ML20137U239

Forwards Response to Section Iv.C of 841213 Order Modifying License to Address Circumstances Associated w/840821 Failure of Reactor Cavity Seal.Response Incorporates Recommendations for Design Change Process Improvement

ML20137U239
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	11/06/1985
From:	Mroczka E, Opeka J CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
A04547, A4547, EA-84-115, NUDOCS 8512090238
Download: ML20137U239 (29)

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CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N, CONNECTICUT P O. BOX 270 HARTFORD. CONNECTICUT 06141-0270 TELEPHONE 203-66s-5000 November 6,1985 Docket No. 50-213 A04547 Dr. Thomas E. Murley Regional Administrator, Region I ,

U. S. Nuclear Regulatory Commission 631 Park Avenue

' King of Prussia, PA 19406 Gentlemen:

Haddam Neck Plant Response to December 13,1984 Order Modifying License The purpose of this letter is to provide Connecticut Yankee Atomic Power Company's (CYAPCO) response to Section IV.C of the Order modifying the operating license which was issued on December 13,1984(l)

Background

On December 13, 1984, the NRC Staff issued a Notice of Violation and Proposed imposition of Civil Penalty and Order Modifying License to CYAPCO. These actions were a result of inspections conducted concerning the circumstances associated with the failure of the reactor cavity seal at the Haddam Neck Plant on August 21,1984.

Subsequent to the issuance of the subject Notice of Violation (NOV) and Order Modifying License, the Staff granted an extension to January 28, 1985 for responding to the Order Modifying License.(2) By letter dated January 7, 1983,(3) CYAPCO confirmed with the Staff our mutual understanding that the extension for responding to January 28, 1985 applied not only to the Order Modifying Licerise but also to the Notice of Violation.

l (1) 3. M. Taylor letter to W. G. Counsil, dated December 13,1984, Order Modifying License and Notice of Violation and Proposed Imposition of Civil Penalty, Docket No. 50-213, EA-84-il5.

(2) 3. M. Taylor letter to W. G. Counsil, dated December 26,1984.

(3) W. G. Counsil letter to J. M. Taylor , dated January 7,1985.

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[., w:[ 'By letter dated January 28,'1985,(4) CYAPCO responded to the subject Notice of Violation and the Order Modifying License. The response to the order outlined a 1 comprehensive plan to review design changes and the design change process.-

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utilized at;Haddam= Neck."The letter also included a description of other on-L going initiatives' within the' Northeast Utilities /CYAPCO organization .that are -

W related to our.overall plan for improving:the design change and safety' review process.

$ By letter dated Feliruary)6,1983(5), CYAPCO transmitted the resumes of the

Plant Design Change Task Group members. : This completed our response to the Order.

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By1 1etter ' dated . March 22,.1985(6), CYAPCO described the interim corrective Lactionsson the design change : control process which were implemented '1n

- February 1985.

, By' letter dated April 23,1985,(7) the NRC Region 1 Administrator accepted the L program plan, the qualifications of the Task Group members and. the interim

' corrective actions.-

ByLletters dated April: l'l(8) and June 21,(9) 1985, the Plant L Design Change -

External Review Group provided the Regional Administrator.with status reports : '

l>  : discussing the progress of their review and the schedule of activities.

- Final Report

'In accordance with Section.IV.B of the Order, the Plant Design Change Extern 31 o -Review Group-transmitted the Group's Final Report on September '6,1985(1W. ,

Of : the: 355 JPlant.. Design Change Requests L(PDCR) and 20,294 Work Permits / Orders reviewed during the period in question only one PDCR raised an L "(4) .W. G. Counsil-fetter to 3. M.. Taylor and Dr. T. E. Murley, dated January 28,1985.- g (5) W. G. Counsit letter to Dr. T. E. Murley, dated February 6,1985.

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, (6). W. G. Counsit letter to Dr. T. E. Murley, dated March 22,1985.

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, (7) T. E. Murley letter to 3. F. Opeka, dated April 23,1985.

(8) D. E. Vandenburgh letter to Dr. T. E. Murley, dated ~ April 11, 1985.-

(9) D. E. Vandenburgh letter to Dr. T. E. Murley, dated June 21, 1985.

(10) D. E. Vandenburgh letter to Dr. T. E. Murley, dated September 6,1985.

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immediate safgty) concern.  : The NRC was'promptly notified and License Event Report '85-017 .1 1

was 1: submitted < by : CYAPCO. Justification for continued operation' was provided and long term corrective actions will be supplied by

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November 12, 1985 in a follow-up report. ' Detailed listings of other deficiencies

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m. ~ were ldentified in the' Connecticut. Yankee Plant Design Change Ta.4 Group

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V,CYPDCTG) Final Report which accompanied the External Review Group's Final i: Report. - 1 Report Conclusions 1 '

s in general,.the(CYPD' CTG final report concluded that throughout the period _ of

review, design changes have been made with conarn for both quality and safety.

