ML20011D692
| ML20011D692 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 12/01/1989 |
| From: | Whittier G Maine Yankee |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| GDW-89-371, MN-89-145, NUDOCS 8912280272 | |
| Download: ML20011D692 (4) | |
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L MaineYankee Hi t1ABLE (ttCTRCTY FOR MAINE E.tNCI 1972 EDISON DRIVE e AUGUSTA. MAINE 04336 + G07) 622 4868 December 1, 1989 MN-89-145 GDW-89-371 Region-1 UNITED STATES NUCLEAR REGULATORY COMMISSION 475 Allendale Road King of Prussia, PA 19406 Attention:
Mr. William T. Russell, Regional Administrator
References:
(a)
License No. DPR-36 (Docket No. 50-309)
(b)
USNRC Letter to Maine Yankee dated October 27, 1989, i
inspection No. 50-309/89-81
Subject:
Response to Concern - Emergency Procedures Inspection No. 50-309/89-81 Gentlemen:
During the recent NRC team inspection of the emergency procedures at Maine Yankee, one concern was identified and subsequently documented in Reference (b):
"This concern is the direction given to the operators that the emergency procedures are not to be considered verbatim compliance-documents but are intended to be used.as a guide."
During the inspection, we agreed-that our written guidance on adhering to abnormal and emergency operating procedures would be revised. We have ' revised this guidance,. contained in our Quality Assurance Manual Procedure 0-05-1,
" Procedure Preparation, Classification, Format, Use and: Adherence", and are in the process of incorporating the identical language in Operations Department Procedure 1-200-10, " Conduct of Operations". A copy of this guidance, from Procedure 0-05-1, is attached. Operations Department personnel have been required to review this revised guidance, and the Manager, Operations, has-reviewed this guidance with all six Operations Crews to ensure that there is common understanding in the Operations Department..
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GDW89371.LTR 8912280272 B91201 0
PDR ADOCK 05000309 Q
PNU
t UNITED STATES NUCLEAR REGULATORY COMMISSION MN-89-145 Attention: Mr. William T. Russell Page two t
Our understanding is that we reached agreement with your inspection team leader on the general philosophy of procedure adherence. We feel that the attached guidance reflects this agreed-upon philosophy and should resolve your concerns in this matter.
Should you have any questions on this matter, please contact me.
Very truly yotcs, -
SEA lEbL h
J<G.D.Whittier, Manager Nuclear Engineering and Licensing GDW:WSD Attachment c:
Document Control Desk Mr. Eric J. Leeds Mr. Cornelius F. Holden l
GDW89371.LTR L
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Prce. No. 0-05-1
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- i Rev. No. 4 Page 16 of 18-q l
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8.2 ABNORMAL / EMERGENCY PROCEDURE ADHERENCE i
8.2.1 Abnormal Oneratina Procedures (AOP's) i Abnormal Operating Procedures are the best pre-approved procedure available to the o>erating crews to respond to an off-normal i
situation.
As suc1, Maine Yankee expects that.they will be 1
followed to deal with the condition or casualty. : Unanticipated circumstances may occur during the casualty which may require-
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different action than that considered when the procedure was written. Special circumstances can arise during casualties where A0P's could be in conflict or not applicable.. Maine Yankee expects that when the procedures are'not working the operators will take whatever corrective actions are necessary to enable recovery from-the specific circumstances. Decisions to deviate from AOP guidance will be made by the on-shift supervisors (PSS or SOS) and-i i
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Proc. No. 0-05-1 Rev. No.
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Page 17 of 18 j
documented in the shift operating log. Additionally, these actions will be evaluated for general. applicability to the AOP and a PCR l
will be generated, after the fact, to incorporate the action into the AOP.
l 8.2.2 Emeroency Doeratina Procedure (EOP's?
Emergency Operating Procedures will be used by the operating crew i
to respond to emergency conditions which may develop. The E0P's are based on the Westinghouse Owner's Group Guidelines and have been specifically adapted for Mains Yankee based on analyses L
performed by Yankee Nuclear Services Division (YNSD) and Westinghouse. The actions specified~in the E0P's should lead.to-successful recovery from all anticipated emergency conditions and Maine Yankee expects that the procedures will be used and followed when entry conditions warrant. Unanticipated circumstances may occur during the course of emergencies which may call for responses in addition to but not contrary from those actions in the E0P's.
Shift supervision (PSS or SOS) is expected to direct additional-I l
action deemed appropriate to correct problems or to recover from situations while following the steps of an E0P.
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Special circumstances can arise during emergencies,where plant emergency procedures could be in conflict or not applicable.
In addition, an accident can take a course different from that-visualized when the emergency procedure-was written, thus requiring a protective response at variance with or which deviate from the-actions specified in the E0P.
In such cases, it is expected that senior-licensed operations shift management (PSS or SOS) will direct protective actions which may be contrary with the'E0P's when it is evident that this is necessary to protect the health and safety.of the public. All deviations'from E0P's will be documented in the shift operating log for future evaluation.
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