ML20151T525

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Suppls 860106 Response to NRC Re Violations Noted in Insp Rept 50-213/85-15.Corrective Actions:Nonemergency Plant Design Change Requests Will Be Distributed 7 Days Prior to Committee Meetings
ML20151T525
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 01/10/1986
From: Opeka J
CONNECTICUT YANKEE ATOMIC POWER CO.
To: Wenzinger E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
A05085, A5085, NUDOCS 8602100292
Download: ML20151T525 (2)


Text

oclcal CONNECTICUT YANKEE ATOMIC POWER COMPANY BERLIN, CO NN EC TICU T P o Box 270 HARTFORD. CONNECTICUT 06141-0270 TELEPHONE 203-665-5000 January 10,1986 Docket No. 50-213 A05085 Mr. Edward C. Wenzinger, Chief Project Branch No. 5 Division of Reactor Projects Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Gentlemen:

Haddam Neck Plant AdditionalInformation Regarding Revised Response to IE Inspection No. 50-213/85-15 The purpose of this letter is to provide additional information to Connecticut Yankee Atomic Power Company's (CYAPCO) anuary 6,1986 letter (l) which provided a response to your December 20,1985( letter.

CYAPCO's response stated that Plant Design Change Request (PDCR) packages would be submitted to the Plant Operations Review Committee (PORC) for thorough, timely and well-documented reviews. CYAPCO's response als9 tated that our previous commitment, by letters dated August 16, 19851 and December 3, 1985(4), to provide PDCR packages to PORC by a fixed period of time prior to the start of an outage were withdrawn.

Further, as a result of our continuing efforts to improve and refine the PDCR process, we find it necessary to revise our previous commitment to distribute non-emergency PDCR's to PORC members seven days prior to the PORC (1)

3. F. Opeka letter to E. C. Wenzinger, dated January 6,1986,

Subject:

Response to Request for Additional Information Regarding Revised Response to IE Inspection No. 50-213/85-15.

(2)

E. C. Wenzinger letter to 3. F. Opeka, date'd December 20, 1985,

Subject:

Inspection Report 50-213/85-15 Revised Response.

(3)

3. F. Opeka letter to E. C. Wenzinger, dated August 16, 1985,

Subject:

Response to I&E Inspection No. 50-213/85-15.

(4)

3. F. Opeka letter to E. C. Wenzinger, dated December 3,1985,

Subject:

Revised Response to I&E Inspection No. 50-213/85-15.

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,, meeting. This change does not impact our original intent, but reflects more

- recent experience in processing plant design changes. At.the time our initial commitment was made, the impact of new procedures from a schedular standpoint was underestimated. Experience using these procedures has shown a significant increase in the time required for processing due to in-depth. probing and questioning, and the need for multiple question and answer iterations. We are continuing to strive for timely PDCR distribution to PORC members, but do not' desire to have a schedule In itself dictate the depth and quality of our review.

Therefore,' in cases where PDCR. distribution seven days prior to the PORC

~

meeting cannot be met, presentations will be made to those PORC members who represent the disciplines of interest for that particular PDCR. Such presentions by the technically cognizant individual will cover the following items:

1.

A description of the PDCR;

- 2.

The design bases affected by the PDCR;

- 3.

A discussion on how the PDCR affects the safety analysis; 4.

Responses to the three questions posed in 10CFR50.59(aX2); and 5.*

A description of any testing planned to verify proper implementation of the PDCR.

This conservative approach will allow PORC members an additional opportunity to 'ask. questions and obtain clarification from the - technically cognizant individual prior to the PORC meeting.

After" the presentations have been completed, at least one day will be allowed for. appropriate discipline review prior to convening a PORC meeting to discuss the PDCR. PORC members will not be pressured to cut their review short of the time they need to complete a thorough review. In summary,'CYAPCO believes this approach will not change the intent of ~ our commitment to complete _ thorough, timely - and well-documented reviews of PDCRs prior to their implementation.

We trust that you will find this additional-information responsive to your concerns. My staff is available to answer any questions you may have regarding

- this matter. We plan to telecopy this letter to you to confirm your concurrence on this matter so that we may implement this process as needed. We of course,-

will cooperate fully with you and your staff to facilitate your oversight of our

- efforts.-

Very truly yours, CONNECTICUT-YANKEE ATOMIC POWER COMPANY hh[A_

1/ l o lh 3.F.Opeka V

Senior Vice President