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In several instances, the ' identified deficiency was not 'related to the change itself, but to the original design basis of the system being modified.

The most frequent source of identified deficiencies was the seismic qualification of equipment.. The most signficant deficiencies identified in the CYPDCTG final report are: a) incomplete consideration of charging system outleakage in post-e accident release analyses and Technical Specifications, b) inconsistent seismic jqualification of the service-water system and portions of CVCS; c) potential

= degradation of containment isolation under certain post-accident conditions, and ,

d); inability' ofithe' plant 'to achieve ~ cold shutdown utilizing only seismically

qualified equipment.  ;

L Also, the CYPDCTG concluded that existing procedural controls over the design.

- change process' are effective. Only a.few deficiencies that occurred In past  :

Edesign changes have not been addressed adequately in current' design change

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i procedures. - A significant improvement in PDCR packages with' time was noted.- '

? Report Recommendations .

The CYPDCTG recommendations for improvements in the design change process .

were primarily.in the areas ~of:

' l. - Control of design basis information. ;

2.- _ Training of engineers ~on the design change process, ,

3.. The definition of Plant Design Change",

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4. - The documentation of activities that may not be controlled under PDCR's.. 4 u

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The need for a more integrated review process.. ,

6.- - Specific procedure improvements for clarity and consistency.

The CYPDCTG findings and recommendations were summarized in Tables 5,6,7 and 8 of the CYPDCTG Final Report.

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~(11); R. H. Graves. letter to NRC-Document Control Desk, dated August 14, 1985.,

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Limprovement Plans

A plan ~ for improvements based on evaluation of the .CYPDCTG findings _and v . recommendations is provided as - Attachment 1. The plan / includes (1) action

-items to be performed and (2) a schedule for completion of each specific action sitem which has. not Jalready been completed.~ To date,' the. completed action

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. ' items have adopted the recommendations of the final report.

Special Reports .

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During the course of this review,:two additional design change problems were. ,

s ^ identified to.the CYPDCTG for consideration.(12) One of these design changes-

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- affected the Haddam Neck Piant, and the other' design change concerned . ,

Millstone Unit No.' 2. The CYPDCTG completed-its review of ~ these two plant

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~ design changes and provided the following reports to the NRC by . letter dated October ll, 1985(13):

o "Special Report - Connecticut Yankee PDCR 713," dated August 30,1985

,  : PDCR 713 involved modifications to the computer room and associated

.' smoke detectors.

o "Special Report - Millstone Unit 2 PDCR 2-8-85," dated September !!,

1985 PDCR 2-8-85 involved modifications to the pressurizer pressure control.

system.

The recommendations of these special reports are summarized in Attachment 2. --

J A plan for improvements 1 based on. evaluation of the CYPDCTG fin' dings .and rscommendations is included in Attachment'2 and will be included in the plan to

~ address the CYPDCTG findings and recommendations discussed in Attachment'l..

Summary in. summary,' the plans described in Attachments -1 and 2 provide our response to Section IV.C of the Order. The results of the planned evaluations 'and reviews

discussed in Attachments 1 and 2 will be' documented, filed and available for n . f uture ~ review, CYAPCO hereby requests the NRC' review and approve the -

. attached plans in accordance with the Order.

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'(12)l E. C. Wenzinger letter to R.'3. Schmidt, dated July 19,1985 (Docket No.

50-213),'and E. C. Wenzinger letter to R. 3. Schmidt, dated August 14, 1985 (Docket No. 50-336).

(13) 3. F. Opeka letter to E. C. Wenzinge.', dated October 11,1985.

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- If you have any questions or comments, please let me know.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY GEOnu J. F. Opeka Senior Vice President By: -E. J//Mroczkap Vice Prdident Attachments

- STATE OF CONNECTICUT )

) ss. Berlin COUNTY OF HARTFORD )

Then personally appeared before me E. J. Mroczka, who being duly sworn, did state that he is a Vice President of Connecticut Yankee Atomic Power Company, Licensee .herein, that he is authorized to execute and file the foregoing information in' the name and on behalf of the Licensee herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.

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.. ,,i Docket No. 50-213 Attachment I Connecticut Yankee Improvement Plan a

November,1985

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g ;,3  : Deficiencies in Specific Plant Design Changes TABLE 5 Deficiency No; li - PDCR No. 294 RHR Purification Flow Valve Reach Rod  !

Piping _is not'se.smically qualified.

