ML20043E577

Provides Info Re Implementation of Administrative Controls & Training Related to Use of Tech Spec 3.0.4.Util Intends to Implement Amend 30 Changes by 900618.All Licensed Operators Would Receive Training to Generic Ltr 87-09

ML20043E577
Person / Time
Site:	Perry
Issue date:	06/08/1990
From:	Lyster M CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-87-09, GL-87-9, PY-CEI-NRR-1183, TAC-66284, NUDOCS 9006130159
Download: ML20043E577 (3)

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.. -as 6200 Ook free Bouleverd . Moit Address

- independence OH PO Box 94661

- 216 447-3100 Clevetond. 0H 44101-4661 June 8, 1990 PY-CEI/NRR-1183 L 1

U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555  ;

Perry Nuclear Power Plant  :

Docket No. 50-440 l Implementation of Administrative -i Controls and Training Related to Use of T.S. 3.0.4 (TAC No. 66284)

Gentlement i

The. requested information on the implementation date for administrative l controls over the use of Technical Specification 3.0.4 and on operator training related to Amendment'30 of the PNPP Operating License is provided

-herein.

It is our intent to fully implement the Amendment 30 changes by June 18, 1990.

Five items were discussed in our previous letter on this subject (PY-CEI/NRR- '

1122L) dated-March 12,-1990. Each of these-items is discussed individually. i below.

The first item committed that a management directive would be provided to.make ,

it clear that good practice dictates that plant startup should be initiated '

only when all required equipment is operable, and that plant startup with inoperable equipment must be the exception rather than the rule. This l management directive will be provided from the Vice President, Nuclear-Perry to PNPP's Plant' Manager, Operations Section Manager and Operations

. Superintendent on Monday, June 18, 1990. For your information, since the time ,

of the previous March 12, 1990 letter, it was determined that providing this same type of guidance directly to the operators in a written form would be desirable, therefore a Technical Specification Position Statement will be issued to express this same philosophy. ,

9006130159 900608 PDR ADOCK 05000440 P- PDC Operating Companies.

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USNRC Juno 8, 1990 PY-CEI/NRR-ll83 L.

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l The second item noted that all licensed operators, including Unit Supervisors ,

and Shift Supervisors, vould receive training to the Generic Letter 87-09 Tech i Spec 3.0.4 related changes and their intent. This training vill be completed I on June 15, 1990. This training includes those licensed operator personnel (

from the Training Section who are responsible for training future operator ,

classes. At this time, four of the six operator shifts have completed the I training during this cycle of normally scheduled requalification classes. l Although the commitment was to provide training to the 3.0.4 portion of the  !

Amendment, training is also being provided on the 4.0.3 and 4.0.4 changes. In case a need should arise to implement the 4.0.3 and 4.0.4 portions of this Amendme.nt prior to the 3.0.4 portion, due to an inadvertently missed surveillance or a forced shutdown, a training package on the use of 4.0.3 and 4.0.4 has been provided to the Control Room in case one of the two remaining operating shifts are on shift and need to be trained. If the 4.0.3 and 4.0.4 l portion needs to be implemented prior to the 3.0.4 portion, a subsequent letter vill be provided to the NRC to identify that this course of action was taken. This is based on our understanding that the implementation hold applies to the 3.0.4 portion of Amendment 30.

The third item, which involved revision of a plant procedure to include a policy statement to the effect that LCO's vill be tracked with the purpose of clearing them prior to plant startup, whether or not startup is prohibited by T.S. 3.0.4., has been approved by management, and vill be made effective on June 18, 1990.

The fourth item involved revision of plant procedures to add a review of open LCO's prior to plant startup, with the intent of clearing the LCOs, where practicable. In keeping with the Staff's desire for implementation of administrative controls and for ongoing awareness of the philosophy with regard to plant startup with inoperable equipment, procedural changes have been approved, and vill be made effective on June 18 in accordance with the following commitment which has been revised to reflect the actual wording utilized in the 10I's: "4. Procedural changes vill be made to require a review to be performed as a part of the plant startup checklists which vill record the Technical Specification number, Applicability, identification of equipment / item not meeting an LC0 requirement, and corrective actions taken/ planned for any LCO's for which the provisions of Technical Specification 3.0.4 vill be relied upon to permit a plant startup. TMse revisions vill _be made to the startup checklists within the instrucM ons which control plant startups, 10I-001, " Cold Startup", and I0I-002, " Hot Startup".

These startup checklists provide for review and approval by the Unit Supervisor and Shift Supervisor. This reviev vill be performed with the purpose of clearing open LC0's prior to startup, where practicable."

The above commitment has also removed reference to I0I-009 " Refueling," since it has no relationship to mode changes involving startup of the plant. This commitment vill implement the Staff conclusion in Amendment 30 that "the licensees have in place adequate administrative controls and procedures which vill ensure that it vill be the exception rather than the rule that startup of the plant with important safety features inoperable vill occur."

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kl; The fifth item noted that future audits of PNPP Tech Spec activities conducted by the Nuclear Assurance Department will-include an assessment of ranformance

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to T.S. 3.0.4 policy as expressed in the revised bases for T.S. 3.0.4-and in the administrative controls and training described in items 1 through 4 above.

A change to the Audit / Surveillance Planning Guide for this activity,will be -

made effective prior to the next conduct of operations Audit, which will provide for this review to be completed in future audits.

As noted above, it is our intent to have Amendment 30 fully' implemented by June 18, 1990. . If there are'any questions, please feel free to call. I Very t b yours,

/

Michael D. Lyst r Vice President, Nuclear - Perry y l

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I MDL/njc cc T. Colburn i

-P. Hiland  !

.USNRC Region III i

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