ML20210A604
| ML20210A604 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/19/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20210A601 | List: |
| References | |
| NUDOCS 9907220150 | |
| Download: ML20210A604 (13) | |
Text
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-1 L'NITED STAc 3 l
,j NUCLEAR REGULATORY COMMISSION l
~t WASHINGTON, D.C. 20555-0001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l
RELATED TO AMENDMENT NO.171TO FACILITY OPERATING LICENSE NO. DPR-28 VERMONT YANKEE NUCLEAR POWER CORPORATION VERMONT YANKEE NUCLEAR POWER STATION i
DOCKET NO. 50-271
1.0 INTRODUCTION
The Verment Yankee Nuclear Power Station is a boiling water reactor (BWR), model BWR-4, with a Mark I containment. By letter dated February 1,1999, as supplemented on April 19 and April 23,1999, the Vermont Yankee Nuclear Power Corporation, the licensee for the Vermont Yankee Nuclear Power Station, submitted for U. S. Nuclear Regulatory Commission (NRC or the Commission) staff's review a proposed change to the technical specifications (TS). The licensee proposed to modify Section 6.0 including removing or relocating requirements that are adequately controlled by existing regulations other than 10 CFR 50.36 and the TS.
Administrative changos to cortain other sections of the TSs were also proposed to conform to the changes resulting from the re-write of Section 6.0.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act of 1954, as amended (the Act) requires applicants for nuclear power plant operating licenses to include the TSs as part of the license. The Commission's regulatory requirements related to the content of the TSs are set forth in 10 CFR 50.36. That regulation requires that the TS include items in eight specific categories. The cc.tegories are (1) safety limits, limiting safety system settings, and limiting control settings; I
(2) limiting conditions for operation; (3) surveillance requirements; (4) d3 sign features; (5) administrative controls; (6) decommissioning; (7) initial notification; and (8) written reports.
However, the regulation does not specify the particular requirements to be included in a plant's TSs.
The Commission amended 10 CFR 50.36 (60 FR 36593, July 19,1995), and codified four criteria to be used in determining whether a particular matter is required to be included in a limiting condition for operation (LCO), as follows: (1) lostalled 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
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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; (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 the ;ailure of or presents a challenge to the integrity of a fission product barrier; or (4) a structure, system, or component which operating experience or probabilistk safety assessment has shown to be significant to public health and safety. LCOs and related requirements that fall within or satisfy any of the 9907220150 990719 PDR ADOCK 05000271 P
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2-criteria in the regulation must be retained in the TS, while those requirements that do not fall within or satisfy these criteria may be relocated to licensee-controlled documents. While the criteria specifically apply to LCOs, in adopting the revision to the Rule the Commission noted that the staff had used the intent of these criteria to identify the optimum set of administrative controls in the TS (60 FR 36957).
- The regulation at 10 CFR 50.36 states that Administrative Controls "are the provisions relating i
to organization and management, procedures, recordkeeping, review and aud!!, and reporting necessary to assure operation of the facility in a safe manner." The specific content of the Administrative Controls section of the TS is, therefore, that information which the Commission deems essential for the safe ooeration of the facility which is not already adequately covered by other regulations. Accordingly, the staff has determined that requirements that are n'ot specifically required under 10 CFR 50.36(c)(5), and that are not otherwise necessary for operation of the facility in a safe manner, can be removed from Section 6.0 Administrative i
Controls.
3.0 EVALUATION The following discussions set forth in detail the staff's conclusions regarding the removal or relocation of selected administrative controls from the Vermont Yankee TS. The changes were reviewed in accordance with the guidance provided in, or planned for, the Standard Technical Specifications (STS), NUREG-1433. In addition, these changes were reviewed in accordance with the guidance provided in Administrative Letter 95-06 " Relocation of TechnK,d Specifications Administrative Controls Related to Oaality Assurance."
License amendment requests should describe the relocation of each selected requirement to a particular licensee-controlled document or program (e.g., the final safety analysis repo:t (FSAR) or tne quality assurance (QA) p!an). The description should also address the submittal of the revised documents to the NRC in accordance with the applicable regulation (e.g.,10 CFR 50.71(e)). In the amendment request, the licensee should clearly describe the program it will use to control changes to relocated requirements (e.g.,10 CFR 50.59 or 50.54(a)). Control of the relocated requirements in accordance with the applicable regulation ensures that NRC review and approval will be proposed for changes exceeding the stated regulatory threshold (e.g., an unreviewed safety question or a reduction in commitment), Elimination of reporting requirements that are recommended for relocation or removal from the TS can be proposed if they are not required by 10 CFR 50.72,10 CFR 50.73, or other regulations.