Response

.The piping around valve RH-V-874A will be analyzed. The seismic qualif'ication i 'of the RHR. system has previously been identified as Issue 1.04 in the Integrated Safety ' Assessment Program. The analysis and schedule for modifications (if

. required) will be completed by January 31,1987.

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Deficiency No. 2: PDCR Nd.~ 306 Containment' Fan Filter Timers

No procedure to ensure continued paper functioning of the timers.

' [ Response: f A surveillance procedure will be established by January 15,1986.

- Deficiency No. 3: -PDCR 326 Fire Suppression System .

- Seismic evaluation of fire ' suppression system located above safety related  ;

equipment. -

Response

The fire suppression piping which is located abo.ve safety related equipment will bej seismically analyzed. The analysis?and schedule for modifications -(if required) will be completed by July 30,1986.

, ' Deficiency No. 4: PDCR 326 Fire Suppression System Impact of fire suppression fluids sprayed on safety related equipment.

R_eponse:

In ' 1983, the Nuclear Regulatory Commission issued an I&E Information Notice

-(83-41) entitled "Acutation of Fire Suppression Systems Causing Inoperability of Safety-Related Equipment". This notice highlighted several examples where actuation of fire suppression systems' caused damage or inoperability to systems

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important to safety. Based on this concern, NU initiated an evaluation for the three operating plants to determine if any fire suppression system could cause damage or incapacitate shutdown systems.

The evaluation was comprehensive and involved verification walkdowns, drawing reviews, verification of fire system designs, installation and operating characteristics,' plant procedures and a final determination of its impact on safe

- shutdown systems. - The report for- CYAPCO concluded that operation and/or failure of fire suppression systems had no impact on safe shutdown capability.

. One' exception was noted and corrective action in terms of a hardware L

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modification is scheduled to be implemented during the January 1986 refueling outage. The report is entitled " Inadvertent Operation / Rupture of Fire Protection Equipment" dated January 1984, and a copy is available for your review.

This deficiency is resolved.

Deficiency No. 5: PDCR 333 Combustible Gas Detection System No procedures to establish maintenance and calibration of the system.

Response

Maintenance Further detailsand calibration on this procedures deficiency will be were provided in established by July 2,19(8Q.

our August 30,1985 letter.11 Deficiency No._6: PDCR 344 - Containment Isolation Reset Modification inadequate training plan and procedures to adequately identify all steps to clear SI/HCP bluck. ,

Response

Procedures and training plans will be upgraded by May 2,1986.

Deficiency No. 7: PDCR 347 Reactor Coolant System Venting System Uncertainty of ability of valves to function with water.

Response

The reactor vessel and pressurizer non-condensible gas vent system isolation valve design will be evaluated to determine the effects of passing water flow.

The evaluation will be completed by February 28, 1986 and a schedule of modifications (if any) will then be determined.

Deficiency No. 8: PDCR 347 Reactor Coolant System Venting System Failure to test valves against full differential pressure.

Response: ,

The reactor vessel and pressurizer non-condensible gas vent system isolation valves will be evaluated to confirm the ability to open and close against full differential pressure. The evaluaticn will be completed by February 28, 1986.

(1) J. F. Opeka letter to Dr. T. E. Murley, dated August 30, 1985.

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In-situ lor prototype testinnwill be performed by July 2,< 1986 to support ther

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! D'eficiency No. 9:1 PDCR 347 Reactor Coolant System Venting System Failure of AOP 3.2-22 to utilize revised calculations on venting times.

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. Responses AOP 3.2-22 will be revised by July 2,1986.

Deficiency No.10: PDCR 347 Reactor Coolant System Venting System L

Failure to verify actual plug movement in surveillance tests.--

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Responses' -

Surveillance procedures will be revised by July 2,1986.

Deficiency No.113 PDCR 368 RCP. Seal Water Supply Valves (Uncertainty of seismic qualification of the RCP seal water system. >

. Response -

The requirement for RCP operation in post accident conditions will be verif_ led '

'and the seal water piping system will be seismically analyzed. Analysis and

. modifications' (if required) will be combined with evaluations regarding PDCR 380 whenever possible. The analysis will be completed by January 31, 1987..

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Deficiency No.12: PDCR 317.TMI 2.1.8 Additional Equipment to Follow Course -

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Inconsistent procedures as related to calculations.

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" Response:

l-Procedures will be clarified by May 2,1986.

.~, Deficiency No.13: PDCR 380 - RCP Component Cooling Water and Seal Water -

,.,.. isolation Modification.

Inadequate ' dose analysis and Tech. Spec. treatment of charging system outleakage. ,

Ret.wnse CYAPCO has implemented necessary administrative controls to monitor and limit the combined leakage from -the RHR and charging systems to less ti.an

. three liters per hour. This will ensure that the actual leakage from all sources is

! ' within that assumed in the radiological analysis. Additionally, CYAPCO wl!!

