B12797, Discusses Issue of Formally Incorporating Schedule for Correction of Human Engineering Discrepancies Identified During Crdr Into Isap.Issuance of License Condition Prior to 880225 Requested

Discusses Issue of Formally Incorporating Schedule for Correction of Human Engineering Discrepancies Identified During Crdr Into Isap.Issuance of License Condition Prior to 880225 Requested

ML20196A439
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	01/29/1988
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
B12797, NUDOCS 8802050041
Download: ML20196A439 (5)

Text

CONNECTICUT YANKEE ATO MIC POWER COMPANY j B E R L I N. CONNECTICUT P O. BOX 270 e HARTFORD. CONNECTICUT 06141-0270 T EL EMONE January 29, 1988 203465-$000 Docket No. 50-213 B12797 Re: CRDR/ISAP U.S. Nuclear Regulatory Commission I Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Haddam Neck Plant Control Room Design Review Revision to License Condition to Reflect Intearated Safety Assessment Proaram The purpose of this letter is to address the issue of formally incorporating the schedule for the correction of Human Engi-neering Discrepancies (HEDs) identified as part of the Control Room Design Review (CRDR) at the Haddam Neck Plant into the Integrated Safety Assessment Program (ISAP) . The Haddam Neck Plant has as part of its operating license, DPR-61, a cgfirma-tory order issued via a letter dated August 12, 1986 That order specifies that the Summary Report for the CRDR would be transmitted to the Staff by February 25, 1988, and that a schedule for implementation of corrective actions would be submitted with that report.

By letter dated December 12, 1986,(2) Connecticut Yankee Atomic Power Company (CYAPCO) submitted a comprehensive report to the NRC Staff on the ISAP at the Haddam Neck Plant. This report reflected several years of cooperative effort with the Staff in the development and implementation of this pilot program to (1) C. I. Grimes letter to J. F. Opeka, "Correction to Order Confirming Licensee Commitments in Emergency Response Capability (Generic Letter 82-33, NUREG-0737)," dated August 12, 1986.

(2) E. J. Mroczka letter to C. I. Grimes, "Integrated Safety Assessment Program -

Final Report for the Haddam Neck Plant," dated December 12, 1986.

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l U.S. Nuclear Regulatory Commission B12797/Page 2 January 29, 1988 1

l assess and prioritize pending plant modifications and licensing I issues at the Haddam Neck Plant. '

During June of 1987, meetings were held between the NRC Staff and CYAPCO during which the issue of CRDR implementation and its relationship to ISAP were discussed. Based upon these discussions, it was our understanding that the schedules of CRDR

-identifiedHEDswouldbedetegnedbyISAP.

letter dated November 13, 1987, Accordingly, in a CYAPCO formally documented our j

intention to schedule the CRDR implementation within the Inte-grated Implementation Schedule (IIS). A similar statement was madebyNortheastNuclearEnergyCganyforMillstoneUnitNo.

in a letter dated August 4, 1987.

1 CYAPCO hereby requests t&.at the confirmatory order in the Haddam Neck Plant license be changed to reflect a commitment date of November 1, 1988 fo submittal to the Staff of a schedule for correction of HEDs. gI CYAPCO intends to submit a revised IIS to the Staff by early fall, 1988 which will incorporate HED correc-tion schedules. November 1, 1988 was selected to allow for the revised ISAP review to be conducted and submitted to the Staff.

A proposed modification to the Haddam Neck Plant license condi-tion is included as an attachment to this letter.

CYAPCO believes that a potential extension of eight months for submitting a CRDR HED correction schedule to the Staff is not a l

l (3) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, "Integrated Safety Assessment Program (ISAP) , " dated November 13, 1987.

(4) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, "Integrated Safety Assessment Program (IS AP) , " dated August 4, 1987.

(5) In a letter from J. F. Opeka to J. A. Zwolinski ("Haddam Neck Plant -

Emergency Operations Procedures Generation Package"), dated July 12, 1985, CYAPCO similarly requested  :

that the Staff modify an order and defer the implementation  !

date of the new Emergency Operating Procedures from "prior i to the start of cycle 14" to "by September 1, 1986." I Explanation and justification for the request was provided. ]

The Staff simply responded to CYAPCO in a letter from '

H. L. Thompson, Jr. to J. F. Opeka, dated August 26, 1985, approving the revised due date for implementation of the updated EOP's.

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7 U.S. Nuclear Regulatory Commission B12797/Page 3 January 29, 1988 safety concern. Resolutions of HEDs that are generated by the CRDR are typically scheduled over a number of future refueling outages. The proposed change to the license condition will not appreciably impact the overall implementation schedule. However, more importantly, evaluation of the schedule for HED resolution within ISAP takes into account safety significance, as well as other factors. Therefore those projects that are concluded to be of a higher priority will be scheduled accordingly. This is the overall purpose of ISAP which has been endorsed by the Staff as well as by CYAPCO.

CYAPCO respectfully requests that the change to the license condition for the Haddam Neck Plant be issued prior to February 25, 1988, the due date in the current license condition. CYAPCO also wishes to affirm that the CRDR Summary Report will be submitted to the Staff on or before February 25, 1988, but without schedules for correction of the HEDs.

Please contact us if you have any questions.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY HV E. 'J/ lir'oczkgp' Senior Vice President Attachment cc: W. T. Russell, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Resident Inspector, Haddam Neck Plant I

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i Docket No. 50-213 B12797  !

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i Attachment Haddam Neck Plant Proposed change to License Condition Schedule for CRDR Implementation i

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January, 1988 I

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Page 1 of 2 June 12, 1984 Revised August 12, 1986 HADDAM NFCK PLANT LICENSEE'S COMMITMENTS ON SUPPLEMENT 1 TO NUREG-0737 LICENSEE'S COMPLETION j TITLE REOUIREMENT SCHEDULE (OR STATUS)

1. Safety Parameter Display la. Submit a safety analysis and Complete 5/13/86 System (SPDS) an implementation plan to the NRC.

Ib. SPDS fully operational and March 25, 1988 or operators trained. 6 months from start of Cycle 15

2. Detailed Control Room Design 2a. Submit a program plan to the Complete 2/28/86 Review (DCRDR) NRC.

2b. 1) Submit Summary Report to NRC. February 25, 1988 -

2) Submit Schedule for November 1, 1988 Implementation to NRC.

3. Regulatory Guide 1.97 - 3a. Submit a report to the NRC Complete 02/29/84 Application to Emergency describing how the requirements Response Facilities of Supplement i to NUREG-0737 have been or will be met.

3b. Implement (installation or Schedule submitted upgrade) requirements. by 7/17/84 Complete

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