3.1 Table of Contents The proposed changes to the Table of Contents reflect the changes to Section 6.0. These changes to the Table of Contents are administrative only and reflect the proposed changes discussed in this saftay evaluation (SE). Tiie changes do not change the technical requirements. Therefore, the proposed changes to the Table of Contents are acceptable to the staff.
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-, 3.2 Changes to TS other than Section 6.0 The licensee proposed numerous editorial changes to the TS outside of Section 6.0 which were necessary to reflect the proposed changes to Section 6.0 such as changing the title of the
" Annual Radioactive Etfluent Release Report" to the " Radioactive Effluent Release Report",
changing the title of the " Annual Radiological Environmental Surveillance Report" to the " Annual i
Radiological Environmental Operating Report," and other editorial changes necessary to reflect the proposed change numbering and relocations. The staff considers these proposed changes to be acceptable since they are administrative only, do not change the technical requirements in the TS, and ei.sure consistency with the proposed changes to TS Section 6.0 which are discussed later in this evaluation.
3.3 Administrative Controls Section 6.0 The cunent TS provides a general description of the Administrative Controls and states that these controls shall be adhered to. The licensee propo ;ed to delete this section since 10 CFR 50.36(c)(5) clearly and formally explains the purpose of the Administrative Controls section of the TS. The staff agrees that the description in 10 CFR 50.36(c)(5) is adequate and the information can be deleted from the TS. Therefore, this change is acceptable to the staff.
3.4 Responsibility Section 6.1 l
The current title of TS Section 6.1, " Organization," is being changed to " Responsibility." The first paragraph of the current TS Section 6.1 is revised to conform to the STS, with the following exceptions. Th3 title " Plant Manager" is used instead of Plant Superintendent since it is the title currently in use at Vermont Yankee for the position with overall responsibility. These changes are administrative and are consistent with the licensee's organization; therefore, they are acceptable to the staff.
The second paragraph of Section 6.1, added in conformance with the STS, provides further description of the plant manager's responsibilities and is acceptable to the staff. The third paragraph of Section 6.1, added in conformance with the STS, specifies the responsibilities of the Shift Supervisor. -These changes include relocation of requirements from the current TS Table 6.1.1 and addition of more restrictive requirements not in the current TS that appropriately describe the duties of these positions. Therefore, the proposed changes are acceptable to the staff. In addition, the proposed changes are consistent with NUREG-1433.
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3.5 Organization - Onsite and Offsite Organizations Current TS 6.1, " Organization." which includes the following sections:
TS 6.1.A Lines of authority, responsibility, and communication TS 6.1.B Plant Manager responsibilities i
TS 6.1.C Manager of Operations responsibilities 1
TS 6.1.D Conduct of Operations (plant staff requirements and qualifications)
TS 6.1.E Fire Brigade requirements
c is proposed to be renumbered TS 6.2, " Organization." Revised TS 6.2 consists of TS 6.2.A.
"Onsite and Offsite Or9anization," TS 6.2.B, " Unit Staff", and TS 6.2.C " Unit Staff Qualifications," to conform with the organization of the STS.
Proposed TS 6.2.A conforms in content with the STS. The following changes from the current TS were proposed in developing TS 6.2.A.
The licensee proposed an administrative change to the current TS Section 6.1.A to raference the " Vermont" Yankca Operation Quality Assurance Manual (OA Manual) rather than the Yankee Operational Quality Assurance Manual due to a change in nomenclature. This does not represent a technical change; therefore, the proposed change is acceptable to the staff.
Succession requirements for the Plant Manager were moved from current TS 6.1.B to TS 6.'I.A.
j This change is acceptable to the staff since the proposed TS 6.1.A adequately addresses the requirements in this area.
