.9 Containment Purge Supply, Purge None 5.7 Exhaust, and Purge Exhaust -

Bypass isolation System l 3/4.9.10 Water Level- Reactor Vessel None 5.7 3/4.9.11 Water Level- Spent Fuel Pool 3/4.9.11 5.10 3/4.9.12 Fuel Storage Building Air Cleanup None TRM, Note 2 5.1 System 3.9.12 Limiting Condition for Operation None TRM, Note 2 5.1 3.9.12 The above specification None 5.1 Footnote 3.9.12.a With the Fuel Storage None TRM, Note 2 5.1 3.9.12.b The provisions - None 5.1 4.9.12 Surveillance Requirement None TRM, Note 2 5.1 4.9.12.a At least once per 18 months None TRM, Note 2 5.1 4.9.12.a.1 Verifying that the cleanup None TRM, Note 2 5.1

HNP List of Changes _ Attachment 1 Page 6 CTS Section Description ATS Section Commitment SER Section 4.9.12.a.2 Verifying, within 31 days' None 5.1 4.9.12.a.3 Verifying a system - None TRM, Note 2 5.1 4.9.12.b After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> None 5.1 4.9.1h.c At least once per 18 months None TRM, Note 2 5.1 4.9.12.c.1 Verifying that the pressure None TRM, Note 2 5.1 4.9.1'2.c.2 Verifying that the system None TRM, Note 2 5.1 4.9.12.d - After each complete ... HEPA . None TRM, Note 2 5.1 4.9.12.e After each complete ... charcoal None TRM, Note 2 5.1 3/4.9.13 F.iovement of Fuelin Spent Fuel 3/4.9.13 5.10 i Pool 1 3/4.9.14 Spent Fuel Pool- Reactivity 3/4.9.14 5.10 Condition

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Figure 3.9-2 Spent Fuel Pool Rack Minimum Figure 3.9-2 5.10 Burnup Requirements for Region 2

Figure 3.9-3 Spent Fuel Pool Rack Minimum Figure 3.9-3 5.10 Burnup Requirements for Region 3

Figure 3.9-4 Spent Fuel Pool Rack Region Figure 3.9-4 5.10 Locations 3/4.9.15- Spent Fuel Cooling None 5.7 3/4.9.16 Spent Fuel Cooling Defueled 3/4.9.16 5.10 3/4.10 Deleted in previous amendment None 5.10 3/4.11 Radioactive Effluents None 5.2 3/4.11.1 Liquid Effluents None 5.2 3/4.11.1.1 Liquid Effluents - Concentration None REMODCM, 5.2 Note 1 3/4.11.1.2 ' Dose, Liquids None 5.2 l 3/4.11.2 Gaseous Effluents None REMODCM, 5.2 Note 1 3/4.11.2.1- Dose Rate None REMODCM, 5.2 Note 1 l

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l CTS Section Description ATS Section Commitment SER Section 3/4.11.2.2 Dose, Noble Gases None REMODCM, 52  ;

Note 1 j 3/4.11.2.3 Dose, Radioactive Materialin None- REMODCM, 5.2 Particulate Form and Note 1

, Radionuclides Other than Noble Gases '

3/4.11.3 Total Dose None REMODCM, - 5.2 .

Note 1 5.1 Site 5.1 5.4 5.1.1 Exclusion Area None 5.9 5.1.2 Low Population Zone None 5.9 Figure 5.1-1 Exclusion Area Boundary and Site None 5.9 Boundary for Liquid and Gaseous Effluents -

Figure 5.1-2 Low Population Zone None 5.9 5.5 Meteorological Tower Location None 5.9 5.6 Spent Fuel Storage 5.2 5.10 5.6.1 Criticality 5.2.1 5.10 5.6.1.a For Region 1 5.2.1.a 5.10 5.6.1.b For Region 2 5.2.1.b 5.10 5.6.1.c For Region 3 5.2.1.c 5.10 5.6.2 Drainage ' 5.2.2 5.10 5.6.3 Capacity 5.2.3 5.10 6,1 Responsibility 6.1 5.10 6.1.1 VP- Operations & 6.1.1 NA Decommissioning None Unit Director 6.1.2 5.4 i

