B11525, Suppls 850128 Response to Insp Rept 50-213/84-28 & 841213 Order Modifying License Re Failure of Reactor Cavity Seal Ring.Possible Misinterpretation of 850128 Response Re Design Changes Deemed Significant Clarified

Suppls 850128 Response to Insp Rept 50-213/84-28 & 841213 Order Modifying License Re Failure of Reactor Cavity Seal Ring.Possible Misinterpretation of 850128 Response Re Design Changes Deemed Significant Clarified

ML20128P006
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/28/1985
From:	Opeka J, Seans C CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Murley T, Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
B11525, EA-84-115, NUDOCS 8506030438
Download: ML20128P006 (4)

Text

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j CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N, CONNECTICUT P.o box 270 HARTFORD. CONNECTICUT 06141-0270 TELEPHONE 203-685-5000 May 28,1985 ,,

Docket No. 50-213 Bil525 Mr. James M. Taylor, Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Thomas E. Murley Regional Administrator, Region !

U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Gentlemen:

Haddam Neck Plant Supplement to Response to Order Modifying License (Inspection Report No. 50-213/84-23, EA 84-115)

On December 13,1984(l) the NRC Staff issued an Order Modifying License to the Connecticut Yankee Atomic Power Company (CYAPCO) as a result of findings associated with the investigation into the failure of the reactor cavity seal ring on August 21, 1984, and two other unrelated instances of inadequate control and implementation of design changes.

CYAPCO's response to the subject Order was provided to the Staff on January 28, 1985(2). In the process of establishing the review group described in CYAPCO's response and developing its associated guidelines and procedures, we became aware of a portion of our response which could have the potential for misinterpretation. We are taking this opportunity to clarify our intent so that the Staff will more clearly understand the intent of our design change review process.

On page 8 of Attachment 2 to our January 28,1985 Response to Order Modifying License,it is stated that:

(1) 3. M. Taylor letter to W. G. Counsil, dated December 13, 1984, forwarding Order Modifying Licence and Notice of Violation and Proposed Imposition of Civil Penalty, Docket No. 50-213, EA 34-115.

(2) W. G. Counsil letter to 3. M. Taylor and T. E. Murley, dated January 28, 1985.

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I"Following screening of all ~ design changes approved after January 1,1979, those q'g m 4

t j design changes deemed significant will be subjected. to a' detailed review-of the 4

> following aspects:

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to Engineering '

. <o Design

o" Construction '

o! Inspection,

= o Pre-Operational Testing .

.: o Turnover .

- o Training;

"=' Wei believe ~it possible that:the above st_atement. could be' interpreted to mean

.that gsignificant design changes will be reviewed in detail.with respect to all

of the above. Items.~ The ' intent of this; statement is that those design changes -

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[which, through the-screening review, are deemed significant will be subjected to Ja -detailed . review of those ' aspects -of. the design change which are directly m related Dtoithe ibasis .upon which the i design - change - was _. deemed 1 to be E~

'"significant". f We do not necessarily i_ntend to conduct a detailed review of all c.

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(phases of the project, from preliminary engineering to training, for every design,

. change selected for review.L The. Plant Design' Change Task Group (PDCTG) has.

c. completed the' identification of those changes deemed to be "important". from a

. . safety . standpoint,- in Laccordance with our January 28, 1985 response. . Some of

these changes were

selecte'd because of ia' specific concern, and may. not' be M' L complex "afety-related changes.1 For those changes, a' detailed review of all of

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ithe aboye aspects would not accomplish the desired in-depth process review.- For

. example, - a ' piping ' modification ; may be ~ selected because .of potential shortcomings in its seismic qualification. Therefore, a: detailed review of the g

7design for that modification would be; warranted.1However, a detalled review of y , -

preoperational testing,: turnover,'or training aspects would not be. expected to o <

produce. meaningful insight-into the effectiveness of those aspects of the design .