4 The licensee proposed to change the reference to the Manager of Operations in current TS 6.1.C to " corporate executive with direct respansibility for the plant." This replaces a specific titl3 with a corporate position with the samc corresponaing responsibilities. Future changes in title for individuals in this position will therefore not necessitate a TS change. This change is acceptable to the staff since the proposed change adequately describes the position of the individual with these responsibilities.
Proposed TS 6.2.A.4 is a copy of current TS 6.1.D.8. with minor editorial changes that do not represent technical changes. Therefore, the proposed change is acceptable, j
Proposed TS 6.2.B " Unit Staff" conforms in general content with the STS. The following changes from the current TS were proposed in developing TS 6.2.B.
I Proposed TS r 8.B.1 specifies the requirements for non-licensed operators. The designation of this individuai was changed from " auxiliary operator" to "non-licensed operator" which is an equivalent title for the position. These requiremer' were moved from the current TS Table 6.1.1 with no change in meaning. Proposeo.S 6.2.B.2 specifies the requirements for i
licensed reactor operators when fuel is in the reactor. This was moved from the current TS Table 6.1.1 with no change in meaning. Proposed TS 6.2.B.3 specifies the requirements for
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licensed operators in the control room during plant startup and normal operation. This was j
moved from the m ent TS Table 6.1.1 with no change in meaning. The staff finds these i
changes acceptable since they are movements of requirements within the TS with
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nomenclature, format, and wording changes which do not change the meaning of the TS.
Proposed TS o.2.B.4 specifies the minimum shift staffing requirements and provides for the conditional short-term absence of shift personnel due to an unexpected abser.ce. Title 10 of j
the Code of Federal Reculations (10 CFR) section 50.54(m) specifies the minimum shift staffing requirements and states that temporary deviations from the requirements shall be in i
accordance with the criteria established in the TS. The proposed TS allows for unexpected i
absence of on-duty shift crew members for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided immediate action is taken to restore the shift crew composition to within the minimum requirements. The staff finds this
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5-change to be acceptable since it is reasonable to allow for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for unexpected absences of shift personnel; and, this short absence will have slight or negligible impact on operation of the facility. In addition, the proposed change is consistent with NUREG-1433.
Proposed TS 6.2.B.5 specifies the requir9ments for an individual qualified in radiation protection procedores. This was moved from the current TS 6.1.D.1, which the staff finds acceptable, with the addition of a provision that allows for this position to be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position. The only potenti Iimpact of this addition is delayed entry into radiation areas to repair equipment. The staff finds this change to be acceptable since it is reasonable to allow this position to be vacant for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for unexpected absences and this short absence will have slight or negligible impact on the time equipment is out of service. In addition, the proposed change is consistent with NUREG-1433.
Prgosed TS 6.2.B.6 specifies the requirements associated with limits on working hours of the staff. The licensee stated that this is an addition to the TS as the current TS does not specify any requirements in this area. The staff finds the propo?ed change to be acceptable since it provides reasonable asourance that impaired performance caused by excessive working hours will not jeopardize safe plant operations.
Proposed TS 6.2.B.7 states that the operations manager or an assistant operations manager shall hold an SRO license. The staff considers tnat this requirement is equivalent to the requiremersts of the current TS 6.1.D.7, provides for an adequate level of operational knowledge to oversee the operations area, and is, therefore, acceptable.
Proposed TS 6.2.B.8 specifies rel uirements associated with the Shift Engineer. The licensee t
stated that this was relocated from the current TS Table 6.1.1 with clarification which does not modify any mquirement. The staff considers the proposed change to be acceptable since it is a movement of requirements within the TS.
Proposed TS 6.2.C " Unit Staff Qualifications" conforms in general content with the STS. This proposed section replaces current TS sections 6.1.D.4,6.1.D.5, and 6.1.D.6 with essentially the same requirements except for the listing of specific titles of plant personnel. The details of organizational titles have been relocated to the Technical Requirements Manual (TRM) which is incorporated by reference into the FSAR and subject to the provisions of 10 CFR 50.59. The staff finds the proposed changes to be acceptable since they constitute a movement of current requirements within the TS and those items relocated to the TRM are adequately controlled by the provisions of iO CFR 50.59.
Other sections of current TS 6.1 and Table 6.1.1 were relocated to the TRM. The staff has reviewed these items and considers the proposed changes to be acceptable since 10 CFR 50.36 does not require these items to be controlled in the TS and control of changes by the provisions of 10 CFR 50.59 is adequate.