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submit a liunse amendment request to formalize the above mentioned administrative measures by January 313 1986. This deficiency was discussed in LER 85-17 submitted August 14, 1985.(21 Deficiency No.14: PDCR 380 - RCP Component Cooling Water and Seal Water Isolation Modification Unevaluated impact of modification as related to reduced containment integrity.

. Response:

The requirement for RCP operation in post accident conditions will be verified and the CCW and seal injection systems pip;ng analyzed accordingly. The analysis will be combined with PDCR 368. Modifications (if any) will be

' identified and a schedule for implementation will be developed by January 31, 1986

-Deficiency 15: PDCR 380 - RCP Component Cooling Water and Seal Water Isolation Modification Inadequate precedures to assure prompt manual valve closure.

Response

Procedures will be upgraded by May 2,1986.

Deficiency No.16: PDCR 380 - RCP Component Cooling Water and Seal Water injection Modification.

Seismic qualification of isolation valves and associated piping.

Response

See response to Deficiency No.11.

Deficiency No.1,7_: PDCR 380 - RCP Component Conting Water and Seal Water Injection Modification.

Faulty logic for activation of valve FCV-608.

Response

The control logic for the CCW return ficw control valve will be reviewed to determine if a high flow signal will keep tl e vaive closed. Modifications (if any) will be identified and a schedule for in.p!ementation will be completed by March 28,1986.

(2) R. H. Graves letter to NRC Document Control Desk dated August 14,1985, transmitting LER 50-213/85-017-00 entitled " Post-LOCA Release Paths Outside Containment."

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Deficiency No.18: PDCR 380 - RCP Component Cooling Water and Seal Water

Isolation Modification. ,

Potential release path from contanment via seal return line'and relief valve CH-RV-332.1

Response

See' response to Deficiency No.13.

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Deficiency No.' 192 PDCR 380 - RCP Component Cooling Water and Seal Water

Isolation Modification Resolution of CYPDCTG Report " Containment Piping Penetrations" Responses

The current configuration of each containment penetration will be reviewed to determine compliance to isolation criteria. . Deficiencies 11,16 and '18 will be i included. The analysis and identification of modifications (if any) and exemption requests will be completed by July 30,1986.

Deficiency No. 20: PDCR Nos. 384/401 - Automatic Initiation of Auxiliary

, Feedwater

. - -- Questionable design basis analysis of the AFW system.

- Response:

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The AFW system design basis will be evaluated in more detail.- It is noted that our letter dated Septepber 20, 1985 provides considerable detail on the current J AFW- system design.(3/ This evaluation will be completed and modifications (if any) will be identified by August 31,1986.

Deficiency No. 21:- PDCR 388 - Primary Vent Stack Ring Evaluate the means of accomplishing cold reactor shutdown following a seismic event utilizing only seismically qualified and protected equipment.

- Response:

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- CYAPCO will . evaluate the need' to achieve cold shutdown in light of design Lbasis, SEP, accident analyses, and current operating procedures by July 30, 1986 and identify modifications..(if ;any) required in _ the evaluation.-. Responses to

' Deficiency defined in .25 the &; 36 will 19, January be included in th9.)~will 1981 letterW evaluation. The Staffduring be- considered position as this

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~ evaluation.

~(3) . 3. F. Opeka letter to 3. A. Zwolinski, dated September 20,1985.

1 [(4) - D. G.' Eisenhut letter to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits, dated January 19, 1981, entitled "Information Regarding the Program For Environmental.

. Qualification of Safety-Related Electrical Equipment (Generic Letter 81-

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( Deficiency No. 22: PDCR 418 - PORY and Block Valve Logic Modification

, Failure to seismically qualify relays and mounting. ,

Response:

The seismic qualification of th"e PORV and Block valve relays and their mounting .

on the Main Control Board will.be evaluated and modifications Of any) will be identified by July 30,1986.

Deficiency No. 23: PDCR 436~ Upgrade of. Spent Fuel Building North Crane

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CRS-1A Upgrade bothf fuel. handling : cranes equipment and QA classifications and refueling manipulation to QA Category I.

Response: -

The need to upgrade the cranes to QA Category 1 (safety related) will be n evaluated and modifications Qf any) will be identified by August 31,'1986.;

Deficiency No. 24:- PDCP .443 - Flood Protection Requirements Failure to test or verify adequacy of cooling of service water pumps with flood' protective covers in place. '

' Response: -

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Inservice testing or heat load calculations will be performed by July 2,1986.

