A06374, Responds to Violation Noted in Insp Rept 50-213/87-01. Corrective Actions:Procedure ACP 1.2-6.4 Revised on 870115 by Indicating That Substitutions Could Be Made Only If Substitute Instrumentation Has Equal or Better Accuracy

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Responds to Violation Noted in Insp Rept 50-213/87-01. Corrective Actions:Procedure ACP 1.2-6.4 Revised on 870115 by Indicating That Substitutions Could Be Made Only If Substitute Instrumentation Has Equal or Better Accuracy
ML20207R825
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 03/10/1987
From: Mroczka E
CONNECTICUT YANKEE ATOMIC POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
A06374, A6374, NUDOCS 8703180175
Download: ML20207R825 (2)


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CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N. CONNECTICUT P O box 270 HARTFORD. CONNECTICUT 06141-0270 TELEPHONE 203-665-5000 March 10, 1987 Docket No. 50-213 A06374 Re: 10 CFR 50, App. B U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

Reference:

(1) S. D. Eoneter letter to J. F. Opeka, dated February 11, 1987, transmitting Inspection Report No. 50-213/87-01.

Gentlemen:

Haddam Neck Plant Response to I&E Inspection No. 50-213/87-01 Pursuant to the provisions of Section 2.201 (" Notice of Violation") and Appendix C (Enforcement Policy) of the NRC Rules of Practice (10CFR2), this report is submitted in reply to Reference (1), which informed Connecticut Yankee Atomic Power Company (CYAPCO) of a violation identified during a routine inspection at the Haddam Neck Plant from January 6-9, 1987.

Requirement 10 CFR 50, Appendix B, Criterion V, states in part that activities instructions, affecting quality shall be prescribed by documented procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, and drawings; Criterion II further states that the quality assurance program shall provide control over activities affecting quality.

Finding Contrary to the above, as of January 9, 1987, the control provided by procedure ACP 1.2-6.4, Temporary Procedure Change, Rev. 18, over changes and substitution of test equipment was not adequate in that it permitted test personnel to change, modify, and/or substitute test methods without any higher supervisory or technical review, and without documenting such changes, modification or substitutions in the test procedures.

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~. U. S. Nuclear Regulatory Commission A06374/Page 2 March 10, 1987 Root-Cause The intent of paragraph 6.4.2.2 of ACP 1.2-6.4, Temporary i

Procedure Change, Rev. 18, was to allow substitute methods for data acquisition. However, the procedure did not specify the level of review required or the method of documenting a substitution.

Resolution / Corrective Action ACP 1.2-6.4 had the following changes made on January 15, 1987.

1. Added the caveat that substitutions could be made only if the substitute instrumentation has equal or better accuracy and adequate range to measure the desired parameter.

2.. Added that instrument equivalence can be determined only by a Level 2 or higher certified individual.

, 3. Added that any instrument substitution shall be noted in the applicable portion of the procedure.

Additionally, the changes made to ACP 1.2-6.4 were reviewed with the I&C Department during a department meeting.

Copies of these changes were transmitted to the NRC on or about January 15, 1987.

Actions to Prevent Recurrence i

The above corrective action will prevent recurrence.

Very truly yours,

! CONNECTICUT YANKEE ATOMIC POWER COMPANY

! A E.60. Mroczka Senior Vice President cc: Dr. T. E. Murley, Region I Administrator F. M. Akstulewicz, NRC Project Manager, Haddam Neck Plant P. D. Swetland, Resident Inspector, Haddam Neck Plant

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