ML19257A065
| ML19257A065 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 11/09/1979 |
| From: | Moody D Maine Yankee |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19257A064 | List: |
| References | |
| WMY-79-130, NUDOCS 8001020033 | |
| Download: ML19257A065 (4) | |
Text
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__ eQ B.4.1.1 MiY 79-130 November 9,1979 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention: Office of Inspection and Enforcement Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch
Reference:
(a) License No. DPR-36 (Docket No. 50-309)
(b)
I&E Letter to MYAPC dated Octcber 15, 1979 Inspection Report No. 50-309/79-14
Dear Sir:
Subject:
Response to Inspection No. 50-309/79-14 In response to reference (b), Maine Yankee Atomic Power Company hereby submits the following information:
Item A Apparent Item of Non-Compliance Technical Specification 5.8.2 states, in part, "Each procedure of 5.8.1 above, and changes thereto, shall be.
. reviewed periodically as set forth in administrative procedures." Plant Procedure 0-06-2, " Procedure Review, Approval, and Distribution,"
Paragraphs 5.1.8 and 5.1.9 states the following:
"5.1.8 - Class A and B procedures shall be reviewed at least every three years."
Contrary to the above, it appears that procedure review was not adequately implemented in that the review for Revision 4 to the alarm response procedures issued in June, 1979, did not identify and revise twenty-seven safeguards alarms previously updated in December, 1977, and incorporated into emergency procedure 2-36, " Safeguards Annunciators." Hence, two different scts of procedures existed in the Control Room for twenty-seven of sixty-eight safeguards alarmn.
In addition, seven administrative procedures (Class A), one test precedure (Class B), and two operating procedures (Class C),
had exceeded their review dates without prompt action having been taken to review these procedures.
1664 542 00102g ()}
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United States Nuclear Regulatory Commission Page Two Attention: Office of Inspection and Enforcement November 9, 1979 RESPONSE TO ITEM A With regard to the discrepancy between the alarm response procedures in the alarm response book, procedure 2-100-1, Response to Panalarms, and emergency procedure 2-36, Safe-guards Annunciators, the discrepancy occurred due to personnel oversight following the review and revision of 2-100-1.
To correct this error and prevent a similar re-occurrence, procedure 2-36 Las been reviewed and revised.
The new revision deletes the inclusion of the actual response sheets in the procedure and now simply lists the appropriate response sheets and makes reference to the use of the Panalarm Response Book where the correct revision for the response sheets can be found.
With regard to the administrative and operating procedures which had exceeded their review date, the review and revision of all but two of these procedures has been completed. Due to some significant changes which are being incorporated into these procedures, the final revisions have not yet been completed.
It is presently expected that the review and revision of these two procedures will be completed by December 1, 1979.
Personnel responsible for the timely review of these procedures have been reminded of their responsibilities.
Item B Apparent Item of Non-Compliance Technical Specification 5.8.1 states, in part, " Written procedures shall be established, implemented, and maintained covering the activities referenced below:
a.
The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972." Plant Procedure No. 0-06-2, " Procedure Review, Approval, and Distribution," states, in part the following:
"5.3.3 - The Administrative Department Head shall be responsible for irsuring that procedures.
. are distribution to each person in accordance with.
(Procedure No. 0-05-1, Document Control).
5.6.1.5 - The Secretary of PORC shall submit a copy of permanent Procedure Change Reports to the Administrative Department Head.
to be issued under Controlled Distribution."
Contrary to the above, Control Copy No. 1 of the Alarm Response Book with Revision 3, dated March 18, 1976, was observed in the 1664 343
E United States Nuclear Regulatory Commission Page Three Attention: Office of Inspection and Enforcement November 9, 1979 Control Room although a later revision, Revision 4, dated June 22, 1979, is currently in effect.
In addition, two Procedure Change Reports (PCR's), which had been cancelled, were still posted to their respective procedures in the Control Room; eight PCR's, subsequent to their approval by the Plant Manager, were not placed in controlled distribution; and, one PCR was posted to a procedure for which a later revision had been issued which, in part, incorporated the provisions of that PCR.
RESPONSE TO ITEM B When procedure 2-100-1, Response to Panalarm, and the Panalarm Response Book was reviewed and revised in June of 1979, the entire Panalarm Response Book was changed and placed in one, new, large binder instead of using the two small binders of the previous revision. The new revision in the single binder was sent out on Controlled Distribution and given to the operator in the Control Room. After receiving the revised copy, the Control Room operator forgot to remove and d estroy the two outdated binders. Upon discovery, the outdated books were immediately removed and destroyed.
The operator was reminded of the importance of removing outdated material when new revisions are received.
With regard to the two Procedure Change Reports (PCR's) which had been terminated but still remained in the Control Room - both PCR's were " temporary" in nature. They were written to permit a deviation from the existing procedures due to specific plant conditions at the time the procedure was to be performed. Temporary PCR's are normally used for one-time events and are terminated following their use.
The operators, wh n generating these PCR's, mistakenly made additional copies of the PCR's and placed them with their respective procedures in the Control Room.
In the case of temporary PCR's, this should not have been done.
When permanent PCR's are generated, copies are immediately attached to applicable procedures in the Control Room to ensure operators will be aware of the latest information relative to any particular procedure.
The original copy of the PCR is then forwarded to the Secretary of the Plant Operations Review Committee (PORC) who ensures the PCR is reviewed by the PORC and is apprcved by the Plant Manager within the 14 day time frame required by Technical Specification.
Following this review and approval, the PCR's are sent out on Controlled Distribution to ensure all other holders of the applicable procedures receive the PCR. This Controlled Distribution normally takes place shortly after the meeting of the PORC. Due to a backing of Controlled Distribution, 1664 344
6 United States Nuclear Regulatory Commission Page Four Attention:
Office of Inspection and Enforcement November 9, 1979 the PCR's found in the Control Room had not yet been issued showing the review and approval of the PORC and Plant Manager.
Should a PCR ever be disapproved, all copies of the PCR are immediately removed from the Control Room and destroyed. The lateness of the distribution of the approved PCR's in no way affected plant safety as the information contained in the PCR's was available to the operators on the copies of the PCR's which were attached to the procedures.
The individual PCR which had not been removed when the revised procedure was issued is considered an isolated case. Had the operators attempted to utilize this PCR in the performance of the procedure, it would have become obvious that the PCR was no longer applicable as the numbers referred on the PCR were now corrected in the revised procedure. Personnel performing the Controlled Distribution have been reminded to ensure that terminated PCR's are removed and destroyed when the revised procedures are issued.
We trust this information will be satisfactory. Should any additional information be required, please contact us.
Very truly yours, MAINE YANKEE ATOMIC POWER COMPAh7
.t.
D. E. Moody Manager of Operations DEM/stw I664 545