- Deficiency No. 25: PDCR 459 Re-evaluation of Safety Related Piping

.Re-evaluate scope of pre,'ect to ensure safe reactor thutdown to cold conditions following a seismic event.

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Reshnse:

9 See response to Deficiency No. 21

• Deficiency No. 26: PDCR 486 Terry Turbine Steam Control.-

Ina'dequate consideration of operabilty with loss'of control air.

Response

Automatic initiation with loss of control air may cause the turbines to overspeed ~

, ~ and result in a turbine trip and loss of auxiliary feedwater. The scenario will be canalyzed and modifications Of any) will be identified by March 28,1986.  !

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- Deficiency No. 27: .PDCR 486 Terry Turbine Steam Control Incomplete consideration of error analysis' in verifying the capacity ,of the

. system.

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System capacity. testing will be performed by July 2,1986.

- Deficiency No. 28: ~ PDCR 592 Charging Pump Failure to assess impact of change of pump curve on DBA.- -

Response

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The evaluatlon of the effect of the change in pump performance on the small-break LOCA analysis will be completed by April 30,1986. The evaluation of the effect of the change in pump performance on the feed and bleed analysis will be completed by January 31,1986.

Deficiency No. 29: PDCR No. 392 Charging Pump Failure to assess degraded voltage operability of main lube oil motor.

< Response: ,

' Degraded voltage conditions will be' evaluated and modifications (if any) will be identified by January 31,1986.

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g Deficiency No. 30: PDCR 592 Charging Pump Failure to upgrade several procedures.

Response

, Procedures will be upgraded by July 2,1986.

. Deficiency No. 31: PDCR 626 Replacement of Foxboro Feedwater Flow i Transmitters Failure to establish the uncertainty of flow measurement.

Response

~ Flow measurment uncertainty will be established.and included in surveillance

y. procedures and accident analyses by May 1,1986.

. Deficiency No. 32: PDCR No. 626 Replacement 'of Foxboro Feedwater Flow i' Transmitters

[ - Failure to determine seismic adequacy of the Hagen flow transmitters.

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Response

The seismic . adequacy of the Hagen flow transmitters, which supply a reactor trip function, and associated sensing lines will be determined.. The analysis will-be completed and modifications (if any) will be identified by July 30,1986.

Deficiency No. 33: PDCR 634 Replacement of Foxboro Pressure Transmitters PT 403 & 404' Failure to seismically qualify instrument tubing.

Response: .

Instrument tubing will be analyzed'for seismic capability by August 31,1986 and modifications needed (if any) will be identified.

Deficiency No. 34: PDCR 634 Replacernent of Foxboro Pressure Transmitters-PT403 and PT404.

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~ Failure to clarify Reg. Guide 1.97. submittal.

Response

~ The Reg.. Guide 'l.97 report for Connecticut Yankee was submitted on May 31, 1984. This submittal.will be revised by September 30,1986 if the analysis results of Deficiency ' No. 33 ' determine the instruments are not fully seismically qualified.

]. c Deficiency No. 35: PDCR 653 Vital Inverter Cabinet Ventilation Failure to. conduct seismic analysis . on cabinets with --l actual components locations.

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' Response:

. Seismic analyses using actual component locations'will be completed by February 28,1986 and will identify any needed modifications.

Deficiency No. 36: . PDCR 660 Relief Valve for Spent Fuel Pool Heat Exchanger Failure to perform complete seismic analysis of service water system.

' Response:

See response to Deficiency No. 21.-- ,

+ ' Deficiency No. 37:.. PDCR 684 Replacement of RCS Loop RTDS Incomplete review of acceptance limits for the RTD's.

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'A sensitivity study will be performed to determine if the. acceptance band for-the RTD's is appropriate for all power levels, and to determine its acceptability considering three loop operation, and the most limiting desiga basis event. The study and identification of modifications (if any) will be completed by August 31,-.

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Deficiency No. 38: . PDCR 684 Replacement of RCS Loop RTD's -

Failure to conduct response t'irie tests.

Response:

Response time testing will be conducted on RTD's installed during the 1986 refueling outage as soon as practical following the 1986 outage. The actual date for performing the test will be governed by the duration of the outage.

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Design' Change Process Recommendations Table 6 F R.ecommendation 1:

Expand scope of controlled documen+ation~ to include design bases, classifications, and other information. -

-Respense:

The updated FSAR fora Connecticut Yankee will ' include controlled documentation for the design bases, classifications, system descriptions and other information. The updated FSAR wi)1 accordance with our October 11,1985 letter.ll) be completed and submitted in Recommendation 2:

Improve timeliness and quality of "as built" documentation updating.

Response

A plan to address this recommendation will be developed by February 28,-1986.

Recommendatien 3:

Provide training on the plant modification process.