3.6 Review and Audit The licensee proposed that the review and audit functions associated with the Plant Operations Review Committee (PORC) and Nuclear Safety Audit and Review Committee specified in
, current TS 6.2 be relocated to the Vermont Yankee Operational Quality Assurance Manual (VOOAM). Future changes would be controlled by the requirements of 10 CFR 50.54(a). The staff indicated in Administrative Letter 95-06," Relocation of Technical Specifications Administrative Controls Related to Quality Assurance," that relocation of these requirements to the OA plan was acceptable since the provisions of 10 CFR 50.54(a) provide adequate controls. The proposed change is acceptable to the staff since the provisions of 10 CFR 50.54(a) are adequate to control future changes and 10 CFR 50.36 does not require tais information to be contained in the TS.
3.7 Repwo Occurrences
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Current TS 6.3 specifies actions to be taken in the event of an occurrence in plant operation that requires reporting. The licensee proposed relocating these requirements to the TRM which is incorporated by reference into the FSAR and st hiec* to the provisions of 10 CFR 50.59. The staff finds the proposed changes to be acceptable since the reporting requirements of 10 CFR 50.72 and 50.73 adequately specify reporting requirements and those items relocated to the i
TRM are adequately controlled by the provision of 10 CFR 50.59.
I 3.8 Exceeding Safety Limits i
Current TS 6.4 specifies the actions to be taken if a safety limit is exceeded. The licensee proposed to relocate portions of TS 6.4 to the TRM. These portions of TS 6.4 are associated with prohibiting resumption of reactor operation until authorized by the NRC and internal (within the licensee's organization) reporting and analysis. Title 10 of the Code of Federal Regulations, section 50.36(c)(1)(i)(A) adequately specifies the requirements to be met if a safety limit is exceeded and the staff considers that it is not necessary to duplicate these requirements in the TS. Therefore, the proposed change is acceptable.
3.9 Procedures The licensee proposed changing current TS 6.5, " Plant Operating Procedures," to TS 6.4,
" Procedures." The title of the section and numbering changes proposed in this section do not change the technical requirements of the TS, and are therefore, acceptable to the staff. The following changes to this section were proposed.
The licensee proposed to replace the introductory section of current TS 6.5 to state " Written procedures shall be established, implemented, and maintained covering the following activities:." The staff considers this an administrative change which does not change the technical requirements, and therefore, considers the proposed change to be acceptable. In addition, this wording is consistent with the introduction section contained in NUREG-1433.
The licensee propossd to move and revise ihe requirements of current TS 6 5.B associated with radiation control standards to a new section 6.5,"High Radiation Area." ibis :s discussed in the next section of this evaluation.
The licensee proposed relocating current TS 6.5.C,6.5.D, and 6.5.E to the VOOAM. These sections involve procedures for review and approval of plant procedures and temporary
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. changes to procedures. Future changes would be controlled by the requirements of 10 CFR 50.54(a). The staff indicated in Administrative Letter 95 06 that relocation of these requirements to the QA plan wac acceptable since tne provisions of 10 CFR 50.54(a) provide adequate controls. The proposed change is acceptable to the staff since the provisions of 10 CFR 50.54(a) are adequate to control future changes and 10 CFR 50.36 does not require
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this information to be contained in the TS.
I The licensee proposed relocating current TS 6.5.F specifying controls associated with licensed radioactive sealed sources to the TRM. The staff considers the proposed change to current TS 6.5.F to be acceptable since this inf ormation is not required to be included in the TS per 10 CFR 50.36 and the provisions of 10 CFR 50.59 provide adequate controls for these items.
3.10 High Radiation Area j
The licensee proposed to move and revise the requirements of current TS 6.5.B associated with radiation control standards to a new section 6.5,"High Radiation Area." The new heading j
for proposed TS 6.5 and formatting / numbering changes do not change the technical meaning j
of the TS and are therefore acceptable to the staff. The following additional changes were proposed.
The licensee proposed to relocate the introductory paragraph of the current TS 6.5.B addressing radiation control standards and procedures to the VOQAM along with the requirements contained in current TS 6.5.8 related to the radiation protection program. The staff finds this proposed change to be acceptable since: (1) 10 CFR 20.1101 adequately addresses radiation protection program requirements; (2) 10 CFR 50.36 does not require this information to be contained in the TS; and (3) the provisions of 10 CFR 50.54(a) provide adequate contiols for these items.