None' Shift Manager 6.1.3 5.4 1 6.2 - Organization 6.2 5.10

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6.2.1 . Onsite & Offsite Organization 6.2.1 5.4 6.2.1.a- Lines of authority- 6.2.1.a NA 6.2.1.b Unit Director 6.2.1.b 5.4

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6.2.1.c VP- Operations & 6.2.1.c NA Decommissioning 6.2.1.d Individuals who train 6.2.1.d 5.4 6.2.2 Facility Staff 6.2.2 5.10 6.2.2.a Each on-duty shift 6.2.2.a NA l 6.2.2.b At least one person qualified 6.2.2.b 5.10 i 6.2.2.c Individual qualified in radiation 6.2.2.c NA l protection (includes footnote) 6.2.2.d All fuel handling operations 6.2.2.d 5.4 6.2.2.e Deleted . None 5.4 6.2.2.f Administrative procedures shall 6.2.2.e 5.4 None The Shift Manager shall 6.2.2.f 5.4 Table 6.2-1 Minimum Shift Crew Composition Table 6.2-1 5.4 (includes footnote) 6.3 Facility Staff Qualifications 6.3 5.10 6.3.1 Each member of - 6.3.1 NA 6.3.1.1 The position of Health Physics 6.3.1.1 NA j l Manager 6.3.1.1.a Academic degree 6.3.1.1.a NA 6.3.1.1.b Minimum of five years 6.3.1.1.b NA 6.3.1.1.c Technical experience 6.3.1.1.c NA 6.3.1.1.d Academic and technical 6.3.1.1.d NA experience 6.3.1.2 Deleted in previous amendment None 5.10 l

6.4 Training 6.4 5.4 None An NRC approved retraining 6.4.1 5.4 1

! 6.5 Review and Audit None OAP, Note 4 5.3 6.5.1 - Plant Operational Review None OAP, Note 4 5.3 Committee (PORC)

(and subsections) 6.5.1.1 Function None OAP, Note 4 5.3 L

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J HNP List of Changes Attachment 1 Page 9 CTS Section Description ATS Section Commitment SER Section 6.5.1.2 Composition None OAP, Note 4 5.3 6.5.1.3 Alternates None OAP, Note 4 5.3 6.5.1.4 Meeting Frequency None OAP, Note 4 5.3 6.5.1.5 ' Ouorum None OAP, Note 4 5.3 6.5.1.6'- Responsibilities None' OAP, Note 4 5.3 6.5.1.6.a Review of: (1) all procedures None OAP, Note 4 5.3 6.5.1.6.b Review of all proposed tests None OAP, Note 4 5.3 6.5.1.6.c Rev.'ew of all proposed changes None OAP, Note 4 53 to the Technical Specifications 6.5.1.6.d Review of all proposed changes None OAP, Note 4 5.3 or modifications -

6.5.1.6.e Investigation None OAP, Note 4 5.3 6.5.1.6.f Review of all reportable events None OAP, Note 4 5.3 6.5.1.6.g Review of facility operations None OAP, Note 4 5.3 6.5.1.6.h Performance of special reviews None OAP, Note 4 5.3 6.5.1.6.i Not used - None OAP, Note 4 5.3 6.5.1.6.J- Not use'd None OAP, Note 4 5.3 6.5.1.6.k Review of the Fire Protection None OAP, Note 4 5.3 6.5.1.7 Authority None OAP, Note 4 5.3 6.5.1.7.a Report to None OAP, Note 4 5.3 6.5.1.7.b Render determination None OAP, Note 4 5.3 6.5.1.7.c' Provide written notification None OAP, Note 4 5.3 6.5.1.8 Records None OAP, Note 4 5.3 6.5.2 Nuclear Safety Assessment None OAP, Note 4 5.3 Board 6.5.2.1 Function None OAP, Note 4 5.3 6.5.2.1.a The Chairperson None OAP, Note 4 5.3 6.5.2.1.a.1 An academic degree None OAP, Note 4 5.3 6.5.2.1.a.2 A minimum None OAP, Note 4 5.3 6.5.2.1.b The NSAB None OAP, Note 4 5.3 i