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Response

1.  : Familiarization of PDCR requirements, design inputs, safety evaluations, and all associated PDCR NEO procedures will be stressed in the NEO Procedure Familiarization Course starting November 30,1985. 4

.2. Detailed PDCR training will be conducted by supervisors in departmental--

sessions. Students will be instructed in how their department is to perform the specific steps necessary to implement the PDCR and associated procedures. Training will be completed by July 31,1986.

Recommendation 4:

Revise NEO3.03, " Preparation, Review, and Disposition of Plant Design Change

-Requests", to address PDCRs of general scope and PDCRs not completed.

Response

$ - NEO3.03 will be revised and issued by March 15,1986.

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(1) 3. F. Opeka letter to H. L. Thompson,-3r.,' dated October 11, 1985.

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Recommendation 5:

Expedite'.':the -Implementation of NEOS.04, " Safety Evaluation . of - Proposed

. Changes to Station Procedures"

Response

NEO 8.04 will be issued by January 31,1986.

Recommendation 6:

- Evaluate the effectiveness of the QA program to ensure compliance with process procedures.

Response

An engineering assurance program will be developed and implemented as -a--

~ NUSCO _QA function by April 1,- 1986.

-Recommendation 7:

' Develop a more effective definition of " plant design change".

~ Response:

A . Task Force will be appointed to develop and review this and other related' ~

issues.-- NEO 3.03 will be revised and reissued by November 30,1986.

Recommendation 8:

Perform a technical review of specified categories of Automated Work Orders.

- Response:

' See response to Recommendation 7.

-Recommendation 9:

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( . Develop a simplified means to document plant design changes that are " remote to safety" or " equivalent component".

. Response:

See response to Recommendation 7.

Recommendation '10:

Attempt to streamline PDCR process.

Response

See' response to Recommendation 7.

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2 Recomendation l'l :

Revise NE03.03 to prohibit unrelated changes on a single PDCR.

Response

[ iSee response to Recommendation 4.

Recommendation 12: .

. Provide improved multi-discipline reviews and integration.

Response

.. A' plan to address this recommendation' will,be developed by-February 28, 1986,

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' with the intent of completing implementation of the plan by December 31,-1986.

Recommendation 13:

' Provide _ guidance / training- on the -interface needs/ reviews on technical -

documents.

Response

A D new NE&O ' proce' dure on " Interface Controls" will' . be developed

and -

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implemented by April 1,1986. . This procedure will provide-the mechanism for-the -guidance / training .to satisfy this recommendation. -.This procedure will also

. provide the mechanisni ta delete the interface control : requirements now

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'specified in the project assignment procedure.

- Recommendation 14:-

Improve' incorporation of system interaction criteria and secondary effects in

! design changes. -

U Response -

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See response to Recommendation 12.

Recommendation 15

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Develop controlled documentation for the impact of location dependent issues

' (e.g., seismic, fire protection, flooding, EEQ).

Response

A plan to address this recommendation will be developed by February 28,1986.

Recommendation 16: - -

^3 (Develop means to evaluate the cumulative effects of a number of minor changes (e.g., core boring, control board additions). -

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Response

-See response to Recommendation 12.

j Recom'mendation 17i Develop an NEO level procedure on project descriptions, perhaps elevating GEC

- Procedure 2.07.

- Response: -

.; A .new NE&O_ ' procedure on " Project Descriptions" will be developed and

-implemented by April 1,1986.

L-Recommendation 18:

Address the recommendations in Table 7 on specific procedure changes.

Response:-:

Refer to'the following recommendations for Table 7 and their responses.

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Table 7

' Recommendation l':- Procedure 5.05

1. - Design verification can be performed using independent review, alternate calculation- or -testing. This proced.ure should be revised to . require a decision and indication of the method of design verification.

2.1 iSome items do not seem appropriate for the checklist, Figure 7.1.

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For example,31, and 32 appear to address ~ questions. raised after the document

. . review has been completed. . Review each item 'on the list for

- appropriateness and revise as necessary.

,p 3. . Clarify' the . application of the design input documentation requirements.

~ For example, refer to NEO 5.05 in' step 6.2.3.4 of NEO 3.03.

Response

. NEO Procedure '5.05 will be revised to address the above recommendations and i

. th: revised procedure will be ssued by February 1,1986.

~ Recommendation 24 Procedure 3.03  :

= 1.- Clarify- the application of the_ design. input ' documentation requirements. ,

, For example, refer to NEO 5.05 in step 6.2.3.4 of NEO 3.03. ,

'2. Step 6.2.2.2 of 7.02 specifies walkdown criteria be determined in the PDCR.. However, this is not specified in NEO 3.03. Revise either 7.02 or '

~ 3.03 to be consistent.