The licensee proposed to add an introductory paragraph stating that "As provided in paragraph 20.1601(c) of 10 CFR 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraphs 20.1601(a) and 20.1601(b) of 10 CFR 20:." Title 10 of the cme of Federal Reaulations (10 CFR) section 20.1601(c) allows for alternative methods for controlling access to high radiation areas. The proposed paragraph provides an introduction to the following sections which identify the alternative methods that are allowed. The proposed change is acceptable to the staff since it merely provides an introduction to the following sections and does not change the technical content of the TS.
The licensee proposed moving a footnote to current TS 6.5.B.1, involving health physics personnel requirements with regard to radiation work permit requirements, to the body of the TS (proposed TS section 6.5.A) making minor changes in wording which do not affect the technical requirements of the TS. The staff considers the proposed change to be acceptable since it does not change the technical content of the TS.
The licensee proposed to allow the use of remote monitoring (such as closed circuit TV cameras) for periodic radiation surveillance of activities addressed in current TS 6.5.B.1.c. Also proposed was changing TS 6.5.B.1 which requires " locked doors" to prevent unauthorized entry into high radiation areas to state " locked or continuously guarded entryways" may be used. The 1
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o o staff considers these changes to be acceptable since they provide an adequate level of radiological control.
3.11 Plant Operating Records The licensee proposed relocating current TS 6.6 regarding retention of plant operating records to the VOOAM, The liq.1see stated that the requirements for retention of records related to activities affecting quality are contained in 10 CFR Part 50, Appendix B, Criterion XVil and other sections of 10 CFR Part 50. Future changes would be controlled by the requirements of 10 CFR 50.54(a). The staff indicated in Administrative Letter 95-06 that relocation of these requirements to the OA plan was acceptable since the provisions of 10 CFR 50.54(a) provide adequate controls. The proposed change is acceptable to the staff since the provisions of 10 CFR 50.54(a) are adequate to control future changes and 10 CFR 50.36 does not require this information to be contained in the TS.
3.12 Reporting Requirements Over the last several years, there were several initiatives to reduce unnecessary administrative burdens associated with reporting requirements, while retaining an appropriate level of publicly accessible information flow. The staff has concluded that many reports are unnecessary because the information is duplicated in other reports, such as reports specified by the Offsite Dose Calculation Manual, Radioactive Effluent Controls Program, and Radiological i
Environment Monitoring Program, or the reports are not required for the safe operation of the plant. In addition, the notification requirements in 10 CFR 50.72 and 50.73 for plant conditions that may be safety significant, or warrant emergency response, address these matters.
The licensee proposed changes to the current TS 6.7, " Reporting Requirements," which will become TS 6.6. Current TG 6.7 contains major report groups consisting of TS 6.7.A," Routine j
Reports;" TS 6.7.B, " Reportable Occurrences;" and TS 6.7.C, " Unique Reporting Requirements." The licensee proposed removing these major report group headings since each individual report will be listed rather than group headings. The staff considers this and other editorial and numbering changes to this section to be acceptable since they do not change the technical content of the TS. The following addiional changes were proposed.
The licensee proposed to change the introductory paragraph in current TS 6.7 to ead "The following reports shall be submitted in accordance with 10 CFR 50.4." The curre. t TS states that the reports shall be submitted to the Director of the appropriate Regional Office of Inspection and Enforcement unless otherwise noted. This position no longer exists in the NRC.
The staff considers the proposed change to be acceptable since 10 CFR 50.4," Written Communications," adequately describes tha requirements in this area. In addition the staff notes that this wording is consistent with NUREG-1433.
The licensee proposed relocating cur:ent TS 6.7.A.1 "Startup Report" to the TRM. The staff finds this proposed change to be acceptable since 10 CFR 50.36 does not require this information to be contained in the TS and the provisions of 10 CFR 50.59 provide adequate controls for this item.