HNP List of Changes Attachment 1 Page 10 CTS Section Description ATS Section Commitment SER Section 6.5.2.2 Composition None OAP, Note 4 5.3 6.5.2.3 Alternates None OAP, Note 4 5.3 6.5.2.4 Meeting Frequency None OAP, Note 4 5.3 6.5.2.5 Ouorum None OAP, Note 4 5.3 6.5.2.6 Review Responsibilities None OAP, Note 4 5.3 6.5.2.6.a The safety None OAP, Note 4 5.3 6.5.2.6.b Proposed changes to procedures None OAP, Note 4 5.3 6.5.2.6.c Proposed tests None OAP, Note 4 5.3 6.5.2.6.d Proposed to Technical None OAP, Note 4 5.3 Epecifications 6.5.2.6.e Walations None OAP, Note 4 5.3 6.5.2.6.f All f.lcensee Event None OAP, Note 4 5.3 6.5.2.6.g Indications None OAP, Note 4 5.3 6.5.2.6.h Signsficant accidental None OAP, Note 4 5.3 6.5.2.6.1 Significant operating None OAP, Note 4 5.3 6.5.2.6.1 The performance None OAP, Note 4 5.3 6.5.2.6.k Audits None OAP, Note 4 5.3 6.5.2.7 Audit Program Responsibilities None OAP, Note 4 5.3 6.5.2.7 a The confomlance None OAP, Note 4 5.3 6.5.2.7.b The training None OAP, Note 4 5.3 6.5.2.7.c The implementation None OAP, Note 4 5.3 6.5.2.7.d The Fire Protection Program None OAP, Note 4 5.3 6.5.2.7.e The fire protection equipment None OAP, Note 4 5.3 6.5.2.7.f Actions taken None OAP, Note 4 5.3 6.5.2.7.g Other activities None OAP, Note 4 5.3 6.5.2.8 Records None OAP, Note 4 5.3

- 6.6 Reportable Event Action None 5.8 6.6.1.a The Commission None 5.8 6.6.1.b Each reportable event None 5.8

p HNP List of Changes ' Attachment 1 Page 11 CTS Section . Description ATS Section Commitment SER Section 6.7 - Deleted in previous amendment None 5.10 6.8 - Procedures and Programs ' 6.5 5.10 6.8.1 Written procedures 6.5.1 5.4 6.8.1.a Apply Reg Guide 1.33 6.5.1.a 5.4 6.8.1.b ANSI N 18.7-1976 None 5.4 None Programs in ATS 6.6 - 6.5.1.b 5.4 6.8.1.c Fire protection 6.5.1.c 5.10

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6.8.1.d' Ouality controls for effluents 6.5.1.d 5.10 6.8.1.e Radiological Effluent Monitoring 6.5.1.b 5.4 and Offsite Dose Manual -

(REMODCM) 6.8.1.f Process Control Program 6.5.1.b 5.4 implementation None- Process Control Program (PCP) 6.6.2 5.4 None Shall be documented 6.6.2.a 5.4 None sufficient information 6.6.2.a.1 5.4 None a determination 6.6.2.a.2 5.4 None Shall become effective 6.6.2.b 5.4 6.8.1.g Spent fuel cooling and makeup 6.6.6 5.4 monitoring 6.8.2 Procedures of CTS 6.8.1 shall be 6.5.2 5.4 reviewed 6.8.3 Temporary changes 6.5.3 5.4 6.8.3.a intent not altered 6.5.3.a 5.4 6.8.3.b Approved by CFH 6.5.3.b 5.4 6.8.3.c' Documented and approved by 6.5.3.c 5.4 Unit Director- i 6.8.4 Procedures for REMODCM- 6.5.1.b 5.4 6.8.5 Review of changes to None S.4 Radiological Environmental Monitoring Manual i

HNP List of Changes = Attachment 1 Page 12 CTS Section ' Description ATS Section Commitment SER Section None' Radioactwe Effluent Controls - 6.6.4 5.2 Program None- Limitations on tt.a functional 6.6.4.a 5.2 capability.