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Response

" NEO Procedure' 3.03 will be. revised to address the above recommendations and ,

1 the revised procedure will be issued by March 15,1986.

Recommendation 3: ' Procedure NEO 5.11 Add documentation indicating whether or not there is an impact on the safety or O environment :eviews on Figure 7.2.'

< Response:

No action necessary. This recommendation has been implemented.

R'ecommendation 4: Procedure NEO.5.15 Develop and release in a timely manner.

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- Response:'

.No action necessary.' This recommendation has been implemented.

Recommendation 5

. Procedure NEO 7.01 -

r 1.. Resolve - conflict between parallel review specified in step 6.16 and sequential review shown.in the flow chart for OUES and QC.

2. Reword step 6.2.4 to _ clarify the timing of inspection. requirements. The wording implies .that inspection is completed prior to approval of work -

order..

m 3. - Define Unit Engineer as indicated in step 6.4

' _ 4. - ' Step 6.16 is performed by the Job Supervisor-while the flow chart shows

. that it is performed by the originator. Resolve this conflict.

7- 5.. - Add requirement for the appropriate QC group and the Design group to be

' responsible for verification of."As Builts". -

'6. Resolve conflicting definition of when turnover occurs.

Response

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NEO Procedure 7'.01 will be revised to address the above recommendations and

.t.he revised procedures will be issued by February-1,1986.

Recommendation 6: Procedure NEO 7.02

11. . Define.the requirements for a pre-construction meeting that-is'shown in

the flow chart.

2.'  ! Step 6.2.2.2 of--7.02 ' specifies walkdown criteria be determined in' the ~

PDCR.= However, this is not specified in NEO 3.03. Revise either 7.02 or -

, 3.03 to be consistent.

< -3. ' Resolve corsilicting definition of when turnover occurs.

Response

NEO Procedure.7,02 will be revised to address the above recommendation and

- , the revised procedure will be issued by April 1,1986.

Recommendation 7:- ~ Procedure NEO 7.03

- 1. -- ~ Revise to include review and approval of test procedures. ,

' 2.' , Revise Das necessary to include NUSCO managers / supervisors in the

' Instruction Section to reflect the Responsibility Section.

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3. ' Clarify the definitions for Retest,. Pre-Operation Test, Phase I Test and Phase 11 Test to indicate the distinction between the terms.

4. Reorder as necessary the substeps in Step 6.3.~

5. . Clarify the term "ultin ate acceptance".

6.- 3 Resolve conflicting definition of when turnover occurs.

Respo'nse:

. NEO Procedurel7.03 will be revised to address the above recommendations and

- the revised procedure will be issued by April 1,1986.

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PART I- WORK PERMITS / ORDERS' INVOLVING DESIGN CHANGES OF POTENTIAL SAFETY SIGNIFICANCE TABLE 8 Open Items Work Permit -

Number Description of Change Required Evaluation flC0429 Relocated charging pump discharge Seismic Evaluation pressure gauge MA0051: Installed 1/2" drain valve on Seismic Evaluation seal water relief valve return piping M A 0821_' Changed m'anual steam generator- Seismic Evaluation blowdown valve to another model MA0831 L Installed non-seismic monitor Seismic Evaluations or stand near seismic equipment remove monitor stand MA1102 Installed small tank'in Safety- Seismic Evaluation Injection Cubicle

. MA4604 Change'd manual reactor vessel Seismic Evaluation -

vent valve to heavier model -

L CY840104 Changed steam generator level Seismic Evaluation Isolation valve to another model LCY8404526 Replaced HPSI recirc. line pressure Evaluate consequences

, gauge with higher range gauge CY8406242 - ' Seal welded a plug on RHR relief Verify that post valve - No post weld heat weld heat treatment treatment is not required.

. Response:

The required evaluations will be completed by June 30,1986 except for Work Permit Number CY8406242 which will be completed by February 28,1986.

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. Open Items

-Work Permit Number Description of Worl< Permit / Order Action MA0693 ' These 6 WP's involved plugging Inspect Heat Exchangers MA2174 of Emergency Diesel Generator to determine total MA2176 Heat Exchange Tubes - Total number of tubes plugged MA2424 number of plugged tubes could and if design basis is MA2822 not be determined invalidated.

MA2851 IC0080 Hook up RTD on Polar Crane - Containment entry required to evaluate-IC0203 Relocated gauges on service work performed, water to CAR fan pressure Shutdown Required sensing lines IC0444 Installe'd sirens in Containment

' M A0065 Installed gates on S. G. skirts MA0136 Modified grating and ladders near RCP's MA0220 Welded unistrut to polar crane MA1189 Cable modifications to CAR fan MA1485 Installed light changing fixture on polar crane MA1816 Elec. Change due to relocation of spray valve air compressors CY8405888 Installed handrails around steam generators CY8406326 ' Replace PORV air pressure gauge with different model.

