ML19260C252
| ML19260C252 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/10/1979 |
| From: | Counsil W CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19260C250 | List: |
| References | |
| NUDOCS 7912260116 | |
| Download: ML19260C252 (3) | |
Text
U CONNECTICUT YANKEE ATOMIC POWER COMPANY BERLIN, CO N N ECTIC U T P.O.80X 270 H ARTFORD. CONNECTICUT 06101 203-666 6911 October 10, 1979 Docket No. 50-213 Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch U. S. Nuclear Regulatory Commission Region I Office of Inspection and Enforcement 631 Park Avenue King of Prussia, PA 19406
Reference:
Letter, E. J. Brunner to W. G. Counsil, dated September 18, 1979 Inspection 50-213/79-11
Dear Mr. Brunner:
This correspondence is in response to the Notice of Violation as described in the report of Inspection 50-213/79-11 that was conducted during July 17-20, 1979.
Deficiency Technical Specification 6.8.1 states, in part:
" Written procedures and administrative policies shall be established, implemented and maintained..."
Contrary to the above, the following examples of failure to implement plant procedures were identified during this inspection.
1.
On March 4,1979, several data sheets from Surveillance Procedure, SUR 5.3-6, Revision 6, dated February 27, 1979, were not completed in that all of the required plant parameters were not recorded on the data sheets.
2.
On February 27, 1979, numerous changes to valve checklists in Normal Operating Procedure N0P 2.4-1, Revision 3, dated November 23, 1977 were made without initiating a temporary change request.
In addition, step 7.1.2.7 of the procedure did not contain operator initials signifying completion of this step.
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4 2-3.
On March 4,1979, step 7.6.1 of Normal Operating Procedure N0P 2.1-2, Revision 4, dated August 25, 1978, was not completed in that the required information was not recorded in the procedure.
Response
1.
Surveillance Procedure SUR 5.3-6, Control Rod Group Reactivity Worth Combined with Baron Worth and Ejected Rod Worth, is being revised to ensure that all required plant parameters are recorded on the data reduction sheets. This revision is expected to be in effect by October 20, 1979.
2.
Changes to valve checklists were made to accurately reflect the positions of certain valves during the completion of Normal Operating Procedure N0P 2.4-1.
The positions of these valves are not relevant to the successful and safe completion of N0P 2.41, Filling and Venting of Entire System. This procedure will be revised by November 1, 1979, to indicate those valves which may be in either an open or closed position, or to delete these valves from the checklist entirely.
Step 7.1.2.7 of the above procedure requires the operator to verify that the Control Rod Drive Mechanisms have been vented.
This action is no longer a part of the venting process and will be deleted from the procedure. This change will also be completed by November 1,1979.
3.
Step 6.7.1 of NOP 2.1-2, Reactor Startup, included the required plant data but was not initialed by the operator.
Involved personnel have been reminded that all procedure checklists are to be completed in full.
Deficiency Technical Specification 6.8.3 states, in part:
" Temporary changes to procedures... may be made, provided:
"The change is documented, reviewed by the Plant Operations Review Committee (PORC) and approved by the Station Superintendent within 14 days of implementation."
Contrary to the above, on February 27, 1979, a temporary procedure change was made to Normal Operating Procedure, N0P 2.4-1, Revision 3, dated November 23, 1977, Filling and Venting of Entire System, while the procedure was being used, without subsequent review and Station Superintendent approval as of July 20, 1979.
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Response
The original copy of the described Temporary Procedure Change (TPC) was inadvertently attached to the working copy of Normal Operating Procedure N0P 2.4-1.
Quality Assurance procedure QA 1.2-6.4, Temporary Procedure Changes, states that a copy of the TPC shall be attached to the working copy of the procedure and the original TPC shall be forwarded to the Office Supervisor to schedule Plsnt Operations Review Committee (PORC) review and approval.
The requirements of this Q.A. procedure have been reviewed with the involved personnel as well as the Technical Specification requirements in this area.
The specific TPC to N0P 2.4-1 was reviewed and approved by the PORC and the Station Superintendent on July 24, 1979.
Very truly yours, CONNECTICUT YANKEE ATOM POWER C0 PANY a.
W. G. Counsil Vice-President 1616 1~94