None Limitations on the conoantrations 6.6.4.b 5.2 None_ Monitoring, sampling, and 6.6.4.c- 5.2 analysis .

None Limitations ea the annual 6.6.4.d 5.2 -

None Determination of cumulative 6.6.4.e 5.2 None Limitations on the functional 6.6.4.f 5.2 capability and use None- Limitations on the dose rates 6.6.4.g~ 5.2 None for noble gases 6.6.4.g.1 5.2 None: for tritium 6.6.4.g.2 5.2 None Limitation on the annual 6.6.4.h- 5.2 None' Limitations on the annual 6.6.4.1 5.2 None Limitations on the annual - 6.6.4.) 5.2 None' Radiological Effluent Monitoring 6.6.5 5.4 I Program None Monitoring, sampling, and 6.6.5.a 5.4 None Participating in 6.6.5.b 5.4 None Technical Specification (TS) 6.6.7 5.4 Bases Control Program -

None- Changes to the Bases 6.6.7.a 5.4 None Changes may 6.6.7.b, 5.4 None a change in the TS 6.6.7.b.1 5.4 None- a change to the updated FSAR 6.6.7.b.2 5.4 None The Bases Control Program 6.6.7.c 5.4 None Proposed changes 6.6,7.d 5.4 6.9 Reporting Requirements 6.7 5.10 6.9.1 Routine Reports : None 5.10

HNP List of Changes Attachment 1 Page 13 CTS Section Description - ATS Section Commitment SER Section 6.9.1.1 Deleted None 5.10 6.9.1.2 DeMed None 5.10 6.9.1.3 Deleted None 5.10 6.9.1.4 Annual Reports None 5.4 I 6.9.1.5 Reports required on an annual 6.7.1 5.4 basis

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6.9.1.5.a A tabulation 6.7.1 5.4 6.9.1.5.b Deleted None 5.10 6.9.1.5.c Deleted None 5.10 6.9.1.6 Annual Radiological 6.7.2 5.4 i Environmental Operating Report 6'9.1.7

. Semiannual Radioactive Effluent 6.7.3 5.4 Release Report 6.9.1.8 Deleted None 5.10 6.9.1.9 Deleted None 5.10 l

6.9.2 Special Reports None 5.8  ;

OAP, Note 4 I 6.10 Record Retention None 5.3 6.10.1 in addition to None OAP, Note 4 5.3 6.10.2 The following records None OAP, Note 4 5.3 6.10.1.a Records and logs of facility None OAP, Note 4 5.3 6.10.1.b Records and logs of principal None OAP, Note 4 5.3 6.10.1.c All reportable events None OAP, Note 4 5.3 6.10.1.d Records of surveillance None OAP, Note 4 5.3 6.10.1.e Records of tests None OAP, Note 4 5.3 6.10.1.f Records of changes None OAP, Note 4 5.3 6.10.1.g Records of radioactive None OAP, Note 4 5.3 6.10.1.h~ Records of sealed None OAP, Note 4 5.3 6.10.1.1 Records of annual None OAP, Note 4 5.3 t

6.10.3 The following records None OAP, Note 4 5.3 l 6.10.3.a Record and drawing None OAP, Note 4 5.3

p:J HNP List of Changes Attachment 1 Page 14 l

CTS Section - Description ATS Section Commitment SER Section 6.10.3.b Records of new None OAP, Note 4 5.3 6.10.3.c Records of facility None OAP, Note 4 5.3 6.10.3.d Records of radiation None. CAP, Note 4_ 5.3

.3.3.e Records of gaseous None OAP, Note 4 5.3 1 6.10.3.f Records of transient None OAP, Notr. 4 5.3 6.10.3.g Records of training None OAP, Note 4 - 5.3 6.10.3.h Records of insentice None OAP, Note 4 5.3 QAP, Note 4 6.10.3.1 Records of quality None 5.3 l l