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The licensee proposed changing the title of current TS 6.7.A.2 from " Annual Report" to
" Occupational Radiation Exposure Report" to more accurately describe the content of the report. In addition, the licensee proposed changing the submittal date from " prior to March 1" to
" prior to April 30" of each year. The licensee also proposed to change the word "shall" to "should" in the last sentence of current TS 6.7.A.2 such that it would read "In the aggregate, at least 80% of the total whole body dose received from external sources should be assigned to specific major work functions." The staff considers the proposed changes to be acceptable since the title change more accurately describes the report, submittal by April 30 of each year is considered timely, and the change from "shall" to "should" provides flexibility and reasonable assurance that radiological requirements will continue to be met. In addition, the staff notes that these changes are consistent with NUREG-1433.
The lictensee proposed changing the title of current TS 6.7.A.3 from " Monthly Statistical Report" to "Moethly Operating Reports" to more accurately describe the report's contents. In addition, the licolsee proposed removing a statement in this section and current TS section 6.7.A.4,
" Core Operating Limits Report," indicating to whi:h NRC offices the reports are a be sent. The staff considers these changes to be acceptable since the title change more accurately describes the report and 10 CFR 50.4, " Written Communications," adequately describes the requirements regarding submitting written communications to the NRC. In addition, the staff I
notes that this wording is consistent with NUREG-1433.
The licensee proposed changing the title of current TS 6.7.C.1 from " Annual Radioactive Effluent Release Report" to " Radioactive Effluent Rebse Report," relocating the information in this section to the Offsite Dose Calculation Manual (ODCM), and replacing the information in TS with the following:"The Radioactive Effluent Release Report covering the operation of the
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unit shall be submitted by May 15 of each year and in accordance with 10 CFR 50.3Sa. The report shallinclude a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released for the unit. The material provided shall be consistent with the objectives
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outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a 1
and t 0 CFR 50, Appendix 1,Section IV.B.1." The staff considers the proposed changes to be i
acceptable since the title change adequately describes the report, the information relocated to i
the ODCM is not required to remain in the TS by 10 CFR 50.36, and the information added to j
the TS adequately summarizes the report requirements. In addition, the staff notes that these change are consistent with NUREG-1433.
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The licensee proposed relocating special reports required by current TS 6.7.C.2.a through I
6.7.C.2.e from TS to the ODCM. The reports involve liquid effluents, gaseous offluents, total dose, radiological environmental monitoring, and land use. The staff considers the proposed i
changes to be acceptable since the reports are not reauired for safe operation of the plant and 10 CFR 50.36 does not require this information to be contained in the TS. In addition, the staff notes that these change are consistent with NUREG-1433.
The licensee proposed changing the title of current TS 6.7.C, proposed to become TS 6.6.E, from " Environmental Radiological Monitoring" to " Annual Radiological Environmental Operating Report" and changing references to this revised report title withir, the TS. The staff considers the proposed changes to be acceptable since the title change adequately describes the report.
In addition, the licensee proposed to change the submittal requirement for this report from
t May 1 to May 15 of each year. The staff considers this proposed change to be acceptable since submittal by May 15 of each year is considered timely. The licensee proposed replacing wording in this section describing the contents of the report to state '"The material provided shall be consistent with the objectives outlined in the ODCM, and in 10 CFR 50, Appendix 1, Sections IV.B.2, N.B.3, and IV.C." This proposed change is acceptable to the staff since it adequately describes the information that the NRC expects to be contained in this report. The licensee proposed to relocate other reporting details from TS 6.7.C to the ODCM. The staff considers this change to be acceptable since 10 CFR 50.36 does not require the reporting details being removed to be contained in the TS. In addition, the staff notes the change to current TS 6.7.C is consistent with NUREG-1433.
3.13 Fire Protection inspection The licensee proposed relocating current TS Section 6.8, " Fire Protection inspection," to the VOOAM. Future changes would be controlled by the requirements of 10 CFR 50.54(a). The staff indicated in Administrative Letter 95-06 that relocation of these requirements to the QA plan was acceptable since the provisions of 10 CFR 50.54(a) provide adequate controls. The proposed change is acceptable to the staff since the provisions of 10 CFR 50.54(a) are adequate to control future changes and 10 CFR 50.36 does not require this information to be contained in the TS.
3.14 Environmental Qualification The licensee proposed removing current TS 6.9, " Environmental Qualification," from the TS.
