ML20136J017

Responds to NRC Re Violations Noted in Insp Rept 50-213/85-15.Corrective Actions:Detailed Plant Operations Review Committee Reviews of Removal of Three Control Room Smoke Detectors Implemented

ML20136J017
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	01/06/1986
From:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
A05085, A5085, NUDOCS 8601130139
Download: ML20136J017 (3)

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a . o CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N. CONNECTICUT P o. BOX 270 HARTFORo. CONNECTICUT 06141-0270 TELEPHONE 203-665-5000 January 6,1986 Docket No. 50-213 A05085 Mr. Edward C. Wenzinger, Chief Project Branch No. 3 Division of Reactor Projects Region i U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Gentlemen:

Haddam Neck Plant Response to Request for AdditionalInformation Regarding Revised Response to IE Inspection No. 50-213/85-15

Background

This letter is in response to your December 20,1985(l) letter expressing concern over a " negation" of an earlier commitment to provide proposed modification packages to the onsite review committee at least one month prior to the start of an outage. For the purpose of gaining perspective, a chronological summary of events on the second of two violations reported as part of Special Inspection 50-213/85-15 is provided below.

o item 2 of the pppendix 50-213/85-15(2 stated A, Notice ofofViolation a violation Technical for Specification Special Inspection 6.5.1 occurred when the Plant Operations Review Committee (PORC) failed to identify to the Plant Superintendent that the removal of three Control Room smoke detectors, detailed in the Plant Design Change Request (PDCR) 713 work scope, would violate Technical Specification 3.22.E.1.

o As stated in our response (3) to item 1, the inability to recognize that a technical specification change request (for T.S. 3.22.E.1) would be required to do the modification was due largely because of the lack of clarity of the Technical Specifications in identifying where (1) E. C. Wenzinger letter to 3. F. Opeka, inspection Report 50-213/85-15 Revised Response, dated December 20,1985.

(2) E. C. Wenzinger letter to 3. F. Opeka, Special Inspection 50-213/85-15, dated July 19,1985.

(3) 3. F. Opeka !ctter to E. C. Wenzinger, Response to IE Inspection No. 50-213/85-15, dated August 16,1985, i

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,. n c detectors were located. Reviewers made the error of assuming that the three detectors removed from the Process Computer Room were not considered among the ten Control Room detectors.' Eight of these are required to be operable to meet the requirements of '

Technical Specification 3.22.E.1. Because of this ambiguity, PORC, as stated in the second but mutually dependent violation, failed to advise the Station Superintendent of the impact on Technical Specifications (i.e. impacts on fire protection) of PDCR 713. As a result, Connecticut Yankee Atomic Power Company (CYAPCO) '

implemented corrective actions to resolve the ~ immediate problem and Project Engineers were advised that they were accountable for evaluating the potential for required changes to Technical Specifications as part of developing a PDCR. In addition, CYAPCO took measures to improve PORC's review of PDCR's.

o in our December 3,1985 letter (4) we revised a portion of our response to item 2 that stated PDCR's are required to be submitted to PORC for approval at least one month prior to the start of an outage. We pointed out that in retrospect this commitment was inflexible as stated.

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o in your December 20, 1985 letter, you expressed concern over the negation of the above commitment and asked that we provide assurance that thorough, timely, and well documented reviews are conducted prior to implementing modifications.

Response

First, we emphasize that the fundamental objective of our corrective actions remains unchanged, and is appropriately phrased in your December 20, 1985 letter as:

"to assure that thorough, timely, and well-documented reviews are conducted prior to implementation of modifications."

Our focus, which we believe you share, is to meet the above objective. How the objective is met is of secondary importance, and we are still in the process of optimizing the review, approval, and implementation of PDCR's. Among the corrective actions implemented to improve PORC reviews has been the implementation of more detailed " pre-PORC" reviews designed to ensure a thorough Plant staff review prior to formal PORC review and approval. Current tabulations show all PDCR's scheduled for the outage are being reviewed by plant discipline reviewers as part of the pre-PORC review, and most have been at this stage for several weeks. Eight of the thirty-two have been approved by PORC as of this date.

We recognize that a significant amount of PORC review's are still required for approval of all outage PDCR's. Not completing these reviews prior to the start of the outage could potentially cause outage work scheduling contingencies but (4) 3. F. Opeka letter to E. C. Wenzinger, Revised Response, dated December 3,1985.

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'p in ' no way _ will compromise the process of completing thorough and well documented PDCR reviews. Our recent experience with the processing of PDCR's has resulted in in-depth probing and questioning, and the need for multiple question and answer iterations. Improvements to the PDCR process have been the result of -increased awareness among personnel as to the

-Importance of PDCR reviews and also as a result of a revised set of " Nuclear Engineering and Operations" (NE&O) procedures which have improved the PDCR review process. At the time our initial commitment was made the impact of new procedures from a schedular standpoint was underestimated. We are continuing to strive for "early" PDCR approvals, but will not let a committed

- schedule dictate the depth and quality of our review. While we wish our review process was further advanced, we do not believe we should be criticized for our efforts to date. The bottom line is that work will not begin on any given PDCR unless all required reviews are complete. The exception to this would be if a

" Pre-PDCR Work Authorization" was approved. This is allowed by procedure but it _does not allow any work completed under such authorization to be utilized until PDCR approval is obtained. Work performed under this authorization also cannot be performed unless properly isolated so as not to affect plant operations or the operability of any safety systems required, considering the mode of operation of the unit.

v Summary In light of our recent experience, we hereby withdraw our previous commitment to provide design packages to PORC a fixed period of time prior to the start of an outage, and instead re-affirm our commitment to complete thorough, timely, and well-documented reviews prior to implementation of modifications. We of t course, will cooperate fully with you and your staff to facilitate your oversight of our efforts.

l We trust the above response adequately responds to your concerns.

Very truly yours,

-g-CONNECTICUT YANKEE ATOMIC POWER COMPANY g' 4

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J. F. Opbkad V Senior Vice President l

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