6.10.3.] Records of reviews - None OAP, Note 4 5.3 )

i i 6.10.3.k Records of meetings None OAP, Note 4 5.3 6.10.3.1 Records for Environmental None OAP, Note 4 5.3 6.10.3.m Records of reviews None OAP, Note 4 5.3 6.11 Radiation Protection Program 6.6.1 5.10-6.11.1 Procedures for personnel 6.6.1 5.10 6.12 High Radiation Area 6.8 5.10 6.12.1 Pursuant to 6.8.1 5.10 I i

6.12.1.a - A radiation monitoring device 6.8.1.a 5.10 i which continuously indicates 6.12.1.b A radiation monitoring device 6.8.1.b 5.10 which continuously indicates 6.12.1.c An individual qualified 6.8.1.c 5.10 6.12.2 in addition to 6.8.2 5.10 (first paragraph) 6.12.2 For individual high radiation 6.8.3 5.10 l (second paragraph) 6.13 Radiological Effluent Monitoring 6.6.3 5.4 and Offsite Dose Calculation Manual (REMODCM) 6.13.a Shall be documented 6.6.3.a 53 6.13.a.1 Sufficient information 6.6.3.a.1 5.4 L

. HNP List of Changes Attachment 1 Page 15 CTS Section _ Description - f ATS Section Commitment SER Section 6.13.a.2 A determination 6.6.3.a.2 5.4 6.13.b Shall become effective - 6.6.3.b- 5.4 6.13.c i Shall be submitted : 6.6.3.c 5.4 6.14: Radiosctive Waste Treatment 6.5.1.e 5.4 -

6.15, Deleted None. 5.10 4

6.16 Deleted None 5.10

-Abbreviations:

1. TS = Technical specifications 2; 3/4 = Represents a limiting condition for operation and its requirement (s) :

'3. :TRM = Technical Requirements Manual

. 4.' REMODCM = Radioactive Effluent Monitoring and Offsite Dose Calculation Manual

5. QAP = Quality Assurance Plan 6.' ' UFSAR = Updated Final Safety Analysis Report .

c 7. CFH = Certified Fuel Handler

8. - SER = Safety Evaluation Report

9. NA = Not applicable. Where this appears in the SER column, no change was made to the TS listed

. in the corresponding row.

Notes:

1. By letter dated August 24,1999, the licensee submitted commitment number CY-99-105-02 to i- relocate these requirements to its REMODCM.

2. By letter dated August 24,1999, the licensee submitted commitment number CY-99-105-01 to

. relocate these requirements to its TRM. _ _

- 3. - The licensee clarified in a phone call on Seplamber 2,1999, that commitment number CY-99-105-01 was intended to include relocation of the tabbs associated with CTS 3/4.3.3.4 to the TRM.

/ 4. By letter dated August 24,1999i the licensee submitted commitment number CY-99-105-03 to

, relocate these requirements to its QAP.

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F ATTACHMENT 2 l

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I List of Amended Technical Specifications June 3,1999 TS Change Request A1S Section Description CTS Section SER Section License C(6) Fuel Movement License C(7) 5.6 License D Expiration Date - License D 5.6 -

Index- Index Index 5.10  ;

1.1. Action 1.1 NA 1.2 Certified Fuel Handla- None 5.4 l 1.3 Member (s) of the Public 1.15 5.10 1.4 Operable - Operability 1.17 5.10 1.5 Radioactive Waste Treatment 1.23 5.10 Systems 1.6 Radiological Effluent Monitoring and 1.24 5.10 Offsite Dose Calculation Manual (REMODCM) 1.7 Site Boundary 1.29 5.10 3/4.0 Applicability 3/4.0 NA 3.0.1 Compliance with LCO 3.0.1 NA 3.0.2 Noncompliance with specification 3.0.2 NA 3.0.3 Deleted 3.0.3 NA 3.0.4 - Entryinto ACTION requirement 3.0.4 NA 4.0.1 Surveillance requirements shall be 4.0.1 NA met 4.0.2 Surveillance requirements shall be 4.0.2 NA performed 4.0.3 Failure to perform a surveillance 4.0.3 NA requirement 4.0.4 No entry into applicable condition 4.0.4 NA unless surveillance has been performed 3/4.9- Refueling Operation 3/4.9  ;