The staff considers this change to be acceptable since 10 CFR 50.49," Environmental qualification of electric equipment important to safety for nuclear power plants," adequately addresses the requirements in this area. In addition, the staff notes this change is consistent with NUREG-1433 and 10 CFR 50.36 does not require this information to be contained in the TS.
3.15 Programs and Manuals The licensee proposed inserting a new heading prior to current TS 6.10 stating "6.7 PROGRAMS AND MANUALS," to indicate the material which follows it in the TS. The staff considers this change to be acceptable since it adequately describes the material which follows it in the TS. In addition, the staff notes this change is consistent with NUREG-1433. The j
licensee also proposed the following changes to the programs and manuals section of TS.
l The licensee proposed relocating current TS section 6.11," lodine Monitoring," and i
section 6.12," Process Control Program," to the TRM. The staff finds these proposed changes to be acceptable since 10 CFR 50.36 does not require this information to be contained in the TS and the prcvisionc of 10 CFR 50.59 prr/ide adequate controls for these item. In addition, the staff notes this change is consistent with NUREG-1433.
The licensee proposed numbering, editorial, and administrative changes to current TS 3.13, "Off-Site Dose Calculation Manual (ODCM)," which do not change the technical requirements of this section. The staff considers the proposed changes to be acceptable since they do not
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o change the technical content of the TS. In addition, the licensee proposed adding the following l
to this section "The ODCM shall also contain the radioactive effluent controls and radiological I
environmenial monitoring activities and descriptions of the information that should be included f
in the Radioactive Effluent Release Report and the Annual Radiological Environmental j
Operating Report required by Specification 6.6.D and Specification 6.6.E, respectively." The l
staff corisiders this proposed addition to be acceptable since it adequately describes the NRC's
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expected content of the ODCM. In addition, the staff notes this change is consistent with j
I The licensee proposed relocating current TS Section 6.14, " Major changes to Radioactive I
Liquid, Gaseous, and solid Waste Treatment Systems," to the ODCM. The staff finds this proposed change to be acceptable since 10 CFR 50.36 does not require this information to be I
contained in TS. In addition, the staff notes this chang? is consistent with NUREG-1433.
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The licensee proposed adding a new section TS 6.7.D," Radioactive Effluent Controls l
Program." The licensee stated that the current TS do not specify requirements for a program which addresses only radioactive effluent controls. This section is added to provide a comprehensive program to implement guidance derived from NRC Generic Letter 89 01. This addition is more restrictive than the current TS. The staff finds the proposed addition to be acceptable since it adequately describes a radioactive effluent controls program expected by the staff.
3.16 Other Administrativs Changes The licensee proposed other editorial changes to Section 6.0 such as those required to support the renumbering of sections in TS Section 6.0. The staff considers these proposed changes to O
be acceptable since they are administrative only and do not change the technical requirements in the TS.
3.17 Licen: ee Commitments I
As described in the application and the supplements, and as set forth above, the licensee has committed to relocate certain TS requirements to the TRM, ODCM, and VOOAM. Such commitments are important because the acceptability of removing these requirements from the l
TSs is based on those requirements being relocated to licensee-controlled documents where further changes to the requirements will be controlled by the regulations (e.g., changes to the l
UFSAR will be in accordance with 10 CFR 50.59). Because the licensee has duplicated the relevant TS requirements in the TRM, ODCM, and VOQAM before completion of NRC review of l
the requested amendment, the licensee has already satisfied these commitments, and these requirements are already subject to appropriate regulatory control under 10 CFR 50.59 or 10 CFR 50.54(a), as applicable. Accordingly, the commitments have been adequately implemented.
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4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Vermont State official was notified of the proposed issuance of the amendment. The State official had no comments.
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5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component. located within the restricted area as defined in 10 CFR Part 20 and changes surveillance 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 amendment involves no significant hazards consideration, and there has been no puolic comment on such finding (64 FR 27328). The amendment also relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10). Pursuant to 10 CFR 51.22(b), no environmentalimpact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 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 operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: R. Croteau Date: July 19, 1999 i
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DATED: anly 10 - 1000 AMENDMENT NO. 171 TO FACILITY OPERATING LICENSE NO. DPR-28 VERMONT YANKEE NUCLEAR POWER STATION DISTRIBUTION Docket File.
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