CY8408165 Drill & tap holes in RCP's

~ CY8409197 Resupport SG vent line CY8400453 Replace pressurizer steam sample Not yet performed and CY8400454 isol. valves with different valves inside containment.

-- CY8400455 Review prior to work for PDCR requirement.

CY3409926 - Modify Rx Cavity Railing Not yet performed and inside containment.

Review for potential secondary effects.

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Response

The required evaluations and inspections will be completed by July 2,1986.

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_ Table 8 PDCR#' Title ~ Action

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460 Head Area ' Cable Support Perform as-built review Structure (HACSS) .of HACSS/ Missile Shield to verify' seismic design requirements were met.

Requires shutdown.

. Response

< The review of PDCR460 will be completed by June 30,'1986.

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Docket No. 50-213 s

- Attachment 2 Connecticut Yankee Special Reports 9

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November,1985 s - _

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Recommendations of Special Report Connecticut Yankee PDCR 713

. Recommendation 1:

1 Revise ' Tech. ISpec. 3.2.2 to . clearly _ identify the applicable' detectors in the

. control room.J- As a minimum, assure that Standard Tech Specs are definitive in this regard.'

Response:

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? 'A license-amendment request to revise Technical Specification 3.2.2 will be

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k-submitted- by June ' 1,' .1986.- The ! request will clearly identify the applicable

' detectors in the Control Room Fire Area.

Recommendation 2:

Provide improved controlled documentation to describe 'the plant design bases (Ref: CYPDCTG Final Report, Table 6, Recommendation 1).

Response

The' : updated FSAR for. Connecticut ~ Yankee will include contro!!ed

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documentation- for the design bases, classifications, system descriptions _ and

' other : Information. The updated FSAR_ wi)1

- accordance with our October 11,1985 letter.LI) be completed 'and submitted in i Recommendation 3:

Increase .the ' awareness of' design engineers with respect to Tech. Specs. This

. action could be included in the training already recommended. (Ref: CYPDCTG -

Final Report, Table 6, Recommendation 3).-

Response

1. . Familiarization of PDCR requirements, design-_ inputs, safety. evaluations,-

and all associated PDCR NEO procedures will be stressed .in" the NEO

< - Procedure Familiarization Course starting November 30,'_1985.

'2. Detailed PDCR training will be conducted by supervisors in departmental F

,  ; sessions. Students will be instructed in how their department is to perform -

the specific steps necessary (to implement the . PDCR and associated procedures. Training will be completed by July 31,1986.

Recommendation 4:

Revise procedures as follows:

a. In NEO 3.03, page 1 of Figure'7.1, change " Fire Protection" to Fire -

Protection QA" and "Radwaste System" to "Radwaste System QA".

b. Add an item on the: Generation Fire Protection Engineering checklist to

- = address Tech. Specs.

L(1) 3. F. Opeka~ letter to H. L. Thompson, Jr., dated October 11,1985.

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fc. . Add an item on Fir;ure 7.1 of NEO 5.05 to address Tech. Specs.

d. LRevise NEO 5.12Jt o. include GFPE: PDCR review check-off list.' . Revise H ~.NEO 5.05 to' permit use of GFPE check-off list during PDCR. verification

ac'tivities.

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~ Response: :

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4.a - . NEO Procedure 3.03 will be revised and issued by March 15,1986.

4.b ' The item to address Technical Specifications has been added.

4.c,- . = NEO Procedure 5.05 will be revised and issued by_ February 1,1986.

14.d.':1). NEO Procedure 5.12 has been revised and issued.

'2) . - NEO Procedure' 3.05 will be revised and issued by April 1,1986.

Recommendation' 5:

, Revise SUR 5.5-13 to reflect all smoke detectors.

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- Response:: -

' SUR 5.5-13 will be revised by January 31, 1986.

[: -Recommendation 6:

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z 4 Assure that QA/NRB' audits of Tech. Specs verify the' adequacy of surveillance L procedures that implement Tech. Spec. requirements.

Response:

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M  : The. adequacy of surveillance procedures is verified as part of the QA/NRB audit

" program. Improvements were made in this area,'in 1983 when the responsibility 1 for NRB audits of Tech. Spec. was assigned to the Quality Assurance Branch and w , teams-_ of "QA auditors" and " technical experts" were then utilized to- perform these audits.' The benefits of this change in direction have not yet been fully

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realized. ~ Therefore, a new program will be established by January _15,1986 to

verify the adequacy of surveillance procedures.

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