3/4.9.7 Crane Travel- Spent Fuel Building 3/4.9.7 5.5 3/4.9.11 Water Level- Spent Fuel Pool 3/4.9.11 5.10 3/4.9.13 Movement of Fuelin Spent Fuel 3/4.9.13 5.10 j Pool 3/4.9.14' Spent Fuel Pool Reactivity 3/4.9.14 5.10

,- Condition l

7

)

ATS Listing Attachment 2 Page 2 ATS Section Description CTS Section SER Section Figure 3.9-2 Spent Fuel Pool Rack Minimum Figure 3.9-2 5.10 Burnup Requirements for Region 2 Figune d.9-3 Spent Fuel Pool Rack Minimum Figure 3.9-3 5.10 Burnup Requirements for Region 3 Figure 3.9-4 Spent Fuel Pool Rack Region Figure 3.9-4 5.10 Locations 3/4.9.16 Spent Fuel Cooling - Defueled 3/4.9.16 5.10 5.1 Site 5.1 5.4 5.2 Spent Fuel Storage 5.6 5.10 5.2.1 Criticality 5.6.1 5.10 5.2.1.a For Region 1 5.6.1.a 5.10 l

5.2.1.b For Region 2 5.6.1.b 5.10 l 5.2.1.c For Region 3 5.6.1.c 5.10 5.2.2 Drainage 5.6.2 5.10 5.2.3 Capacity 5.6.3 5.10

]

6.1 Responsibility 6.1 J 5.10 l 6.1.1 VP - Operations & 6.1.1 NA l Decommissioning l l

6.1.2 Unit Director None 5.4 6.1.3 Shift Manager None 5.4 )

6.2 Organization 6.2 5.10 6.2.1 General Organizational 6.2.1 5.4 Requirements '

6.2.1.a Lines of authority 6.2.1.a NA 6.2.1.b The Unit Director 6.2.1.b 5.4 6.2.1.c The VP Operations & 6.2.1.c NA Decommissioning 6.2.1.d The individuals who train 6.2.1.d 5.4 6.2.2 Facility Staff 6.2.2 5.10 6.2.2.a Each on-duty shift 6.2.2.a NA ,

6.2.2.b At least one person qualified 6.2.2.b 5.10 6.2.2.c Individual qualified in radiation 6.2.2.c NA protection (includes footnote) 6.2.2.d All fuel handling operations 6.2.2.d 5.4

l ATS Listing Attachrnent 2 Page 3 ATS Section Description CTS Section SER Section 6.2.2.e Administrative procedures shall 6.2.2.f 5.4 6.2.2.f The Shift Manager shall None 5.4 Table 6.21 Minimum Shift Crew Composition Table 6.2-1 5.4 (includes footnote) 6.3 Facility Staff Qualifications 6.3 5.10 6.3.1 Each member of 6.3.1 NA 6.3.1.1 The position of Health Physics 6.3.1.1 NA Manager 6.3.1.1.a Academic degree 6.3.1.1.a NA 6.3.1.1.b Minimum of five years 6.3.1.1.b NA 6.3.1.1.c Technical experience 6.3.1.1.c NA 6.3.1.1.d Academic and technical experience 6.3.1.1.d NA 6.4 Training 6.4 5.4 I J

6.4.1 An NRC approved retraining None 5.4 6.5 Procedures and Programs 6.8 5.10 6.5.1 Written procedures 6.8.1 5.4 1

6.5.1.a Apply Reg Guide 1.33 6.8.1.a 5.4 6.5.1.b All programs specified in 6.8.1.e 5.4  ;

Specification 6.6 6.8.4 5.4 1 6.13 5.4 6.5.1.c Fire protection 6.8.1.c 5.10 6.5.1.d Quality controls for effluents 6.8.1.d 5.10 6.5.1.e Radioactive Waste Treatment 6.13 5.4 6.14 5.4 6.5.2 Procedures of ATS 6.5.1 & ATS 6.6 6.8.2 5.4 shall be reviewed 6.5.3 Temporary changes 6.8.3 5.4 6.5.3.a Intent not altered 6.8.3.a 5.4 6.5.3.b Approved by CFH 6.8.3.b 5.4 6.5.3.c- Documented and approved by Unit 6.8.3.c 5.4 Director 6.6i1 Radiation Protection Program 6.11 5.10 6.6.1 A program for 6.11.1 5.10 6.6.2 Process Control Program (PCP) 6.8.1.f 5.4

