ML20236N024

Responds to NRC Re Deviation Noted in Insp Rept 50-213/87-10 on 870413-17.Corrective Actions:Procedures Validated Using Table Top Validation Method & Simulator Training Matls Revised as Necessary

ML20236N024
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	08/05/1987
From:	Mroczka E, Sears C CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
A06649, A6649, GL-82-33, NUDOCS 8708110339
Download: ML20236N024 (3)

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}- CONNECTICUT YANKEE ATOMIC POWER COMPANY 1 i

B E R I.l N, CONNECT l CUT P.O DOx 270 HARTFORD. CONNECTICUT 06141 0270 TELEPHONE 203-665-5000 Aug us t 5, 1987 Docket No. 50-213 A06649  ;

l Mr. William V. Johnston, Acting Director Division of Reactor Safety j Region I '

U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Reference:

W. V. Johnston letter to E. J. Mroczka, dated June 29, 1987, Inspection Report No. 50-213/87-10.

Gentlemen:

Haddam Neck Plant Inspection Report No. 50-213/87-10 Pursuant to the provisions of 10 CFR 2 Appendix C, paragraph E(2) this. report is submitted in reply to Reference (1). The above reference informed the Connecticut Yankee Atomic Power Company (C YAPCO ) of a deviation that was identified during an inspection at the Haddam Neck Plant from April 13-17, 1987.

Deviation NRC . Generic Letter 82-33 (GL82-33) identified to licensees basic requirements for upgrading their emergency response capabilities .

Connecticut Yankee Atomic Power Company (CYAPCO) responded to one of the basic requirements of GL 82-33, upgrading of their Emergency Operating Procedures, in letters dated April 15, 1983 and September 1, 1983. In these letters, Connecticut Yankee Atomic Power Company (CYAPCO) committed to using an approved Procedures Generation Package ,PGP) for upgrading their EOP's .

The NRC approved the PGP which included a " Writers Guide" containing detailed instructions for the preparation of the Emergency Operating Procedures.

Contrary to the above, as of April 16, 1987, many of the Emergency Operating Procedures, although technically adequate, did not adhere to the guidelines in the Writers Guide portion of the PGP.

5 I e708110339 870805 PDR ADDCK0500g3

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9 A human factors review of the Writers Guide revealed nunerous deficiencies that require attention. These deficiencies included, but were not limited to, the incorrect and inconsistent use of logic statements in the EOP, and a lack of correlation l between instrumentation nomenclature in the procedures and that  !

in the control room. The validation and training programs were j found to be deficient for all but two Functional Response j Procedures (FRP's). There was also some concern about the amount of time necessary to obtain utility approval for changes to the EOP's and how the EOP's were being implemented.

Response

The root cause is a personnel error in failure to adhere to the guidelines in the Writers Guide Portion of the PGP. Our corrective actions are as follows:

1. The EOP's will be reviewed by Human Factors personnel. This review will include the resolution of the deficiencies identified in Attachment B of Reference (1). In addition, the disparities between EOP and control room nomenclature will be resolved.

2. Procedures not validated prior to the inspection have since been validated using a table top validation method.

3. A control room or simulator walkthrough will be performed on those FRP's which could not be validated on the simulator.

Simulator training personnel will evaluate which PRP's should be included in future simulator exercises.

4. The process for making temporary changes to EOP's will be reviewed and methods of improving implementation time will be evaluated.

5. The appropriate simulator training materials will be revised as necessvry to have instructors re-enforce the importance of not skippi6.g over notes, cautions, and temporary procedure changes by procedure readers.

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The above actions are scheduled to be completed by December 31, 1987. The January-1, 1988 to March 31, 1988 time period will be used to incorporate the changes, verify and validate, and as necessary, approve and issue the revised EOP's.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY b N .h /ct.4 Q E. J. Mroctka Senior Vice President b

C. F. Sears Vice President, Nuclear & Environmental Engineering cc: F .. M. Akstulewicz, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Resident Inspector, Haddam Neck Plant STATE OF CONNECTICUT )

) as: Berlin COUNTY OF HARTFORD )

Then personally appeared before me C. F. Sears , who being duly sworn, did state that he is Vice President of Connecticut Yankee Atomic Power Company, a 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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nfi f 140tary Pu Ic My Commission Expires March 31.1988 l

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