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lltlis our[ intent.' to thoroughly review. pertinent aspects of the design-change

- ; process,f where 7 meaningful,i (for those design ' changes where concerns are identified. - When a Edetailed review lis not necessary, 'a brief Dstatement V

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Edocumenting the basis;for that decision will be made. The PDCTG recognizes

- i:the need to review: all aspects .for; the purpose ofl Identifying any further bW >

potentia!. improvements to the_ CYAPCO design change process. The. PDCTG will 1 m ,

. ensure that each aspect is reviewed in-detail by review of the' current process' 1 ~itself and/or the. process concerns identified during the review of specific design-

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1. changes.1 : This will provide sufficient insight into the pastLand current design change. process to identify any appropriate recommendations on improvements to

> ' !the' present design change process. The External Review Group has reviewed this approach and found it to be acceptable., We believe that the process outlined in, our January 28, 1985 letter, as clarified above, is fully responsive to the Order c

Modifying License issued on December '13,1984!and satisfies the objectives of that order. ,

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J ' On -another matter related to this effort, we recently received.' the NRC's

' approval (3) of our Order response. On page 2 of the NRC's transmittal letter,it

~is stated that:

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'?Since-none of the 6-member task force of Northeast Utilities /CYAPCO employees has been involved in the design modification process in the past..." _,

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-Our January 28, 1985 Order response did not state that these individuals had no s prior involvement in the design modification process in the past, but only that C v ' . they-would "be relieved of their normal line organization responsibilities until

. the completion of their effort". Additionally, the criteria for selection of these individuals specifically _ stated that = they would be' selected "from the various major functional elements within the organization", which includes departments '

such_ as Generation Engineering who are a part.of the CYAPCO design change process. .

On - February 6, '1985(4), we submitted . resumes of the individuals who are members of the PDCTG. These resumes made it clear that several of these

~ individuals have been involved with ' plant design changes in the past; in several

--instances there are explicit references to specific projects with which.these Individuals were involved.

IWe believe. that these individuals are fully capable of independently fulfilling their obligations to the PDCTG. We do not believe that their prior involvement -

- in.' the design' change process will in any way compromise their objectivity or integrity. It would be neither desirable nor feasible to staff .the PDCTG with individuals who have had no involvement in the design change process in the past.

E Due to the number and complexity of previous design changes, essentially all of cthe qualified NUSCO/CYAPCO staff have been involved at some -time in the design change process. Additionally, we believe that some first-hand knowledge of the_ design change process is essential for these individuals to effectively .

complete their assignment. 'It is unlikely that individuals with no knowledge of

~the functioning _ of the existing'-design change process would be capable of

. identifying areas where improvements in the process are warranted. Thus,' the selection of individuals for the - PDCTG .must . involve a balancing of prior involvement with the knowledge necessary to complete the task.

We previously considered the possibility that member (s) of the PDCTG may have been involved in specific design changes which were selected for detailed review.

j PDCTG procedures ' state that if -any member has been instrumental in the engineering, design or evaluation of the change, the member shall be replaced by an alternate member for the review of that change. The results of the screening <

review to date have revealed that replacement is appropriate-in only a very

limited number of cases. Again, we believe that this plan is fully consistent and responsive to the Order Modifying License.

. (3) T. E. Murley letter to J.'Opeka, dated April 23,1985.

. (4) W. G. Counsit letter to T. E. Murley, dated February 6,1985.

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_4 Since this letter merely serves to clarify our previous submittals and an apparent

.: misunderstanding on the part of the Staff, no response is requested unless you disagree with the above. ' We believe that the intent of the Order is being satisfied,' and _we are proceeding with our review - as proposed in our earlier -

, submittals and as clarified above. -

We remain available to discuss this matter further should you so desire.'

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY

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3. F. opeka Senior Vice President b

By:- C. F. Sears Vice President

~ STATE OF CONNECTICUT )

) ss. Berlin COUNTY OF HARTFORD ')

Then personally appeared before me C. F. Sears, who being duly sworn, did state that he is Vice President of . Connecticut Yankee Atomic Power Company, a Licensee ~ herein, that he is authorized to execute and file - the foregoing information in the name ~and on behalf. of the Licensee herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.

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