I ATS Listing Attachment 2 Page 4 ATS Section Description CTS Section SER Section 6.6.2.a Shall be documented None 5.4 6.6.2.a.1 sufficient information None 5.4 6.6.2.a.2 a determination None 5.4 6.6.2.b Shall become effective None 5.4 6.6.3 Radiological Effluent Monitoring and 6.13 5.4 Offsite Dose Calculation Manual (REMODCM) 6.6.3.a Shall be documented 6.13.a 5.4 i 6.6.3.a.1 Sufficient information 6.13.a.1 5.10 6.6.3.a.2 A determination 6.13.a.2 5.10 l

6.6.3.b Shall become effective 6.13 b 5.4 6.6.3.c Shall be submitted 8.13.c 5.4 I 6.6.4 Radioactive Effluent Controls None 5.2 i Program 6.6.4.a Limitations on the functional None 5.2 capability i 6.6.4.b Limitations on the concentrations None 5.2 6.6.4.c Monito, ig, sampling, and analysis None 5.2 6.6.4.d Limitations on the annual None 5.2 6.6.4.e Determination of cumulative None 5.2 6.6.4.f Limitations on the functional None 5.2 capability and use l 6.6.4.g Limitations on the dose rates None 5.2 6.6.4.g.1 for noble gases None 5.2 6.6.4.g.2 for tritium None 5.2 6.6.4.h Limitation on the annual None 5.2 6.6.4.i Limitations on the annual None 5.2 6.6.4.j Limitations on the annual None 5.2 6.6.5 Radiological Effluent Monitoring None 5.4 Program ,

6.6.5.a Monitoring, sampling, and None 5.4 6.6.5.b Participation in None 5.4 6.6.6 Spent fuel cooling and makeup 6.8.1.g 5.4

! monitoring

ATS Listing . Attachment 2 Page 5 ATS Section Description - CTS Section , SER Section L 6.6.7 Technical Specification (TS) Bases - None 5.4 Control Program B 6.7.a Changes to the Bases None 5.4 1 6.6.7.b_ Changes may None 5.4 6.6.7.b.1 a change in the TS None 5.4 6.6.7.b.2' a change to the updated FSAR None 5.4 6.6.7.c The Bases Control Program None 5.4 6.6.7.d Proposed changes None 5.4 6.7 Reporting Requirements 6.9 5.10 6.7.1 Occupational Radiation Exposure 6.9.1.5 5.4 l

Report 6.9.1.5.a 6.7.2 Annual Radiological Environmental 6.9.1.6 5.4 Operating Report

6.7.3 Annual Radioactive Effluent 6.9.1.7 5.4 Release Report

! 6.8 High Radiation Area 6.12 5.10 6.8.1 Pursuant to 6.12.1 5.10 6.8.1.a A radiation monitoring device that - 6.12.1.a 5.10 contir uously indicates 6.8.1.b A radiation monitoring device that 6.12.1.b 5.10 continuously indicates 6.8.1.c An individual qualified 6.12.1.c 5.10 6.8.2 in addition to 6.12.2 5.10 (first paragraph)

G.8.3 For individual high radiation 6.12.2 5.10 (second i paragraph) l Abbreviations:

l-

1. TS = Technical specifications L 2, 3/4 = Represents a limiting condition for operation and its associated surveillance requirement (s)

3. TRM = Technical Requirements Manual 4; . REMODCM = Radioactive Effluent Monitoring and Offsite Dose Calculation Manual j L t

~

5. CAP = Quality Assurance Plan I l 6. UFSAR = Updated Final Safety Analysis Report

.7. CFH = Certified Fuel Handler

8. SER = Safety Evaluation Report j l

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